1. Wastewater Permit Renewals
Smithfield 2012 Environmental Conference
Wastewater Permit Renewals
Susan Murphy, FFI

2. Wastewater Permit Renewal: Regulatory Checklist
Ensure you have the latest permit application available
What is in your file at the agency? Find out
Will you get the same permit reviewer as last time?
Have there been any regulatory changes that will influence your new permit limits?
>>water quality criteria of receiving water body
>>municipality’s compliance with their NPDES permit—problems?
How close to your numerical permit limits have you been operating?
What is your compliance history?
When is the application due?

3. Have you checked ECHO?
EPA Enforcement and Compliance History Online (ECHO)

4. Wastewater Permit Renewal: Facility Checklist
Does the description restrict your operation? (“pork processing into patties…”
Are the equipment descriptions, drawings, equipment capacities correct?
What are the construction notification requirements, and has the plant been following these?
Are there any planned new products or expansions possible in the next 5 years (permit term)?

5. Wastewater Permit Renewal
Follow the instructions (ask questions!)
A word about Water Priority Pollutants…
Has the sanitation contractor reviewed the application chemical list? (and do you provide them a “restriction list” on a regular basis?

6. FOR IMMEDIATE RELEASE May 9, 2012
What is New at EPA?
FOR IMMEDIATE RELEASE May 9, 2012
EPA Promotes Safer Alternatives to Nonylphenol Ethoxylates WASHINGTON — The U.S. Environmental Protection Agency has released the final report on alternatives to nonylphenol ethoxylates (NPE) through the Design for the Environment (DfE) Alternatives Assessment Program. NPEs are widely used surfactants with a range of industrial applications and are commonly found in consumer products, such as laundry detergents. When released into the environment, they can be persistent and highly toxic to aquatic organisms. The report identifies eight safer alternatives to NPE that meet EPA’s criteria for safer surfactants.
More information on the DfE Alternatives Assessment Program and the NPEs Report:

7. Develop Your “If Only I Could…” List
Can you get reduced sampling or change your reporting burden?
Is the description of the sampling point correct, and would it be better to move it?
Is there a benefit to changing the flow verification requirements?
Does it matter if you increase the flow limitation?
pH probes are often in the wrong place
Do you need to generate all those paper charts?
Are you paying for too much flow?
Why do I have to take that sample every month when the result has not changed in 10 years?

8. Costs
Surcharge Rates—Are you subject to a strength category of billing, and is it correct?
Can you pay a different rate for condensation? Sanitary sewer?
Is the sampler in the right place, and can you reduce any storm water infiltration?

9. Permit Language
Ensure your storm water is included in permit description if there are areas that are part of the effluent
Question every permit condition, even if it had been in the permit for years
Agency meeting vs. written review
Is your permit language similar to other agency issued permits?

10. Public Comment Period You can comment on your own permit
Agencies prefer you work out the differences before posting for public comment

11. Milan’s Wastewater Permit
1.08 MGD design
DAF, anaerobic contact system, primary clarification, extended aeration, activated sludge, nitrification and denitrification, secondary clarification, disinfection, and dechlorination
Direct discharge to a tributary, to a branch of a creek that has designations from livestock watering to recreational full body contact
Facility had to submit historical data as part of the permit application

12. Milan’s Permit Renewal
After receiving a DRAFT, it was decided to meet with the permit engineer and ask questions face-to-face
Agency department leader attended and interjected information in our favor
We eliminated system efficiency demonstration ($), retained storm water coverage ($), and eliminated downstream monitoring ($)
Changed chloride limit to monitor only
Reduced fecal coliform sampling from weekly to quarterly ($)
Oil and grease was lowered to conventional limits (15/10 mg/l, daily max and mos. Average, respectively

13. Milan’s Rainbow