NC DPPEA Compliance Assistance - Water Keyes McGee Division of Pollution Prevention and Environmental Assistance 919-733-4398 keyes.mcgee@ncmail.net 1-800-763-0136 NC DPPEA Compliance Assistance - Water Keyes McGee Division of Pollution Prevention and Environmental Assistance 919-733-4398 keyes.mcgee@ncmail.net 1-800-763-0136

DPPEA Compliance Assistance Non-regulatory Confidential Staff Experience DPPEA Compliance Assistance Non-regulatory Confidential Staff Experience

Compliance Problems? National Pollutant Discharge Elimination System Permits (NPDES) Pretreatment Permits Sewer Use Ordinance Collection System Permits Water Conservation Ordinance Stormwater Permits Compliance Problems? National Pollutant Discharge Elimination System Permits (NPDES) - These are issued by the NC Division of Water Quality to dischargers of treated water into the waters of the state. DWQ is a delegated authority by the Environmental Protection Agency Pretreatment Permits – Required by Publicly Owned Treatment Works as part of their National Pollution Discharge Elimination System Permit. Permits are issued by the local control authority. Sewer Use Ordinance – This document is the legal basis for control authority operation of a wastewater treatment plant. It has specific limits and prohibitions that supercede the pretreatment permit. Water Conservation Ordinance Stormwater Permits

Regulations NPDES Pretreatment Sampling & Analysis Federal Water Pollution Control Act (CWA) Pretreatment 15A NCAC 2H .0900 40 CFR 403 Sampling & Analysis 40 CFR 136 Regulations NPDES Federal Water Pollution Control Act (CWA) The 1972 amendments to the Federal Water Pollution Control Act (known as the Clean Water Act or CWA) provide the statutory basis for the NPDES permit program and the basic structure for regulating the discharge of pollutants from point sources to waters of the United States. Section 402 of the CWA specifically required EPA to develop and implement the NPDES program. The CWA gives EPA the authority to set effluent limits on an industry-wide (technology-based) basis and on a water-quality basis that ensure protection of the receiving water. The CWA requires anyone who wants to discharge pollutants to first obtain an NPDES permit, or else that discharge will be considered illegal. The CWA allowed EPA to authorize the NPDES Permit Program to state governments, enabling states to perform many of the permitting, administrative, and enforcement aspects of the NPDES Program. In states that have been authorized to implement CWA programs, EPA still retains oversight responsibilities. The key sections of the CWA that directly relate to the NPDES Permit Program include: Title I - Research and Related Programs Section 101 - Declaration of Goals and Policy Title II - Grants for the Construction of Treatment Works Title III - Standards and Enforcement Section 301 - Effluent Standards Section 302 - Water Quality-Related Effluent Limitations Section 303 - Water Quality Standards and Implementation Plans Section 304 - Information and Guidelines [Effluent] Section 305 - Water Quality Inventory Section 307 - Toxic and Pretreatment Effluent Standards Title IV - Permits and Licenses Section 402 - National Pollutant Discharge Elimination System Section 405 - Disposal of Sewage Sludge Title V - General Provisions Section 510 - State Authority Section 518 - Indian Tribes Pretreatment 15A NCAC 2H .0900 40 CFR 403 Sampling & Analysis 40 CFR 136

Know Your Water Permits Limits Reporting Special Conditions Collection System Surveillance Know Your Water Permits Limits Reporting Special Conditions Collection System Surveillance

Thinking Ahead! Preventing compliance problems: Environmental Management System Pollution Prevention Sustainability Campus Community Involvement Management Support Thinking Ahead! Preventing compliance problems: Environmental Management System Pollution Prevention Sustainability Campus Community Involvement Management Support

Your Collection System GIS mapped Inventory Categorical Discharges SUO Prohibited Discharges Pretreatment Units SPCC Plans Secondary Containment FOG Interceptors Your Collection System GIS mapped Inventory – Documentation of all the sanitary sewer on your campus. Categorical Discharges – contact water processes that are governed under title 40 Code of Federal Regulations. SUO Prohibited Discharges – Local control authority limits as a basis for system protection. Do you have a copy handy? Pretreatment Units – Not the pretreatment program, but treatment systems that you are responsible for operating. Usually physical/chemical units. SPCC Plans – Spill Prevention, Control and Countermeasure. Secondary Containment – Chemical storage spill prevention devices and designs. FOG Interceptors – Fats, Oils, and Grease Interceptors. Grease traps and oil / water separators. All the above are SYSTEM PROTECTION components! System Protection!

Notices of Violation Solve problems before they get bigger. Seek consultation. We can help! Prepare a timely response. Gather information (data and narratives). Develop a plan with defined responsibilities. Long term corrective action processes. Feedback for continuous improvement. Notices of Violation Solve problems before they get bigger. Seek consultation. We can help! Prepare a timely response. Gather information (data and narratives). Develop a plan with defined responsibilities. Long term corrective action processes. Feedback for continuous improvement. Follow the EMS Model: Plan, Do, Check, Act

Negotiation Technically Defensible Limits Categorically Defined Water Use Pretreatment Level Water Conservation Credit Negotiation Technically Defensible Limits Categorically Defined Water Use Pretreatment Level – Are pretreatment units needed? Efficacy should protect POTW – not treat to NPDES standards for conventional pollutants. Water Conservation Credit

Compliance Assistance Answering questions you’d rather not ask your regulator! Helping to interpret rules. Identification of prohibited discharges Pollution Prevention Technologies Compliance Assistance Answering questions you’d rather not ask your regulator! Helping to interpret rules. Identification of prohibited discharges Pollution Prevention Technologies Wastewater and Waste Reduction Assistance The N.C. Division of Pollution Prevention (DPPEA) provides North Carolina local governments with assistance on a range of environmental issues. Assistance is given in the form of on-site visits, workshops, publications and other materials, grants and responses to telephone and e-mail inquiries. DPPEA offers a complete range of services to local municipalities on wastewater issues. Highlighted below are DPPEA services that address special needs of North Carolina local governments. Reduction of Toxic Discharges If it is determined that an industry is discharging certain toxic chemicals into the publicly owned treatment works (POTW), DPPEA will assist in the investigation for nontoxic alternatives/substitutions to reduce the toxicity of the discharge. Source Reduction Strategies for Specific Pollutants If a municipality needs to focus on the reduction of a specific pollutant, either organic, metal or solid, DPPEA can assist potential dischargers of the targeted pollutant with the following strategies: Evaluation of processes Training on alternatives or substitutions Investigation of alternative uses or markets for the waste Facility Designs for Waste Reduction DPPEA will assist industries with the design of new or expanding facilities to ensure optimum prevention/reduction of waste generation and facilitate pollution prevention and water recycling. Source Reduction Training DPPEA will train local municipal staff or specific commercial/industrial staff in source reduction techniques. This training can include options for specific commercial/industrial sectors, general source reduction options or resources, and/or assistance with options that address current or pending regulations. Assistance With Compliance Problems DPPEA's services are non-regulatory. DPPEA staff can assist municipalities in which industries have compliance problems by conducting a waste assessment, working up a detailed analysis of waste reduction alternatives, and assisting with the use of effective waste reduction strategies. If you would like additional information, contact DPPEA at (919) 715-6500 or (800) 763-0136

DPPEA Resources www.p2pays.org/mercury/ www.p2pays.org/food/ www.p2pays.org/compost/ wrrc.p2pays.org/industry/laboratory.htm DPPEA Resources www.p2pays.org/mercury/ - information on mercury found in schools, information on the health effects of mercury, mercury emissions, how to perform a mercury audit, and mercury reduction options. www.p2pays.org/food/ - Green Plan for the Food Service Industry; Fats, Oils & Grease; Food Waste. www.p2pays.org/compost/ - Promote and encourage the development of a viable composting and organics recycling industry in North Carolina to reduce the amount of organic wastes being disposed of in landfills Provide accurate technical information on how to compost biodegradable materials Stimulate market demand for use of top-quality composts in landscaping, gardening, horticulture, agriculture, wetlands development, and sediment and erosion control wrrc.p2pays.org/industry/laboratory.htm - Core Sector Laboratory hazardous and chemical waste from the wide variety of chemical testing and processing that is performed in individual labs. Waste reduction and reuse techniques. Hazardous waste reduction. Process modifications. Bulk chemical storage containers, spill prevention techniques. Chemical handling, and specific problem wastes such as mercury.

http://www.p2pays.org Pollution Prevention Pays Slide I hope this presentation has helped to introduce you to the Division of Pollution Prevention’s water compliance assistance! http://www.p2pays.org