2010 Michigan 2010 Michigan Environmental Compliance Environmental Compliance Conference Conference NPDES Permit Program and NPDES Permit Program and Compliance Inspections Compliance Inspections Presented by Presented by Chris Veldkamp Chris Veldkamp Senior EQA- -Water Resource Division Water Resource Division Senior EQA Grand Rapids District Office Grand Rapids District Office
Goals and Objectives Goals and Objectives � A discussion about the NPDES permit A discussion about the NPDES permit � � Information about the inspection process Information about the inspection process � � Common violations found during an Common violations found during an � inspection inspection � How to avoid those violations How to avoid those violations � � What What’ ’s New? s New? �
Why Are Permits Needed? Why Are Permits Needed? Rouge River -1969 Rouge River - 1971 Rouge River - 1987
2000 Red Cedar River Red Cedar River 1966
Regulatory Programs Regulatory Programs Wastewater Destinations (3.1) Wastewater Destinations (3.1) LIQUID / WASTEWATER (INCLUDING STORMWATER) DISCHARCHES DIRECT DISCHARGE INDIRECT DISCHARGE 3.4 and 3.5 3.4 NPDES PERMIT STATE PERMIT POTW PUMP and HAUL (Surface Water Discharge) (Ground Water Discharge) 3.2.1 3.2.2 3.2.3 3.2.4 INDIVIDUAL GENERAL PERMIT-BY-RULE 3.2.3.a 3.2.3.c 3.2.3.b STORM WATER NON-STORM WATER 3.2.3.d 3.2.3.c
Who Needs A NPDES Permit? Who Needs A NPDES Permit? � Any entity that discharges Any entity that discharges � wastewater to surface waters wastewater to surface waters of the state of the state � Any entity that discharges Any entity that discharges � storm water when associated storm water when associated with certain industrial, with certain industrial, municipal and construction municipal and construction activities activities � Concentrated animal feeding Concentrated animal feeding � operations operations
Three Types of NPDES Permits Three Types of NPDES Permits Individual Permits – – these permits these permits 1. Individual Permits 1. are facility specific and are written to are facility specific and are written to authorize discharges that are tailored to authorize discharges that are tailored to the facility’ ’s discharge and the s discharge and the the facility receiving water they receiving water they discharge to. discharge to. See Section 3.2.3.a
Three Types of NPDES Permits Three Types of NPDES Permits Rule - - The The 2 . . Permit Permit- -By By- -Rule 2 requirements are stated in requirements are stated in a formally promulgated a formally promulgated administrative rule. A administrative rule. A facility requiring this facility requiring this coverage must abide by coverage must abide by the provisions written in the provisions written in the rule. the rule. At this time, storm water from At this time, storm water from construction sites of one acre construction sites of one acre See Section or more are covered by a or more are covered by a 3.2.3.b Permit- -By By- -Rule. Rule. Permit
Three Types of NPDES Permits Three Types of NPDES Permits General Permits – – are designed to authorize are designed to authorize 3 . . General Permits 3 similar type discharges. A general permit must be similar type discharges. A general permit must be complemented by a Certificate of Coverage to complemented by a Certificate of Coverage to constitute a valid authorization to discharge. constitute a valid authorization to discharge. EXAMPLES EXAMPLES Storm Water Storm Water Wastewater Lagoons Wastewater Lagoons Noncontact Cooling Water Noncontact Cooling Water Sand and Gravel Operations Sand and Gravel Operations Petroleum Contaminated Groundwater Petroleum Contaminated Groundwater See Section 3.2.3.c
WHAT DO YOU WHAT DO YOU KNOW ABOUT KNOW ABOUT YOUR NPDES YOUR NPDES PERMIT? PERMIT?
Key Elements of a NPDES Permit Key Elements of a NPDES Permit : authorization statement : � The � The authorization statement “During the period beginning on the effective During the period beginning on the effective “ date of this permit and lasting until the expiration date of this permit and lasting until the expiration date of this permit, the permittee is authorized to date of this permit, the permittee is authorized to discharge a maximum of nine hundred and discharge a maximum of nine hundred and seventy thousand (970,000) gallons per day of seventy thousand (970,000) gallons per day of process wastewater, noncontact cooling water, process wastewater, noncontact cooling water, and an unspecified amount of well water and and an unspecified amount of well water and storm water from Monitoring Point 001A through storm water from Monitoring Point 001A through Outfall 001. 001.” ” Outfall
Key Elements of a NPDES Permit Key Elements of a NPDES Permit � Effluent limitations and monitoring Effluent limitations and monitoring � requirements – – parameters, sample parameters, sample requirements type and location, quantification levels, type and location, quantification levels, and the narrative standard narrative standard and the “ The receiving water shall contain no unnatural “ The receiving water shall contain no unnatural turbidity, color, oil films, floating solids, foams, turbidity, color, oil films, floating solids, foams, settleable solids, suspended solids, or deposits settleable solids, suspended solids, or deposits as a result of this discharge in quantities which as a result of this discharge in quantities which are or may become injurious to any are or may become injurious to any designated use.” ” designated use.
Key Elements of a NPDES Permit Key Elements of a NPDES Permit Additional Studies - - mercury study, mercury study, � Additional Studies � waste characterization study, whole waste characterization study, whole effluent toxicity, thermal plume study effluent toxicity, thermal plume study Specific Programs – – industrial industrial � � Specific Programs pretreatment program, pollutant pretreatment program, pollutant minimization program and storm water minimization program and storm water
Key Elements of a NPDES Permit Key Elements of a NPDES Permit Definitions - - of terms used in the permit of terms used in the permit � Definitions � � Monitoring Procedures Monitoring Procedures � - Test Procedures Test Procedures - - Instrumentation Instrumentation - - Record Results Record Results - - Records Retention Records Retention - - Electronic reporting (how data must Electronic reporting (how data must - be saved and stored) be saved and stored)
Key Elements of a NPDES Permit Key Elements of a NPDES Permit � Reporting Requirements Reporting Requirements � � Additional Monitoring Requirements Additional Monitoring Requirements � � Self Self- -monitoring Requirements monitoring Requirements � � eDMR � eDMR system system � Retained Self Retained Self- -monitoring monitoring � � Change in Operations/Discharge � Change in Operations/Discharge � Noncompliance Notification � Noncompliance Notification � 24 24- - Hour Reporting (Verbal) Hour Reporting (Verbal) � � Other Reporting Other Reporting �
Key Elements of a NPDES Permit Key Elements of a NPDES Permit � Noncompliance Notification Noncompliance Notification � “a. a. 24 24- -hour reporting hour reporting - - Any noncompliance which Any noncompliance which “ may endanger health or the environment may endanger health or the environment (including maximum daily concentration (including maximum daily concentration discharge limitation exceedances) shall be discharge limitation exceedances) shall be reported, verbally, within 24 hours from the time reported, verbally, within 24 hours from the time the permittee becomes aware of the the permittee becomes aware of the noncompliance. A written submission shall also noncompliance. A written submission shall also be provided within five (5) days. be provided within five (5) days.
Key Elements of a NPDES Permit Key Elements of a NPDES Permit � Noncompliance Notification Noncompliance Notification � b. other reporting other reporting - - The permittee shall report, in The permittee shall report, in b. writing, all other instances of noncompliance not writing, all other instances of noncompliance not described in a. above at the time monitoring described in a. above at the time monitoring reports are submitted; or, in the case of retained reports are submitted; or, in the case of retained self- -monitoring, within five (5) days from the time monitoring, within five (5) days from the time self the permittee becomes aware of the the permittee becomes aware of the noncompliance. noncompliance.
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