Connecticut Department of Energy and Environmental Protection
Categorical General Permit Questions & Answers Presented to CBIA May 16, 2014 Mariana Miller, DEEP-WPED Peter Ploch, DEEP-WPED Oswald Inglese, Director, DEEP-WPED Connecticut Department of Energy and Environmental Protection
Q: If two or more outfalls associated with the site fall in different sampling frequency categories, will the more frequent sampling be applied to all monitoring tables in the Approval of Registration, or will each outfall be counted separately? A: Each outfall will be counted separately. Connecticut Department of Energy and Environmental Protection
Q: Please explain the correct way to complete the Monitoring Waiver form. A: • List all parameters associated with the request. • Sample for these parameters before any treatment. • Sample for these parameters after treatment. • Sample the incoming water for any parameters associated with the request that are detected in the analyses before and after treatment. Note: Total toxic organics are not eligible for the waiver. Connecticut Department of Energy and Environmental Protection
Q: How long will it take to approve the Monitoring Waiver? Is this something that could hold up the issuance of the Approval of Registration? A: Assuming the table is filled out correctly, it would take no longer than a week to process the waiver request. The company should know which parameters it will be requesting for the waiver. A compliance condition can then be incorporated into the Approval of Registration, indicating that the monitoring waiver table shall go into effect only after the Monitoring Waiver Request Form is approved. The monitoring waiver request is not something that could hold up the issuance of the Approval of Registration. Connecticut Department of Energy and Environmental Protection
Q: If there are two or more outfalls associated with the site, will there be a separate monitoring waiver table for each outfall? A: Yes. Each outfall is evaluated individually. Connecticut Department of Energy and Environmental Protection
Q: When compared with the parameters listed in Table 1 of the general permit, there are additional parameters listed in Attachment F, Table 1 of the registration form. Will there be effluent limits for the following: Ammonia (as Nitrogen), Biochemical Oxygen Demand (5-Day), Chemical Oxygen Demand, Total Oil and Grease, Total Kjeldahl Nitrogen? A: These specific parameters are pollutants that can cause a load on treatment plants. In accordance with section 22a-430-4(c)(20)(A)(i) of the Regulations of Connecticut State Agencies, this information is required. This information helps the Department to determine whether or not the discharge(s) can be covered under the general permit. If not, the Department may suggest coverage under an individual permit instead. Connecticut Department of Energy and Environmental Protection
Q: Please clarify the amount of samples that must be taken and analyzed when completing Attachment F. Will one sample suffice? A: No. In accordance with section 22a-430-4(c)(20) of the RCSA, analytical data from at least one sample representative of typical daily operations and one sample representative of anticipated maximum effluent pollutant concentration(s) must be used when completing the tables in Attachment F. Connecticut Department of Energy and Environmental Protection
Q: I have retained a Qualified Professional Engineer (“QPE”). Can the QPE sign off as the Preparer as well? A: No. In order to expedite the permitting process, the Department has created this role in order to cut down on application review time. Previously, DEEP permit engineers served as a third party, reviewing all plans and documents submitted with the application. This new process allows the QPE to serve as the third party, reviewing these documents prior to submitting the application. For this reason, the QPE cannot sign off as the Preparer. The QPE is a professional engineer who has not engaged in any activities associated with the preparation, planning, design or engineering of the plans and specifications for the engineered treatment systems for which a certification is being submitted. Connecticut Department of Energy and Environmental Protection
Q: I would like to register/or my application was received at the DEEP for this general permit, but my individual permit expires soon. Will this application allow the permit to be continued in effect until the Approval of Registration is issued? A: Companies registered under individual permits expiring in less than one year that are considering filing for registration under this general permit should submit an application for renewal of the individual permit, along with the appropriate application fee. If a timely and sufficient application is submitted prior to the expiration date, the terms and conditions of that permit remain in effect until a new permit is issued. Although there is no legal basis for this yet, there will be a cutoff point for application submittals in the future. This will be contingent upon the submittal date and the expiration date of the individual permit. Note: Any difference between the application fees for the individual permit and registration under the general permit would be refunded once the registration is approved and the individual permit is revoked. Connecticut Department of Energy and Environmental Protection
Q: What is the typical timeframe for permit issuance? A: Assuming a complete application is submitted, the Approval of Registration is expected to be issued within ninety (90) days from the receipt date. Processing timeframes are generally expected to decrease in the future. Connecticut Department of Energy and Environmental Protection
Q: Are total toxic organics (“TTOs”) eligible for the waiver? If not, is an updated Solvent Management Plan required to be submitted with the application? A: TTOs are not eligible for the monitoring waiver. A Solvent Management Plan shall be submitted when a registrant proposes to forego monitoring of TTOs in accordance with section 5(b)(1) of the general permit. Connecticut Department of Energy and Environmental Protection
Questions? Contact Information: Oswald Inglese: (860) 424-3725 | Oswald.Inglese@ct.gov Mariana Miller: (860) 424-3805 | Mariana.Miller@ct.gov Peter Ploch: (860) 424-3280 | Peter.Ploch@ct.gov WPED Engineer of the Day: (860) 424-3025 Connecticut Department of Energy and Environmental Protection
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