All discharges of water to surface waters require a National Pollution Discharge Elimination System (NPDES) permit. This includes process water, cooling water, wastewater treatment plant discharges and other water discharge. For new discharges, an application must be filed 180 days before the occurrence of the discharge. Because many states are backlogged for NPDES permits, facilities should consider applying a year in advance of the discharge. Knowledge of water discharge flow rates and chemical contents is required to fill out the applications. Application difficulty varies depending on what kind of waters the discharge is entering, typically the cleaner the water, the more difficult discharge standards will be. Also, antidegradation rules are in place to protect high quality waters and existing water quality. This is a federal program, so forms are usually consistent within states, but each state may have additional requirements other than the federal. NPDES permits come up for renewal every 5 years. A new application must be submitted 180 days before the permit expires. This keeps the current permit in effect until a renewal is issued.
States also have General Permits that contain discharge standards or Best Management Practices for groups of similar discharges that do not have federal effluent guidelines. General Permits require a Notice of Intent and are often easier to obtain than individual NPDES Permits.
Facilities using groundwater for cooling or other purposes, including drinking water, generally are required to apply for a permit and pay a fee to obtain a state permit that allots a certain quantity of groundwater to the facility for a fixed period of time. The time limit will vary by state. Typically, annual groundwater usage reports are required by the permit. Monthly groundwater totals are requested. It is best to have the groundwater metered to accurately track usage.
Facilities that discharge to the sanitary sewer and consequently the Publicly Owned Treatment Works (POTW) may require a permit. Permits are rarely required for sanitary discharges such as bathrooms, locker rooms, and cafeterias. However, discharge of process water from a paint system or oily wastewater from machining operations e. g., will typically require a permit from the City where the discharge occurs. Pretreatment may be required as City Sewer Ordinances specify what concentration of contaminants may be discharged to the sanitary sewer. Many discharges also have federal discharge requirements as found at 40 CFR, Chapter I, and Subchapter N. A facility water balance will be required with the application, i.e. how much water is evaporated, used in a boiler, used as sanitary water, used for cooling, as well as all the water consuming processes leading to the need for a permit in the first place.
Facilities that have an individual NPDES permit will have storm water requirements issued within the permit. Facilities that only have a stormwater discharge have to file a Notice of Intent (NOI) General Permit. NOIs are not difficult. However, a Stormwater Pollution Prevention Plan (SWPPP) must be prepared prior to permit issuance. See SWPPP under EHS Plans for more information. Permits are good for 5 years, but SWPPP’s must be kept updated if changes occur that may impact stormwater runoff quality. Erosion control plans are also required. The most common permits are General Permit No. 1 Storm Water Discharge Associated with Industrial Activity. and General Permit No. 2 for Storm Water Associated with Construction Activities that disturb more than one acre of soil. NOIs may be filed with the state and the municipality if the municipality has their own Municipal Separate Storm Sewer permit from the state. Usually, there are both state and municipal requirements for the discharge of storm water. A facility should know the requirements and costs associated with storm water permitting prior to submitting the application.
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