MUNICIPAL WASTEWATER PERMITS TCEQ Environmental Trade Fair Conference
- Slides: 38
MUNICIPAL WASTEWATER PERMITS TCEQ Environmental Trade Fair & Conference May 4, 2016 Sarah A. Johnson, Ph. D. 512 -239 -4649
THE PERMITTING PROCESS Application Water Quality Assessment Applications Team NOD & NORI Issued ISSUED Permit PERMIT Pretreatment NAPD Chief Clerk’s Office Public comments Permit Coordinator EPA Draft Permit Region & Enforcement
APPLICATION FORMS 10053 -inst • Instructions for Completing the Domestic Wastewater Permit Application (DOC) 10053 • Domestic Wastewater Permit Application Administrative Report (DOC) 10054 • Domestic Wastewater Permit Application Technical Report (PDF)
APPLICATION FORM 10053 • • The form on the left is the previous version of the Administrative Report. This version, from 2014, will no longer be accepted after May 16, 2016. The form on the right is the updated version of the Administrative Report. This version, from November 2015, will be mandatory after May 16, 2016.
TYPES OF APPLICATIONS New* Renewal Amendment Brand new facility Continue an existing authorization Major Amendment*substantially change or relax the permit Expired permits re-apply as new facilities Can include a minor amendment Minor Amendmentchange permit without relaxing the permit *Requires additional notice to adjacent and downstream landowners
PERMIT CLASSIFICATIONS Minor Major < 1. 0 MGD ≥ 1. 0 MGD Standard pollutant screening Full pollutant screening Standard pretreatment requirements (for POTWs) Biomonitoring Possibly expanded pretreatment (for POTWs)
TEXAS LAND APPLICATION Vs. REUSE AUTHORIZATION TLAP • TLAP • Reuse (210) – – – Reuse (210) Dedicated disposal site Permittee owns/leases land Requires permit (330 days) – – – At user’s demand Permittee does not control land Attached to existing TPDES/TLAP permit (30 days) For more information about Chapter 210 reuse authorizations, refer to the Dedicated disposal site At user’s demand Permittee owns/leases land Permittee does not control land Requires permit (330 days) Attached to permit (30 days) • Reuse of Domestic Reclaimed Water” as Presented by Louis C. Herrin, III. presentation “
ANTIBACKSLIDING EPA has informed me that you are backsliding. What is backsliding? Can a less stringent permit be issued? Material alteration No control, no remedy Any change in a permit that leads to less stringent conditions Federal Anti-backsliding regulations 40 CFR Part 122. 44 (l)(2)(i) Appropriate treatment can’t meet limit New information
REGIONALIZATION State policy prefers regional or area-wide wastewater treatment systems over a large number of smaller treatment systems New and expanding plants contact existing wastewater treatment providers Provide a 3 mile radius map from the point of discharge that lists all permitted municipal facilities or collection systems CCN issues (512 -239 -4691)
BEFORE ACCEPTING WASTE… Domestic septage (septic tanks) or chemical toilet waste Is it good for my treatment process? Domestic WWTP biosolids Grit or grease Do I have organic capacity? Brewery, bottling, and food processing wastewater Animal feed or animal processing wastewater
ADMINISTRATIVE REVIEW TO AVOID COMMON ERRORS. . . Fill out all contact information Sign the form Provide complete maps Arrange to have the application displayed in a public building Update the location description (as needed) Provide a complete landowner list (as needed)
TECHNICAL REVIEW TO AVOID COMMON ERRORS. . . Address Other Requirements Provide a clear buffer zone map: should be 8. 5 X 11, black and white Provide a complete, current pollutant analysis with lab results sheets Include justification for unbuilt phases or flow request Provide description of treatment process, list unit dimensions, complete process flow chart (for all phases)
COMPLIANCE HISTORY REVIEW No further review High No Adm Satisfactory Poor <10 & s r e d r in O NOVs Admin Orders or ≥ 10 NOVs Executive Review Committee Other Review
DRAFT PERMIT PACKAGE Statement of Basis Fact Sheet Public Notice (NAPD) Cover Letter • Draft Permit Package – – – Cover Letter Public Notice (NAPD) Statement of Basis Fact Sheet Draft Permit
NORI vs. NAPD
Review the notices for accuracy
New language in the public notice
KNOWING YOUR DRAFT PERMIT Standard Provisions Sludge Provisions Other Requirements Effluent Limits • Authorization Page Draft Permit – – – Authorization Page (review carefully) Effluent Limits (review carefully ) Standard Provisions Sludge Provisions Other Requirements (review carefully ) Pretreatment & Biomonitoring (review carefully ) Draft Permit Pretreatment & Biomonitoring
WHAT’S IN YOUR PERMIT BOD, TSS, DO, NH 3 -N, bacteria, others • Segment & geographic issues • Treatment technology • Past performance Other Requirements • Segment & geographic issues • Past performance • Permit specific issues Pretreatment Requirements • POTW • Full program required for >4. 0 MGD Biomonitoring Requirements • Major permits • Freshwater or saltwater Whole Effluent Toxicity (WET) • Major permits • Past performance
RECENT CHANGES Samples taken on or after July 14, 2014 must use the new minimum analytical level (MAL) New application forms are now available MAL Lab Result (one sample) Valid? 10 μg/L 15 μg/L Yes 10 μg/L < 15 μg/L No – retest
RECENT CHANGES 2014 List of Impaired Waters (Clean Water Act 303(d) List) TCEQ adopted June 3, 2015 and EPA approved November 19, 2015 E-reporting is required for DMRs and annual sludge report for TPDES permits Sludge Provisions have been updated in accordance with EPA mandates
THE PERMITTING PROCESS Application Water Quality Assessment Applications Team NOD & NORI Issued ISSUED Permit PERMIT Pretreatment NAPD Chief Clerk’s Office Public comments Permit Coordinator EPA Draft Permit Region & Enforcement
DON’T GET BOGGED DOWN… • Respond to Notices of Deficiency • Publish both public notices and return documents (30 days NORI, 45 days NAPD) • • Check for bilingual requirements Check accuracy and formatting Complete/correct affidavit and verification Contact the Chief Clerk’s Office at 512 -239 -3300 with questions about the publication process • Review draft permit and send approval or comments
HELPFUL WEBSITE RESOURCES
COMMISSIONERS’ INTEGRATED DATABASE PART 1 http: //www 14. tceq. texas. gov/epic/e. CID/
COMMISSIONERS’ INTEGRATED DATABASE PART 2 http: //www 14. tceq. texas. gov/epic/e. CID/
COMMISSIONERS’ INTEGRATED DATABASE PART 3 http: //www 14. tceq. texas. gov/epic/e. CID/
APPLICATION HELP If I have questions… • Call (512) 239 -4671 If I have lots of questions… • Consider preapplication meeting with TCEQ staff
ANY QUESTIONS?
Supplemental SUPPLEMENTAL INFORMATION Information
TCEQ/EPA BACTERIA LIMITS Bacteria limits in all discharge permits Typically 126 CFU per 100 m. L E. coli for freshwater Typically 35 CFU per 100 m. L enterococci for saltwater May be less with TMDL Minimum Required Bacteria Monitoring Frequency (30 TAC 319. 9 Table 2) Flow (MGD) Chlorine Systems Ultraviolet Systems Natural Systems >10 5/week Daily >5 -10 3/week Daily 5/week >1 -5 1/week Daily 3/week >0. 5 -1. 0 2/month Daily 1/week 0. 1 -0. 5 1/month 5/week 2/month <0. 1 1/quarter 5/week 1/month
GEOMETRIC MEAN FOR BACTERIA By hand… =GEOMEAN In Excel… (choose cells) On the Search for “Geometric Mean Calculator” on the web… TCEQ webpage *For any “ 0” values, use “ 1” Sample 1 5 Sample 2 7 Sample 3 1000 Sample 4 2 Average 254 Geomean 16
2010 Implementation Procedures Nutrient criteria (as chlorophyll a) has been added for reservoirs Applies to all new or expanding permits larger than 0. 25 MGD, and renewals on a case-by-case basis May result in total nitrogen or total phosphorus limits For details refer to Procedures to Implement the Texas Surface Water Quality Standards (2010) and 30 TAC, Chapter 307, Appendix F
PROGRAM LOCATION QUICK REFERENCE Commissioners Chief Clerk Executive Director • • The TCEQ's Office of Water handles wastewater permits. Office of Administrative Services The Office of Water and the Chief Clerk's Office are in different branches of the TCEQ. The Office of Water is under the Executive Director. Other Offices in this branch include the Office of Administrative Services, Chief Engineer’s Office, Office of Compliance and Enforcement, Office of Legal Services, Office of Air, and Office of Water. Chief Engineer’s Office of Compliance and Enforcement Office of Legal Services Office of Air Office of Waste Office of Water
PROGRAM LOCATION QUICK REFERENCE Office of Water Quality Permits Water Availability Industrial Water Quality Municipal (Domestic) Water Quality Planning Stormwater Water Supply Agriculture
HELPFUL RESOURCES TCEQ website: http: //www. tceq. state. tx. us Keyword/forms search (database, Spanish templates, 10053, 10054, municipal wastewater permits, etc. ) Central Records 512 -239 -2900 Chief Clerk’s Office: 512 -239 -3300 Water Quality Division: 512 -239 -4671 Regional Offices
References • Comic was adapted from Reverendfun. com by Mikel Rice copyright Bible Gateway http: //www. reverendfun. com/? date=2001070 2
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