For wastewater systems near bodies of water, navigating National Pollutant Discharge Elimination System (NPDES) permits is important for protecting our water bodies. Here’s a quick guide to better understand and effectively manage your NPDES permit.
Permit Types
It is first important to understand if your facility is regulated under an individual or a general permit. Individual permits are written specifically for each facility while general permits apply to groups of facilities with similar discharges, simplifying the compliance process by setting uniform conditions. Understanding whether your facility operates under an individual or general permit is important as it impacts your plant’s compliance, reporting requirements, and operational flexibility.
Read Your Permit and Factsheet
Read the entire permit and its accompanying factsheet. There is often critical information about special monitoring requirements or conditions that aren’t apparent in the main monitoring table sections. Pay particular attention to footnotes included in the monitoring tables as they may direct you to other parts of the permit with additional monitoring and compliance details. Also, for permit renewals, review the change table in the factsheet carefully to understand any new changes to your permit.
Effluent Limits and Standards
Understand how effluent limits are established in your permit. There are two main types of limits: Technology-Based Effluent Limits (TBELs) and Water Quality-Based Effluent Limits (WQBELs). TBELs provide baseline protection and are based on the best available technology for treating specific pollutants. For municipal wastewater treatment plants, the TBELs include limits on Biochemical Oxygen Demand (BOD) and Total Suspended Solids (TSS).
Alternatively, WQBELs are derived from the water quality standards of the receiving waters. These limits ensure that discharges do not cause or contribute to violating these standards. Examples of WQBELs might include limits on nutrients like nitrogen and phosphorus, or metals such as copper and zinc. WQBELs are typically established based on modeling that considers the critical flow conditions of the receiving water and the wastewater flow from the treatment facility. Understanding how these limits are created is important to ensure that regulators have applied the correct flow criteria.
Monitoring, Compliance and Planning
Consistent monitoring and reporting are important for maintaining compliance with your NPDES permit. The permits require electronic reporting of discharge monitoring reports (DMRs), streamlining the process and improving transparency. It also outlines specific conditions and necessary actions for when there are exceedances of permit limits. Additionally, check for compliance schedules that provide a structured timeline for meeting more stringent permit requirements. Proactively planning for these changes can help you secure the necessary resources to meet the new requirements.
Proactive Communication with Regulators
Establishing and maintaining open communication lines with your regulatory agency is invaluable. Transparent discussions about operational challenges, exceedances or other non-compliance issues can foster a supportive approach to finding solutions. Proactive communication helps build trust and may lead to more supportive interactions in contrast to punitive responses when issues are not disclosed.
Timely Reapplication
A critical aspect of permit management is the duty to reapply for permit renewal within 180 days before the permit expires. Failing to reapply on time can lead to your permit not being administratively continued, which might result in enforcement actions, especially if the permit does not get reissued before the permit expiration date.
Conclusion
Understanding your NPDES permit is critical for you to stay in compliance. If you have questions about your NPDES permit, whether about the application process, specific monitoring and reporting requirements, or special compliance conditions, email our team at Moonshot Missions (info@moonshotmissions.org). We can provide help at no cost to your utility!