ISAT 422: Environmental Management Water Regulations n "Clean Water Act (CWA)" = Water Pollution Control Act of 1972 n Amended by Clean Water Act of 1977 (influenced by 1976 consent decree pursuant to NRDC’s suit of EPA re: toxics) n Amended again by the Water Quality Act of 1987

ISAT 422: Environmental Management NPDES Permit Program n NPDES: National Pollutant Discharge Elimination System n Point sources into waters of US require permit n State by state WQS (Water Quality Standards) used, similar to NAAQS, based on intended use of water

ISAT 422: Environmental Management Control Technologies n Applied on an industry-by-industry basis n BAT: Best Available Technology Economically Achievable – For “priority pollutants” (126+ toxics)

ISAT 422: Environmental Management BPT: Best Practicable Control Technology Currently Available n Intended to capture existing sources n For pollutants requiring a substantial level of control n To have expired to BAT by July 1, 1983

ISAT 422: Environmental Management BCT: Best Conventional Pollutant Control Technology n Added by 1977 amendments, extended by 1987 n Considered by Congress to be comparable to secondary treatment n For conventional pollutants: – BOD, TSS, pH, Fecal coliform, Oil and grease (40 CFR )

ISAT 422: Environmental Management Pretreatment Program n Industrial waters discharged into POTW are required to be pretreated to prevent damage to or overwhelming of POTW n General, Categorical, and Local standards may apply

ISAT 422: Environmental Management General n “Significant” industrial users (25,000 gal/day, or 5% of either the avg dry weather hydraulic capacity or organic capacity of the POTW). n Prohibit flammables or explosives, pH <, flow limiting solids or liquids, excessive temperature, or oils which may inhibit POTW operations

ISAT 422: Environmental Management Categorical n Based on industry category n Limits on end-of-pipe discharges

ISAT 422: Environmental Management Local n Local POTW greater than 5 MGD required to develop local pretreatment program requirements

ISAT 422: Environmental Management Others n New Source Performance Standards – Somewhat more stringent categorical standards for new sources n Stormwater – Stormwater discharge permits n Wetlands

ISAT 422: Environmental Management Enforcement n Civil Liabilities: – Class 1 Civil Penalty n $10,000 per violation n $25,000 maximum per penalty n Written notice of intent to issue order n Administrative hearing, if requested within 30 days – Class II Civil Penalty n $10,000 per violation n $125,000 maximum per penalty n Legal procedure at 5USC554

ISAT 422: Environmental Management Criminal Liabilities:

ISAT 422: Environmental Management Criminal Liabilities:

ISAT 422: Environmental Management Criminal Liabilities:

ISAT 422: Environmental Management Water Permits n NPDES – Application 180 days in advance of activity! – Limits on stream, limits on bypass, reporting of upsets – Discharge Monitoring Reports (DMR)

ISAT 422: Environmental Management Water Permits (2) n Standard clauses: – Bypass – Upset – Halt or abate – Duty to mitigate – Notification – Operation and maintenance n Stormwater Permits – NOI (Notice of Intent) regarding activities, impervious cover, &c

ISAT 422: Environmental Management Water Pollution Control n Start with water balance around plant – Account for all sources and sinks – Characterize possible contaminants of water n Primary Industrial Types – Process water – Cooling water – Sanitary water (including kitchens) – Importance of the inventory