1. National Pollutant Discharge Elimination System (NPDES) Program
Cara Cowan Watts
Graduate Student
Biosystems Engineering

2. Source of Class Materials
Presentations and Handouts
adapted from
The U.S. EPA’s
Water Quality Standards Academy
November 27-December 1, 2006
Washington, DC

3. National Pollutant Discharge Elimination System (NPDES)
CWA
Section National Pollutant Discharge Elimination System permits based on technology and water quality
Permit
License granting permission to do something which would be illegal otherwise
No right to permit and revocable for cause (noncompliance)
NPDES permit is license to discharge

4. Facility-Specific Waste Load Allocation
ABC, Inc.
Maximum allowable pollutant concentration in the effluent from ABC, Inc. after accounting for available dilution will meet water quality standards in-stream

5. Is Dilution Allowed?
Clean Water Act does not require attaining water quality criteria at the point of discharge
States have discretion to allow dilution
States should specify any conditions on dilution allowances as part of their water quality standards
States establishing Water Quality-Based Effluent Limitations (WQBELs) “should account for dilution of the effluent in the receiving water (where appropriate)”

6. Statutory Framework All “point” sources “Discharging pollutants”
Into “waters of the U.S.”
MUST obtain an NPDES permit from EPA or an authorized State or Tribe

7. Point Source (40 CFR 122.2)
Any discernible, confined and discrete conveyance (not limited to)
Any pipe, ditch, channel, tunnel, conduit, well discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be discharged.
Does not include return flows from irrigated agriculture or agricultural storm water runoff

8. Pollutant (40 CFR 122.2) Dredged spoil Solid waste Incinerator residue
Filter backwash
Sewage
Garbage
Sewage sludge
Munitions
Chemical wastes
Biological materials
Sand
Radioactive materials heat
Wrecked or discarded equipment
Cellar dirt
Rock
Industrial, municipal, and agricultural waste discharged into water
Does NOT include sewage from vessels or injected wastes

9. CWA Classes of Pollutants
Conventional pollutants
Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS), Oil and Grease, Fecal Coliform bacteria, and pH
Toxic pollutants
126 “Priority Pollutants”
Heavy metals (e.g., Cu, Pb, Hg)
Organics compounds (e.g., PCBs, dioxin)
Non-Conventional
Everything else such as Chlorine, Ammonia, Nitrogen & Phosphorus

10. Waters of the U.S.
Regulatory definition would cover virtually all types of surface waters including
Rivers and streams
Lakes and ponds
Wetlands
Sloughs
Prairie potholes
Intermittent streams
Territorial seas
And, more!

11. Reasonable Potential (40 CFR 122.44 d.1.i)
Limitations must control all pollutants or pollutant parameters that are or may be discharged at a level which will cause, have reasonable potential to cause, or contribute to an excursion above any state water quality standard

12. Types of NPDES Permits Individual General
Appropriate where site-specific limits, management practices, monitoring and reporting, or other facility-specific permit conditions are needed
General
Appropriate where multiple dischargers require permit coverage, sources and discharges are similar, permit conditions are relatively uniform
Permit must identify
Area of coverage
Sources covered
Application process (Notice of Intent)

13. Implementation Before State or Tribal program approval
EPA issues permits
EPA conducts compliance and monitoring activities
EPA enforces
After State or Tribal program approval
States implement as above
EPA role = oversight
Grants
Administrative, technical and legal support and training
Enforcement as necessary

14. State NPDES Program Authority (as of January 2006)AK
U.S. Territories
American Samoa
Guam
Johnston Atoll
Midway/Wake Islands
Northern Mariana Islands
Puerto Rico
Virgin Islands
State NPDES Program Status
Fully authorized
Unauthorized HI CA AZ OR WA ID UT CO WY MT ND SD NE KS IA MO NM OK TX AR LA MN WI IL IN OH MI PA WV VA MS AL TN KY NC SC GA FL ME VT NH MA RI CT NY NJ DC MD DE NV

15. Current and Projected NPDES (Estimates as of 4/03)
Individual Permits
Privately Owned Treatment
Works (POTWs)
Non-municipals
6,700
(4,200)
(2,500)
POTWs
48,000
(16,000)
(32,000)
Covered by General Permits
Non-Storm Water
POTWs and industrial
facilities
37,000
Approximate
Number of Facilities
Type of Facility
Major
Minor
Minor

16. Current and Projected Cont’d
Storm water: Phase I MS4s
270
Storm water: Phase II MS4s
5,000
Storm water: Phase I Industrial
90,000 est.
Storm water: Phase II Industrial
80,000 est.
Storm water: Phase I Construction
190,000 est. per year
Storm water: Phase II Construction
200,000 est. per year
Sludge-Only Facilities
6,000 est.
Approximate
Number of Facilities
Type of Facility
Approximate
Number of Facilities
Type of Facility
MS4 = small municipal separate storm sewer system

17. Questions?