1. NC DPPEA Compliance Assistance - Water
Keyes McGee
Division of Pollution Prevention and Environmental Assistance
NC DPPEA Compliance Assistance - Water
Keyes McGee
Division of Pollution Prevention and Environmental Assistance

2. DPPEA Compliance Assistance
Non-regulatory
Confidential
Staff Experience
DPPEA Compliance Assistance
Non-regulatory
Confidential
Staff Experience

3. Compliance Problems?
National Pollutant Discharge Elimination System Permits (NPDES)
Pretreatment Permits
Sewer Use Ordinance
Collection System Permits
Water Conservation Ordinance
Stormwater Permits
Compliance Problems?
National Pollutant Discharge Elimination System Permits (NPDES) - These are issued by the NC Division of Water Quality to dischargers of treated water into the waters of the state. DWQ is a delegated authority by the Environmental Protection Agency
Pretreatment Permits – Required by Publicly Owned Treatment Works as part of their National Pollution Discharge Elimination System Permit. Permits are issued by the local control authority.
Sewer Use Ordinance – This document is the legal basis for control authority operation of a wastewater treatment plant. It has specific limits and prohibitions that supercede the pretreatment permit.
Water Conservation Ordinance
Stormwater Permits

4. Regulations NPDES Pretreatment Sampling & Analysis
Federal Water Pollution Control Act (CWA)
Pretreatment
15A NCAC 2H .0900
40 CFR 403
Sampling & Analysis
40 CFR 136
Regulations
NPDES
Federal Water Pollution Control Act (CWA)
The 1972 amendments to the Federal Water Pollution Control Act (known as the Clean Water Act or CWA) provide the statutory basis for the NPDES permit program and the basic structure for regulating the discharge of pollutants from point sources to waters of the United States. Section 402 of the CWA specifically required EPA to develop and implement the NPDES program.
The CWA gives EPA the authority to set effluent limits on an industry-wide (technology-based) basis and on a water-quality basis that ensure protection of the receiving water. The CWA requires anyone who wants to discharge pollutants to first obtain an NPDES permit, or else that discharge will be considered illegal.
The CWA allowed EPA to authorize the NPDES Permit Program to state governments, enabling states to perform many of the permitting, administrative, and enforcement aspects of the NPDES Program. In states that have been authorized to implement CWA programs, EPA still retains oversight responsibilities.
The key sections of the CWA that directly relate to the NPDES Permit Program include:
Title I - Research and Related Programs
Section Declaration of Goals and Policy
Title II - Grants for the Construction of Treatment Works
Title III - Standards and Enforcement
Section Effluent Standards
Section Water Quality-Related Effluent Limitations
Section Water Quality Standards and Implementation Plans
Section Information and Guidelines [Effluent]
Section Water Quality Inventory
Section Toxic and Pretreatment Effluent Standards
Title IV - Permits and Licenses
Section National Pollutant Discharge Elimination System
Section Disposal of Sewage Sludge
Title V - General Provisions
Section State Authority
Section Indian Tribes
Pretreatment
15A NCAC 2H .0900
40 CFR 403
Sampling & Analysis
40 CFR 136

5. Know Your Water Permits
Limits
Reporting
Special Conditions
Collection System Surveillance
Know Your Water Permits
Limits
Reporting
Special Conditions
Collection System Surveillance

6. Thinking Ahead! Preventing compliance problems:
Environmental Management System
Pollution Prevention
Sustainability
Campus Community Involvement
Management Support
Thinking Ahead!
Preventing compliance problems:
Environmental Management System
Pollution Prevention
Sustainability
Campus Community Involvement
Management Support

7. Your Collection System
GIS mapped Inventory
Categorical Discharges
SUO Prohibited Discharges
Pretreatment Units
SPCC Plans
Secondary Containment
FOG Interceptors
Your Collection System
GIS mapped Inventory – Documentation of all the sanitary sewer on your campus.
Categorical Discharges – contact water processes that are governed under title 40 Code of Federal Regulations.
SUO Prohibited Discharges – Local control authority limits as a basis for system protection. Do you have a copy handy?
Pretreatment Units – Not the pretreatment program, but treatment systems that you are responsible for operating. Usually physical/chemical units.
SPCC Plans – Spill Prevention, Control and Countermeasure.
Secondary Containment – Chemical storage spill prevention devices and designs.
FOG Interceptors – Fats, Oils, and Grease Interceptors. Grease traps and oil / water separators.
All the above are SYSTEM PROTECTION components!
System Protection!

8. Notices of Violation Solve problems before they get bigger.
Seek consultation. We can help!
Prepare a timely response.
Gather information (data and narratives).
Develop a plan with defined responsibilities.
Long term corrective action processes.
Feedback for continuous improvement.
Notices of Violation
Solve problems before they get bigger.
Seek consultation. We can help!
Prepare a timely response.
Gather information (data and narratives).
Develop a plan with defined responsibilities.
Long term corrective action processes.
Feedback for continuous improvement.
Follow the EMS Model: Plan, Do, Check, Act

9. Negotiation Technically Defensible Limits
Categorically Defined Water Use
Pretreatment Level
Water Conservation Credit
Negotiation
Technically Defensible Limits
Categorically Defined Water Use
Pretreatment Level – Are pretreatment units needed? Efficacy should protect POTW – not treat to NPDES standards for conventional pollutants.
Water Conservation Credit

10. Compliance Assistance
Answering questions you’d rather not ask your regulator!
Helping to interpret rules.
Identification of prohibited discharges
Pollution Prevention Technologies
Compliance Assistance
Answering questions you’d rather not ask your regulator!
Helping to interpret rules.
Identification of prohibited discharges
Pollution Prevention Technologies
Wastewater and Waste Reduction Assistance
The N.C. Division of Pollution Prevention (DPPEA) provides North Carolina local governments with assistance on a range of environmental issues. Assistance is given in the form of on-site visits, workshops, publications and other materials, grants and responses to telephone and inquiries. DPPEA offers a complete range of services to local municipalities on wastewater issues. Highlighted below are DPPEA services that address special needs of North Carolina local governments.
Reduction of Toxic Discharges
If it is determined that an industry is discharging certain toxic chemicals into the publicly owned treatment works (POTW), DPPEA will assist in the investigation for nontoxic alternatives/substitutions to reduce the toxicity of the discharge.
Source Reduction Strategies for Specific Pollutants
If a municipality needs to focus on the reduction of a specific pollutant, either organic, metal or solid, DPPEA can assist potential dischargers of the targeted pollutant with the following strategies:
Evaluation of processes
Training on alternatives or substitutions
Investigation of alternative uses or markets for the waste
Facility Designs for Waste Reduction
DPPEA will assist industries with the design of new or expanding facilities to ensure optimum prevention/reduction of waste generation and facilitate pollution prevention and water recycling.
Source Reduction Training
DPPEA will train local municipal staff or specific commercial/industrial staff in source reduction techniques. This training can include options for specific commercial/industrial sectors, general source reduction options or resources, and/or assistance with options that address current or pending regulations.
Assistance With Compliance Problems
DPPEA's services are non-regulatory. DPPEA staff can assist municipalities in which industries have compliance problems by conducting a waste assessment, working up a detailed analysis of waste reduction alternatives, and assisting with the use of effective waste reduction strategies.
If you would like additional information, contact DPPEA at (919) or (800)

11. DPPEA Resources www.p2pays.org/mercury/ www.p2pays.org/food/
wrrc.p2pays.org/industry/laboratory.htm
DPPEA Resources
- information on mercury found in schools, information on the health effects of mercury, mercury emissions, how to perform a mercury audit, and mercury reduction options.
- Green Plan for the Food Service Industry; Fats, Oils & Grease; Food Waste. -
Promote and encourage the development of a viable composting and organics recycling industry in North Carolina to reduce the amount of organic wastes being disposed of in landfills
Provide accurate technical information on how to compost biodegradable materials
Stimulate market demand for use of top-quality composts in landscaping, gardening, horticulture, agriculture, wetlands development, and sediment and erosion control
wrrc.p2pays.org/industry/laboratory.htm - Core Sector
Laboratory hazardous and chemical waste from the wide variety of chemical testing and processing that is performed in individual labs. Waste reduction and reuse techniques. Hazardous waste reduction. Process modifications. Bulk chemical storage containers, spill prevention techniques. Chemical handling, and specific problem wastes such as mercury.

12. http://www.p2pays.org Pollution Prevention Pays Slide
I hope this presentation has helped to introduce you to the Division of Pollution Prevention’s water compliance assistance!