Keeping Current With Changing Wastewater Regulations
May 20, 2014
Businesses large and small face the need to comply with wide-ranging government regulations. These can sometimes seem like moving targets, but given the penalties for noncompliance – including negative perceptions of the marketplace – business owners who ignore regulatory matters do so at their own peril.
This week we welcome guest blogger Bill Williams of Williams Environmental Services, LLC in East Granby to offer some insight on the latest developments in the permitting process dealing with wastewater discharge.
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The State of Connecticut’s Department of Energy and Environmental Protection (DEEP) administers its wastewater permitting program as authorized by the U.S. Environmental Protection Agency (EPA). The DEEP offers permits for those business entities discharging process wastewater to each of three principal areas:
- sanitary sewers
Each of the above areas requires its own particular permit.
In the Beginning: Site-Specific Permits
Historically, virtually all businesses have had to acquire individual, site-specific permits. These were written for each particular site, industry and discharge type, and were unique in that they represented the discharge for that business only. They offered specific regulatory control for a wide range of discharges, but the permitting process could be costly and complicated.
Site-specific Permits Make Way for General Permits
Over the last twenty years, the DEEP has responded to a growing need to streamline this permitting program, removing the more time-consuming aspects of the process to develop “General Permits.” These are issued by the DEEP in place of the individual permits. Rather than being written for specific businesses, General Permits cover an entire industry or discharge category.
In most cases the discharge types and amounts associated with these businesses are unlikely to cause environmental problems. General Permits, which include specific discharge standards and operating conditions, offer a far more efficient way to permit discharges to sanitary sewers; interested parties fill out some registration forms, send some data to Hartford, and wait for approval. In some cases there is a permit registration fee.
Expanding the Scope with Financial Incentives
Seeing the success of this new process, the DEEP has widened the scope over the last few years. They issued two new General Permits in 2013, including one for electroplating and metal finishing, which will be of particular interest to some CONNSTEP clients. In order to entice these businesses to come into the General Permit program, the DEEP has offered some significant financial incentives.
In particular, those moving to the General Permit can do so without paying annual fees, a savings of up to $12,000/year.
Also of interest to many CONNSTEP clients is the “General Permit for Miscellaneous Discharges of Sewer-Compatible Wastewater,” also called the “MISC General Permit.” MISC was one of 10 general permits, and in 2013 the DEEP issued a new, significantly expanded MISC to cover the other nine permits. Effective last October, the MISC permit can now cover all of these discharges.
Transitioning to the MISC General Permit
In sum, if your business discharges wastewater to a sanitary sewer, and you haven’t already migrated to the MISC general permit, you need to take steps right away to begin the transition. General Permits for Boiler Blowdown (GBB) and Tumbling and Cleaning (GTC) expired in December, and another (Swimming Pool (GPL)) will expire in early July.
Like it or not, any industrial discharge to a sewer requires a permit. Compliance is mandatory, but the good news is that these permits are now easier to get than ever.
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