Our client, a sanitation district with a small pretreatment program, asked ALG to help revise their industrial user (IU) wastewater discharge permits and develop a streamlined permit for controlling minor wastewater discharges from previously unregulated facilities. The IU discharge permit template’s update needed to incorporate all elements required by the federal pretreatment program and effectively communicate district concerns to existing and new IUs. In addition, the regulation of minor facilities was expected to increase the size of the sanitation district’s pretreatment program by several orders of magnitude. As such, the district needed a focused yet comprehensive control mechanism that could be easily understood by previously non-permitted facilities and be issued and overseen by staff with limited time resources.
Using Environmental Protection Agency (EPA) guidance manuals and referencing applicable federal and state regulations, ALG drafted an updated industrial user permit template incorporating all required elements. The template included annotations providing guidance for tailoring the permit template to various types of industrial users expected to be regulated in the district service area.
ALG also developed a single-page wastewater discharge control permit broadly applicable to minor users, including facilities discharging fats, oils, and grease (FOG). The permit contained the general prohibitions, notification requirements, and required best management practices (BMPs), establishing a simple yet enforceable framework for evaluating compliance.
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With these updated permitting tools, district staff were able to re-issue industrial user permits that were compliant with all federal and state pretreatment program requirements and issue a significant number minor facility permits in a short amount of time. Upon successful completion of these initial requests, ALG was directed to review other pretreatment program issues, for which ALG provided facility characterization and permitting determinations together with standard operating procedures for program implementation.