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How to Prepare for Wastewater Permits and Monthly DMRs October 29, 2015 Frank Capic, PE Senior Civil / Environmental Engineer

Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Page 1: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

How to Prepare for Wastewater Permits and Monthly DMRs

October 29, 2015

Frank Capic, PESenior Civil / Environmental

Engineer

Page 2: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Overview► Different types of applicable

wastewater permits

► Permit process / Net MSGP

► Net Discharge Monitoring Reports (DMRs)

► Summary / Conclusion

Page 3: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Different Types of Applicable Wastewater Permits for NPDESFrom Direct Point Source Discharges into Waters of the United States► General permit (multiple facilities within

specific category), categories:• Stormwater point sources

• Facilities with similar types of operations

• Facilities that discharges same types of wastes or same types of sludge use or disposal practices

• Facilities that require same effluent limits, operations or standards for sludge or disposal

• Facilities that require same monitoring

► Individual permits (typically five year period with re-application prior to expiration)• Process wastewater discharges

• Non-process wastewater discharges

• Industrial stormwater program

Page 4: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Different Types of Applicable Wastewater Permits for NPDESFrom Direct Point Source Discharges into Waters of the United States► Type of Users:

• Municipal / Publically Owned Treatment Works (POTWs) dischargers

• Non-Municipal (Industrial) dischargers (10 Categories of Facilities per 40 CFR 122.26(b)(14)► Subject to federal stormwater effluent discharge standards

► Manufacturing / standard industrial classifications (SIC) codes, 29 different sectors

► Coal and mineral mining and oil and gas, some caveats

► Hazardous waste treatment, storage, or disposal

► Landfills, land application and open dumps with industrial wastes

► Recycling (i.e. metal/auto scrapyards, battery reclaimers

► Steam electric power generating plants

► Transportation with vehicle maintenance, cleaning or airport deicing

► Domestic wastewater / sewage treatment > 1 MGD

► Light manufacturing (i.e. food processing, printing, electrical production, warehousing, and storage

Page 5: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Different Types of Applicable Wastewater Permits for NPDESFrom Direct Point Source Discharges into Waters of the United States► NPDES program areas

applicable to Non-Municipal (Industrial) Sources include:• Process wastewater discharges

• Non-process wastewater discharges

• Industrial stormwater program

Page 6: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Different Types of Applicable Stormwater Permits for NPDES► Types:

• Municipal Separate Storm Sewer Systems (MS4s) (from large to small categories)

• Construction activities / if USEPA authority – Construction General Permit (CGPs)

• Industrial activities / if USEPA authority –Multi-Sector General Permit (MSGP)

Page 7: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Permit Process – Net MSGP► MSGP = Multi Sector General Permit

• 2015 MSGP requires operators to submit electronic documents

• Facilities include allowable stormwater discharge or an allowable non-stormwater discharge associated with industrial activities

• Review the final MSGP June 2015 permit to determine if your facility or industrial activity falls within the MSGP requirements

Page 8: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Permit Process – Net MSGP► Net = NPDES eReporting Tool► Net MSGPs include:

• NOIs (Notice of Intents), NOTs (Notice of Terminations), Annual Reports, and No Exposure Certificates

• Accessed through EPA Central Data Exchange (CDX)

• Register CDX accounts (new or existing) to Net-MSGP program services

• Users registered as “Certifier” or “Duly Authorization Representative of Certifier” sign an Electronic Signature Agreement; or sign and mail paper agreement

• Once registered, launch Net-MSGP

• Above noted for areas as USEPA permitting authority. Review each State for the applicable programs available in those States for General Permit notifications.► Stormwater Pollution Prevention Plans (SWPPPs)

Page 9: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Login to website: https://netdmr.epa.gov/netdmr/public/home.htm

► Register with applicable State’s Net DMR program, if facility under a State jurisdiction

► Permit holders complete, sign and submit the Net DMR Subscriber Agreement

► May complete Net DMR tests to confirm accessibility

Page 10: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Login to website: https://netdmr.epa.gov/netdmr/public/home.htm

Page 11: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Advance to the Net DMR page for the particular permit. May

review Certificates of Record (COR) for the applicable Permit ID number and Facility

Page 12: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Open COR example which has been submitted:

Page 13: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Associated Monthly Monitoring Report (MMR) submitted and

attached to the COR is depicted

Page 14: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Associated MMR Sample from IDEM, with data included:

Page 15: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Net DMR► Upon the month’s Net DMR completion, save and submit the

COR and approve the COR Certification Statement:

Page 16: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

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Summary► Confirm the applicable program

for the wastewater discharge from your facility.

► The 2015 MSGP requires electronic submittal of documents, particularly if area is in USEPA authority. If your State is authority, confirm with your State on specific documents if electronic or hard copy submittals.

► Net DMR is accessible for facilities under USEPA and State authorities for submittal of electronic DMRs.

Page 17: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015

Frank Capic, P.E.Senior Civil / Environmental Engineer

1431 Opus Place, Suite 400Downers Grove, IL 60515

630-724-3242 – Direct630-669-9857 – Cell

Questions & Comments

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Page 18: Frank Capic, PE, Burns & McDonnell, How to Prepare for Wastewater Permits and Monthly DMRs, Midwest Environmental Compliance Conference, Chicago, October 29-30, 2015