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5.1
Conduct a Facility Survey
5.2.3
Drinking Water
5.4
Wastewater and Storm Water Reduction Through Pollution Prevention
All chemical companies will have water management issues. Properly managing the volume, use, and disposal of water can help you achieve your objective of an environmentally sound operation. By characterizing how your operation uses and discharges water, you will also better understand the regulatory implications. The information and references in this Section will assist you in:
Figure 5-1 below outlines the process you should follow in managing your on-site wastewater, storm water, and drinking water issues. As previously discussed, you should first conduct a facility survey; then, determine if any waters related to your facility are regulated (i.e. requires a permit); and finally, understand what your reporting, recordkeeping, and notification requirements are. Figure 5-1 Water Regulatory Determination Flow Diagram
The first step towards proper water management is to physically “walk through” your operation and identify the various operations or processes that use water and generate wastewater. After identifying the sources of wastewater, you need to determine where these waters go. Ultimately, you should know where your wastewater goes and the volume being discharged. For larger facilities, a plumbing and/or water delivery system diagram will show sanitary sewer lines and storm sewer piping. Storm sewer piping is normally meant for rain water, although water from fire sprinkler drainage, non-contact cooling water, and other permitted process water may also drain to storm sewers. Floor drains are normally routed either to the storm sewer or sanitary sewer. You may want to walk around the perimeter of your facility and look for any water flowing (or evidence of previously flowing water) from your operation. It is best to do this on a dry day to avoid being confused by storm water. You should look for water flowing directly onto the ground from a pipe or other structure, or water flowing from a pipe into a creek, stream, river, pond or other water body. Next, you should determine if storm water comes into contact with any of your industrial activities, and where the storm water ultimately ends up. Generally, if precipitation can come into contact with any raw materials, chemicals, finished products, or wastes, then your storm water has been associated with your industrial activity and must be recorded as such. Finally, you should survey your drinking water system to determine where it comes from and how it is delivered (i.e. faucets, water coolers) to the end users. This information will help you to determine if your facility is considered a public water supply and if there is the potential for lead contamination of the drinking water. 5.2 Determine Regulatory ApplicabilityMost chemical companies are heavily dependent on water for use in their various processes. In addition to process water, drinking water and storm water may also enter into the regulatory equation. Factors specific to your operation and location will determine if you are regulated. 5.2.1 WastewaterIt is crucial that you can determine where your wastewater goes. “Mystery” discharges can damage the environment and expose your operation to potential liability. Once your facility wastewater survey is complete, refer to Figure 5-2 to help determine if your wastewater is regulated. Wastewater Discharged to a POTWMost chemical companies receiving water from a local water utility will discharge their process, non-sanitary wastewater and sanitary wastewater (from toilets and sinks) to a sanitary sewer system. The wastewater then flows to a treatment plant (Publicly Owned Treatment Works - POTW). After treating the wastewater, the POTW discharges the treated water into a river, lake, stream, or other water body. Companies that discharge to POTW are “indirect dischargers” and are subject to the requirements of the POTW’s pretreatment program. You will most likely require an indirect discharge permit if your wastewater flows to a POTW and your company will be considered a significant industrial user. A significant industrial user is defined in OAC 3745-3-01(BB). Each POTW has specific limits on the types and amounts of pollutants that may be present in the wastewater that it treats and these limits are known as local limits. If the POTW has an approved pretreatment program (Ohio EPA List of Approved Pretreatment Programs), then the POTW will issue the applicable permits, otherwise, Ohio EPA develops and issues the indirect discharge permits. These permit limits are developed by comparing the applicable categorical pretreatment standards in 40 CFR Subpart N and POTW-specific limits (local limits) based on the following criteria (which have the potential to pass through the POTW or interfere with its operations):
Note: The indirect discharge permit is issued to a discharger by the Ohio EPA if the POTW does not have an approved pretreatment program. More information about the Ohio EPA issued indirect discharge permits are available by accessing the Ohio EPA Non-Targeted Indirect Discharge Permit Program. Figure 5-2: Regulatory Determination for Wastewater
Your facility may also be required to meet National Pretreatment Standards in 40 CFR Subpart N. The following is an abbreviated list of some of the industries that must adhere to categorical pretreatment standards:
The entire list can be found at OAC 3745-3 . Even if your facility does not have to adhere to a categorical standard, you may still need a discharge permit if:
The most efficient method of building a relationship with your POTW is to send a letter that identifies your operation and type of discharge. You should be able to locate the appropriate person by contacting the utility that issues your water bill, or placing a call to your city or town government office, or department of public works. You may also want to schedule a meeting with POTW representatives to ensure both sides are made aware and are clear about the pretreatment requirements. Regular wastewater sampling may not be required for small wastewater discharges. However, permitted discharges will most likely have sampling requirements. Your POTW or department of public works may also conduct “spot” sampling to evaluate your discharge and ensure it is within the pretreatment discharge specifications. If sampling is performed, samples should be taken outside your facility at the manhole connection where your discharge enters the POTW’s collection system (rather than inside your building). In order to protect yourself from erroneous sampling or analyses, a "spilt sample" should be obtained from the individuals collecting the samples. (A “split” sample is one in which the sampler takes one sample and divides it for separate analysis). The same handling, and analytical methods should be used on both samples. Do not accept “duplicate” samples, where the sampler takes two samples and leaves you with one of them. “Duplicate” samples are more difficult to defend (since they originate from two different samples) if you have doubts about the analysis. Wastewater Discharged to a Creek, River or Other Body of Water In addition to pretreatment requirements, chemical companies need to be concerned if any wastewater does not proceed to the POTW. In other words, if wastewater is discharged directly from your facility to a storm sewer, creek, ditch, stream, river, pond, or other water body, additional regulations may apply. These discharges require a National Pollutant Discharge Elimination System (“NPDES”) permit from the Ohio EPA Division of Surface Water. Note: Your facility may also require a NPDES permit if your POTW does not have a pretreatment program. Further, if your company treats its wastewater, that treatment process may also require a permit. The only regulatory exceptions are for air conditioning condensation, water from building foundation drainage, and firefighting water. Even if you discharge non-contact cooling water into a storm water drainage swale on your property, you are required to obtain a NPDES permit. The NPDES permit system serves to protect the quality of all the various water bodies in Ohio. Protecting the use of Ohio’s rivers, lakes, and streams for drinking water, aquatic life, and recreational uses (such as fishing and swimming) requires stringent limits on the amount and concentration of pollutants that are discharged. Wastewater Discharged to a Septic Tank System New wastewater discharges into a septic tank and leach field system are regulated by Ohio EPA and require a permit. Chemical companies installing a new system or discharging to an existing system need to be concerned with contaminants such as metals that will build-up over time and pose a future clean-up liability. You should consider discharging only sanitary wastewater to the septic tank system and treat all other wastewater separately. Industrial wastewaters cannot be discharged to an on-site septic system. This type of discharge is considered a Class V injection well, which requires a permit from the Ohio EPA Division of Drinking and Ground Waters – Underground Injection Control Program. Chemical companies with wastewater discharges to a septic tank system should check with the Ohio EPA Division of Drinking and Ground Waters to determine if they require a permit. Chemical companies that want to install or modify their water “disposal systems” must first apply for a Permit-to-Install (PTI) from the Ohio EPA Division of Surface Water. The services of a professional engineer who is experienced in the preparation of detailed plans for the size of the system needed and familiar with Ohio EPA guidelines must be obtained. Once the detailed plans are completed, the plans, along with a completed permit application, can be submitted to the Ohio EPA for approval. Chemical companies are required to obtain a storm water discharge permit from Ohio EPA if storm water runoff on their property is associated with “industrial activity” (discharges from any conveyance that is used for collecting and conveying storm water that comes in contact with industrial activities and may become contaminated with raw materials, chemicals, intermediate or finished products, or wastes). This applies to all facilities with a major SIC code of 28. Operations which are entirely indoors or covered to protect manufacturing equipment, raw materials, byproduct, and wastes from contact with storm water will generally not require a storm water permit, but may be required to file a "No Exposure Certification", depending on their SIC code. SIC codes 283 and 285 are eligible. The complete list of SICs that are eligible for a No Exposure Certification can be found in 40 CFR 122.26(b)(14)(i)-(ix) and (xi). No Exposure Certifications should be submitted to:
Ohio Environmental Protection Agency However, many chemical companies may be regulated regardless. Your company or operation might fall under an industry category that requires an NPDES permit for storm water discharges. Further, a storm water permit is required for any new construction or construction projects that encompass five or more acres. To help determine if your facility is required to obtain a storm water permit, refer to Figure 5-3. Discharges to combined sewer systems do not require a storm water permit. Facilities that require a storm water permit must also prepare a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP is a detailed plan that can help facilities reduce the amount of storm water associated with industrial activity. The SWPPP is an integral component in achieving an environmentally sound operation. Details of SWPPPs and specific pollution prevention ideas for storm water can be found at the end of this Water Management Section. Consult Chapter 2 (Pollution Prevention) of this guide for general pollution prevention information. The Ohio EPA Division of Surface Water should be contacted for more information concerning storm water issues. Figure 5-3: Regulatory Determination for Storm Water START
NOTE: The permit requirement for construction activities will be reduced from 5 acres to 1 acre effective December 9, 2001. Spill Prevention Control and Countermeasures Plans There is another set of rules that may apply to your operation, based on your facility’s oil storage capacity. You may be subject to the Spill Prevention Control and Countermeasure (SPCC) regulation. To help determine if your operation is regulated under the SPCC, refer to Figure 5-4. The Spill Prevention Control and Countermeasures (SPCC) regulation establishes spill prevention and spill control requirements for facilities meeting certain oil related requirements. This regulation applies specifically to oil storage capacity, regardless of whether the tank or container is completely filled. Chemical facilities that fall under the SPCC regulation must design a SPCC plan to minimize the risk associated with oil usage and storage. The plan must address issues of oil storage, spill prevention measures, personnel training, and facility security, and it further outlines the procedures to be taken in the event of a spill. Figure 5-4 Regulatory Determination for SPCC Regulations START
The SPCC plan must be certified by a registered professional engineer and reviewed every 3 years, or whenever there is a change at the facility that could impact any aspect of the plan. The Ohio EPA Division of Emergency and Remedial Response can give you further guidance on SPCC requirements and details of a plan. If there is a spill of more than 1,000 gallons, or two spill events occurring within any 12 month period, you will need to prepare a report for the U.S. EPA and the Ohio EPA Division of Emergency and Remedial Response. The report must include:
If you are in fact regulated under the SPCC regulation, you may have to submit a Facility Response Plan (FRP). Refer to the following section to determine if you require an FRP. If, because of its location, your facility could reasonably be expected to cause “substantial harm” to the environment by discharging oil into or onto navigable waters or adjoining shorelines, you must prepare and submit a Facility Response Plan (FRP) to the Regional Administrator of the U.S. EPA. The FRP is a very detailed and comprehensive spill response plan that is typically applicable to very large facilities or those located close to waterways. Refer to Figure 5-5 to help determine if your facility requires a FRP. The U.S. EPA is solely responsible for the approval and administration of FRPs. Figure 5-5: Regulatory Determination for Facility Response Plans START
There are two main issues you will want to address in reviewing your drinking water supply:
Refer to Figure 5-6 to help determine if your water supply is regulated or if a possibility exists for lead contamination.
Figure 5-6: Regulatory Determination for Drinking Water START
You must first determine where your water comes from. If water is supplied by a water utility, no drinking water regulations will apply to your facility. However, if your water source is an on-site well and you provide water (i.e. for drinking, cooking, washing hands or dishes, and bathing) to 25 people or more at least 60 days a year, then you are considered a “public water system.” Public water systems are regulated by the Ohio EPA Division of Drinking and Ground Waters. Specific requirements include:
The second water concern is lead (Pb) in your water supply. Lead in the water is most commonly caused by lead solder used in piping and water fountains (coolers). Although lead has not been allowed for these drinking water purposes for several years, older facilities may still have lead in parts of their water delivery systems. For a quick reference for water fountains (coolers), refer to the EPA notice : “Drinking Water Coolers that are Not Lead Free”. This document can be ordered through the US EPA at the following location: http://www.epa.gov/safewater/Pubs/standards.html#lead1 Although not required by regulations, chemical facilities should do all they can to rid their drinking supply of lead for the overall health and safety of their employees. 5.3 Recordkeeping, Reporting, and Notification Companies desiring to discharge any water (wastewater or storm water) directly to waters of the State must first obtain a NPDES permit from the Ohio EPA Division of Surface Water. The permit may be either general or individual. General Permits cover facilities that have similar operations and discharges. These permits are for discharges that have a minimal environmental impact, and they are a potential alternative to the more detailed individual permits for companies who meet the eligibility criteria. Some of the advantages of a general permit include:
Applicable general permits currently available cover construction storm water, industrial storm water, and non-contact cooling water discharges. Conversely, Individual Permits are unique to the facility, and they are based on the facility’s operations, type and amount of discharge, and receiving stream, among others. More time and resources will be spent obtaining an individual permit then required for a general permit. NPDES requirements include:
If your facility discharges to a POTW, then you will not need a NPDES permit. Instead you will require an indirect discharger permit from the POTW (or the Ohio EPA if the POTW does not have a pretreatment program). You must take care to notify the POTW if any changes to your discharge is expected (i.e. chemical, biological, volume, periodicity, etc.). Your permit requirements will either follow a categorical standard or the POTW’s own requirements as part of a pretreatment program. In general, all indirect dischargers to a POTW must complete a baseline report and perform periodic testing, monitoring, and reporting of discharges (e.g. Semi-Annual Sampling and Analysis Report). If your facility is considered to provide a public water system you must:
The key contacts for any water discharges are the Ohio EPA Divisions of Surface Water and Division of Drinking and Ground Waters, and your local POTW administrator. Sharing as much information as possible with these contacts will make the permitting and reporting process much smoother and less frustrating. 5.4 Wastewater and Storm Water Reduction Through Pollution Prevention 5.4.1 Wastewater Pollution Prevention The chemical industry is extremely diverse. There are literally thousands of different processes and operations across the state. It is impossible to describe all the possible pollution prevention ideas relating to every chemical process. Appendix E of this Section includes a listing of “Wastewater Pollution Prevention” resources that could be of value to your operations. Check it out, and see if any of the ideas can help you reduce your regulated wastewater. Water pollution prevention principles often rely on three general approaches: (1) decreasing water usage; (2) reusing water through closed-loop recycling; and (3) ensuring that sanitary wastewater is not contaminated with non-sanitary wastewater. By no means do these three general areas provide an exhaustive list of wastewater issues to investigate. However, improvements in these areas will decrease your wastewater volume, improve pollutant characteristics and lead you towards an environmentally sound operation. 5.4.2 Storm Water Pollution Prevention Some chemical companies may be able to avoid the storm water permitting requirements by taking steps to prevent storm water from contacting “industrial activity.” Industrial activity may include:
However, most chemical companies will be required to have Storm Water Pollution Prevention Plans (SWPPP) as part of their storm water permit (required as a result of your Standard Industrial Classification (SIC)). Elements of these plans include:
It is highly desirable to incorporate the SWPPP into a more comprehensive, facility-wide, Pollution Prevention Plan. You can contact the Ohio EPA Division of Surface Water and Office of Pollution Prevention for regulatory information and assistance in developing these plans. In general, it is best to have your drum storage areas (even for empty drums) inside or under protective cover to prevent storm water contact. Items such as shipping pallets, waste packaging, and recyclable material should also be kept under cover. Trash dumpsters should either be moved under cover or equipped with effective lids to prevent contact with storm water precipitation and runoff from exiting the dumpster. Simple ideas like these will go a long way in reducing your storm water regulatory burden and making your operations more environmentally sound. Sources of Additional Information and Assistance Permitting and Technical Assistance:
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