Industrial Wastewater Permits

Industrial Wastewater PermitsFlorida Department of Environmental Protection (FDEP) regulates wastewater discharges in Florida.  There are two types of wastewater, domestic and industrial.  Domestic wastewater is sanitary wastewater or sewage, while industrial wastewater is generally everything else.  Industrial wastewater can come from various sources.  These include manufacturing plants, industrial operations, construction, agricultural production and processing, commercial businesses, car washes, food processing facilities, ready mix concrete plants, boat repair yards, marinas, petroleum and solvent cleanup sites, mines, and more.

 

To be regulated, the discharges must have pollutants in them and be discharged to waters of the State (or to groundwater, which is not the focus of this article) or have a reasonable expectation to be a source of water pollution.  Waters of the state include rivers, streams, lakes, ponds, estuaries, bays, the gulf, and oceans.  Ditches that flow into these waters are included.

 

The pollutants are identified in 62-302, Florida Administrative Code (F.A.C.).  They include organic matter and chemicals, metals, nutrients, solvents, petroleum hydrocarbons, particulates, pesticides, radioactive materials, and more.

 

All industrial wastewater permits stem from the federal Clean Water Act enacted by the U.S. Congress in the 1970’s and implemented by the U.S. Environmental Protection Agency (EPA, www.epa.gov) under its National Pollutant Discharge Elimination System (NPDES).  In Florida, the NPDES regulations are implemented by FDEP (www.flwaterpermits.com).   Usually, the local FDEP District Office is the permitting authority.  Sometimes, it is a county environmental office and for a couple of permit types, it is the State FDEP Office in Tallahassee.

 

There are NPDES permits for point sources (e.g., discharge pipe from a manufacturing plant) and nonpoint sources (i.e., stormwater runoff).  In this article, we are focusing on point sources.  Regardless of that, FDEP issues one NPDES permit for the facility which serves as both the state and the federal permit.

 

Not every facility needs an individual industrial wastewater permit.  There are general or generic permits which cover common facilities with similar operations, pollutants, controls, and discharges.  These are available for concrete ready mix facilities, tomato wash operations, laundromats, fish farms, sand and limestone mines, fresh citrus wash water, and car wash systems.

 

The first step is to determine if you are discharging to waters of the State and if the discharge contains pollutants.  After that, you will need to calculate volumes and concentrations of pollutants in the discharge.  Testing may be required to determine the concentrations.  The testing may require a simple grab sample or may require a sample composited over 24 hours or more.  A state certified lab will be required to analyze the samples.  A Chain-of-Custody form will be required to follow the sample bottles from the laboratory shipping the empty bottles through sample collection, transportation, and submission to the laboratory.  While you may save money collecting the sample yourself, it pays great dividends to have a trained environmental scientist or engineer collect it.

 

Whatever your needs are, Environmental Safety Consultants (www.escflorida.com) can help you evaluate your operation, test your discharge, and apply for your industrial wastewater permit.  We are a Florida-licensed Engineering business with a Professional Engineer (P.E.) on staff.  We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net).  Contact us today!

Air Emissions Permits

Certain businesses often ask us at Environmental Safety Consultants if they are required to apply for air emissions permits.  The Air Emissions Permitsanswer depends on what types of equipment they operate, what chemicals they use, and what kinds of pollutants they generate.  Although the State of Florida reserves the right to permit any sources of pollution, it does not want to get bogged down with a multitude of small or “de minimis” sources.Why then are sources such as paint spray booths, dry cleaners, and fiberglass spa manufacturers regulated?  The answer lies in the pollutants generated.  Certain chemicals such as methyl ethyl ketone (MEK) in paint or solvents, tetrachloroethylene or perc used in dry cleaning, and styrene in fiberglass manufacturing are categorized as hazardous air pollutants (HAPs) by the U.S. Environmental Protection Agency (EPA).  You can find information on the EPA at www.epa.gov.These chemicals present a higher risk to human health than others and, consequently, are regulated more strictly.  Beyond HAPs, those sources that can generate a significant nuisance such as blowing dust, paint overspray, metals, or fuel odors are also targeted for permitting.  General usage of solvents and chemicals inside a facility can require an air permit for fugitive emissions since there is no single emissions point such as a smoke stack.

Obtaining an air emissions permit for a source, even a small one, can be a lengthy, complicated, and expensive process for any business.  Fortunately, there are some less harrowing alternatives for certain sources.  Additionally, modifying the process or substituting less hazardous materials or chemicals may eliminate the need for a permit or may simplify the permit.  Reducing the amount of material escaping to the atmosphere can drop a source’s emissions below a permitting threshold.For common sources with similar operations, there may be a general permit available with less rigorous application and compliance requirements.  To determine permit requirements, businesses must review their operations, chemicals, controls, and pollutants.  With this information, they will be ready to determine permit requirements.

There are a few different types of air emissions permits.  Title V Permits cover the largest sources and are the most complicated to obtain.  For smaller sources which still require an individual permit, there is the Federally Enforceable State Operating Permit (FESOP).  Finally, there are General Permits for commonly encountered sources such as concrete ready-mix plants, crematories, and other facilities.For individual air emissions permits such as Title V Permits or FESOPs, the air permit application is a two-step process.  First, the Construction Permit application is submitted so the source can be constructed or installed.  After it is up and running, an Operating Permit application is submitted.  There may be inspections, engineering certifications by a Florida Professional Engineer (P.E.), and emissions testing required before the Operating Permit application can be submitted.  The Operating Permit will contain general conditions and specific conditions which can include record keeping, testing, and reporting.Permitting requirements all originate with the Clean Air Act (CAA) passed years ago by Congress.  EPA has promulgated regulations to implement the CAA.  Florida Department of Environmental Protection (FDEP) has passed its own state regulations to enforce the EPA’s federal regulations.  Check FDEP out at https://floridadep.gov.  Therefore, in Florida the FDEP is the air permitting authority.  So typically, the appropriate FDEP district office is contacted to determine permit requirements.  For some of the larger counties, the counties themselves are the permitting authority for the FDEP.  But, FDEP can tell you that.

So, there you have it.  A broad picture of air emissions permits in Florida.  Let us know at (941) 795-2399 if we at Environmental Safety Consultants can help you.  You will be able to breathe a lot easier!