NPDES Permit Renewal – Don’t get stuck doing the same ole thing

by | Sep 17, 2014 | Blog |

NPDES Permits

National Pollution Discharge Elimination System (NPDES) permit renewal may feel like one of those redundant tasks that just has to get done, like renewing your driver’s license.  However, permit renewal should be more than just filling out some forms and cutting a check.  Once a permit is renewed, you are held to your permit requirements for five years, and some of your site information becomes public.  A carefully completed NPDES permit renewal application can have significant monetary and social impacts.  We’ve compiled a list of questions you may want to consider when preparing your next NPDES application.

Five questions to ask before you submit for your permit renewal

  1. Are you sure you have an applicable discharge? – This may seem like a strange question, but a common misconception regarding NPDES permitting is that you must have a permit if you might have a discharge.  An NPDES permit is only required if you will definitely have a wastewater or stormwater discharge from your site.
  2. Could you change structures or practices at your site to prevent the need for a permit? – Sometimes changes, such as hiring a truck-washing company that captures all the wash water to prevent runoff or moving all activities indoors or under roofs, can prevent the need for a permit and open the door for a No Exposure Certificate.
  3. Does the state your site is located in require discharge testing before you can acquire a permit? – Some states default to the federal requirements; however, others, such as Kentucky for example, require characterization sampling of stormwater discharges before a permit can be acquired.  All wastewater permits require discharge sampling.
  4. Could your current permit requirements be reduced?  If you’re not sure, ask yourself:  Has my discharge changed since I acquired or last renewed my permit?  Am I over testing/analyzing my discharge? – We recently helped a client renew their Individual NPDES wastewater permit with a significant reduction in their discharge monitoring requirements.  Their influent monitoring frequency was reduced from monthly to quarterly, effluent monitoring was reduced from weekly to quarterly, and non-applicable chemicals they were required to test for were removed.  Those changes are saving our client about $11,000 a year.  You know your site best.  Make sure the regulators understand your site like you do.
  5. Do you understand where your discharge will flow when it leaves your site, and who controls the receiving waters?  – We recently helped a client with a site in Idaho that was adjacent to an irrigation ditch.  It turns out that, unlike county drains in Michigan which are managed by a government entity, the water rights in Idaho are owned and managed by private irrigation companies and Irrigation Districts.  In this case, the Irrigation District would not allow our client to discharge stormwater to the irrigation ditch.  Our client had to submit a No-Exposure Certificate to the state and set up site management procedures to prevent a stormwater discharge from the site.

One important thing I’ve learned in this business is that the devil is in the details.  If you would like a fresh pair of eyes to look at your site and help you prepare a balanced permit application that is both protective of the environment and your budget, please give us a call.  You can reach me (aowen@dragun.com) at 248 932-0228, ext. 147.