ENV-00-173 Sustainable Long-Term Compliance for Industrial Wastewater Discharges Through Innovative Permitting Techniques

Description:

Although meeting specific permit requirements can be one of the most challenging tasks facing the management of operating facilities, less planning and forethought is often put into wastewater discharge permit development than with other regulatory programs. As a result, many operating facilities find themselves being squeezed into more and more stringent permit requirements that are not consistent with their long term goals and development plans. One reason for this is the confusion that surrounds development and determination of permit numerical limits and monitoring frequency requirements. When a facility takes the time to review and analyze carefully each component of their existing wastewater discharge permit, they may find outdated and obsolete conditions. Flexible methods of complying with new permit requirements may be possible when the permittee understands the regulatory driving force and technical basis behind certain permit conditions. When performed in a cooperative manner with the regulating agency, new innovative permitting techniques can be implemented, which can provide the facility a greater degree of operating flexibility, while still providing protection of human health and the environment. Up-front negotiations between the facility and the regulatory agency can facilitate the permitting process, and remove the mystery surrounding “what one asks for” in a permit application, and “what one gets,” resulting in more sustainable long-term permit compliance and improved operating flexibility.