ADEM Permit Applications and Renewalsby Energy Technical Services on 02/27/15
This blogpost was written by Lennette West
Most industries and municipalities know they are required to have a permit to discharge wastewater from their facility. But a lot of time and energy needs to go into to the application process to ensure the environment is protected and the entity isn't unfairly held responsible for items beyond their control. Permits are generally in effect for five years and have to be renewed before the expiration date. In Alabama, the Alabama Department of Environmental Management (ADEM), has primacy, which means their regulations are at least as stringent as Environmental Protection Agency (EPA) and can be more stringent.
Most people in the environmental industry are familiar with the term 'NPDES,' which stands for National Pollutant Discharge Elimination System; but did you know there are different types of NPDES? There are individual permits and general permits. Individual permit numbers start with 'AL' and are issued to entities that have specific processes and discharges. These are issued to municipal wastewater treatment plants and companies with individual processes that don’t fit the general permit parameters. The five year active time starts when the permit is issued. General permit numbers start with 'ALG' and are issued to generalized industrial processes. These include asphalt, lumber and wood, transportation, salvage and recycling, and offshore industries. These permits are on a set schedule for expiration and renewal dates. So if you receive a permit in the middle of the cycle, you would have to renew before five years.
In the actual permit, there may be more than one set of testing and monitoring requirements. This has been especially true of stormwater monitoring. Years ago, many permits didn’t require stormwater testing, but there has been a big push with regulatory agencies to start monitoring stormwater. Certain industries are required to collect and test the stormwater leaving their property if they have fueling on-site or have a large volume discharge of stormwater. And yes, stormwater collection means the samples are collected during a rain, which in Alabama is usually not a problem.
All permit renewal applications are due to the state at least 180 days before the permit actually expires. This allows the regulatory agency time to evaluate all the data. If the application is received under the 180 days, and the permit expires, the regulatory agency has the right to charge the facility a penalty for each day there is discharge. Also, if the company goes out of business, they still have to notify the regulatory agency and have the permit closed officially.
When renewing a permit, be aware that there may be some additional testing requirements. EPA has set requirements for information and test requirements based on the facility. EPA Form 2A is for wastewater plants. Wastewater plants are required to do three sets of additional testing during the existing permit period. Within this additional testing, there are specific tests that have to be analyzed, based on the size of the plant. EPA Form 2C is for existing industrial process wastewater facilities. Only one set of additional testing is required for permit renewal for these wastewater facilities. EPA Form 2F covers the stormwater testing. On top of all this, state agencies have additional requirements for these facilities.
After the permit application and all fees are received, the regulatory agency will issue a “draft permit” to the entity before the permit goes into effect. This, to me, is one of the most important times in the issuance of permits. It allows the entity to review and discuss any concerns that will be on the permit. The entity, their facility engineers, and their laboratory should all review the draft permit together. Once the permit is official, it is a difficult process to have changes made- and additional fees may be required. Draft permits are generally good for 30 days, so it is best not to put off reviewing. Also, during this time, the public has a chance to comment on the permit.
This is just a general overview of permitting within the state of Alabama. Detailed information can be found on the ADEM and EPA websites:
ETS would love to help you and your facility with state permitting. If you would like more information, please give us a call, or email, to discuss your specific needs.
Have a great day everyone!