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Fact Sheet For NPDES Permit No. OHW000004 Ohio EPA Permit No. 5IGW0004 Ohio Environmental Protection Agency Fact Sheet For National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges from Water Treatment Plants I. Background The Federal Water Pollution Control Act [also referred to as the Clean Water Act (CWA)], the Ohio Water Pollution Control Act and the Ohio Revised Code (ORC Chapter 6111) provide that discharge of pollutants to waters of the state from any point source is unlawful, unless the discharge is in compliance with an effective NPDES permit. The purpose of issuing NPDES permits to water treatment plant operators is to ensure that any wastewater discharges from these systems are in compliance with all applicable state and federal water pollution control laws. Wastewaters are generated while producing potable water in water treatment plants. During normal operations, the common types of wastewaters from water plants and the processes that generate them are (a) clarifier sludge blowdown and particulate filter backwash from plain purification and lime-soda softening process, (b) iron filter backwash wastewater from iron and manganese removal process, and (c) wastewater containing dissolved solids from sodium cycle ion-exchange processes and reverse osmosis processes. During times when harmful algal blooms (HABs) enter the plant above threshold values, plant operators change operations in ways that increase discharge volumes or cause pollutants to be discharged that would not normally be discharged. Ohio EPA has elected to renew the existing statewide general permit authorizing the discharge of wastewater from water treatment systems to waters of the State. Dischargers which meet the eligibility requirements may apply for coverage under this NPDES general permit instead of seeking coverage under an individual NPDES permit. The eligibility requirements of the permit (Part I of the general permit) define which discharges can be covered. Discharge limitations are listed in Part V of this fact sheet. Draft changes to the permit are described in Part VI. Discharge limitations and Best Management Practices are listed in Part VII of this fact sheet. The general permit is intended to cover any eligible water treatment system discharge that was designed to meet these limits and that would consequently have a minimal impact on the environment. II. Antidegradation Because this permit does not authorize new discharges of pollutants to waters of the State, this permit is not applicable to the Antidegradation Rule in Ohio Administrative Code (OAC) 3745-1-05. Regardless of the water treatment system, these facilities are expected to discharge total suspended solids (TSS) and 1 total residual chlorine to surface waters of the state. Depending on the processes in the water treatment system, the discharge is expected to contain significant quantities of halomethanes, total recoverable copper, suspended iron, suspended manganese, total dissolved solids, algal toxins, and/or organic carbon. III. Description of General Permit Coverage and Type of Discharge The permit covers discharges from three water treatment system processes to waters of the State. These three processes include: Plain Purification Processes; Lime-Soda Softening Processes; and Iron/Manganese Removal Processes. Discharges from these types of plants can meet all applicable NPDES requirements through treatment technology limits, or broadly set water quality limitations. See Attachment A for the definitions of these processes. For these three processes, HAB-related water treatment plant discharges are also covered under this permit. HAB-related water treatment plant discharges are generated to minimize concentration of HAB toxins in the drinking water supply. For example, plant operators often increase filter backwash discharge to prevent toxins from being recycled to the head of the plant and potentially into the water system. This operational change causes increased volumes of discharge to receiving waters and can add pollutants such as algal toxins (i.e. microcystin) and organic carbon that the plant does not normally discharge as authorized under the existing permit. Discharges from Ion Exchange Processes and Reverse Osmosis Processes require individual permits because site-specific water quality-based limitations for total dissolved solids, and possibly other related pollutant parameters, will be needed. Individual NPDES permits may be obtained by submitting individual permit applications (Form 1, Form 2D or 2E, and an Antidegradation Addendum) available through Ohio EPA’s eBusiness Center (https://ebiz.epa.ohio.gov/login.html) or Ohio EPA’s website (http://www.epa.ohio.gov/dsw/permits/npdesform.aspx) . IV. Procedures for Participation in the Formulation of Final Determinations The draft action shall be issued as a final action unless the Director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the Administrator of the U.S. Environmental Protection Agency. Within thirty days of the date of the Public Notice, any person may request or petition for a public meeting for presentation of evidence, statements or opinions. The purpose of the public meeting is to obtain additional evidence. Statements concerning the issues raised by the party requesting the meeting are invited. Evidence may be presented by the applicant, the state, or other parties, and following presentation of such evidence, other interested persons may present testimony of facts or statements of opinion. Requests for public meetings shall be in writing and shall state the action of the Director objected to, the questions to be considered, and the reasons the action is contested. Such requests should be addressed to: 2 DSW Permits Processing Unit Ohio Environmental Protection Agency P.O. Box 1049 Columbus, Ohio 43216-1049 Interested persons are invited to submit written comments upon the discharge permit. Comments should be submitted in person or by mail no later than 30 days after the date of this Public Notice. Deliver or mail all comments to: Ohio Environmental Protection Agency Attention: Division of Surface Water Permits and Compliance Section P.O. Box 1049 Columbus, Ohio 43216-1049 The OEPA permit number and Public Notice numbers should appear on each page of any submitted comments. All comments received no later than 30 days after the date of the Public Notice will be considered. Citizens may conduct file reviews regarding specific companies or sites. Appointments are necessary to conduct file reviews, because requests to review files have increased dramatically in recent years. The first 250 pages copied are free. For requests to copy more than 250 pages, there is a five-cent charge for each page copied. Payment is required by check or money order, made payable to Treasurer State of Ohio. For additional information about this fact sheet or the draft permit, contact Phoebe Low, (614) 644-2134, [email protected]. V. Description of Application Process Notice of Intent (NOI) – Each facility seeking coverage under this general permit must submit a NOI form. Individuals with an existing discharge who intend to obtain coverage for wastewater discharges under this general permit shall submit an NOI form within 45 days of the effective date of this permit. An applicant will not be covered under the general permit until they receive written notification from the Director of Ohio EPA that a discharge is authorized under the general permit. Dischargers who fail to obtain coverage under the general permit and are not otherwise covered by a NPDES permit are in violation of Ohio Revised Code (ORC) 6111. Federal regulations found in 40 CFR 122.21(a) exclude persons covered by general permits from requirements to submit an application for an individual permit. NOI requirements are intended to establish a mechanism that can be used to establish a clear accounting of the number of permittees covered by the general permit, the identities, locations, mailing addresses, and nature of discharge. The NOI application form and instructions for completing the form are available on the following internet website by clicking on "Applying for Coverage": http://www.epa.ohio.gov/dsw/permits/gpfact.aspx 3 Completed NOI application shall be submitted through the Ohio EPA eBusiness Center Division of Surface Water NPDES Permit Application STREAMS service in the link below. https://ebiz.epa.ohio.gov/login.html For facilities that discharge water treatment plant wastewater through a municipal separate storm sewer system (MS4) shall also submit a signed copy of the NOI to the operator of the MS4. More details are included in Part II.D of this general permit. Application Fee – All applicants must submit the $200 fee for NOI processing. Payment can be electronically submitted through the agency eBusiness Center ePay service. Instructions on submitting fee payments via the ePay service can be found in the link below. http://epa.ohio.gov/portals/35/edmr/doc/ePAYwalkthrough.pdf VI. Eligibility Determining Factors A. Except for discharges identified in paragraph B, this permit may cover discharges of wastewater from water treatment plants to waters of the State. B. The following wastewater discharges associated with the production of potable water supplies (water treatment plants) are not eligible for coverage under this permit: 1. Wastewater discharges associated with ion exchange or reverse osmosis processes.1 This includes wastewater from plants
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