Real Estate & Land Use

Part Four of Four
This is the last in a series of four articles about NPDES permits for Publicly-owned Treatment Works (POTWs). The first three articles in this series discussed Technology-based limits-—TBELs-—and Water quality-based effluent limits-—WQBELs-— in both numerical and narrative form. This article discusses what may be the most important aspect of Permits as they apply to Certified Operators: reporting. Because the reporting rules are so complicated, and because some NPDES permit provisions conflict with the regulations, this article cannot prescribe what to do in all situations. Attempts to obtain clarification from DEP have not been successful, although at the time of writing (fall, 2017) we have received some preliminary and informal comments that might result in revision of this article if they are affirmed by DEP administrative staff.

This is the third article in this 4-part series: [1] about NPDES permits for wastewater discharges from Publicly-Owned Treatment Works (POTWs). All POTWs are required by regulation to give a copy of the current NPDES Permit to all of their Certified Operators. Certified operators, in turn, are required by regulation to know what the Permit requirements are and report to the Owner when a violation is-—or is likely to-—occur. Hence, all Certified Operators should become familiar with the provisions of their permits. Because it is the most complex topic, we discuss effluent limits in the first three installments. The fourth article will explore reporting requirements.

In the first article in this 4-part series, we discussed “Technology-Based” Effluent Limits, or TBELs, for C-BOD, TSS, pH, fecal coliform bacteria, residual chlorine, and oil and grease. These limits are set by regulation and apply to all POTW discharges regardless of whether or not they are necessary to protect water quality.

Part One of Four
This is the first in a series of four articles [1] about NPDES permits for wastewater discharges from Publicly-Owned Treatment Works (POTWs). All POTWs are required by regulation to give a copy of the current NPDES Permit to all of their Certified Operators.