Jump to content

  • Quick Navigation
Photo

EPA Meeting @ Village Hall to defend Direct Discharge Request


  • You cannot start a new topic
  • Please log in to reply
14 replies to this topic

#1 it_rains_inside

it_rains_inside

    Grade - SIFSQN

  • IFSQN Senior
  • 341 posts
  • 86 thanks
41
Excellent

  • United States
    United States
  • Gender:Female
  • Location:Ohio

Posted 15 December 2014 - 05:38 PM

So the plant manager sprung this one on me... I've been asked to attend a village hall meeting tonight to defend a request for direct discharge into a local creek.

 

Anyone have any pointers on dealing with the EPA? As far as I know, because we run all our water through an internal wastewater system, the water we would be directly discharging into the creek would be cleaner than what the city puts into it after they've "treated" it. (They take our wastewater out put, re-treat then discharge into the same creek we are asking to directly discharge into). The real tussle is that without our water output the village would be significantly raising water costs to cover the gap. 

 

See article from local paper below:

Discharge petition up for public comment Monday at 6 p.m.

Ohio -- Village Officials encourage village residents to attend a meeting with the Ohio Environmental Protection Agency on Monday evening.

A public meeting with the Ohio EPA concerning a direct discharge petition by XXXXXX XXXXXXXX is set for Monday night at 6 p.m.

If approved by the state, the permit allows the factory to discharge up to 100 thousand gallons of water a day into Wills Creek, treated only by their facility.

Village officials have voiced both economic and ecologic concerns about this proposal, and has issued an Impact Analysis document, which is available for public review at Village Hall.

The meeting is a part of the EPA's information gathering procedure before rendering a verdict

 

 


  • 0

"Peace is the result of retraining your mind to process life as it is, rather than as you think it should be"

                                -Wayne W. Dyer

 


#2 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 15 December 2014 - 05:59 PM

Do you have test data on the water that your company releases?  Does that test data include the items that the local water reclamation outfit tests when they take in your water and "clean" it?  If you can prove that the water that you will be discharging is lower than the allowed values that may go a long way to helping your argument.

 

Also having a retention system to ensure that it's all tested before it's discharged may help... I'm not too versed with the EPA, especially Ohio EPA, but if have some common sense points they can't shoot down it may help in a town hall setup.  It sounds like they are going to try to get public fear to help them shut down your request.  If you address the facts in front of the people it may help.

 

Nothing like the present to spring something like this on you.  Good luck.


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#3 it_rains_inside

it_rains_inside

    Grade - SIFSQN

  • IFSQN Senior
  • 341 posts
  • 86 thanks
41
Excellent

  • United States
    United States
  • Gender:Female
  • Location:Ohio

Posted 15 December 2014 - 06:21 PM

They are totally using fear, calling it an ecological concern. Even the way they talk about it on the radio sounds crazy. "They will ONLY be treating by their facility before releasing into the public water stream"

 

Uh... ok. Yeah we are ONLY treating by our facility, but we are also better equipped to handle water than the village. Whatevs yo. 

 

I've spent today collecting our water data and comparing it to those of the local water sheds. As far as retention of water before discharging, it really isnt possible with the volumes that we are looking at. We are probably going to be relying heavily on historical data to help us with that one. 

 

EDIT: I have am definitely not up to date on any EPA standards, and it all reads like greek to me. 


Edited by it_rains_inside, 15 December 2014 - 06:22 PM.

  • 0

"Peace is the result of retraining your mind to process life as it is, rather than as you think it should be"

                                -Wayne W. Dyer

 


#4 fgjuadi

fgjuadi

    Grade - PIFSQN

  • Banned
  • 898 posts
  • 193 thanks
9
Neutral

  • United States
    United States
  • Gender:Male

Posted 15 December 2014 - 06:24 PM

Ah.  I've had to do this but on the other end - someone was building a (smelly) cement mixing factory right next to food manufacturing plant.   We hired...lawyers.  Lots of lawyers. 

 

Make sure you review the Impact Analysis - did it say you would have little impact?  Is there any analyte they are concerned about?

 

You'll want tests of your discharge before and after treatment and focus on the limits  that the local authorities have set (by locality, not by state).  Sometimes it's BOD, TSS, etc.   The name on your water bill will be the name of the organization that lists the standards you'd have to comply with - probably these - http://ohiowatershed...ontaminant-list

 

Edit: They even have a cool form! http://ohiowatershed...rpretation-tool


Edited by magenta_majors, 15 December 2014 - 06:29 PM.

  • 0
.--. .- -. - ... / --- .--. - .. --- -. .- .-..

Thanked by 1 Member:

#5 Setanta

Setanta

    Grade - PIFSQN

  • IFSQN Principal
  • 959 posts
  • 220 thanks
115
Excellent

  • United States
    United States
  • Gender:Female
  • Interests:Reading: historical fiction, fantasy, Sci-Fi
    Movies
    Gardening
    Birding

Posted 15 December 2014 - 06:30 PM

Wow. Seems kinda skeevy to annouce to you that it's today.  Do you have company lawyers who might be able to assist you? I doubt they'd want you going into this alone and it is what they are on retainer for...


  • 0

-Setanta                 WeepingAngela.gif

 


#6 it_rains_inside

it_rains_inside

    Grade - SIFSQN

  • IFSQN Senior
  • 341 posts
  • 86 thanks
41
Excellent

  • United States
    United States
  • Gender:Female
  • Location:Ohio

Posted 15 December 2014 - 07:07 PM

Our WW company is going to be present also, they are a separate entity/ business... but we are their only business; They are built onto our facility. And the plant manager, he'll be there too. Im not sure of who else... They asked me to be there to defend the water testing results that we do, both in house and the samples that we have sent to third party labs. (I guess kind of like I do with auditors, but with the EPA instead?) 

 

I knew the meeting was today, just didn't know that my presence was expected... I've been reading the OEPA Water quality survey from the location and all the goodies that come with it. I haven't made it up to village hall yet to read the impact analysis (Im headed that way now) Ill let y'all know. Thanks for the input!


  • 0

"Peace is the result of retraining your mind to process life as it is, rather than as you think it should be"

                                -Wayne W. Dyer

 


#7 it_rains_inside

it_rains_inside

    Grade - SIFSQN

  • IFSQN Senior
  • 341 posts
  • 86 thanks
41
Excellent

  • United States
    United States
  • Gender:Female
  • Location:Ohio

Posted 15 December 2014 - 08:14 PM

Ok -was just given the full low-down, or down-low or whatever...

 

Apparently a 18 months ago we proposed dumping 30% into the creek so the EPA did a study for 12 months on the effects it would have. The EPA has given us permission to dump 100% of our water into the creek, the city is refuting this study. So it is us AND the EPA against the city.

 

Question answered. Thanks for all that pitched in


  • 1

"Peace is the result of retraining your mind to process life as it is, rather than as you think it should be"

                                -Wayne W. Dyer

 


#8 RG3

RG3

    Grade - PIFSQN

  • IFSQN Principal
  • 501 posts
  • 153 thanks
70
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:"We cannot solve our problems with the same thinking we used when we created them" Albert Einstein

Posted 15 December 2014 - 10:56 PM

Has anyone ever seen the movie called A Civil Action (1998)? Interesting stuff, based on a true story.


  • 0

#9 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,581 posts
  • 3275 thanks
350
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 16 December 2014 - 03:49 PM

Dear it rains inside,

 

Principle 1. QA are always the last to know.  :smile:

 

Rgds / Charles.C


  • 0

Kind Regards,

 

Charles.C


#10 MWidra

MWidra

    Grade - PIFSQN

  • IFSQN Principal
  • 771 posts
  • 285 thanks
120
Excellent

  • United States
    United States
  • Gender:Female
  • Location:On the Beautiful Eastern Shore of MD
  • Interests:My Dogs (Beagles),Gardening, SciFi, Video Games (WoW, D3, HoS, PvZ), Classical Music, Legal Stuff, Science Stuff. I'm a Geeky Nerd.

Posted 28 April 2015 - 05:57 PM

Has anyone ever seen the movie called A Civil Action (1998)? Interesting stuff, based on a true story.

The book is even better, it gives great insight into how civil actions play out.  It's used in law schools, btw.

 

Martha


  • 0

"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


#11 GSH19

GSH19

    Grade - Active

  • IFSQN Associate
  • 14 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 28 April 2015 - 06:20 PM

I would appreciate receiving any information regarding Storm Water Discharge Prevention program for food manufacturing facilities. Our products are organic herbs, spices, tea, botanicals. Our  facility storm water discharges to municipal sanitary sewer systems. Should we apply for No exposure certificate?

Thanks.


  • 0

#12 MWidra

MWidra

    Grade - PIFSQN

  • IFSQN Principal
  • 771 posts
  • 285 thanks
120
Excellent

  • United States
    United States
  • Gender:Female
  • Location:On the Beautiful Eastern Shore of MD
  • Interests:My Dogs (Beagles),Gardening, SciFi, Video Games (WoW, D3, HoS, PvZ), Classical Music, Legal Stuff, Science Stuff. I'm a Geeky Nerd.

Posted 28 April 2015 - 06:27 PM

I would appreciate receiving any information regarding Storm Water Discharge Prevention program for food manufacturing facilities. Our products are organic herbs, spices, tea, botanicals. Our  facility storm water discharges to municipal sanitary sewer systems. Should we apply for No exposure certificate?

Thanks.

You would need to have one from someone in your state, because most states administer this program through their own departments of the environment.  There are many variations on the regulations, they only have to be as effective as the EPA requirements, and can be more strict or different.

 

So, what state are you located within?

 

Martha


  • 0

"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


#13 GSH19

GSH19

    Grade - Active

  • IFSQN Associate
  • 14 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 28 April 2015 - 06:43 PM

We are located in California. All manufacturing facilities are required to get a permit for storm water pollution prevention program before July 1st 2015.


  • 0

#14 MWidra

MWidra

    Grade - PIFSQN

  • IFSQN Principal
  • 771 posts
  • 285 thanks
120
Excellent

  • United States
    United States
  • Gender:Female
  • Location:On the Beautiful Eastern Shore of MD
  • Interests:My Dogs (Beagles),Gardening, SciFi, Video Games (WoW, D3, HoS, PvZ), Classical Music, Legal Stuff, Science Stuff. I'm a Geeky Nerd.

Posted 28 April 2015 - 08:02 PM

We are located in California. All manufacturing facilities are required to get a permit for storm water pollution prevention program before July 1st 2015.

It appears that if your manufacturing site does not have the potential to expose any polluting material to storm water (rain, snow, etc.), then you could get a NEC exemption, if you can certify that your site has a condition of "no exposure."  They list items like that you don't store raw material or finished goods outside exposed to the elements, and that your dumpsters are covered, things like that, as requirements to be able to apply for the exemption.

 

I don't know enough about your plant to be able to advise you, and I should not anyway, but I do think that you need to check out the information on the NEC exemption.  All that information appears to be in Appendix 2 of the permit application, starting on p. 200 of the pdf.  I did not read the entire document, you will need to do that, but I think you should look into that first before you go through all the hassle of developing a plan to curtail storm runoff that is not needed.  Your plan will have to be customized to your site and pollutants, so someone else's plan may not fit.  I also would encourage you to talk to California EPA for help, and it appears that there's a video on their site.  There's a general industrial toolbox available on the site also, with some resources to help you.

 

Toolbox:

http://www.swrcb.ca....r/toolbox.shtml

 

Permit:

http://www.swrcb.ca....dwq_revised.pdf

 

Welcome to the world of environmental regulations.  :)

 

Martha


  • 0

"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


Thanked by 1 Member:

#15 GSH19

GSH19

    Grade - Active

  • IFSQN Associate
  • 14 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 28 April 2015 - 08:21 PM

Thank you Martha for helpful information.


  • 0




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users