EPA Meeting @ Village Hall to defend Direct Discharge Request

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:

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.

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. 

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

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...

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!

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

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

Dear it rains inside,

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

Rgds / Charles.C

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

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.

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

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

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