from the wastewater program and may require special reporting or
Solids NPDES Permit. FOTW residual solids
management has received special attention under the Federal
program (40 CFR Part 503). Solids management will typically be
addressed as part of the FOTW operating permit. However, if
there is no surface discharge and, consequently, no discharge
permit, an NPDES permit for the solids may still be required.
Par. 2.4.3 covers Part 503 sludge regulations.
NPDES Compliance. Failing to comply with the
NPDES permit may result in fines and other penalties. In some
cases, it may even result in criminal prosecution. The specific
and general conditions in the permit are the compliance
provisions. Monitoring reports and emergency conditions bear
special note. Since the NPDES program relies on self-reporting
for implementation, EPA places special emphasis on timely and
complete reporting. Enforcement actions are often swift and
severe for being late with the monthly operating reports or for
failing to report violations. Emergency failures or spills
typically require notice within 24 hours to the agencies.
Exceedance of water quality limits will also draw
regulatory attention and possible enforcement action. Some
parameters, like residual chlorine, cannot always be monitored at
the low permit limit levels. The FOTW operator needs to be sure
that readings below detection limits are properly reported on the
monthly operating reports. Compliance exceedances because of
process failures or overloading need to be corrected in a timely
manner. Sometimes the permitting agency will enter into a
compliance implementation schedule to allow the treatment
facility time to come into compliance. However, proactive
planning prior to the permit renewal application can reduce the
likelihood of enforcement actions.
Permit Renewal. NPDES permits are valid for
5 years but may be modified at earlier intervals by regulators.
Permit renewal applications need to be submitted 180 days (about
6 months) before the expiration date. Ideally, preparation for
the application begins approximately 1 year before the permit
application is due. Preparation involves assessing plant
performance and improvement needs and conducting the necessary
planning and design required to keep the facility in compliance.
Your installation's environmental office may ask you to assist in
review of a Capacity Analysis Report and an Operation and
Maintenance Report, as described below. These reports are