typically conducted by licensed engineering staff with operations
staff input. Each of these reports may take a couple of months
to develop and may lead to additional work, so a 1-year lead time
is not excessive.
If the permit renewal is due and the assessments are
not complete, the FOTW still needs to apply 180 days before the
deadline. Failure to apply in a timely manner is a permit
violation. If you have objections to your existing or proposed
permit you must file them during the official comment period.
Even if your changes are not adopted, you are on record with the
objections, making it easier to negotiate changes at a later
date. Changes to the permit can be applied for at any time
during the permit duration. There may be an additional fee for
each permit modification application. Combining requests for
changes with the permit renewal application is often convenient.
If the existing permit is being violated regularly, the FOTW may
need to conduct the following assessments and act before permit
Capacity Analysis Report. This report documents
the predicted future flows and loads within the treatment
facility, and evaluates the capacity of existing unit processes
to reliably treat those loads for the next permitting cycle. The
historical flows and the treatment performance of the preceding
5 years need to be analyzed. The carbonaceous biochemical oxygen
demand (CBOD) and total suspended solids (TSS) loading (in pounds
per day) also need to be verified. Population, flow, and load
projections are then made to estimate what future loads will be,
based on historical growth trends. The capacity of each unit
process needs to be determined. Note that these capacity
assessments may already have been done for past renewals.
However, the capacity rating of each process needs to be checked
against the latest loadings and flow. Reliability and backup
provisions must also be adequate.
Finally, an assessment of the future 5-year flow and
loads needs to be conducted. New mission and realignment
decisions must be incorporated and future projections considered.
If the plant is undersized, then an expansion needs to be
initiated and a Preliminary Engineering Report for improvements
developed. Higher discharge rates will also precipitate
additional permit application requirements to address
Operation and Maintenance Report. This report
reviews plant operations data over the last permit cycle to
evaluate needed improvements to the facility. Any upsets or