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works (POTWs). That is, these facilities comply with the
construction permitting, operational permitting, and effluent
discharge and residuals handling permitting requirements as
administered by individual states and/or the U.S. Environmental
Protection Agency (EPA).
2.2.2
Permitting Requirements. Permits are issued for the
construction or modifications of FOTWs, discharge of treated
effluent, discharge of stormwater runoff, and residual solids
management practices. These permits can be issued by Federal
(EPA), state, or local governments. Sometimes all three levels
of government issue separate permits. More often, the FOTW
operating permits are combined.
Managed by the EPA, the National Pollutant Discharge
Elimination System (NPDES) program issues NPDES operating permits
required before an FOTW can discharge any process water into
waters of the state. Many states are considered to have "NPDES
primacy," meaning they are authorized to issue these permits.
Typically, states with this primacy will also incorporate any
unique state requirements into the NPDES permit. Some states
also have their own discharge permitting program. This program
requires the permittee to obtain a state discharge permit in
addition to the NPDES discharge permit. Local governments may
have separate requirements, so FOTW designers should check with
requirements may also pertain. FOTW designers will need to be
aware of all operating permit requirements to effectively design
or modify existing systems. In addition to wastewater, NPDES
permits can also address stormwater and solids. Treated effluent
that is entirely disposed into the groundwater does not need an
NPDES permit to discharge, but it may be subject to NPDES permits
for stormwater or solids. A valid NPDES permit will identify the
owner, describe the process, describe the discharge location and
frequency, and contain specific and general conditions.
An NPDES permit is not a construction permit. In some
states, an owner may construct or modify a facility, but it is a
violation to operate the modified facility until a valid
operating permit is obtained. Other states limit all
construction activities until the changes or modifications are
approved. Any change or modification to the process should be
reviewed with the permitting agency prior to implementation to
determine if a permit modification is required.
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