Slide 1

Module 3B

How to Apply for an Individual APDES PermitFilling out the application for an Individual Permit is important because the end product the permit is important. The permit is important because it is a license to discharge waste under the terms of the permit. A permittee discharging in compliance with the terms of a valid APDES permit enjoy the benefits of the shield as specified in section 402 (k) of the Clean Water Act and by 18 AAC 83.155. Waste streams clearly identified in the application process and their identified pollutants are covered by this shield. Pollutants that were identified in the application process and listed in the permit or fact sheet, but were not given discharge limits are covered by the shield. Pollutants identified in the permit application as being part of the wastestream but are not listed in the permit or fact sheet. The permit my specifically prohibit or limit the scope of any discharge or identified pollutant.Careful and complete reporting of pollutants that may be present or are known to be present in the permit application is critical to writing a permit the provide the optimum shield to the permittee.1Wes HarveyEnvironmental Program Specialist IIIModule 3B Applying for an Individual APDES Permit2Identify DEC Seafood Processing Waste Web Page ResourcesReview the Individual Permit Applications RequiredIdentify Common Errors and Omissions in Permit Applications

Module 3B OBJECTIVES3

Where are Application Forms Located4DEC Seafood Application Portalhttp://dec.alaska.gov/water/wwdp/seafood/seafoodww.html

Each one of the application forms have their own set of instructions at the back. State Law prohibits discharge of pollutants into the waters of the US. Seafood processors which cannot obtain coverage under a general permit have a duty to apply for an individual permit.4All Non-POTW Individual Permit Applications Require a Completed Form 1Which Forms are Required?5http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form1-GeneralInformationReaderEnabled.pdfWho must apply for a permit? Anybody know the answer to this one? The operator.

5Applications for an existing facility: An existing facility includes Existing Manufacturing, Commercial, Mining, and Silvicultural OperationsAPDES IP Form 2C- Existing Industrial FacilitiesWhich Forms are Required?6http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form2C-Reader1.15.10.pdfIn addition to Form 1, Form 2C is needed for Seafood wastewater dischargers unless it is a new source:

Facility is a new source if it has never held an APDES discharge permit and did not start discharging before 1979.

6Applications for a new source and new discharge: New manufacturing, commercial, mining, or silvicultural discharge

APDES IP Form 2D- New Source New Industrial DischargeWhich Forms are Required?7http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form2C-Reader1.15.10.pdf

A new facility requiring a permit to discharge seafood wastewater and not covered under a general permit would complete form 2D, New Source discharges.

7If your discharges do not meet State WQS at the End of Pipe:Complete an APDES Form 2M- Mixing Zone ApplicationWhich Forms are Required?8http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form2C-Reader1.15.10.pdf A separate Form 2M must be completed for each outfall that requires a mixing zone. How do you know if you require a mixing zone? You need a mixing zone if any pollutant in the wastestream will or has the potential to exceed State of Alaska water quality standards.

8 Application Forms and Data are subject to public review and can be provided to the public Business Confidential Information must be specified for special handling by the DEC.Status of Information Provided9Any page of the application that the permittee wishes to not be part of the public record must be stamped business confidential. The department will determine if the data is business confidential based on 40 CFR Section 2.208 and adopted by the State in 18 AAC 83.010.9Specified information will be treated confidential if it satisfies 40 CFR 2.208 and is not otherwise required to be public by state law. Two test for compliance:No statute specifically requires disclosure, and:Disclosure will cause substantial harm to the business competitive positionEach page must be stamped business confidential

Business Confidential Information1010Name and address of permit application or facilityPermit ApplicationPermit effluent dataInformation required by an APDES or NPDES form on the form itself or any attachment to satisfy a form requirementNot limited to this list

Examples of Information Not Business Confidential11Some information cannot be considered business confidential. 11Every line needs to be completedUse NA if appropriateUse attachments if there is not enough room and refer to the attachmentAttach copies of previous submittals that answer application APDES Form Requirements12Dont leave any blanks. If you attach extra data, be sure it identifies the facility and the operator.12Section 1 - Basic Facility InformationForm 1 General Application Form13http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form1-GeneralInformationReaderEnabled.pdfThe responsible party will be designated as the bill to party unless otherwise specified.13Location InformationPage 1 is Facility Information not discharge/outfall informationCoordinatesDecimal Degree preferredProvide referenced point-facility front door, middle of parcel, NW corner of property line

Key Points of Form 1-Page 114

Do Not give the outfall coordinates. Give the lat and long of the facility processing building location. Identify the datum and xy coordinate system used.14Accuracy of Latitude and Longitude must be to the 5th decimal place at a minimumState uses North American Datum 1983 or NAD 83. Most GPS devices default to WGS 84. Location data submitted without datum will cause delays in processing the application

Accuracy and Datum-Page 115http://www.epa.gov/brownfields/pubs/acres/cqrg_latitude_longitude.pdf Please specify the datum used. The web page is an excellent reference for understanding coordinate systems.15311711 and 311712 are common codes for Seafood Processorshttp://www.census.gov/eos/www/naics/

NAICS Codes - Page 11616Alaska Coastal Zone and District Program was terminated last year. The following are true about the future of the program:Future is uncertain at this pointCoastal Questionnaire Not required at this timeMay change in the future

Coastal Zone Boundary-Coastal District -Page 117The fate of the coastal zone program is still up in the air. Coastal Questionnaires not currently required.17Section 318

The reason a corporate officer is required to sign is that the permit requirements must be addressed by a responsible party.18Responsible party is the person who has authority to sign the application and signs the application. 18 AAC 83.385 requires specific authority to sign an application.

A president, secretary, treasurer, or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision making functions for the corporation

Section 319The president, CEO, or other corporate officer that has responsibility for the principal business function can designate a responsible person such as an environmental manager, but the designation requires a signed statement.19Authorized individual is a duly authorized individual who has authority to sign reports for the responsible party.Can be delegated to a title instead of a specific person:Operation Manager, QA manager

Section 32020Enter in Permit numbers or whether application has been submitted

Section 5 Existing Permits - Page 221

This section is used to tell the DEC that you have other environmental permits.21

Section 6 Pollutant Characteristics22If existing processor, normally check Yes for question B

If yes on section 6 B, complete Form 2C.22Zone of Deposit (ZOD) informationNo separate ZOD application at this time is required.Provide ZOD information on a supplemental attachmentSection 923

Normally, with seafood processing waste discharges, a zone of deposit will form at least temporarily. If this is true or could be true, you should request a ZOD.23Thermal DischargeNoncontact cooling water and other non-process wastewaters may have a thermal discharge. Apply for a mixing zone if the State WQS cannot be met at the end of the discharge pipe.

Section 924

Fill out a separate Form 2M for each outfall that requires a mixing zone.24C. Site Specific CriteriaIn naturally mineralized area that often occur in a mining region, site specific information must be submitted to allow a change in the designated specific uses. This is often a lengthy process involves the permittee providing data indicating that a site-specific criterion may be required to alleviate an unnecessary restrictive general criterion.Section 925

The applicant must supply all data necessary to determine that a site specific criterion exists and would justify changing the designated uses for the waterbody, 18 AAC 70.235-6. Site specific criterion are most often justified by some specific condition that is naturally occurring in the receiving water. Guidance for the Implementation of Natural Condition-Based Water Quality Standards, 2006.25Mixing Zone-If yes require a mixing zone, complete Form 2M

Section 926

Mark all that apply26Signature. Must be person identified in Section 3 with adequate authorityAll forms must be signed

Section 1027

27Form 2C28Existing Manufacturing, Commercial, Mining, and Silvicultural OperationsSeafood Processor who discharge process wastewater - Wastewater exposed to a raw productAll lines need to be complete or marked NA

28Common for Seafood Processors (Page 32) Table 2C-1 Physical Treatment Processes1-L Grinding1-T Screening

Section 3: Treatment29

List all discharge outfalls.29Basis for Rainfall EventMethod of Estimation

Storm Water Flows30

30Part B: Line Drawing31

This Figure is a common problem for permittees to provide. Keep it simple and calculate the balance between input and outfall.31Common IssuesWater input location are not identifiedWater input structure not provided if water is pump from waters of US.Water input and output are not balanced Part B: Line Drawing32Each system or process within the facility are diagrammed separately instead of a combined overall system wide drawing.32Question A - YesQuestion B - YesComplete CSection 433

Section 4 A would be answered yes for seafood processors, because the inch grind requirements is an ELG.Section 4 B would be answered no for a seafood processor, because the ELG, inch grind, is not production based.Seafood processors would not be required to complete 4 C.33Section 634

Section 5 would not be completed unless there is an enforcement order requiring changes to the treatment facility.

Look in Table 2C-3 and if any of the listed the pollutants are in your discharge list them here and describe the source.34Section 635

Complete this table for every outfall separately. These tests are required for each application submittal. These parameters are specified by 40 CFR Part 122.21 and have been adopted by reference in 18 AAC 83.35At least one analysis for each parameter in effluent.If pollutant from source water, an analysis should also be conductedRequired even if last permit did not require the analysisOne table for each outfallTable 6 - A (Page 19)3636Mark Believed Present or Believed Absent.If believed Present, at least 1 analysis requiredOne table for each outfallTable 6 - B (Page 20 - 21)37

If you think a pollutant is present, say why and test for that parameter. If the tests are ND, mark believe absent and input the new data.37Table 6 - C (Page 22 - 30)38

Same as the previous slide. These parameters would not normally be in seafood waste, but there are always exception.38There are no Tests Required for the Seafood Processing Primary Industry CategoryReview remaining table to determine if believed present or believed absentIf believed present, conduct at least 1 analysis of the effluent dischargeSource water analysis recommended, but optional if believed presentTable 6 - C (Page 22 - 30)3939Metals-Pollutant of Interest in Seafood Processing wastewaterUse clean sampling techniquesWork with lab to ensure appropriate sample containers and preservation Indicate in Section 9 the laboratory and analysis performed by the lab

Table 6 - C Continued4040Signed by the same responsible party as form 1Must be signedSection 1041

This section for Form 2C is often missed, but is required to be completed by the responsible party or his designee.41Required for every Individual Permit application that has a current mixing zone or seeks to continue with a mixing zone.

Form 2M42http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form2M_MixingZones.pdf

Unless there are zero discharges of seafood processing waste, all seafood processors would require a mixing zone to meet State WQS.42In-depth review of the application beyond the scope of the workshopWork with DEC staff on specific issuesConsultant are often required to satisfy the mixing zone application requirements

Form 2M43Cormix or Plumes modeling are normally required by the department to accept a Form 2M.43Many similarities to Form 2C, but Section 6 is not as structured as an existing facility applicationStill have to determine which parameters are likely in effluent discharge but estimates are used (since it is not discharging yet)

Form 2D New Discharger/New Source 44http://dec.alaska.gov/water/wwdp/online_permitting/pdfs/Form2D-Reader.pdf

44No form at this timeWork with DEC if a zone of deposit is needed

Zone of Deposit Application4545

End of Module 3B4646

For Agency Use Permit Tracking #___________

APDES Form 1 [September 2009] Page 1 of 16

ALASKA POLLUTANT DISCHARGE ELIMINATION SYSTEM (APDES)

APPLICATION FORM 1

General Information

Please submit this Form to: ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Wastewater Discharge Authorization Program 555 Cordova Street

Anchorage, AK 99501 DEC.Water.WQPermit@alaska.gov

Form 1 must be completed by all applicants required to obtain an APDES permit under 18 AAC 83.015. Applicants for new or existing Publicly Owned Treatment Works (POTWs) and other treatment works treating domestic sewage (TWTDS) are not required to complete Form 1 but must complete Form 2A. See attached instructions. See Section D of the instructions for definitions of the bold-faced terms.

SECTION 1 FACILITY INFORMATION

Facility Name:

Mailing Address: City: State: AK Zip:

Physical Address/Location: City: State: AK Zip:

Phone: Cell Phone: Fax:

E-mail:

Geographic Location: Latitude: Longitude:

Lat/Long Coordinate Source: Internet Map GPS/Survey Other___________________

Source Map Scale (if applicable): Facility Reference Point:

Horizontal Accuracy: Horizontal Datum:

Is this a new or existing facility? New Existing

NAICS Code (formerly the Standard Industrial Code (SIC)) in order of priority:

First: Second:

Third: Fourth:

Is the facility located on Indian country? Yes No

Is the discharge associated with this permit located within a coastal zone boundary of an approved coastal district?

Yes No

If Yes, submit a completed Coastal Project Questionnaire along with this APDES permit application.

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Wastewater Discharge Authorizations Program 555 Cordova Street

Anchorage, AK 99501 DEC.Water.WQPermit@alaska.gov

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SECTION 2 OUTFALL LOCATION

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For Agency Use Permit #_________

APDES Form 2M [April 2010] Page 1 of 5

ALASKA POLLUTANT DISCHARGE ELIMINATION SYSTEM APPLICATION FORM 2M Request for a Mixing Zone

Please submit this form to: ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Wastewater Discharge Authorization Program 555 Cordova Street

Anchorage, AK 99501 DEC.Water.WQPermit@alaska.gov

Form 2M must be completed by all applicants who answered Yes to question 9D on Form 1 or 2A. Any applicant who indicates a need for a mixing zone on a General Permit Notice of Intent must also fill out Form 2M. THE FOLLOWING INFORMATION MUST BE PROVIDED. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 18 AAC 70.270 (July 2003) rests with the applicant. ADEC may request additional information when necessary.

SECTION 1 FACILITY INFORMATION (This information must match the facility information entered in Section 1 on Form 1 or 2A)

Facility Name:

Physical Address:

SECTION 2 OUTFALL INFORMATION

Provide the following information for each outfall. Attach additional copies of this section as necessary.

Outfall No.: Latitude: Longitude:

Distance from shoreline to end of pipe or first port on diffuser (measured at MLLW for marine):

Orientation of diffuser to shoreline: (e.g. perpendicular, 45, parallel):

Depth to center line of end of pipe or middle of diffuser: (measured at MLLW for marine):

Number of ports (1 for pipe): Diameter of pipe or ports:

Length of diffuser: Port spacing:

SECTION 3 RECEIVING WATER INFORMATION

Provide the following information about the receiving water body.

A) For Marine Discharges

Maximum current:

Provide salinity and temperature data from the surface to the depth of the discharge port or diffuser. Provide actual data or source for the estimate and/or assumed values. Clearly identify data that was estimated or an assumed value that was used. To capture variations with the water column, data from both late winter/early spring and late summer/early fall is preferable. Attach additional sheets if necessary.

For Agency Use Permit Tracking #___________

APDES Form 1 [September 2009] Page 1 of 16

ALASKA POLLUTANT DISCHARGE ELIMINATION SYSTEM (APDES)

APPLICATION FORM 1

General Information

Please submit this Form to: ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Wastewater Discharge Authorization Program 555 Cordova Street

Anchorage, AK 99501 DEC.Water.WQPermit@alaska.gov

Form 1 must be completed by all applicants required to obtain an APDES permit under 18 AAC 83.015. Applicants for new or existing Publicly Owned Treatment Works (POTWs) and other treatment works treating domestic sewage (TWTDS) are not required to complete Form 1 but must complete Form 2A. See attached instructions. See Section D of the instructions for definitions of the bold-faced terms.

SECTION 1 FACILITY INFORMATION

Facility Name:

Mailing Address: City: State: AK Zip:

Physical Address/Location: City: State: AK Zip:

Phone: Cell Phone: Fax:

E-mail:

Geographic Location: Latitude: Longitude:

Lat/Long Coordinate Source: Internet Map GPS/Survey Other___________________

Source Map Scale (if applicable): Facility Reference Point:

Horizontal Accuracy: Horizontal Datum:

Is this a new or existing facility? New Existing

NAICS Code (formerly the Standard Industrial Code (SIC)) in order of priority:

First: Second:

Third: Fourth:

Is the facility located on Indian country? Yes No

Is the discharge associated with this permit located within a coastal zone boundary of an approved coastal district?

Yes No

If Yes, submit a completed Coastal Project Questionnaire along with this APDES permit application.

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Wastewater Discharge Authorizations Program 555 Cordova Street

Anchorage, AK 99501 DEC.Water.WQPermit@alaska.gov

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For Agency Use Permit #_________

APDES Form 2M [April 2010] Page 1 of 5

ALASKA POLLUTANT DISCHARGE ELIMINATION SYSTEM APPLICATION FORM 2M Request for a Mixing Zone

Please submit this form to: ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Wastewater Discharge Authorization Program 555 Cordova Street

Anchorage, AK 99501 DEC.Water.WQPermit@alaska.gov

Form 2M must be completed by all applicants who answered Yes to question 9D on Form 1 or 2A. Any applicant who indicates a need for a mixing zone on a General Permit Notice of Intent must also fill out Form 2M. THE FOLLOWING INFORMATION MUST BE PROVIDED. The burden of proof for justifying a mixing zone through demonstrating compliance with the requirements of 18 AAC 70.240 18 AAC 70.270 (July 2003) rests with the applicant. ADEC may request additional information when necessary.

SECTION 1 FACILITY INFORMATION (This information must match the facility information entered in Section 1 on Form 1 or 2A)

Facility Name:

Physical Address:

SECTION 2 OUTFALL INFORMATION

Provide the following information for each outfall. Attach additional copies of this section as necessary.

Outfall No.: Latitude: Longitude:

Distance from shoreline to end of pipe or first port on diffuser (measured at MLLW for marine):

Orientation of diffuser to shoreline: (e.g. perpendicular, 45, parallel):

Depth to center line of end of pipe or middle of diffuser: (measured at MLLW for marine):

Number of ports (1 for pipe): Diameter of pipe or ports:

Length of diffuser: Port spacing:

SECTION 3 RECEIVING WATER INFORMATION

Provide the following information about the receiving water body.

A) For Marine Discharges

Maximum current:

Provide salinity and temperature data from the surface to the depth of the discharge port or diffuser. Provide actual data or source for the estimate and/or assumed values. Clearly identify data that was estimated or an assumed value that was used. To capture variations with the water column, data from both late winter/early spring and late summer/early fall is preferable. Attach additional sheets if necessary.

For Agency Use Permit Tracking #___________

APDES Form 2D [February 2010] Page 1 of 22

ALASKA POLLUTANT DISCHARGE ELIMINATION SYSTEM

APPLICATION FORM 2D

New Sources and New Dischargers Application for Permit to Discharge Process Wastewater

Please submit this form to:

DEPARTMENT OF ENVIRONMENTAL CONSERVATION Wastewater Discharge Authorization Program

555 Cordova Street Anchorage, AK 99501

DEC.Water.WQPermit@alaska.gov

Form 2D must be completed for a new manufacturing, commercial, mining, or silvicultural discharge. This form must be completed by an applicant who checked yes to Section 6-C in APDES Form 1. Form 2D must be completed in conjunction with Form 1. Instructions for completing this form are attached.

SECTION 1 FACILITY INFORMATION (This information must match the facility information entered in Section 1 on Form 1.)

Facility Name:

Physical Address/Location:

SECTION 2 OUTFALL LOCATION List the latitude and longitude of each outfall location to the sixth decimal place and the name of the receiving water.

Outfall Number (list) Latitude Longitude Receiving Water (name)

q q

Lat/Long Coordinate Source: Internet Map GPS/Survey Other___________________

Source Map Scale (if applicable):

Horizontal Accuracy: Horizontal Datum:

SECTION 3 DISCHARGE DATE On what date do you expect to begin discharging? (mm/dd/yyyy) ________________________