Difficulty in Getting Required Permits

Q. Due to a significant increase in volume, we are considering performing acid zinc plating of our metal stampings in house rather than continue to send them to a job shop plater. One of our supervisors has extensive zinc plating experience so we feel comfortable in that regard. How difficult is it to get the required wastewater permits for our discharge? How long does this permitting usually take? Can we start installation of equipment before permits are issued? A.M.

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A. In general, we have found that it is not too difficult to obtain the required wastewater permits for a new plating discharge provided that you do your homework and have a solid concept of what your process and wastewater pretreatment system will be. Certainly there are some areas more difficult, if not impossible, as compared to others due to very stringent discharge limits and onerous regulatory requirements, however, even in these areas, you could evaluate the feasibility of building and operating a zero-discharge facility where all wastes generated leave the facility in a container for off-site treatment or disposal.

The length of the permitting process varies. USEPA requires that a Baseline Monitoring Report (BMR) be submitted to the “control authority” (this could be your city, county, local sewer district, state EPA, and/or USEPA) at least 90 days before discharge begins. Most local sewer districts require that a permit application be submitted to them 60–120 days before discharges commences. If you plan to discharge your process wastewaters directly into a surface water, such as a creek, river, or lake, a National Pollution Discharge Elimination System (NPDES) permit application must be filed and approved by the state EPA and/or USEPA. These can sometimes take more than six months to obtain. Lastly, some states also require a permit-to-install or a permit-to-construct for any process wastewater discharge and associated pollution control equipment; these can take 3–6 months to obtain.

Regarding whether or not you can begin to install your system before obtaining a permit varies. Some states and localities require permit in-hand before any construction begins, while others allow some construction to proceed without permit. Whether required or not, the prudent action is to be well through the permit approval process before beginning any major construction or installation activity so as to be able to incorporate any revisions to your design that the government regulators demand or “suggest” during their review of your permit application.

Finally, even before submitting your permit application, it is extremely valuable to sit down with the regulatory agencies, explain your concept in sufficient detail to convey it accurately and obtain their expectations regarding limitations, spill control, operational restrictions, monitoring, recordkeeping, permit conditions, etc. This upfront cooperation will give you a much better chance of “smooth sailing” through the permit approval process.