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Permitting and Regulatory Services

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Pretreatment Program Assistance

Perkins Engineering Consultants, Inc. (PECI), provided training to new staff that were responsible for implementing an Industrial Pretreatment Program for the City of Temple. With key personnel having over 20 years of experience with such services, PECI understands how to implement an effective Pretreatment Program and how to comply with the complex rules that are applicable to Pretreatment Programs. Not only must there be compliance with the federal rules established in Title 40 Code of Federal Regulations Part 403, each program coordinator must understand how to apply the federal categorical rules and comply with the specific requirements established in their program that has been approved by the Texas Commission on Environmental Quality. PECI reviewed the City’s ordinance, the program documents, enforcement response plan, and standard operating procedures before having training sessions with the client. The staff presented issues that needed more explanation.  Annual reports, enforcement response plans, industrial user permits, monitoring locations, monitoring data deficiencies, and publication of significant noncompliant industries were discussed. References to sources that could provide additional information related to the areas of concern were also presented during the sessions. 

Upon completion of the on-site training sessions, PECI continued to provide on-call support. In response to questions from the client, memorandums were prepared.  A memo that described the applicable regulations and procedures for assessing a specific pollutant listed as a hazardous waste in 40 CFR Part 261 was prepared.  Another memo that presented procedures with examples for implementing local limits based on the contributory flow allocation method was prepared

Current and past projects include:

  • Pretreatment Program Development

  • Audit and Pretreatment Compliance Investigation Support

  • Development and Redevelopment of Technically Based Local Limits

  • Significant Industrial User Categorical Determinations

  • Substantial and Non-substantial Program Modifications

  • Fats, Oils, and Grease Program Development

  • Surcharge Program Development

  • Reallocation of Technically Based Local Limits

  • Reassessment of Technically Based Local Limits

  • Negotiation with Regulatory Agencies

  • Significant Industrial User Compliance and Enforcement

  • Staff Training

Sludge Land Application Rate Calculations

PECI is helping a southeast Texas city comply with requirements specified in its Permit to Land Apply Sewage Sludge.  On an annual basis, the City is required to calculate the appropriate application rate of its sludge using current sludge and soils quality data. If appropriate the City is required to adjust the sludge application rate. 

PECI reviewed the data for the sludge and soils that had been collected during the previous year. The analytical methods were reviewed to verify compliance with the methods specified by TCEQ in the City’s permit.  Information related to the cropping plan, the City’s sludge digestion process, and historical land application rates were obtained and reviewed. Considering the nitrogen requirements for the cropping plan, the nitrogen in the soils, and available nitrogen in the sludge, the maximum sludge application rates for agronomic needs were calculated. The cumulative loading rates for metals were also calculated. The sludge application rate that would ensure that the metals limits established in Title 30 Texas Administrative Code 312, Table 2 were not exceed was determined. 

Permit and Enforcement Assistance

PECI provides assistance with acquisition, amendment, and renewal discharge permits, and assists clients with enforcement actions when necessary. PECI staff members collectively have assisted with acquisition of well over 100 discharge and non-discharge permits throughout Texas. These discharges have ranged from 5,000 gpd to larger, regional systems serving over a million customers. Several have required preparation of nuisance odor prevention plans as part of the permitting process. PECI has assisted with initial acquisition and renewal of site registrations for beneficial application of residuals, and has assembled closure plans for clients wishing to abandon older wastewater treatment facilities. PECI has been retained to assist with permit acquisition or related issues by the following clients:

  • City of Weatherford (Multiple Sites; multiple outfalls per site)

  • City of Kaufman

  • City of Venus

  • City of Victoria

  • Aqua America, Inc.

  • Cantex, Inc.

  • Rocky Point Estates Land Trust

  • Christ for Asia

  • Texas Rain Holdings, Inc. (Multiple Sites in six counties)

  • Northlake Partners, Ltd.

  • Fort Worth Boat Club

  • Benbrook, Texas Limited Partnership

  • MPR Investments (Multiple Sites)

  • City of Newark

  • City of Aubrey

  • City of Lufkin

  • City of The Colony

  • Gaines Bend Utilities

  • City of Runaway Bay

  • City of Winona

  • Trinity River Authority of Texas

  • Texas H2O, Inc.

  • City of Temple

  • City of Sherman

  • Multiple confidential private clients

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