The State of Illinois and Water Pollution Control Construction Permits When does the Illinois Environmental Protection Agency (IL EPA) require a state water pollution control construction permit? That's the question Metafix recently helped one of its printing customers answer. To install a Metafix pH Control neutralization unit for a computer to plate (CtP) system, the local municipality in Illinois required the printer to obtain a state construction permit. Without the permit, the municipality would not allow the printer to discharge the neutralized CtP developer to the sanitary sewer. When Metafix approached IL EPA, we were told that Title 35, Subpart C, Section 309.202 of the IL Administrative Code required a construction permit for "… the construction of any new treatment works, sewer or wastewater source or … the modification of any existing treatment works, sewer or wastewater source." Construction is defined as the commencement of on-site fabrication, erection, or installation. Therefore, the IL EPA considered the installation of a Metafix pH Control CtP neutralization as construction. The cost of the construction permit was $3,000, irrespective of the volume or make-up of the effluent. According to the IL EPA, "The fee regulations do not differentiate between small and large systems. Very small (even tiny) discharges, pay the same fee for a construction permit that large discharges pay." Metafix decided to take a closer look at the IL regulations — specifically the exemptions. They found the regulations do not require a construction permit where the pretreatment works (in this case, the Metafix pH Control neutralization unit) meets each of the following three conditions: Does not discharge toxic pollutants or pollutants that may interfere with the treatment process (IL EPA considers pH to be a toxic pollutant) Does not discharge 15 percent or more of the total hydraulic flow received by the municipal treatment works Does not discharge 15 percent or more of the total biological loading received by the municipal treatment works (as measured by BOD5) Because pH is the only "toxic pollutant" in CtP effluent, once neutralized, the effluent satisfied condition 1. Given the volume of CtP effluent from the customer's site and the typical BOD concentration, conditions 2 and 3 were easily met. Metafix presented this information to the IL EPA for their consideration. Upon review, Mr. Darin LeCrone, IL EPA, Permit Section, Division of Water Pollution Control (DWPC) responded that based on the information provided by Metafix, the customer would not need a state water pollution control construction permit. Additionally, this meant that the customer would not need a state operating water permit. This is truly a success story. At Metafix, we have found that it's not reasonable to expect government regulators to understand the ins and outs of all industries. We have been highly successful in working, on our customers' behalf, to provide agencies with the information they need to apply their regulations as they were intended. This approach makes everyone a winner. For more information, please contact Metafix, Inc. Tel: (800) 667-8921 - sales@metafix.com Judy Zaczkowski Envision Compliance Back to Metafix CTP pH Control