instructional booklet for form e …...form e instructional booklet page 1 of 12 instructional...

ENVIRONMENTAL MANAGEMENT AUTHORITY

Form E Instructional Booklet of 12

INSTRUCTIONAL BOOKLET

FOR FORM E – APPLICATION FOR A WATER POLLUTION PERMIT TO DISCHARGE WATER POLLUTANTS FROM MANUFACTURING, COMMERCIAL, INSTITUTIONAL AND MINING OPERATIONS

THE ENVIRONMENTAL MANAGEMENT ACT CHAPTER 35:05

Water Pollution Rules, 2001 (as amended)

FORM E PACKAGE Table of Contents Part A. General Instructions Part B. Instructions for Form E Part C. Glossary

Disclaimer: These Instructions act as a guide only and do not legally bind the applicant or the EMA. For Legal

requirements refer to the Water Pollution Rules, 2001 (as amended).



FORM E SECTION A—GENERAL INSTRUCTIONS Who Must Apply? Any facility that receives Form D – “Notice of Requirement to Apply for a Water Pollution Permit” from the EMA Where to File The application forms should be delivered by hand or mail to the Head Office of the Environmental Management Authority (EMA) located at:

8 Elizabeth Street St. Clair, Port of Spain,

OR

2 Dumfries Road, La Romain,

Trinidad & Tobago.

OR Department of Natural Resources and the

Environment (DNRE) 78 Wilson Road, Unit 6 & 7

Highmoor Centre Scarborough

Tobago

When to File Within 30 working days of the receipt of Form D by the applicant. Fees A sum of two thousand five hundred dollars ($2,500.00) is payable at any branch of the First Citizens Bank (account number 1183848). Please ensure the bank teller includes the name of the facility on the receipt. The original receipt must be submitted along with the completed application form. A copy of the receipt should be retained for the facility‟s records. Invoices from the EMA for the application fee are available upon written request. A person granted a permit would be required to pay an annual permit fee as prescribed by the Minister and published in the relevant legislation.

Availability of Information to the Public All information contained in this application form will be publicly available for inspection upon request through the Water Polluters Register which shall be available at the Authority‟s Principal Office during working hours. Confidential Information/Trade Secrets Information submitted in your application deemed confidential business information or trade secrets will be omitted from the Water Polluters Register. Claims for confidentiality may be made upon payment of the prescribed fee, in accordance with section 26 of the Rules. Applicants should assert their confidentiality claim and the reason(s) for confidentiality in a separate cover letter attached to their Water Pollution Permit Application Form (Form E). Signatory Requirements THE WATER POLLUTION RULES, 2001 (AS AMENDED) REQUIRE THIS APPLICATION TO BE SIGNED AS FOLLOWS: A. For a corporation, by the principal

executive officer. B. In other instances by the owner or

operator. Filling out the Form Unless otherwise specified in instructions to the form, each item must be answered. To indicate that each item has been considered, enter “NA” (i.e., if a particular item is not applicable). Some items in the form require narrative explanation. If more space is necessary to answer a question, attach a separate sheet entitled “Additional Information”. If you have previously submitted information to the EMA, which answers a question and is still valid, you may either repeat the information in the space provided or attach a copy of the previous submission.



FORM E PART B: COMPLETING THE APPLICATION FORM LINE—BY—LINE INSTRUCTIONS

SECTION I – APPLICANT AND FACILITY DESCRIPTION Item 1 Indicate the type of application you are making by placing a tick in the appropriate box. For permit renewal, give the permit number. If the facility is Source Registered, provide the Registration Certificate number. If not, indicate N/A. Item 2 Enter the parent facility‟s official or legal name as it appears on the Registrar‟s Certificate. Do not use a colloquial name. Item 3a Enter the facility site‟s official or legal name as it appears on the Registrar‟s Certificate. Do not use a colloquial name. Item 3b & 3c Self-explanatory Item 4 Self-explanatory Item 5 Give the address or location of the facility identified in item 3 of this form. If the street name is unknown, provide the most accurate information known. Universal Transverse Mercator (UTM) Eastings and Northings can be obtained from the Topographic maps (see item 15 for relevant zone and datum) or from Global Positioning Systems (GPS) units, Google Earth or any other proven, accurate & reliable method. Item 6 Enter the date the facility started operations. Where the facility has changed ownership, use the original date on which the current process(es) began operating. For companies with integrated facilities on the same location, use the date the first facility was commissioned. Item 7 Provide the contact information of an individual who will be available to liaise with the EMA regarding this application.

The person must be sufficiently familiar with the operation of the facility and the application form submitted to the EMA to be able to answer or obtain the answer to any reasonable question concerning the application. Item 8 Self-explanatory Item 9 Self-explanatory Item 10 Self-explanatory Item 11 Enter the name and address of adjoining property owners. Item 12 Self-explanatory Item 13 Self-explanatory Item 14 Self-explanatory Item 15 Provide a map or maps of the area around the facility, clearly indicating the following:

legal boundaries of the facility;

one kilometer radius (smaller facilities) up to three (3) kilometer radius (larger facilities) around facility. If the acreage is quite extensive a radius beyond three kilometers may be required;

the location of each of your existing or proposed intake and discharge point(s) or outfall(s);

each well where you inject fluids underground;

all springs and surface water bodies in the area, plus all municipal wells within 1 kilometer of the facility which are identified in the public record or otherwise known to you; and

any area where sewage sludge is stored, treated or disposed.

On each map, include the map scale, a meridian arrow showing north, and the geographic coordinates in UTM projections (for zone 20N referencing



FORM E PART B (Cont’d): COMPLETING THE APPLICATION FORM LINE—BY—LINE INSTRUCTIONS

1984 geodetic datum) for the facility. On all maps, show the direction of river flow and in tidal waters, show the directions of the current at low and high tides. The maps should be of a 1:25,000 scale, or be of an appropriate scale whereby all of the above mentioned map requirements can be easily identified. You may trace your map from Topographic Sheet Maps (available from the Lands & Surveys Division of the Ministry of Food Production, Land & Marine Affairs) or you can choose computer-generated maps meeting the above specification. If you trace the map, it should bear a note showing the number or title of the map or chart it was traced from. Include the names of nearby towns, roads, water bodies, and other prominent points. Google Earth or other satellite imagery or aerial photography is acceptable at appropriate scales. An example of an acceptable location map is shown in Figure A-1 of these instructions. (Note: Figure A-1 is provided for purposes of illustration only, and does not represent any real facility). Item 16a Self-explanatory Item 16b For programmes that are planned please complete the table provided. This table is intended to present to the Authority the expected effluent concentration levels reached after the programme(s) are implemented. Only parameters whose effluent levels currently exceed those prescribed in Second Schedule of the Water Pollution Rules, 2001 (as amended) (WPR) are required to be included in the table. The column headed Interim Effluent Levels are to be completed in the instances where the programme(s) are phased and yield reduced effluent concentration levels which will further be reduced to the proposed Final Effluent Levels after the completion of the programme(s). The units for effluent concentration levels should be consistent with those provided in the table in item 5 of the Form. The expected effluent levels

achieved after the programme(s) are completed and fully effective are to be inserted in the column headed Final Effluent Levels. Include the date that each of these levels is expected to be achieved in the columns provided. Mark NA where not applicable. If there are more than one discharge, programme, or interim effluent levels use additional sheets. SECTION II. SITE MAP, INTAKE AND DISCHARGE DESCRIPTION Item 1: Site Map Each applicant is also expected to develop a site map, drawn to an appropriate scale and using, where possible, UTM coordinates for zone 20N referencing WGS 1984 geodetic datum, which clearly outlines the following:

buildings and other permanent structures;

paved areas and roadways;

receiving environments, as categorized by the Second Schedule WPR;

bodies (e.g., rivers, lakes, streams, bays, estuaries) that are located on or about the property which receive or may receive stormwater from the site;

all surface (including to gravel pit ponds) and stormwater discharge locations;

location of each pit latrine, soak away system, septic system or sewer segment, where domestic sewage or process waste water generated by the facility enters storm sewers that discharge to receiving environments, as categorized by the Second Schedule of the WPR;

outline of each drainage area within the facility boundaries and a depiction of flow direction (e.g., arrow head) of stormwater in each drainage area;

outline of each drainage area within the facility boundaries and a depiction of flow direction (e.g., arrow head) of stormwater in each drainage area;

location of existing stormwater structural control measures (e.g., containment, berms, detention/retention basins, grassed swales, oil/water separators);

areas of existing and potential soil erosion;

processes that generate dusts and particles;




locations where source materials are likely to be exposed to stormwater, and the following activities and/or areas, at a minimum;

storage areas, palleted materials, outdoor handling, treatment or disposal areas, loading and/or unloading areas, manufacturing and/or processing areas, waste storage areas, vehicle/equipment maintenance and washout areas, vehicle/equipment fuelling and loading areas, hazardous waste treatment, storage or disposal areas, areas of spills and/or leaks of source materials, access routes, underground storage and on-site lab or testing facilities;

roofs or other surfaces exposed to air emissions from process area; and

location and areas of undisturbed natural areas, or completely claimed areas (there is no machinery at these sites), disturbed sites which have been cleared for mining, areas for processing, storage and where mining takes place; must also be clearly identified in the site map.

Items 2 & 3 You may use the map you provided for item 15 of Form E to determine UTM coordinates of each of your discharge and intake points and the name of the source or receiving water. Item 4A The line drawing should show the general route taken by water in your facility from intake to discharge. Show all operations that produce or contribute wastewater, including process and production areas, sanitary flows, cooling water and storm water runoff. You may group similar operations into a single unit, labeled to correspond to the more detailed listing in item 4 B. The water balance should show average flows. Figures should be in m3/d. Show all significant losses of water to products, atmosphere, seepage and discharge. You should use actual measurements whenever available; otherwise use your best estimate (indicate where estimates were used and how they were determined). An example of an acceptable line drawing is shown in Figure E-2 to these instructions.

(Note: Figure E-2 is provided for purposes of illustration only, and does not represent any real facility). Item 4B List all sources of wastewater leading to each numbered discharge point. Operations contributing wastewater to each discharge may be described in general terms (e.g. process condensate, cooling water, boiler blowdown, storm water, etc.). The volume of effluent (in m

3/day) that each operation contributes to

the discharge should be provided. Each treatment process applied to the wastewater before it is discharged should be listed in order. You should select the proper code from Table E-1 to these instructions to fill in column 3ii for each treatment process. Insert „XX‟ into column 3ii if no code corresponds to each treatment process you list. Describe the ultimate disposal of any solid or liquid wastes not discharged. A schematic of the wastewater treatment process and all treatment processes should accompany this item where applicable. An example of a typical wastewater treatment schematic is shown in Figure E-3 to these instructions. Item 5 This item must be completed by all applicants for all discharges or outfalls leaving the facility including process wastewater, sanitary wastewater, non-contact cooling water, storm water, etc. Applicants are required to report recent analytical data (i.e not more than three years old) for any of the parameters/substances listed in the discharges/outfalls. If no historical data is available then a daily value should be obtained. A Daily Value is an average value representing measurements from an outfall/discharge over normal operating conditions. For example a facility operating over an 8 hour production cycle, a daily value would constitute an average of 4 grab samples taken once every two hours.




Item 6 List any of toxic chemicals/products that you believe to be present and explain why you believe them to be present. No analysis is required but if you have analytical data, you must report it. Base your determination on your knowledge of your raw materials, maintenance chemicals, intermediate and final products, and any previous analyses known to you of your effluent or similar effluent Item 7 If you have any biological testing data you must identify the test method(s) and its objective. Item 8 a List the specifics concerning analyses done by laboratory or consulting firm. Indicate by Yes/No which parameters they have certification for and name the certifying body. Item 8 b If your facility has an in house laboratory, indicate which parameters it is capable of testing. Indicate by Yes/No which parameters they have certification for and name the certifying body. Item 9 Provide a detailed description of the following information records: Sample records: These show that the proper sampling protocol was performed in the field. At a minimum, this documentation should include the names of the persons conducting the activity, sample number, sampling dates and times, sample collection points, maps and diagrams, equipment/method used, climatic conditions, and unusual observations. Chain-of-custody records: Documents the progression of samples as they travel from the original sampling location to the laboratory and finally to their disposal area. QC sample records: These records document the generation of QC samples, such as field, trip, and equipment rinsate blanks and duplicate samples. They also

include documentation on sample integrity and preservation and include calibration and standards traceability documentation capable of providing a reproducible reference point. Quality control sample records should contain information on the frequency, conditions, level of standards, and instrument calibration history. General field procedures: These record the procedures used in the field to collect data and outline areas of difficulty in gathering specimens, thus documenting potential sources of uncertainty. Sample Data: These records contain the times that samples were analyzed to verify that they met the holding times prescribed in the analytical methods. Included should be the overall number of samples, sample location information, any deviations from the standard operating procedures (SOPs), time of day, and date. Sample Management Records: Document sample receipt, handling and storage, and scheduling of analyses. The records verify that the chain-of-custody and proper preservation were maintained, reflect any anomalies in the samples (such as receipt of damaged samples), note proper login of samples into the laboratory, and address procedures used to ensure that holding time requirements were met. Project-specific information from the QA/QC checks such as blanks (field, reagent, rinsate, and method), spikes (matrix, matrix spike replicate, analysis matrix spike, and surrogate spike), calibration check samples (zero check, span check, and mid-range check), replicates, splits, and so on should be included in these reports to facilitate data quality analysis. Data Handling Records: These records document protocols used in data reduction, verification, and validation. Data reduction addresses data transformation operations such as converting raw data into reportable quantities and units, use of significant figures, recording of extreme values, blank corrections, etc. Data verification ensures the accuracy of data transcription and calculations, if




necessary, by checking a set of computer calculations manually. Data validation ensures that QC criteria have been met. Competency of Personnel / Testing Laboratory: Provide certificates that

demonstrate that the person(s) or laboratory possesses the skills, qualifications and experience to conduct the required sampling analysis and reporting.

FORM E: PART C - GLOSSARY

NOTE: This Glossary includes terms used in the instructions and in Form E. If you have any questions concerning the meaning of any of these terms, please contact the Authority. ALIQUOT means a sample of specified volume used to make up a total composite sample. BIOLOGICAL TOXICITY TEST means any test, which includes the use of aquatic algal, invertebrate or vertebrate species to measure the acute or chronic toxicity, and any biological or chemical measure of bioaccumulation. CONTAINER means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. CONTACT COOLING WATER means water used to reduce temperature, which comes into contact with a raw material, intermediate product, waste product other than heat, or finished product. CONTINUOUS DISCHARGE means any discharge that occurs without interruption during the operating hours of the facility, except for infrequent shutdowns for maintenance, process changes or other similar activities. INTERMITTENT DISCHARGE means any discharge that occurs with interruption of known periodicity (except for infrequent shutdowns) during the operating hours of the facility. NON-CONTACT COOLING WATER means water used to reduce temperature, which does not come into direct contact with any raw material, intermediate product, waste product other than heat, or finished product.

OUTFALL means a point source. OWNER means the person who owns a facility or part of a facility. POINT SOURCE means any discernible, confined and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated feeding operation from which pollutants are or may be released into the environment. This term does not include return flows from irrigated agriculture. MAJOR GROUP CODE AND GROUP CODE means any industrial category listed in the Standard Industrial Classification (SIC). Document prepared by the department of International Economic and Social Affairs, Statistical Office of the United Nations, New York, 1990. PROCESS WASTEWATER means any water, which during manufacturing or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, by product or waste product. SEASONAL DISCHARGE means any discharge that occurs only during certain parts of the year. SURFACE IMPOUNDMENT means a facility or part of a facility which is a natural topographic depression, man-made excavation, or dyked area formed primarily of earthen material (although it may be lined with man-made materials), which is designed to hold an accumulation of liquid wastes or wastes containing free liquids, and which is not an injection well. E.g. holding, storage, settling, and aeration pits, ponds or lagoons.



FORM E: PART C (cont’d) - GLOSSARY TREATMENT means any method, technique, or process, including neutralization, designed to change the physical, chemical or biological character or composition of any waste so as to neutralize such waste, or so as to recover energy or material resources form the waste, so to render such waste innocuous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume.

UPSET means an exceptional incident in which there is unintentional and temporary non-compliance with technological controls because of factors beyond the reasonable control of the facility operator. An upset does not include non-compliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventative maintenance or careless or improper operation or failure to adhere to BMPs.

WELL INJECTION means the subsurface emplacement of fluids through a bored, drilled or driven well or through a dug well,where the depth of the dug well is greater than the largest surface dimension.



Figure E-2 (To satisfy Section II, Item 4A). Line Drawing Showing Water Flow from Smith Mills Inc.

(Smith Mills Inc. is not an actual facility, shown only for illustration)

3000m3/d

1000m3/d 1500m

3/d

DRYING

9000m3/d

LOSS

600m3/d

7000m3/d + STORM WATER

3400m3/d

TO PRODUCT

500m3/d

TO

ATMOSPHERE

500m3/d

1000m3/d

COOLING WATER

2000m3/d

4500m3/d 4500m

3/d RAW

MATERIALS

1000m3/d

1000m3/d

4000m3/d

4000m3/d

OUTFALL No.1

STORM WATER

MAX. 2000m3/d

SOLID WASTE

400m3/d

FIBER

PREPARATION DYEING WASHING

GRIT

SEPARATOR

NEUTRALIZATION

TANK WASTE TREATMENT

PLANT #2

WASTE TREATMENT

PLANT #1

Couva River Public Water

Supply

Couva River

OUTFALL No.2

5000m3/d

3600m3/d

4000m3/d



Figure E-3 (To satisfy Section II, Item 4B). Wastewater Treatment

Schematic for Terry’s Battery Inc.

(This is not an actual facility, shown only for illustration)

Collection

Sump

Chemical

Precipitation Settling Solids to

landfill

Diatomaceous

Earth

Filtration

Carbon

Adsorption

Treated effluent to River

Wastewater

MnSO4

NaOH



Table E-1. Codes for Treatment Processes

PHYSICAL TREATMENT PROCESSES

1-A ---------- Ammonia Stripping

1-B ---------- Dialysis

1-C ---------- Diatomaceous Earth Filtration

1-D -----------Distillation

1-E ----------- Electrodialysis

1-F ----------- Evaporation

1-G ---------- Flocculation

1-H ---------- Flotation

1-I ----------- Foam Fractionation

1-J ---------- Freezing

1-K --------- Gas-Phase Separation

1-L --------- Grinding

1-M -------- Grit Removal

1-N -------- Microstraining

1-O -------- Mixing

1-P --------- Moving Bed Filters

1-Q -------- Multimedia Filtration

1-R -------- Rapid Sand Filtration

1-S -------- Reverse Osmosis (Hyperfiltration)

1-T -------- Screening

1-U -------- Sedimentation (Settling)

1-V -------- Slow Sand Filtration

1-W ------- Solvent Extraction

1-X -------- Sorption

CHEMICAL TREATMENT PROCESSES

2-A ---------- Carbon Adsorption

2-B ---------- Chemical Oxidation

2-C ---------- Chemical Precipitation

2-D -----------Coagulation

2-E ----------- Dechlorination

2-F ----------- Disinfection (Chlorine)

2-G -------- Disinfection (Ozone)

2-H -------- Disinfection (Other)

2-I --------- Electrochemical Treatment

2-J --------- Ion Exchannge

2-K -------- Neutralization

2-L -------- Reduction

BIOLOGICAL TREATMENT PROCESSES

3-A ---------- Activated Sludge

3-B ---------- Aerated Lagoons

3-C ---------- Anaerobic Treatment

3-D -----------Nitrification-Denitrification

3-E -------- Pre-aeration

3-F -------- Spray Irrigation/Land Application

3-G -------- Stabilisation Ponds

3-H --------- Trickling Filtration

OTHER PROCESSES

4-A ---------- Discharge to Surface Water

4-B ---------- Marine Discharge through Outfall

4-C-------- Reuse/Recycle of Treated Effluent

4-D-------- Underground Injection

SLUDGE TREATMENT AND DISPOSAL PROCESSES

5-A ---------- Aerobic Digestion

5-B ---------- Anaerobic Digestion

5-C ---------- Belt Filtration

5-D -----------Centrifugation

5-E ----------- Chemical Conditioning

5-F ----------- Chlorine Treatment

5-G ---------- Composting

5-H ---------- Drying Beds

5-I ----------- Eluriation

5-J ---------- Flotation Thickening

5-K --------- Freezing

5-L --------- Gravity Thickening

5-M -------- Heat Drying

5-N -------- Heat Treatment

5-O -------- Incineration

5-P --------- Land Application

5-Q -------- Landfill

5-R -------- Pressure Filtration

5-S -------- Pyrolysis

5-T -------- Sludge Lagoons

5-U -------- Vacuum Filtration

5-V -------- Vibration

5-W ------- Wet Oxidation