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GeoInsighter Summer 2002 Newsletter Hear Ye! Hear Ye! CTDEP's General Permits Have Arrived Return to the Newsletter Index Many in the regulated community have been wondering when the Connecticut Department of Environmental Protection (CTDEP) would reauthorize several general permits that had or were going to expire. In a last-second flurry, the CTDEP Bureau of Water Management (BWM) reauthorized seven and issued six new general permits on June 6 and 12, 2002. The BWM's action follows the CTDEP Bureau of Air Management's reauthorization of two general permits. Those general permits that were recently authorized or reauthorized are listed in the table. Issues facing those facilities with activities affected by these permits are discussed in the paragraphs that follow.
The Emergency Engine General Permit was reauthorized in November 2001. However, those who attempted to renew their registrations experienced that an "approval" of registration was not forthcoming from the CTDEP. Also, although the Surface Coating General Permit was reauthorized on January 30, 2002, those facilities with existing registrations didn't receive a renewal package until March 2002. In June 2002, the CTDEP's intentions became clear. Delaying registration approvals allowed the CTDEP to apply several new regulatory requirements issued on March 15, 2002. Those facilities that operate emergency engines with potential emissions less than 15 tons per year (TPY) received letters from the CTDEP indicating that, in light of the new air regulations, permits were not required. Facilities should be careful to evaluate how this change may affect their aggregate facility wide emissions with regard to Title V regulations because the general permit no longer caps the emergency engine's potential emissions. Most facilities above 15 TPY potential emissions attempting to renew registrations were requested by the CTDEP to select a method of compliance, choosing from the applicable general permit or the new 22a-174-3b and 3c sections of CTDEP air regulations. Generally speaking, this action by the CTDEP is good for the regulated community, offering more flexibility in record keeping. Be careful of Section 3c, however, because some of the "operating requirements" limit fuel or coating purchases to the premises, not the emergency engine or surface coating operation alone. Along with its correspondence regarding the compliance options, the CTDEP included a request for these facilities to complete and submit the new "Signatory Responsibilities Registration Form" documenting specific authorization of the signatory to sign environmental permits. Because this new requirement can be confusing, permittees can obtain guidance and templates by contacting the Engineer of the Day at (860) 424-4152. Due to the fundamental effectiveness of the current wastewater discharge general permits and limited staff resources, these general permits were reissued without changes and reauthorized by a simple one-paragraph cover page signed by the Commissioner. Existing registrants were required to submit a simplified "Registration Form for Reauthorization." It should be pointed out that the current registrants were informed that these general permits may be modified in the near future and that more detailed registration may be required at that time. While the six new Inland Water Resources Division (IWRD) general permits may not affect some readers, it is worth noting that they will hopefully allow IWRD to streamline a number of universal activities. At a time when the allocation of Connecticut's water resources remains uncertain, the re-issue of the Diversion General Permit is a relief for those water utilities and other entities wishing to pursue water diversion activities. It is expected that those entities with existing approvals of registration under the Diversion General Permit will be required to renew their registration. In summary, the long anticipated reauthorization of several general permits has finally occurred. Although many changes were expected, none, except those noted within the Air Bureau, materialized; however some may still be on the way. A listing of all general permits can be found at http://dep.state.ct.us/pao/listgen.htm and most can be downloaded from http://dep.state.ct.us/pao/download.htm. While the general permits can simplify a facility's permitting requirements, they can also be limiting and come with their own record keeping, sampling, and reporting requirements. When reviewing your permitting options, choose wisely and understand to what you are committing. Eric C. Watters Return to the Newsletter
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