Negotiate Permit Type and Conditions with Regulators
Client: Lehigh County Authority
Project: Negotiate Permit Type and Conditions with Regulators
Project Type: Regulatory Permitting
Location: Fogelsville, PA
Lehigh County Authority (LCA) manages wastewater from an industrial park, hauled in waste, and surrounding municipal units at its Industrial Pretreatment plant located in Fogelsville, PA. There is a long tradition of beneficial use of anaerobically digested solids in local agricultural. Regulatory challenges to their permit status as a Class B biosolids threatened their well-established beneficial use program. Material Matters was engaged to sort out the permitting pathways and prepare general permit language favorable to LCA.
Material Matters recognized the benefits of moving from a designation of biosolids to a residual waste, and convinced LCA to move in that direction.
Work sessions with LCA and Material Matters staff identified important program preferences.
Permit conditions were thoughtfully negotiated with regulators based on Material Matters’ understanding of the municipal and residuals waste regulations.
Outcomes and Benefits
LCA was able to continue its beneficial use program with no interruption.
Residual permit conditions were tailored to meet the needs of LCA, with specific language prepared by Material Matters. Critical limits found in existing biosolids general permits (i.e., total solids requirements of 20% for field storage) were replaced with far more favorable conditions.
Residual program costs were reduced as bulking agents used to increase total solids were no longer necessary.