Indirect discharger application WHG (Water Resources Act) as a service

Water-bearing systems are generally subject to regulatory requirements for operation and therefore require an indirect discharger application in accordance with the WHG (Water Resources Act) for the discharge of wastewater into the municipal wastewater treatment plant (or as a direct discharger into a body of water).

Wastewater-bearing systems, especially chemical-physical wastewater systems for wastewater treatment in industry, whether as indirect dischargers into the municipal wastewater treatment plant in accordance with § 58 WHG (Water Resources Act) or as a direct discharger into a body of water according to § 57 WHG (Water Resources Act) require a system permit under water law (or at least a notification) unless they are part of a BImSchG/IED system. As a rule, the approval summarises both the state supervision according to the corresponding annex of the wastewater regulations (e.g. Annex 40 for metal processing companies such as electroplating plants), as well as the municipal monitoring via the local drainage bylaws. The stricter monitoring value is valid.

Wastewater-carrying systems are present in any commercial use of water, outside of sanitary and uncontaminated rainwater, i.e. even washing, residual, cleaning or rinsing water used for low commercial purposes. An exception to the approval obligation exists for wastewater from an softening and industrial reverse osmosis system or a demineralization system, provided that these do not produce more than 10 m³/week of wastewater from process water treatment. Nevertheless, in special constellations, even below this exemption limit, special limit values may be violated, which is why a customer-specific design of the reverse osmosis system or demineralization system is always required.

As a rule, our support for system approval is initially provided in the form of an on-site inspection of the system with our engineers, during which the process parameters are determined and the local conditions are checked and, if necessary, updated on the basis of any existing documents. If engineering has been carried out in advance, the data can also be transferred. Depending on the complexity, a scoping meeting is then held with the relevant authorities to discuss the approval procedure and the required evidence and documents. As a rule, the following topics are discussed at this meeting: WHG direct/indirect discharge, chemical and engineering procedural issues (e.g. also on average and flood protection), BImSchG/IED 2010/75/EU, 12th BImSchV, IZÜV, UVP, WPBV (in Bavaria), OGwV/WRRL as well as e.g. § 60 para. 1 sentence 2 WHG in conjunction with § 60 para. 3 sentence 1 no. 2 WHG in conjunction with DWA M-765 in conjunction with § 3 no. 11 WHG in conjunction with Annex 1 in conjunction with BREF STM. In addition to the responsible authorities, participants usually include representatives of the operator and a team of qualified engineers, chemists and lawyers. The legal procedure itself is described in more detail in Dietrich-RA Naujoks, Hartinger-Handbuch Abwasser- und Recyclingtechnik (Hartinger-Manual wastewater- and recycling technology), 3rd edition 2017, p. 1ff.

On the basis of the scoping meeting, the relevant documents for the application or the so-called “initiation application” are prepared and made available to the applicant company in 5/6 copies. Subsequently, there may be further joint appointments for any additional regulatory requirements, public hearings and/or the technical defense of the system technology vis-à-vis the authorities and third parties. In fulfillment of the regulatory requirements specified in the notification, the operator training courses for specialist personnel and managers required by DWA-M 1000 are carried out subsequently, if not already carried out.

If there is an imminent expiry of the deadline for an extension of the expiring discharge permit, for example, an application for an early start is usually submitted in order to ensure uninterrupted production operations.