Navigating Industrial Waste and Wastewater Permitting

Industrial waste and wastewater permitting involve obtaining necessary authorizations from federal, state, and local regulatory agencies before handling, treating, storing, or disposing of industrial waste. We all know that permitting ensures compliance with environmental regulations, protects public health, and minimizes potential harm from industrial activities. Nevertheless, federal mandates can change with new administrations, complicating the process and timing.

The timing for industrial waste and wastewater permitting can vary significantly depending on the specific type of permit and the regulatory authorities involved, and it is a significant cost factor. New permits may have a long approval cycle, so we provide advice to help expedite the permitting process in this article.

Stakeholder Involvement Early in the Permitting Process

Communicating the stakeholder goals upfront helps identify and address potential challenges before permitting submissions. Stakeholders include any agency involved in the permitting process, such as federal, state, and local agencies. Even the finest environmental consultant does not try to anticipate every potential issue – we work with facts.

Early communication and coordination prevent delays and provide valuable insights, perspectives, and, in our experience, innovation specific to an industry, facility, process, and locality. Aligning your permitting cycle with the needs and expectations of agency stakeholders builds trust and goodwill, smoothing the process and preventing unnecessary slowdowns to address questions.

Example: Working in Partnership with Miami-Dade County

For example, industrial facilities in Miami-Dade County must navigate a comprehensive permitting process to protect public health and the environment. For this article, we base our advice on permitting for a pet food manufacturer, an aircraft maintenance facility, and a water bottling facility – all very different but following a similar strategy. The Industrial Wastewater Facility (IW5) and the Industrial Waste Pretreatment (IW-P) Permits are among the most common and critical permits. While each serves a distinct regulatory purpose, both are essential for facilities that generate or manage industrial waste.

Facilities impacted include dry cleaners, automotive service providers, manufacturers, printers, and film processors. Understanding which permit applies and how to comply can significantly reduce project delays and keep operations on schedule.

Understanding the IW5 and IWP Permits

The IWP Permit regulates facilities that discharge significant volumes of industrial wastewater to the public sanitary sewer system. These discharges are subject to local and federal pretreatment regulations.

The IW5 Permit, the focus of this article, applies to facilities that store or use hazardous materials in smaller quantities and discharge relatively low volumes of wastewater. The permit outlines conditions that facilities must meet to minimize the volume and impact of their discharges on the County’s Publicly Owned Treatment Works (POTW).

Steps in the IW5 Permitting Process

The Miami-Dade Department of Regulatory and Economic Resources (RER), Division of Environmental Resources Management (DERM) administers the permitting process. Facilities submit required documentation through the County’s Electronic Permitting System (EPS). The process typically involves the following phases:

1. Pre-Application Submittals

Before submitting an IW5 permit application, facilities must prepare and upload the following documents:

• Architectural Plans: Prepare using a licensed architect and include floor layouts, chemical storage areas, locations of safety equipment, and spill containment features.
• MEP Plans (Mechanical, Electrical, and Plumbing): Submit detailed connections to the sanitary system in conjunction with the architectural drawings.
• Engineering Report: A Florida-licensed Professional Engineer (EOR) must provide a report describing facility operations, materials handled, waste disposal methods, potential spill scenarios, SIC/NAICS codes, and proximity to protected wellfields.
• Certificate of Use (CU): Required once plans are approved. Facilities located in unincorporated areas must have a valid CU or application in progress.
• Occupational License: This license is typically required before submitting the IW5 application, especially as construction nears completion.

2. Application Submission

Once the CU and Occupational License are secured:

• The EOR finalizes and submits the IW5 application via the EPS portal.
• A site visit confirms current facility conditions and identifies any updates since preparing the engineering report.
• Upload all documentation to the EPS portal for formal review by the Environmental Plan Review Office.

3. Review and Approval

• Initial Review: DERM provides comments or requests for revisions.
• Response and Resubmittal: The EOR addresses any feedback and resubmits for final approval.
• Permit Issuance: Once approved, the IW5 permit is mailed to the facility and posted on the EPS portal. Depending on the project’s complexity and construction schedule, processing time can range from 6 months to 2 years.

Finding the Right Environmental Consultant

The IW5 and IW-P permitting process can be complex, but partnering with an experienced environmental consultant can streamline your path to compliance. Look for a partner who supports industrial clients —from aircraft maintenance and cleanrooms to chemical R&D and clinical pharmacology—through every stage of the permitting process.

Seek a partner who will assist you with early documentation, regulatory coordination, and ongoing compliance to help ensure timely approvals and avoid costly delays. An environmental consultant with in-house experts, including legal and construction, will bring more value to your permitting project.

About the Author: Kokil Bansal is a Professional Engineer and SCS Project Manager responsible for providing environmental services, site redevelopment, and sustainability planning for public and private clients. She is particularly adept at coordinating and managing new facilities and the redevelopment of contaminated sites. Contact her at SCS Engineers or on LinkedIn.