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Regulatory Alert - RA 02-8 - UPDATE - PROPOSED EFFLUENT LIMITATIONS GUIDELINES FOR MEAT AND POULTRY PRODUCTS POINT SOURCE CATEGORY

Member Pipeline - Regulatory - Alert (RA 02-8)

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To: Members & Affiliates, Pretreatment and Hazardous Waste Committee
From: National Office
Date: April 12, 2002
Subject: UPDATE - PROPOSED EFFLUENT LIMITATIONS GUIDELINES FOR MEAT AND POULTRY PRODUCTS POINT SOURCE CATEGORY
Reference: RA 02-8

New Deadline
Action Please By:
June 14, 2002

On March 27, 2002, AMSA alerted the membership to the U.S. Environmental Protection Agency's (EPA's) proposed effluent limitations guidelines (ELGs) for the meat and poultry products point source category (67 Fed. Reg. 8582) (See Regulatory Alert 02-6). There have been a number of developments since the end of March that will affect AMSA's efforts to prepare comments on the proposal.

EPA Public Meeting Sheds Light on Guidelines Proposal
On April 9, EPA held a public meeting on the proposal in Washington, D.C. EPA provided an overview of the proposal and outlined what their next steps would be. Most notably, EPA announced that it would extend the deadline for submitting comments by 60 days. EPA is expected to announce the new deadline, June 25, 2002, in a Federal Register notice in the next few weeks. As a result, AMSA has extended its own deadline for accepting member comments until June 14 (see below).

During the meeting, the Agency provided details of the pretreatment standards originally developed for indirect meat and poultry dischargers, but ultimately removed before the proposal was published. EPA was primarily considering categorical pretreatment standards based on Option 1 (dissolved air flotation, followed by equalization) for all indirect meat and poultry products facilities. The proposal covers facilities that conduct slaughtering (or first processing), further processing, and rendering (including individual renderers accepting animal carcasses and spent grease from restaurants for processing). EPA decided not to propose pretreatment standards based on the lack of sufficient evidence that these discharges were causing any problems for POTWs. If EPA receives additional information that suggests that interference or pass through problems caused by meat and poultry facilities are more widespread, the Agency will consider establishing pretreatment standards for indirect dischargers in the final rule.

EPA also indicated that much of the analysis conducted for the rule would be revised over the coming months. In order to meet its statutory deadline for completing the proposal, EPA was not able to consider approximately one-third of the detailed surveys completed by members of the meat and poultry industry. EPA plans to review the information contained in these surveys and continue to collect information from industry and POTW sources over the next year for use in their analyses. The Agency plans to publish a Notice of Data Availability (NODA) early in 2003 that details any changes to what EPA has proposed before issuing the final regulation in December 2003.

AMSA Requests Member Input
AMSA continues to seek input from member agencies that currently receive wastewater from meat or poultry facilities (including rendering operations). AMSA thanks those member agencies that have already provided data, and encourages other members to evaluate whether they receive discharges from any of the affected industry sectors. AMSA hopes to demonstrate that controls for indirect discharges are not necessary, and if problems do arise, local measures are more than adequate to control the problem.

AMSA requests information on the following:

For agencies that receive discharges from meat or poultry facilities, AMSA requests information on whether those discharges ever interfered with the operation of a treatment plant and what your agency did to control the discharges.

If your agency has developed local limits for meat and poultry pollutants (e.g., oil and grease, ammonia), please tell us what those limits are.

If your agency collects surcharges from meat and poultry facilities, please provide us with an estimate of the amount of revenue (in dollars and as a percent of total revenue) generated from the surcharges.

Please submit your comments and information by June 14, 2002. AMSA would especially like to hear from smaller POTWs (i.e., <10 MGD) that may be handling these wastes. Most of EPA's information regarding interference problems caused by the meat and poultry industry involves smaller POTWs, which EPA believes are limited in their ability to adequately control these discharges with local limits and enforcement. Please send your comments to Chris Hornback, AMSA 202/833-9106 or chornback@amsa-cleanwater.org.