Pretreatment & Hazardous Wastes Issues
Effluent Guidelines Plan
Background: EPA published its final plans for developing new and revised effluent guidelines which regulate industrial discharges to surface waters and to POTWs in the October 7, 1996 Federal Register. Section 304(m) of the Clean Water Act requires EPA to publish a biennial Effluent Guidelines Plan. In the plan, EPA highlights current effluent guidelines under development, the process for selection of new effluent guideline regulations, and preliminary and ongoing studies.
Status: Table 1 presents a summary of effluent guidelines currently under development. The next Task Force meeting is scheduled for September 10-11 at the Madison Hotel in Washington, DC. CONTACT: Sam Hadeed, AMSA 202/833-4655.
Table 1 - Effluent Guidelines Currently Under Development
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Pulp, Paper and Paperboard Pesticide Formulating, Packaging, and Repackaging Centralized Waste Treatment Pharmaceutical Manufacturing Metal Products and Machinery, Phase 1 and Phase 2 Industrial Laundries Transportation Equipment Cleaning Landfills and Incinerators | 12/17/93 4/14/94 reproposal 1/98 5/2/95 10/00 11/97 1/98 11/97 | 10/97 9/96 8/99 4/98 12/02 6/99 2/00 11/99 |
- Pulp, Paper, and Paperboard Effluent Guidelines: EPA issued the proposed Pulp, Paper, and Paperboard "Cluster Rules", covering both effluent guidelines and National Emission Standards for Hazardous Air Pollutants (NESHAP), on December 17, 1993. The proposed effluent guidelines were organized into 12 subcategories. A final rule is expected in 1997.
- Pesticide Formulating, Packaging, and Repackaging : EPA is currently negotiating with the Natural Resources Defense Council (NRDC) an extension to its consent decree for the development of this rulemaking. CONTACT: Shari Zuskin, EPA 202/260-7130.
- Centralized Waste Treatment Facilities: EPA plans to re-propose the effluent guidelines for centralized waste treatment facilities in January 1998. CONTACT: Ed Terry, EPA 202/260-7128.
- Pharmaceutical Manufacturing: EPA has plans to jointly promulgate effluent guidelines along with National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations for the pharmaceutical industry. On August 8, 1997, EPA released a notice of data availability of its analysis of old and newly acquired data to the May 2, 1995 proposal. The release of the notice of data availabitlity was delayed from an earlier date to allow for cost-benefit estimates to be calculated based on a March 20 CAA proposed rule for the pharmaceutical industry. Comments are due to EPA by September 22, 1997. Promulgation is planned for April 1998. CONTACT: Frank Hund, EPA 202/260-7182.
- Metal Products and Machinery: EPA plans to merge the two phases of this regulation into one rule scheduled for proposal in October 2000. CONTACT: Steve Geil, EPA 202/260-9817.
- Industrial Laundries: The Office of Science and Technology held a public meeting in Laurel, Maryland on March 4, 1997. EPA plans to propose effluent guidelines for this category by September 1997. CONTACT: Susan Burris, EPA 202/ 260-5379.
- Transportation Equipment Cleaning: EPA intends to propose effluent limitations guidelines and standards in early 1998. CONTACT: Gina Matthews, EPA 202/260-6036.
Streamlining Pretreatment Program Requirements - Anticipated Proposed Rule
Background: EPA is considering several simplifying changes to the pretreatment program that would reduce the current burden to POTWs and industrial users. These potential changes include exclusions or variable requirements for smaller facilities that contribute insignificant amounts of pollutants, clarification of requirements for implementing pretreatment standards, and more flexible reporting, inspection and sampling requirements. A workshop developed and sponsored by AMSA and WEF to guide EPA's efforts to streamline the national pretreatment program was held on August 10-14, 1996 in Leesburg, Virginia.
Status: The National Office distributed EPA's Draft Pretreatment Program Streamlining Proposal to the membership via Regulatory Alert RA97-13. Changes to thirteen specific issues were proposed including: specific prohibition regarding pH, equivalent mass limits for concentration limits, equivalent concentration limits for flow-based standards, POTW oversight of significant industrial users, slug control plans, sampling for pollutants not present, de minimus categorical industrial users, use of grab and composite samples, removal credits, electronic filing and storage of reports, general permits, best management practices, and modifications of significant noncompliance (SNC) criteria. While supportive of most of the proposed changes, AMSA has major concerns with EPA's proposed modification of SNC criteria. Member comments were forward to EPA on July 11, 1997. Based upon the comments received, EPA will redraft the document as a formal notice of proposed rulemaking (NPRM). Based on discussions at a meeting of various stakeholders including POTWs, EPA Headquarters, Regions and states, AMSA has prepared draft regulatory language under 40 CFR 403 that addresses SNC issues. AMSA forwarded the draft regulatory language to EPA headquarters, EPA regions, State pretreatment coordinators, AMSA Pretreatment & Hazardous Waste Committee, 1996 AMSA-WEF Pretreatment Streamlining Workshop attendees and the Clean Water Coalition for review in August 1997. AMSA has requested that EPA consider the language in the preamble to its pretreatment streamlining proposal. AMSA's Pretreatment Committee leadership forwarded a letter to the Natural Resources Defense Council (NRDC) on August 13, requesting a meeting in September 1997, to discuss EPA's proposed changes to the Pretreatment Program. AMSA's National Office and Pretreatment Committee leadership have scheduled a meeting with NRDC and US Public Interest Research Group representatives on September 29, 1997 in Washington, DC, to discuss SNC and other streamlining issues. Proposed rulemaking is expected in the Federal Register in December 1997. CONTACTS: Sam Hadeed, AMSA 202/833-4655, or Jeff Smith, EPA 202/260-5586.
AMSA, EPA and Silver Council Cooperative Agreement
Background:AMSA, the Silver Council and EPA recently initiated a cooperative agreement for a demonstration project using the photo processing industry as a model to evaluate the use of alternative compliance mechanisms as a means of controlling wastewater discharges in streamlining local pretreatment limits. The AMSA/Silver Council "Code of Management Practice (CMP) for Silver Dischargers" will be used as the model approach for controlling silver discharges. A total of seven communities will be studied; 5 cities implementing the CMP as a best management practice; one city using a general permit mechanism; and one using a flow-adjusted concentration-based limit. The total grant assistance requested from EPA is $150,000, to be augmented by in-kind services from AMSA and up to $150,000 furnished by the Silver Council. The proposed 2 year project will be coordinated at a national level by AMSA, The Silver Council, and EPA using a steering team approach. EPA involvement in the steering team will be directed by the Office of Policy, Planning and Evaluation (OPPE), in cooperation with the Office of Water (OW), Office of Enforcement and Compliance Assurance (OECA), and appropriate EPA Regional offices.
Status: In June 1997, following a pre-bid meeting, the project steering team selected Black & Veatch and Apogee Research, Inc. to provide contractor support for this project. A kick-off meeting with project participants was held on July 29, 1997 to discuss development of the work plan. A work plan is expected in September 1997. Invitation letters were sent to seven prototype cities on August 13, 1997, requesting their participation in the study. The agencies invited include: Hampton Roads Sanitation Districts, Virginia Beach, VA; Passaic Valley Sewerage Commissioners, Newark, NJ; Massachusetts Water Resources Authority, Boston, MA; City of Columbus, OH; City of San Diego, CA; City of Salisbury, MD; and, City of Victoria, TX. A conference call between AMSA, EPA, and the Silver Council has been scheduled for September 19, 1997 to discuss the workplan. Representatives from the pilot cities, and other project participants will meet on November 4, 1997 in Norfolk, VA, during the AMSA-EPA Pretreatment Coordinators' Workshop to discuss logistics for the project. CONTACT: Sam Hadeed, AMSA 202/833-4655.
AMSA-EPA Pretreatment Coordinators' Workshop Scheduled for November
Federal, state, and local pretreatment coordinators from around the country will meet and share their considerable expertise during the fourth AMSA-EPA Pretreatment Coordinators' Workshop, November 5-7 at the Norfolk Waterside Marriott Hotel in Norfolk, Virginia. This marks the eighth year AMSA has sponsored this annual forum for pretreatment coordinators to discuss opportunities to enhance the current and future direction of the national pretreatment program. The workshop format is designed to maximize interaction among the attendees and to allow everyone to actively participate. Discussion topics for the November workshop include: EPA pretreatment program updates relating to effluent guidelines, oil & grease, and other Part 136 issues; pretreatment streamlining, and enforcement and compliance issues; pretreatment reinvention; local limits development including radionucleides; and, impact of privatization on pretreatment programs There will be regional breakouts and panel discussions on handling a variety of special wastes and innovative approaches to pretreatment/pollution prevention programs. The 1997 EPA National Pretreatment Program awardees will also make presentations. A preliminary agenda, registration materials, and a questionnaire designed to ensure that specific issues and questions are addressed during the workshop have been forwarded to AMSA members and EPA representatives via Member Update 97-19. The hotel reservation deadline is October 13; the workshop registration deadline is October 24. CONTACT: Sam Hadeed, AMSA, 202/833-4655.