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 meeting of the Effluent Guidelines Task Force will be held May 20-21, 1998. EPA recently announced that effluent guidelines will be developed for concentrated animal feeding operations (CAFOs), synthetic drilling fluids used in offshore drilling and coal mining. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Beverly Randolph, EPA 202/260-5373.

· Industrial Laundries - The proposed rule, issued in the December 17, 1997 Federal Register, will limit the discharge of pollutants into waters of the US and POTWs from existing and new industrial laundries by establishing pretreatment standards for existing and new sources (PSES and PSNS, respectively). These standards are based on a determination of degree which pollutants through or interfere with POTWs; the best available technology economically achievable for PSES and best available technology for PSNS. EPA estimated the proposed rule would cost about $139.4 million annually while it reduces the discharge of toxic and nonconventional pollutants to POTWs by about 13 million pounds resulting in reduced discharges of 5 million pounds per year of such pollutants as well as significant amounts of other conventional pollutants per year to U.S. waters. A copy of the Federal Register notice can be found at http://www.access.gpo.gov/nara/cfr/index.cfml. AMSA's Pretreatment and Hazardous Waste Committee is currently reviewing the proposal. Comments are due to EPA by February 17, 1998. EPA will conduct a public hearing on pretreatment standards on January 15, 1998 from 9am to 12 noon EST. A second meeting is scheduled for January 21, 1998 in Seattle, Washington. CONTACT: Marta Jordan, EPA 202/260-0817.

· Pulp-Paper Cluster Rule -The final pulp and paper rule, signed November 14, 1997, by EPA Administrator Carol Browner, combines new air and water pollution control requirements into one rule and has been referred to as the "cluster rule." The new requirements are expected to decrease levels of dioxin by 96 percent and significantly reduce levels of other pollutants, such as chloroform, particulate matter, and other hazardous air pollutants (HAPs). The final regulation will require mills to substitute chlorine dioxide for chlorine in the bleaching process. A copy of the rule and additional information are available on the Internet at: http://www.epa.gov/OST/pulppaper. The final rule is expected to be published in the Federal Register in mid-January, 1998. CONTACT: Troy Swackhammer, EPA 202/260­7128.

· Landfills Proposed Rule - The proposed landfill rule, signed November 26, 1997, by EPA Administrator Carol Browner, is aimed at reducing pollution from thousands of hazardous and non-hazardous waste landfills that discharge to surface waters and to wastewater treatment plants and will regulate leachates, gas collection condensates, drained free liquids and contact washwaters. The rule will regulate 595 landfills that receive hazardous waste and 10,330 municipal and privately operated landfills that receive non-hazardous waste. EPA estimates that compliance with the regulation will reduce the discharge of pollutants by 800,000 pounds per year. The proposed rule is expected in the Federal Register in January 1998 and will be followed by a 90-day comment period. CONTACT: John Tinger, EPA 202/260-4992

· Metal Products & Machinery Rule - EPA recently distributed a screener survey to AMSA members with the intent of using data collected as the basis for developing effluent guidelines for the MP&M Phase II industry categories. The survey addresses the costs associated with administrative permitting and sewage sludge use or disposal. AMSA members are legally required to comply with the request by the February deadline. For more information, please call EPA's toll-free help hotline at 800/709-8054.

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. The National Office distributed EPA's Draft Pretreatment Program Streamlining Proposal to the membership via Regulatory Alert RA 97-13. 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, with its proposed changes to the Pretreatment Program.

Status: The draft NPRM was distributed on November 13, 1997 for internal EPA review and workgroup closure. The NPRM is expected in the Federal Register in March 1998. AMSA and the Pretreatment and Hazardous Waste Committee Leadership meet with EPA's Office of Enforcement and Compliance Assurance on December 3, 1997, to reinforce AMSA's position on SNC and encourage EPA to consider our comments when developing the regulatory language. 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. The pilot city agencies 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 Jacksonville, FL. 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. AMSA, EPA, and the Silver Council met on October 14, 1997 to complete review of the workplan prior to submittal to the EPA's Quality Review team and project steering committee. Representatives from the pilot cities, and other project participants met on November 4, 1997 in Norfolk, VA, during the AMSA-EPA Pretreatment Coordinators' Workshop to discuss logistics for the project.

Status: AMSA and the Project Steering Committee held a kick-off meeting with project participants on November 21. The Committee revised the statistical sampling design in December 1997. The contractors plan to initiate sampling in early 1998. CONTACT: Sam Hadeed, AMSA 202/833-4655.

F EPA will hold approximately nine public meetings over the next year to solicit comment relating to the Toxics Release Inventory (TRI) reporting form, Form R. The purpose of the meetings is to obtain comments from stakeholders on ways to improve the type of right-to-know information available to communities and to help streamline right-to-know reporting to ease the paperwork burden for businesses affected by the requirements. CONTACT: Michelle Price, EPA 202/260-3372.

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