Pretreatment and Hazardous Waste 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 at the Best Western Key Bridge in Arlington, Virginia. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Beverly Randolph, EPA 202/260-5373.
Table 1 - Effluent Guidelines Currently Under Development
| Category | EPA Contact | Proposal Consent Decree or actual | Final Action Consent Decree | |
| Pulp, Paper and Paperboard | J. Troy | 202/260-7128 | 10/97 |
2/98 |
| Pesticide Formulating, Packaging, and Repackaging | Shari Zuskin | 202/260-7130 | 4/14/94 | 9/96 |
| Centralized Waste Treatment | Jan Matuszko | 202/260-9126 | reproposal 3/98 | 8/99 |
| Pharmaceutical Manufacturing | Frank Hund | 202/260-7182 | 5/2/95 | 7/98 |
| Metal Products and Machinery | Steve Geil | 202/260-9187 | 10/00 | 12/02 |
| Industrial Laundries | Marta Jordan | 202/260-0817 | 12/97 | 6/99 |
| Transportation Equipment Cleaning | John Tinger | 202/260-4992 | 6/98 | 2/00 |
| Landfills | John Tinger | 202/260-4992 | 2/6/98 | 11/99 |
| Incinerators | Samantha Hopkins | 202/260-7149 | 2/6/98 | 11/99 |
| Feedlots - Swine & Poultry Subcategories | Eric Strassler | 202/260-7120 | 12/99 | 12/01 |
| Feedlots - Dairy & Beef Subcategories | Eric Strassler | 202/260-7120 | 12/00 | 12/02 |
| Oil & Gas Extraction - Synthetic Drilling Fluids | Eric Strassler | 202/260-7120 | 12/98 | 12/00 |
| Coal Mining- Remining & Western Subcategories | Eric Strassler | 202/260-7120 | 12/99 | 12/01 |
·Industrial Laundries - The proposed rule, issued on December 17, 1997, 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. On March 17, 1998, AMSA submitted comments to EPA stressing concerns regarding EPA’s proposal which is based on extremely limited information and technology, and AMSA’s belief that the guidelines for industrial laundries are technically flawed. Based on the comments the National Office received from over 20 agencies, interference or pass through or compromised biosolids quality from industrial laundry discharges is not currently a problem. AMSA is also concerned with the data used by EPA for determining removal rate in its pass through analysis, reliance on the use of one data set for selecting chemical precipitation alone as the basis for the standard for industrial laundries and selection of unapproved test methods. AMSA’s comments can be viewed by visiting the Committee Correspondence Section of the Member Pipeline on AMSA’s Web Site, http://www.amsa-cleanwater.org. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Marta Jordan, EPA 202/260-0817.
·Landfills & Incinerators - On February 6, 1998, EPA issued the proposed rules for the Landfills Point Source Category and the Industrial Waste Combustor Subcategory. The proposed effluent guidelines for the Industrial Waste Combustor Subcategory will cover wastewater discharges from commercially-operating hazardous waste combustor facilities regulated as "incinerators" or "boilers and industrial furnaces" under RCRA, as well as commercially-operating non-hazardous industrial waste combustor facilities. The proposal would not apply to sewage sludge incinerators, medical waste incinerators, municipal waste combustors or other solid waste combustion units. Sources of wastewater that would be regulated under the proposal include flue gas quench, slag quench and air pollution control wastewater. The proposed effluent guidelines for the Landfills Point Source Category will establish limitations for wastewater discharges to navigable waters associated with the operation of new and existing hazardous and non-hazardous landfill facilities regulated under Subtitle C or Subtitle D of RCRA. The proposal would also establish pretreatment standards for the introduction of pollutants into POTWs associated with the operation of new and existing hazardous landfills regulated under Subtitle C of RCRA. The proposal would not establish pretreatment standards for the introduction of pollutants into POTWs associated with the operation of new and existing non-hazardous landfills regulated under Subtitle D of RCRA. Comments on both proposed rules are due to EPA by May 3, 1998. Copies of both of the proposed rules can be found in the Regulatory Outreach section of AMSA’s web site at http://www.amsa-cleanwater.org/private. AMSA’s Pretreatment and Hazardous Waste Committee Leadership are currently reviewing the proposed regulations. CONTACT: Sam Hadeed, AMSA 202/833-4655.
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 including: 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. EPA’s Draft Pretreatment Program Streamlining Proposal was distributed to the membership via Regulatory Alert RA 97-13. 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 on discussions with EPA in 1997, AMSA prepared draft regulatory language under 40 CFR 403 that addresses SNC issues. The draft language was forwarded to a variety of stakeholders for review in August 1997. AMSA requested that EPA consider the language in the preamble to its proposal. 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.
Status: The draft NPRM was distributed on November 13, 1997 for internal EPA review and workgroup closure. The NPRM is expected in June 1998. CONTACTS: Sam Hadeed, AMSA 202/833-4655, or Jeff Smith, EPA 202/260-5586.
AMSA, EPA and Silver Council Cooperative Agreement
Background: In 1997, AMSA, the Silver Council and EPA 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: five 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 proposed 2 year project will be coordinated at a national level by AMSA, The Silver Council, and EPA using a steering team approach. 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.
Status: The project contractors, Black & Veatch and Apogee Research, are currently performing sampling at each of the pilot agencies. AMSA, the Silver Council and the project contractors met on March 16 to discuss the updates to the sampling workplan. The Steering Committee will meet on June 5 to discuss coordination of project efforts. CONTACT: Sam Hadeed, AMSA 202/833-4655.
Related Items of Interest
- Bob Steidel, Environmental Manager for the Hopewell Regional Wastewater Treatment Facility in Hopewell, VA will represent AMSA on EPA’s Toxics Data Reporting Committee of the National Advisory Council for Environmental Policy & Technology, to advise EPA on the Toxic Release Inventory (TRI) Program.
- Twenty AMSA member agencies have volunteered to participate in a new EPA Common Sense Initiative (CSI) Program that will allow the metal finishing industry more flexibility in meeting current national requirements as it attempts to achieve overall environmental improvements. Under the Metal Finishing Strategic Goals Program - a landmark agreement reached under the CSI - participating firms pledge to reduce metal emissions to air and water by 50%, reduce hazardous sludge disposal by 50% and cut down on TRI emissions by 90% by 2002. AMSA’s charter members and future participating states and municipalities will provide the industry with compliance and pollution prevention assistance, particularly in meeting pretreatment requirements. Hampton Roads Sanitation District’s Guy Aydlett, also chair of AMSA’s Pretreatment & Hazardous Waste Committee, is a member of the CSI Metal Finishing Subcommittee and will represent AMSA’s interests as the Initiative proceeds.