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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. 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

Final Action

   

Consent Decree or actual

Consent Decree

Pulp, Paper and Paperboard
Pesticide Formulating, Packaging, and Repackaging
Centralized Waste Treatment
Pharmaceutical Manufacturing
Metal Products and Machinery
Industrial Laundries
Transportation Equipment Cleaning
Landfills and Incinerators
J. Troy 202/260-7128
Shari Zuskin 202/260-7130
Jan Matuszko 202/260-9126
Frank Hund 202/260-7182
Steve Geil 202/260-9187
Susan Burris 202/260-5379
Gina Mathews 202/260-6036
Samantha Hopkins 202/260-7149

10/97
4/14/94
reproposal 3/98
5/2/95
10/00
11/97
1/98
11/97

1/98
9/96
8/99
4/98
12/02
6/99
2/00
11/99

ยท Metal Products and Machinery: EPA held a public meeting on November 5, 1997 in Washington, DC to inform all interested parties of the current status of the guidelines. EPA is currently in the data gathering stage and plans on proposing the MP & M Guidelines in November 2000. CONTACT: Steve Geil, EPA 202/260-9817.

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, with its proposed changes to the Pretreatment Program. Proposed rulemaking is expected in the Federal Register in December 1997 with final promulgation scheduled for December 1998. EPA has indicated that the Office of Management and Budget(OMB) may delay the release of the proposal due to potential concerns with streamlining-related activities. AMSA plans to meet with OMB to encourage the process to move forward. 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 Victoria, TX.

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. 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. AMSA has scheduled a Project Steering Committee kick-off meeting with project participants on November 21. CONTACT: Sam Hadeed, AMSA 202/833-4655.

AMSA-EPA Pretreatment Coordinators’ Workshop Held in Norfolk, VA

The fourth annual AMSA-EPA Pretreatment Coordinators’ Workshop was held November 5-7 at the Norfolk Waterside Marriott Hotel in Norfolk, Virginia. This marked 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. Over 260 people attended the workshop featuring discussions on: 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. Proceedings were distributed at the workshop. Supplemental materials not available during the workshop are being prepared and will be available in early 1998. CONTACT: Sam Hadeed, AMSA, 202/833-4655.

Related Items of Interest

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. Three meetings have been scheduled for November 1997. For more information, contact, Michelle Price, EPA 202/260-3372.


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