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 |
4/15/98 |
| 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 | 12/00 |
| Incinerators | Samantha Hopkins | 202/260-7149 | 2/6/98 | 12/00 |
| 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 |
- 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 7, 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.
- On April 15, 1998, EPA released its final pulp and paper cluster rule. The final rule represents the first time EPA has combined technology based standards to control both air and water pollution from a single industry and is expected to cost the industry $1.8 billion and reduce dioxin emission by 96 percent. The regulation focuses on requiring paper manufacturer use of chlorine dioxide in place of chlorine in their operations. The regulations also include a Voluntary Advanced Technology Incentives Program for certain subcategories within the industry. CONTACT: Penny Lassiter, EPA 919/541-5396.
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. The study’s objective is to examine combinations of voluntary efforts and regulatory requirements to cost-effectively achieve reductions in the discharge of silver to the environment. The CMP is one example of a voluntary effort that can help achieve these reductions while decreasing or avoiding the costs of regulating silver discharge to POTWs and to dischargers. Implementation of the CMP through voluntary cooperation among government and business may enable the use of more flexible regulatory approaches or, in some circumstances, avoid the need for regulation outright. If proven technically and economically successful in the silver user sector, the CMP approach may very well stand as a model for other business sectors and areas of regulation. 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 influent sampling at each of the pilot agencies. A workplan was completed in early April which summarized the objectives of the study and the work to be completed to meet these objectives. The Steering Committee will meet on June 5 to discuss coordination of project efforts. The study is scheduled for completion by July 1999. CONTACT: Sam Hadeed, AMSA 202/833-4655.