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. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Beverly Randolph, EPA 202/260-5373.
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Centralized Waste Treatment Metal Products and Machinery Industrial Laundries Transportation Equipment Cleaning Landfills Incinerators Feedlots - Swine & Poultry Subcategories Feedlots - Dairy & Beef Subcategories Oil & Gas Extraction - Synthetic Drilling Fluids Coal Mining- Remining & Western Subcategories | Jan Matuszko 202/260-9126 Steve Geil 202/260-9187 Marta Jordan 202/260-0817 John Tinger 202/260-4992 John Tinger 202/260-4992 Samantha Hopkins 202/260-7149 Eric Strassler 202/260-7120 Eric Strassler 202/260-7120 Eric Strassler 202/260-7120 Eric Strassler 202/260-7120 | reproposal 3/98 10/00 12/97 6/98 2/98 2/98 12/99 12/00 12/98 12/99 | 8/99 12/02 6/99 6/00 11/99 11/99 12/01 12/02 12/00 12/01 |
- On June 25, 1998, EPA published proposed effluent limitations guidelines, pretreatment standards, and new source performance standards for the transportation equipment cleaning (TEC) point source category. EPA is proposing to establish effluent limitations for existing facilities and new sources discharging wastewater to POTWs in the Truck/Chemical and Rail/Chemical subcategories. EPA is also proposing effluent limitations for new sources discharging wastewater to POTWs in the Barge/Chemical & Petroleum subcategory. EPA is proposing not to establish effluent limitations or pretreatment standards for existing or new facilities in the Truck/Petroleum, Rail/Petroleum, Truck/Hopper, Rail/Hopper, and Barge/Hopper subcategories. Also, EPA is proposing not to establish pretreatment standards for existing or new sources in the Truck/Food, Rail/Food, and Barge/Food subcategories because the pollutants generated by these subcategories are amenable to treatment in POTWs. EPA held a public meeting on August 18 to discuss the proposed TEC guidelines. The Pretreatment & Hazardous Waste Committee is currently reviewing the proposed guidelines and will submit comments to EPA before the September 23 deadline. CONTACT: Sam Hadeed, AMSA, 202/833-4655 or John Tinger, EPA, 202/260-4992.
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 (NPRM) 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: On June 23, as
part of pretreatment program reinvention and streamlining efforts,
EPA proposed a pilot program that would allow as many as 15 POTWs
to experiment with innovative strategies and new technologies
for implementing their CWA pretreatment programs under Project
XL. EPA hopes the pilot projects will provide innovative approaches
to pretreatment program streamlining, that can be used to reform
the national pretreatment program. They are particularly interested
in whether certain indirect discharge permitting reforms are appropriate
or if EPA should pursue reforms that allow POTWs to issue general
permits. Copies of the proposal were distributed to the membership
via Regulatory Alert, RA 98-11. The draft NPRM to streamline the
pretreatment program was distributed on November 13, 1997 for
internal EPA review and workgroup closure. In August, AMSA
met with the Office of Management & Budget (OMB) to press
AMSA's proposed changes to the definition of SNC in EPA's pretreatment
streamlining proposal. While AMSA has met with EPA's Office of
Enforcement & Compliance Assurance (OECA) to address SNC issues,
OECA has resisted taking any further steps on this issue. OMB,
however, was very receptive to AMSA's concerns and is interested
in ensuring that the rule not create unnecessary burdens on POTWs
and is a proponent of streamlining. The proposal is currently
undergoing OMB review and will be issued in the fall. 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. Sampling is currently
underway at the pilot cities. All of the cities have collected
data on demographics of the photo processors and will submit the
data to the project contractors by September 30, 1998. The project
steering committee plans to conduct quarterly conference calls
to review the status of work. The next meeting of the steering
committee is scheduled for January 1999. A revised POTW Guidance
Manual for the CMP for Silver Dischargers is expected this fall
and will include a chapter on pollution prevention. The revised
manual will be distributed to the attendees of the 1997 AMSA/EPA
Pretreatment Coordinators' Workshop. Representatives from
the pilot cities and the project contractors will meet during
1998 AMSA-EPA Pretreatment Coordinators' Workshop in Kansas City,
MO. The study is scheduled for completion by July 1999. CONTACT:
Sam Hadeed, AMSA 202/833-4655.
1998 AMSA-EPA Pretreatment Coordinators' Workshop
The fifth annual joint AMSA-EPA Pretreatment Coordinators'
Workshop will be held October 28-30 at the Hyatt Regency Crown
Center in Kansas City, Missouri. This joint forum will bring together
considerable expertise from local and state governments, and EPA
regions and Headquarters to discuss opportunities to enhance the
current and future direction of the national pretreatment program.
Discussion topics for this year's workshop include sessions on
EPA's pretreatment program, updates on EPA's Engineering &
Analysis Division and Office of Enforcement & Compliance Assurance,
national pretreatment program awardee presentations, pollution
prevention, TRI modeling, industry sector compliance notebooks,
mercury issues, environmental crimes, third party lawsuits, radioactivity
survey/guidance issues, CSI Metal Finishing Strategic Goals, and
Project XL. The workshop will also feature breakout sessions focusing
on regional issues and mercury. Workshop information was forwarded
to the membership via Member Update MU 98-13 in early August
and a detailed flyer in early September. Conference information
and registration is also available at AMSA's web site at http://www.amsacleanwater.org/mtgs/98epa/info.cfm.
CONTACT: Sam Hadeed, AMSA, 202/833-4655.