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: EPA recently selected four industrial categories for which effluent limitations guidelines and standards will be developed. The categories include: 1) Oil and Gas Extraction - Synthetic Drilling Fluids; 2) Coal Mining - Remining and Western Subcategories; 3) Feedlots - Swine and Poultry Subcategories; and 4) Feedlots - Dairy and Beef Cattle Subcategories. EPA plans to develop the new rules on a shorter fast-track schedule. 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
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 | 260-7128 | 10/97 | 2/98 |
| Pesticide Formulating, Packaging, and Repackaging | Shari Zuskin | 260-7130 | 4/14/94 | 9/96 |
| Centralized Waste Treatment | Jan Matuszko | 260-9126 | reproposal 3/98 | 8/99 |
| Pharmaceutical Manufacturing | Frank Hund | 260-7182 | 5/2/95 | 4/98 |
| Metal Products and Machinery | Steve Geil | 260-9187 | 10/00 | 12/02 |
| Industrial Laundries | Marta Jordan | 260-0817 | 12/97 | 6/99 |
| Transportation Equipment Cleaning | John Tinger | 260-4992 | 5/98 | 2/00 |
| Landfills | John Tinger | 260-4992 | 2/6/98 | 12/00 |
| Incinerators | Samantha Hopkins | 260-7149 | 2/6/98 | 1/00 |
| Feedlots - Swine & Poultry Subcategories | Eric Strassler | 260-7120 | 12/99 | 12/01 |
| Feedlots - Dairy & Beef Subcategories | Eric Strassler | 260-7120 | 12/00 | 12/02 |
| Oil & Gas Extraction - Synthetic Drilling Fluids | Eric Strassler | 260-7120 | 12/98 | 12/00 |
| Coal Mining- Remining & Western Subcategories | Eric Strassler | 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. EPA has extended the comment period until March 19, 1998. AMSA's Pretreatment & Hazardous Waste Committee leadership met with laundry industry representatives February 20 to discuss issues of mutual interest. Copies of the Federal Register notice can be found at http://www.access.gpo.gov/nara/cfr/index.cfml. CONTACT: Sam Hadeed, AMSA
· Landfills & Incinerators - On February 6, 1998, EPA issued the proposed rules for the Landfills Point Source Category and the Industria Waste Combustor Subcategory. EPA will conduct workshops and public hearings on the proposed rules on April 1, 1998. The workshop and public hearing for the Industrial Waste Combustor Subcategory is scheduled 9:00 am to 10:30 am, and for the Landfills Point Source Category from 10:30 am to 12:30 pm. Both meetings will be held in Washington, DC, at the EPA Headquarters Auditorium. 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 technology-based effluent 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. CONTACT: Sam Hadeed, AMSA
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.
The National Office distributed EPA's Draft Pretreatment Program Streamlining Proposal 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 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 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 the Federal Register in June 1998. CONTACTS: Sam Hadeed, AMSA
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. The Steering Committee are scheduled to meet on March 16, 1998 to discuss the current status of the project. CONTACT: Sam Hadeed, AMSA