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.
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 | 11/99 |
| 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 |
o 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 has scheduled a public meeting on August 18, from 9:00-11:00 am in Washington, DC 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. 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. The Steering Committee met on June 5 to discuss coordination of project efforts. 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 later this summer 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. A meeting with the pilot city representatives is being planned during the October 28-30, 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 27-30 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. Conference information and registration is also available at AMSA’s web site at http://www.amsa-cleanwater.org/mtgs/98epa/info.cfm. CONTACT: Sam Hadeed, AMSA, 202/833-4655.
Related Items of Interest
The Toxics Data Reporting (TDR) Committee for the National Advisory Council for Environmental Policy & Technology (NACEPT) will meet August 27-28 in Washington, DC. The committee will address many of AMSA’s recommendations made in the May 1997 report, "Improving Toxic Release Inventory Accuracy" as well as the formatting and nomenclature of Form R; opportunities to ease the paperwork burden in Form R and Form A; and, clarification of the elements in Form R and EPA’s presentation of the data in public information documents.