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. Phase I of the effluent guidelines for metal products and machinery has been combined with Phase II and now covers eight additional major industry groups including: buses and trucks, household equipment, instruments, motor vehicles, office machines, precious metals, railroads, and ships and boats. EPA published their proposed biennial plans for developing new and revised effluent guidelines, based on recommendations from the Effluent Guidelines Task Force in the May 28, 1998 Federal Register. EPA proposes to develop effluent limitation guidelines as follows: 1) Continue development of nine rules listed in the 1996 Effluent Guidelines Plan, including: Pulp, Paper and Paperboard, Phases 2 & 3; Centralized Waste Treatment; Pharmaceutical Manufacturing; Metal Products and Machinery; Landfills; Industrial Waste Combustors (Incinerators); Industrial Laundries; Transportation Equipment Cleaning; and Iron and Steel Manufacturing; 2) Continue development of three rules initiated in 1997, including: Oil and Gas Extraction; Coal Mining; and Feedlots (Poultry and Swine subcategories); 3) Begin development of revised effluent guidelines for the Feedlots category (Beef and Dairy Cattle subcategories) and two additional categories (new or revised), by December 1998; 4) Complete preliminary studies on Feedlots, Urban Storm Water, and Airport Deicing; and, 5) Plan for development of two additional effluent guidelines, either new or revised, by December 1999. EPA is requesting comments on the proposed plan by July 27, 1998. EPA is interested in data that would facilitate comparisons of discharger categories with regard to wastestream characteristics, treatment practices, and effects on water quality. 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 |
On June 25, 1998, EPA published proposed effluent limitations guidelines, pretreatment standards, and new source performance standards for the transportation equipment cleaning 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. Comments on the proposed rule are due to EPA by September 23, 1998. CONTACT: 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 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 NPRM is expected in September 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. 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. The study is scheduled for completion by July 1999. CONTACT: Sam Hadeed, AMSA 202/833-4655.
In June, EPA released the 1996 TRI data. Based on this data, EPA plans to profile five sectors, including primary metals, chemical, pulp and paper, petroleum refining and electronics. EPA hopes to profile fifteen additional sectors by the end of the year. At the two digit SIC code level, EPA will include economic statistics such as employment or earnings, as an indicator of whether the industry is contracting or expanding. At the four digit SIC code level, EPA will highlight the chemicals which were the major releases, the waste management practices, and geographical concentrations of the industry. EPA will also identify specific facilities that had unusually large changes in releases or total waste generation. The profiles will not include toxicity weighted TRI emissions or relative risk scores based on the TRI environmental indicator model that has been under discussion. AMSA is participating in an EPA FACA initiative to improve the accuracy of TRI reporting by industry and how to address transfers and removal efficiencies of toxic chemicals to POTWs for further management. The Committee met on May 27-28 to discuss reporting issues for small businesses.