Pretreatment & Hazardous Waste Issues
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. AMSA has played an integral part in the development of these proposed changes, working together with EPA in developing issue papers, hosting the 1996 AMSA-Water Environment Federation Pretreatment Streamlining Workshop, and providing comment on EPA's May 1997 draft proposal. While supportive of most of the proposed changes, AMSA has major concerns with EPA's proposed modification of significant noncompliance (SNC) criteria.
In August 1998, 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.
EPA held an internal briefing on the package in December 1998 and resubmitted the package to OMB in early January 1999. AMSA will develop specific language that reflects a pattern of SNC for use in defining the criteria for SNC during the review and will encourage its members to support this language in individual agency comments to EPA. In addition, AMSA will propose language to address short term pH excursions below 5 that currently contribute to about 25% of SNC violations. The Committee also requested up to $10,000 in Technical Action Fund support via the Regulatory Policy Committee to facilitate AMSA's efforts to collect data on short-term pH fluctuations in industrial discharges to wastewater treatment plants. Results of the study are expected to be part of AMSA's official comments to EPA.Status: On July 22, 1999, EPA formally released proposed regulatory and administrative changes to streamline the national industrial pretreatment program (40 CFR Part 403). The effort is designed to provide administrative changes to reduce the burden on entities regulated under the pretreatment program. AMSA's Pretreatment and Hazardous Waste Committee leadership plans to develop a formal position paper on all of the proposed changes this month and encourages all members to review the proposal and provide any comments by August 25. The position paper will be distributed to the membership in September and AMSA members will be encouraged to attach the paper to their individual comments to EPA. It is imperative that EPA receive numerous comments from AMSA member agencies in support of all of the Association's recommendations on streamlining. CONTACTS: Mark Hoeke, AMSA 202/833-9106, or Jeff Smith, EPA 202/260-5586.
Effluent Guidelines PlanBackground: EPA published its final plans for developing new and revised effluent guidelines which regulate industrial discharges to surface waters and to POTWs in the September 4, 1998 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 is conducting studies on confined animal feeding operations, urban stormwater and airport deicing. EPA recently conducted a total petrochemical hydrocarbon (TPH) study for the industrial laundries industry and issued a notice of data availability of the results in the Federal Register on December 23, 1998. The Effluent Guidelines Task Force met in Crystal City, VA on May 4-5 1999. On July 1,1999, EPA announced that national standards requiring treatment of wastewater from the nation's 1,700 industrial laundries are not warranted, and that better environmental protection could be accomplished through pollution prevention at the source. AMSA was supportive of this conclusion since most local problems can be resolved by local pretreatment authorities. 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 |
Final Action |
|
|
|
Consent Decree or actual |
Consent Decree |
|
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 |
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 |
10/00 12/97 6/98 2/98 2/98 12/99 12/00 12/98 12/99 |
12/02 6/99 6/00 12/00 11/99 12/01 12/02 12/00 12/01 |
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 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 AMSA/Silver Council "Code of Management Practice (CMP) for Silver Dischargers" will be used as the model approach for controlling silver discharges. 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. 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 and 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 steering committee met on January 22, 1999 in Washington, DC to review the progress to date. The project steering committee has also been conducting weekly conference calls to monitor progress. The study is scheduled for completion by December 1999. CONTACT: Mark Hoeke, AMSA 202/833-9106.
AMSA/EPA to Sponsor Pretreatment Coordinators' Workshop in November
Background: The sixth annual joint AMSA-EPA Pretreatment Coordinators' Workshop will be held November 3-5, 1999 at the Sheraton Dallas Park Central Hotel in Dallas, Texas. This year's event will also mark the 10th anniversary of AMSA sponsorship of a pretreatment coordinators' workshop for its membership. 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 EPA program updates from the Offices of Water, Enforcement & Compliance Assurance, and Reinvention, AMSA updates, recognition of national pretreatment program awardees, breakout sessions on regional issues and regulation and characterization of commercial/light industry sources, how to prepare for a criminal case as a witness, criminal investigation case studies, mandatory state pretreatment penalty requirements, overview of the project XL initiative, and looking towards pretreatment in the new millennium.
Status: Workshop information will be sent to the membership via a Member Update in mid-August. CONTACT: Paula Dannenfeldt, AMSA 202/833-4654.