Pretreatment & 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 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. AMSA submitted comments in early February 1999. AMSA's Pretreatment & Hazardous Waste Committee is currently reviewing the reproposed effluent guidelines for the centralized waste treatment (CWT) industry. Comments were submitted to EPA on March 15th. The Effluent Guidelines Task Force met in Crystal City, VA on May 4-5, 1999. 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 |
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 forwarded 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 in December 1997, to reinforce AMSA's position on SNC and encourage EPA to consider our comments when developing the regulatory language.
Status: The draft NPRM to streamline the pretreatment program was distributed in November 1997 for internal EPA review and workgroup closure. 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 resubmited 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 back the collection of data on short-term pH fluctuations in industrial discharges to wastewater treatment plants. OMB cleared the package in late January. The proposal is now anticipated to be issued by early July. 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 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: Sam Hadeed, AMSA 202/833-4655.
AMSA-U.S. Navy Sign Joint Guidance on Shipboard Discharges to POTWs
Background: An investigation of metals in CHT system wastewater onboard Navy ships was conducted by the U.S. Navy, Hampton Roads Sanitation District, and the City of San Diego to classify CHT discharges. The investigation was designed to determine whether elevated metals concentrations in CHT effluent are a result of industrial discharges to the CHT system or from corrosion of metal components of the ships' plumbing systems. The study concluded that elevated metals concentrations in CHT effluent is a result of corrosion of ships' plumbing systems, and that ships' CHT discharges are domestic in nature. Subsequent to the CHT study, a partnering effort was initiated with AMSA to apply the results nationwide. AMSA's Pretreatment & Hazardous Waste Committee reviewed the data submitted by the Navy and agreed with those conclusions.
Status: AMSA and the U.S. Navy recently signed joint guidance regarding the regulation of wastewater discharges from U.S. Navy ship Collection, Holding, and Transfer (CHT) systems. Data collected by the U.S. Navy, in cooperation with AMSA member agencies in Norfolk, Virginia and San Diego, California, demonstrated that Navy CHT wastewater is domestic in nature. The same data also concludes that concentrations of metals, such as copper, nickel, and zinc, in Navy CHT wastewater can be attributed to the corrosion of ship plumbing systems exposed to seawater. Guy Aydlett, Chair, AMSA Pretreatment & Hazardous Waste Committee and Elsie Munsell, Deputy Assistant Secretary of the Navy (Environment and Safety) represented the two organizations at the signing ceremony held at the Pentagon in March.
Based on the conclusions of the report, the following guidance was developed:
- Regulate Navy CHT wastewater as domestic wastewater (uncommingled);
- Implement this guidance on a site-specific basis utilizing existing analytical data;
- Maintain POTW plant performance and comply with approved pretreatment program guidelines; and,
- Make appropriate allowance, within approved pretreatment program guidelines, or metal concentrations in Navy effluent, which contains a mixture of CHT wastewater and industrial wastewater (uncommingled).
A number of AMSA member agencies situated near U.S. Navy installations and Coast Guard operations such as Seattle, Portland, San Francisco, Anchorage, Honolulu, Houston, Philadelphia, Boston, Providence, Newark and some 20 other agencies will benefit from this guidance to regulate CHT wastewater as a domestic source. EPA's Office of Wastewater Management was advised of the guidance and supporting study in mid-June 1999. Copies of the U.S. Navy study can be obtained by contacting Ron Tickle, Chief of Naval Operations, Arlington, VA; 703/602-2787. Implementation questions should be directed to Sam Hadeed, c/o AMSA at 202/833-4655.