Pretreatment & Hazardous Wastes Issues
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 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. The Effluent Guidelines Task Force met on September 10-11, in Washington, DC. The members encouraged EPA to use a "presumptive BAT" approach for future Effluent Guidelines. EPA will be selecting several new rulemaking projects this Fall. The Task Force agreed to develop a Universal Treatment Standard concept, similar to one used in the RCRA land disposal regulations. The next meeting will be held May 20-21, 1998. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Beverly Randolph, EPA 202/260-5373.
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Pulp, Paper and Paperboard Pesticide Formulating, Packaging, and Repackaging Centralized Waste Treatment Pharmaceutical Manufacturing Metal Products and Machinery, Phase 1 and Phase 2 Industrial Laundries Transportation Equipment Cleaning Landfills and Incinerators |
12/17/93 4/14/94 reproposal 1/98 5/2/95 10/00 11/97 1/98 11/97 |
10/97 9/96 8/99 4/98 12/02 6/99 2/00 11/99 |
· Pulp, Paper, and Paperboard Effluent Guidelines: EPA issued the proposed Pulp, Paper, and Paperboard "Cluster Rules", covering both effluent guidelines and National Emission Standards for Hazardous Air Pollutants (NESHAP), on December 17, 1993. The proposed effluent guidelines were organized into 12 subcategories. A final rule is expected in 1997.
· Pesticide Formulating, Packaging, and Repackaging : EPA is currently negotiating with the Natural Resources Defense Council (NRDC) an extension to its consent decree for the development of this rulemaking. CONTACT: Shari Zuskin, EPA 202/260-7130.
· Centralized Waste Treatment Facilities: EPA plans to re-propose the effluent guidelines for centralized waste treatment facilities in early 1998. CONTACT: Jan Matuszko, EPA 202/260-9126.
· Pharmaceutical Manufacturing: EPA has plans to jointly promulgate effluent guidelines along with National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations for the pharmaceutical industry. On August 8, 1997, EPA released a notice of data availability of its analysis of old and newly acquired data to the May 2, 1995 proposal. The release of the notice of data availability was delayed from an earlier date to allow for cost-benefit estimates to be calculated based on a March 20 CAA proposed rule for the pharmaceutical industry. AMSA submitted comments to EPA on September 22, 1997. Promulgation is planned for April 1998. CONTACT: Frank Hund, EPA 202/260-7182.
· Metal Products and Machinery: EPA plans to merge the two phases of this regulation into one rule scheduled for proposal in October 2000. EPA has scheduled a public meeting on November 5, 1997 in Washington, DC to inform all interested parties of the current status of the guidelines. CONTACT: Steve Geil, EPA 202/260-9817.
· Industrial Laundries: The Office of Science and Technology held a public meeting in Laurel, Maryland on March 4, 1997. EPA plans to propose effluent guidelines for this category by November 1997. CONTACT: Susan Burris, EPA 202/ 260-5379.
· Transportation Equipment Cleaning: EPA intends to
propose effluent limitations guidelines and standards in January
1998. CONTACT: Gina Matthews, EPA 202/260-6036.
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. These potential changes include 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. A workshop developed and sponsored by AMSA and WEF to guide EPA's efforts to streamline the national pretreatment program was held on August 10-14, 1996 in Leesburg, Virginia.
Status: The National Office distributed EPA's Draft Pretreatment
Program Streamlining Proposal to the membership via Regulatory
Alert RA97-13. Changes to thirteen specific issues were proposed
including: specific prohibition regarding pH, equivalent mass
limits for concentration limits, equivalent concentration limits
for flow-based standards, POTW oversight of significant industrial
users, slug control plans, sampling for pollutants not present,
de minimus categorical industrial users, use of grab and composite
samples, removal credits, electronic filing and storage of reports,
general permits, best management practices, and modifications
of significant noncompliance (SNC) criteria. 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 upon the comments received,
EPA will redraft the document as a formal notice of proposed rulemaking
(NPRM). Based on discussions at a meeting of various stakeholders
including POTWs, EPA Headquarters, Regions and states, AMSA has
prepared draft regulatory language under 40 CFR 403 that addresses
SNC issues. AMSA forwarded the draft regulatory language 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's Pretreatment Committee leadership forwarded
a letter to the Natural Resources Defense Council (NRDC) on August
13, with its proposed changes to the Pretreatment Program. Proposed
rulemaking is expected in the Federal Register in December
1997. EPA has indicated that the Office of Management and Budget
may delay the release of the proposal due to potential concerns
with streamlining-related activities. CONTACTS: Sam Hadeed,
AMSA 202/833-4655, or Jeff Smith, EPA 202/260-5586.
AMSA, EPA and Silver Council Cooperative Agreement
Background: AMSA, the Silver Council and EPA recently 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; 5 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 total grant assistance requested from EPA is $150,000,
to be augmented by in-kind services from AMSA and up to $150,000
furnished by the Silver Council. The proposed 2 year project will
be coordinated at a national level by AMSA, The Silver Council,
and EPA using a steering team approach. EPA involvement in the
steering team will be directed by the Office of Policy, Planning
and Evaluation (OPPE), in cooperation with the Office of Water
(OW), Office of Enforcement and Compliance Assurance (OECA), and
appropriate EPA Regional offices.
Status: In June 1997, following a pre-bid meeting, the
project steering team selected Black & Veatch and Apogee Research,
Inc. to provide contractor support for this project. A kick-off
meeting with project participants was held on July 29, 1997 to
discuss development of the work plan. A work plan is expected
in September 1997. 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 Victoria, TX. AMSA,
EPA, and the Silver Council met on October 14, 1997 to complete
review of the workplan prior to submittal to the EPA's Quality
Review team and project steering committee. Representatives from
the pilot cities, and other project participants will meet on
November 4, 1997 in Norfolk, VA, during the AMSA-EPA Pretreatment
Coordinators' Workshop to discuss logistics for the project. CONTACT:
Sam Hadeed, AMSA 202/833-4655.
AMSA-EPA Pretreatment Coordinators' Workshop Scheduled for
November
Federal, state, and local pretreatment coordinators from
around the country will meet and share their considerable expertise
during the fourth AMSA-EPA Pretreatment Coordinators' Workshop,
November 5-7 at the Norfolk Waterside Marriott Hotel in Norfolk,
Virginia. This marks the eighth year AMSA has sponsored this annual
forum for pretreatment coordinators to discuss opportunities to
enhance the current and future direction of the national pretreatment
program. The workshop format is designed to maximize interaction
among the attendees and to allow everyone to actively participate.
Discussion topics for the November workshop include: EPA pretreatment
program updates relating to effluent guidelines, oil & grease,
and other Part 136 issues; pretreatment streamlining, and enforcement
and compliance issues; pretreatment reinvention; local limits
development including radionucleides; and, impact of privatization
on pretreatment programs There will be regional breakouts and
panel discussions on handling a variety of special wastes and
innovative approaches to pretreatment/pollution prevention programs.
The 1997 EPA National Pretreatment Program awardees will also
make presentations. A flyer including the agenda and registration
materials was forwarded to the membership in late September.
The workshop registration deadline is October 24. CONTACT:
Sam Hadeed, AMSA, 202/833-4655.
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