Beyond Air

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Beyond AirWastewater2002 SBO/SBAP National
ConferenceFebruary 19, 2002

• Matt Gluckman
• Pretreatment Program Manager
• U.S. Environmental Protection Agency Region 5
• 312/886-6089
• www.epa.gov/r5water/npdestek/npdprta.htm

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Industrial Wastewater Statistics

• gt15,000 Publicly Owned Treatment Works (POTW) in
  U.S- Treat 34 Billion Gal/Day
• 4,300 POTWs in U.S. EPA Region 5
• About 6,000 Significant Industrial Users (SIU) in
  Region 5
• Most of these SIUs discharge to gt300 POTWs, which
  are required to operate Pretreatment Programs

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Indirect v. Direct Wastewater Discharges
Treatment
Treatment
Indirect Discharge Direct Discharge
POTW
Surface Waters
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Introduction to National Pretreatment Program

• POTWs not designed to treat toxic pollutants
• Clean Water Act requires National Pretreatment
  Program to
• Prevent Pass Through
• Prevent Interference, including sludge
  contamination
• Improve recyclability of sludges
• Protect worker health and safety

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How are these goals met?

• Prohibitions
• General Prohibit Pass Through and Interference
• Specific Prohibit fire/explosion hazards,
  corrosives, solid/viscous substances, et cetera.
• Categorical Standards Sector-specific
  technology-based standards
• Local Limits Developed by POTWs to ensure
  compliance with discharge permit requirements

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How are the Standards implemented?

• By POTWs, EPA and States
• Certain POTWs required to develop programs.
  Implementation required through discharge permits
• EPA and States regulate IU discharges in smaller
  POTWs

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What must a POTW do to implement a Program?

• Identify and characterize all IUs
• Issue permits to SIUs Limits, monitoring and
  reporting requirements, duration lt5 yrs, transfer
  conditions, statement of penalties
• Inspect and sample SIUs at least annually
• Review IU reports
• Investigate and respond to noncompliance
• Develop and implement local limits

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How do you ensure compliance by POTWs and IUs?

• Mainly by self-reporting, with POTW, state and
  EPA oversight
• IUs self-monitor and report to POTWs, EPA or
  state
• POTWs review IU reports, inspect and sample IUs,
  enforce against violations
• EPA and delegated states review POTW reports,
  inspect POTWs and IUs
• EPA and states can enforce against POTWs or IUs

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Metal Finishing Regulations
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Current Wastewater Regulations for Metal Finishers

• Older plating and metal finishing job shops
  subject to 40 CFR 413
• Newer job shops and captive facilities subject
  to 40 CFR 433

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Metal Products Machinery Proposal, 40 CFR 438

• January 2001 proposal would set more stringent
  standards for facilities subject to 413 and 433,
  and cover other metal fabricators not currently
  regulated by categorical standards

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MPM Regulatory Subcategories
These subcategories cover facilities that
primarily discharge metal-bearing wastewaters.
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MPM Regulatory Subcategories
These subcategories cover facilities that
primarily discharge oil-bearing wastewaters.
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MPM Jan. 01 Proposal Comments

• Costs underestimated Limits consistently
  unattainable without more advanced equipment
• POTW administrative costs underestimated
• Benefits overestimated
• No further regulation for Metal Finishing
  industry is necessary

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MPM Notice of Data Availability, June 5, 2002
(67 FR 38751)

• Provides new wastewater sampling data to
  recalculate pollutant reductions, costs, economic
  impacts, benefits, and limits.
• - More than 70 sets of data from industry
• - Seven new EPA sampling episodes
• releases some data previously held as
  confidential
• Notices for public comment surveys from AMSA,
  Association of American Railroads, and North
  Carolina Pretreatment Consortium

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Potential Changes from MPM Proposal

• EPA is considering use of
• flow cutoff (or increasing proposed flow cutoff)
• pollution prevention alternatives
• upgrading limits for all sites covered by Part
  413 (Electroplating) to those in Part 433 (Metal
  Finishing)
• applying Part 433 limits to General Metals
  facilities w/o national categorical standards
  and
• no regulation/no further regulation for indirect
  dischargers in several subcategories.

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MPM Next Steps

• EPA is soliciting data and comments on the NODA
  until July 22, 2002
• EPA will analyze the additional information and
  prepare final options for internal Agency
  deliberations
• EPA will sign final MPM rule by Dec. 31, 2002,
  and publish in the Federal Register (www.gpo.gov)
• For more information, see www.epa.gov/waterscien
  ce/guide/mpm/