1 / 96

Basic Pretreatment Training Course

U.S. Environmental Protection Agency 9th Annual Pacific Northwest Pretreatment Conference Greenwood Inn Beaverton, Oregon. Basic Pretreatment Training Course. Objectives History Sections to Note Regulation of Industry NPDES Permitting Program Pretreatment Program

zonta
Download Presentation

Basic Pretreatment Training Course

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. U.S. Environmental Protection Agency 9th Annual Pacific Northwest Pretreatment Conference Greenwood Inn Beaverton, Oregon Basic Pretreatment Training Course

  2. Objectives History Sections to Note Regulation of Industry NPDES Permitting Program Pretreatment Program Relationship with Other Statutes Contents The Clean Water Act

  3. 1956 - Federal Water Pollution Control Act 1965, 1966, 1970 - Amendments 1972 - Major redirection, PL 92-500 - Completely replaced earlier law Annual amendments through 1983 Last revision - February 4, 1987, PL-100-4 Objectives • Restore and maintain the chemical, physical and biological integrity of the Nation's waters • National goal to eliminate discharge of pollutants to navigable waters by 1985 • Interim goal to provide waters that are fishable and swimable by July 1, 1983 • No discharge of toxic pollutants in toxic amounts History

  4. Water quality standards based on desired uses of receiving waters - Drinking water - Fishing - Body contact - Navigation - Recreation Generally ineffective Political, technical and legal weaknesses Stream use designations tailored to protect or attract industrial development Inadequate information on cause and effect of industrial discharges Inadequate consideration of needs of aquatic ecosystems 1956 to 1972

  5. Different philosophy No one has the right to pollute Pollution continues because available treatment technologies are not used National Pollutant Discharge Elimination System (NPDES) permits Nationally uniform industrial effluent limits through categorical standards Secondary treatment required for publicly owned treatment works (POTWs) Construction grant funding for POTWs Comprehensive river basin and regional water quality planning for point and nonpoint sources 1972 to Present

  6. 106 - Water Pollution Control Program Grants 201 - Construction Grants for POTWs 208 - Areawide Waste Treatment Management Plans 303 - Water Quality Standards 304 - Individual Control Strategies for Toxic Pollutants 308 - Inspections, Monitoring and Entry 309 - Federal Enforcement 404 - Permits for Dredged or Fill Material 405 - Disposal of Sewage Sludge 601 - State Water Pollution Control Revolving Funds Sections to Note

  7. Direct discharge to surface water under section 402 Indirect discharge to POTWs under section 307 Industry's most frequent involvement through NPDES permitting or pretreatment program Industry participation needed in areawide planning and water quality standard development NPDES delegated to many states NPDES Program Permit term of five years Many industrial dischargers are high water volume dischargers - Refineries - Canneries - Power plants - Groundwater cleanup Basis for effluent limitations Water quality standards Treatment technology Conventional pollutants - Best Conventional Technology (BCT) Regulation of Industry

  8. Possible variance for Best Practicable Technology (BPT) Toxic pollutants - BAT Section 307(a) "priority pollutants" Section 301 "effluent guidelines" for 34 categories of industry New source performance standards (NSPS) Best Management Practices (BMPs) Housekeeping operations, process alterations Whole effluent toxicity Acute, chronic tests - Nonconventional pollutants - Best Available Technology (BAT) - Pretreatment Program • "Indirect" discharge to sewer • Large number and variety of industry, electronics, aerospace, food processing • Program Objective is to Prevent: • Interference • Pass-through • Sludge contamination • No NPDES permits issued to "indirect" dischargers - see local agency

  9. EPA-developed categorical standards 24 categories, BAT, PSES/PSNS Early development concerned conventional pollutants Consent decree in NRDC v. EPA required EPA to focus on 126 "priority pollutants" and industries discharging them Local limits Developed by POTW to meet program objectives and maintain compliance with its NPDES permit General and Specific Prohibitions in 40 CFR Part 403 Pretreatment Program Implementation - POTWs over 5 MGD (design) must have EPA-approved program Program elements include: Authority Survey/inventory Permitting (not NPDES) Sampling/inspection Local limits Enforcement Resources - Basis for Discharge Limitations

  10. Comprehensive Environment Response, Compensation and Liability Act (CERCLA) (Superfund) Spill Prevention, Control and Countermeasure (SPCC) plans are required under section 311 of the Clean Water Act and CERCLA Section 311 regulates oil spill clean-ups to "Waters of the United States," and oil storage above or below ground CERCLA contains expanded requirements Resource Conservation and Recovery Act (RCRA) RCRA provides two exclusions from its hazardous waste management requirements Industrial wastewater discharged under an NPDES permit Industrial wastewater discharged to POTW sewer systems under the pretreatment program Relationship with Other Statutes

  11. PretreatmentProgram Regulations [40 CFR Part 403]

  12. § 403.8 § 403.9 § 403.11 § 403.18 Requirements of a POTW developed pretreatment program Contents/legal authority of a POTWpretreatment program POTW pretreatment program approval procedures Modifications of POTW Pretreatment Programs Local Pretreatment Programs

  13. § 403.5 § 403.6 § 403.7 § 403.13 § 403.15 General & specific prohibitions Categorical standards Removal credits Variances for fundamentally different factors Net/Gross calculation Program Requirements Affecting IUs

  14. § 403.12 POTW & IU reporting requirements POTW and IU Requirements

  15. § 403.16 § 403.17 Upset provisions Bypass provisions Specific IU Rights

  16. § 403.2 § 403.3 § 403.4 § 403.14 Objectives of regulations Definitions State or local law Confidentiality Miscellaneous Requirements

  17. Industrial Users identify, locate, and notify receive, sample, and analyze survey, investigate, and enforce Public allow participation notify of violators What Minimum Procedures Make Up a Pretreatment Program?[40 CFR § 403.8(f)(2)]

  18. Additional procedures: Funding Local limits Enforcement Response Plan SIU list Minimum Pretreatment Program Procedures, continued[40 CFR § 403.8(f)(2)]

  19. State law Local regulations Sewer Use Ordinance(“SUO”) or Rules and Regulations Legal Authority, a Must

  20. Deny or condition discharges Require compliance Control through permit or similar means Require compliance schedules to comply Inspect, survey, and monitor Enforce Comply with confidentiality requirements POTW Legal Authority[40 CFR § 403.8(f)(1)]

  21. General Prohibitions Specific Prohibitions Categorical Standards Local Limits Prohibitions and Limitations

  22. Deny/condition new or increased contributions Issue control mechanisms/compliance schedules Require development of slug/spill control plans Require pretreatment facilities Control Discharges

  23. BMRs/90 day compliance reports Compliance schedule progress reports Periodic compliance reports Notice of potential problems Notice of limit violations and resampling Notice of changed conditions/discharge Notice of hazardous waste discharged Reports & Notices

  24. Right of entry Right to inspect Right to sample Right to require installation of monitoring/flow measuring equipment Right to inspect and copy record Compliance Monitoring

  25. Non-emergency response injunctive relief civil/criminal penalties Emergency response Remedies for Noncompliance(Enforcement)

  26. Analytical procedures Signatory Record keeping Confidentiality Annual publishing of IUs in SNC Public participation/access to information Other Requirements

  27. Submission to Approval Authority Public notice Approval Authority decision Public access to information Local Program-Approval Process

  28. A POTW’s program accepts discharges from nondomestic users outside the Control Authority’s political boundary. Multi-jurisdictional Issues

  29. Sewer District Covering Several Municipalities

  30. Direct authority Multi-jurisdictional agreements Industrial user contracts Coordination/cooperation Multi-jurisdictional Control

  31. General & specific prohibitions Local limits Categorical standards Pretreatment Standards

  32. No non-domestic user shall introduce into a POTW any pollutants which cause Interference or Pass Through. General Prohibitions[40 CFR § 403.5(a)(1)]

  33. (1) Pollutants which create a fire or explosion hazard; (2) Pollutants which will cause corrosive structural damage to the POTW; (3) Solid or viscous pollutants causing obstruction and resulting in interference; (4) Pollutants released at a flow rate and/or concentration causing interference (5) Heat in amounts which will inhibit biological activity in the POTW resulting in interference; (6) Oils in amounts that will cause interference or pass through; (7) Pollutants which result in the presence of toxic gases, vapors, or fumes; and (8) Trucked or hauled pollutants, except at discharge points designated by the POTW. Specific Prohibitions [40 CFR § 403.5(b)]

  34. Cause POTW to comply with NPDES permit Protect the POTW Protect POTW personnel Improve sludge disposal options Local Limits

  35. Local limits are designed to keep the POTW in compliance with its NPDES permit and prevent problems from occurring in the collection system Failure analysis Violations should be considered serious State and EPA are not the only audience for analysis Local limits should be believable and real Introduction

  36. Municipal treatment plants are generally not extremely sensitive Upsets are generally not common Water quality standards increasing in stringency Toxicity requirements more common in NPDES permits Sludge regulations under review Reuse of effluent will likely become more desirable and require higher quality effluent Environment

  37. Numerical NPDES permit limits Toxicity requirements in NPDES permit Collection system protection Permit compliance schedules and timing Narrative requirements in NPDES permit Water quality standards and preventing new NPDES permit limits Objectives and Basis of Limits

  38. Domestic contribution Septage Mass balance for conservative pollutants Discharges to Treatment Plant

  39. Mass balance for conservative pollutants Metals analysis Effluent limits in NPDES permit below analytical detection limits Removal efficiencies Selecting inhibition values from literature Treatment Plant Analysis

  40. Greatly affected by changes in state water quality standards through NPDES permit limits Generally not comparable between POTWs Allocations first to uncontrollable sources (domestic and infiltration/inflow) and then controllable sources (industrial and commercial) Greatly affected by allocation method (uniform, BMPs, contributory) Local Limits Observations

  41. Applicable to specific industry categories Technology-based limitations Clean Water Act section 307 and 1976 EPA/NRDC consent decree. Currently at 51 categories. Found in 40 CFR Parts 405-471. Applicable to direct & indirect dischargers. Categorical Standards

  42. National standards technology available economic impacts processes performed Apply to regulated process flow only Concentration or mass based limits Daily maximum and long term averages Developed for new and existing sources Categorical Standards

  43. Part 405 - Dairy Products Processing Part 406 - Grain Mills Part 407 - Canned and Preserved Fruits and Vegetables Processing Part 408 - Canned and Preserved Seafood Processing Part 409 - Sugar Processing Part 410 - Textile Mills Part 411 - Cement Manufacturing Part 412 - Feedlots Part 413 - Electroplating Part 414 - Organic Chemicals, Plastics and Synthetic Fibers Part 415 - Inorganic Chemical Manufacturing Part 417 - Soap and Detergent Manufacturing Part 418 - Fertilizer Manufacturing

  44. Part 419 - Petroleum Refining Part 420 - Iron and Steel Manufacturing Part 421 - Nonferrous Metals Manufacturing Part 422 - Phosphate Manufacturing Part 423 - Steam Electric Power Generating Part 424 - Ferroalloy Manufacturing Part 425 - Leather Tanning and Finishing Part 426 - Glass Manufacturing Part 427 - Asbestos Manufacturing Part 428 - Rubber Manufacturing Part 429 - Timber Products Processing Part 430 - Pulp, Paper and Paperboard Part 431 - The Builders’ Paper and Boardmills Part 432 - Meat Products

  45. Part 433 - Metal Finishing Part 434 - Coal Mining Part 435 - Oil and Gas Extraction Part 436 - Mineral and Mining Processing Part 439 - Pharmaceutical Manufacturing Part 440 - Ore Mining and Dressing Part 443 - Paving and Roofing Materials(Tars and Asphalt) Part 446 - Paint Formulating Part 447 - Ink Formulating Part 454 - Gum and Wood Chemicals Manufacturing Part 455 - Pesticide Chemicals Part 457 - Explosives Manufacturing Part 458 - Carbon Black Manufacturing Part 459 - Photographic Processing Part 460 - Hospital

  46. Part 461 - Battery Manufacturing Part 463 - Plastics Molding and Forming Part 464 - Metal Molding and Casting Part 465 - Coil Coating Part 466 - Porcelain Enameling Part 467 - Aluminum Forming Part 468 - Copper Forming Part 469 - Electrical and Electronic Components Part 471 - Nonferrous Metals Forming and Metal Powder The CWA(304(m)) requires that every two years EPA develop and publish plans for effluent guidelines, review, revision, development, and adoption.

  47. Regulated process wastestreams Unregulated process wastestreams Dilute wastestreams Wastestream Types

  48. Production processes/products Raw materials Production volume Determine applicable category Determine applicable subcategory Contact Approval Authority for assistance Categorical Determinations

  49. New source standards generally are more stringent New sources are required to be in compliance upon commencement of discharge New source requirements are triggered by some facility modifications Why is Existing/New Source Determination So Important?

More Related