Title: Beyond Air
1Beyond 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
2Industrial 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
3Indirect v. Direct Wastewater Discharges
Treatment
Treatment
Indirect Discharge Direct Discharge
POTW
Surface Waters
4Introduction 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
5How 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
6How 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
7What 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
8How 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
9Metal Finishing Regulations
10Current 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
11Metal 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
12MPM Regulatory Subcategories
These subcategories cover facilities that
primarily discharge metal-bearing wastewaters.
13MPM Regulatory Subcategories
These subcategories cover facilities that
primarily discharge oil-bearing wastewaters.
14MPM 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
15MPM 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
16Potential 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.
17MPM 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/