PRETREATMENT PERFORMANCE MEASURES Draft

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PRETREATMENT PERFORMANCE MEASURES (Draft)

• 24th EPA REGION 6
• ANNUAL PRETREATMENT WORKSHOP
• OKLAHOMA CITY
• 8/14/08
• Allen Gilliam
• ADEQ State Pretreatment Coordinator
• gilliam_at_adeq.state.ar.us

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WHY Pretreatment Program Performance Measures NOW?
OFFICE OF INSPECTOR GENERAL Evaluation Report
(September 28, 2004)
http//www.epa.gov/oig/reports/2004/20040928-2004-
P-00030.pdf EPA Needs to Reinforce Its National
Pretreatment Program
I. Better Information and Analysis Needed EPA
does not have the information systems necessary
to effectively measure, analyze, demonstrate, and
improve Program performance.
Without sufficient data to show the gains made by
its Pretreatment Program, EPA leaves this program
vulnerable to future budget cuts.
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EPA Needs to Reinforce Its National
Pretreatment Program

• II. Performance Measures Need to Be Results Based

Measuring the impact of a Program is essential to
documenting Program performance to support
continued funding and identify future needs.
The Pretreatment Program is at risk of losing the
gains it has made if EPA does not become more
vigorous in setting national policy and
developing Program measures that can adequately
document the Programs progress.
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9 PROPOSED MEASUREMENTS6 BASIC Pretreatment
Program (POTW is in compliance) and 3 Enhanced
MeasuresTHE 6 BASIC

• Explosions Hazardous Atmosphere(s)
• pH Violations and Observed Corrosion
• Sewer Collection System Overflows
• Interference or Pass Through
• Correct Permits Representative Sampling
• Full Compliance

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9 PROPOSED MEASUREMENTSTHE 3 ENHANCED

• 7. Biosolids Voluntarily Meet EQ Limits
• 8. of Zero Discharging SIUs
• 9. Controls on Emerging Pollutants

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1. Explosions Hazardous Atmosphere(s)

• or of POTW fires, explosion hazards, or other
  type of hazardous atmosphere at plant or in
  collection system attributable to SIUs?
• Fires explosions - Rare and should be an easy
  count?
• Is it standard procedures to use gas/vapor
  detection or explosi-meters before entering
  confined spaces to determine the of hazardous
  conditions that were found in a year?
• No collection system alarms?

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2. pH Violations and Observed Corrosion

• or of SIUs that violated a local limit or
  categorical standard for pH?
• or of SIUs that were in SNC for pH
  violations?
• or of pH related issues (corrosion, odor,
  inhibition, pass-through, worker health safety)
  caused by SIUs?
• Difficult to determine source(s)?
• Was pH even the problem?
• No communication with collection system folks?
• Problems with grabs vs continuous?

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3. Sewer Collection System Overflows

• or of POTWs with active FOG programs?
• of POTWs that consider their FOG program to be
  part of their Pretreatment program?
• or of POTW blockages, spills, or overflows
  due to solidified grease or other (not including
  linens, rags, diapers, etc) not attributed to
  non-domestic dischargers (NDUs)?
• or of blockages, spills, overflows in the
  collection system attributable to non-domestic
  dischargers?
• No communication with collection system folks?

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4. Interference or Pass Through

• of POTW limit violations attributable to
• a) operational problems at the plant,
• b) interference or pass thru by SIUs, or
• c) source is undetermined but not due to
  operational problems at plant?
• OR JUST
• of incidents of pass through or interference
  attributable to SIUs causing POTW to violate its
  NPDES permit limits or be unable to dispose of
  biosolids by intended means?
• Going to have to have excellent communications
  with the OM folks at your POTW(s)!!

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5. Correct(?) Permits and Representative
Sampling(?)

• of SIU permits that contain all required 40 CFR
  403 components,
• of SIU permits that require representative
  sampling,
• of POTWs that ensure representative samples are
  taken of their SIUs process wastewater.
• YOU better know ALL your permitted IUs
  processes, batch discharge frequencies and their
  plumbing! Your production based CWF IUs
  limits have to be correct!

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6. SIUs in Full Compliance

• or of POTWs SIUs in 100 compliance with
  local limits, categorical standards, general
  specific prohibitions, and reporting requirements
• Verified(?) via more detailed, time consuming
  audits PCIs.
• Are your enforcement actions timely effective?
• Do you allow your SIUs to reach SNC?
• Good measurement for small programs?

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7. Biosolids Meet EQ Limits

• of POTWs producing biosolids that meet limits
  in Tables 1 3 of 40 CFR 503.13.
• of POTWs disposing of biosolids by type of
  practice.
• Measure doesnt differentiate how biosolids are
  disposed (landfill, incinerated or lagoon storage
  vs land app.)
• And doesnt include those meeting Class A or
  Exceptional Quality as defined in CFR 503 (but
  could)
• Arent most Cities meeting 503, Tables 1 or 3
  anyway?
• Where or who has the authority to require you
  to analyze your biosolids if youre landfilling,
  incinerating or storing it in a waste lagoon?

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8. of Zero Discharging SIUs

• or of POTWs CIUs and non-categorical SIUs at
  zero-discharge voluntarily (AND/OR ?)
• or Due to NPDES or enforcement requirement?
• Doesnt include those IUs that are hauling their
  wastes off-site
• Looking for IUs that have made process changes,
  incorporated P2 and other innovative approaches
  in managing and using water.

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9. Controls on Emerging Pollutants

• of POTWs with programs addressing emerging
  pollutants or sources
• not subject to categorical standards,
• not traditionally evaluated,
• not typically regulated, or
• recently identified of potential concern to the
  environment, or public health such as
  Pharmaceuticals Personal Care Products (PPCPs)
  http//www.epa.gov/ppcp/

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Collection of Data? The who and hows

• 1. Explosions Hazardous Atmosphere(s)
• 2. pH Violations and Observed Corrosion
• 3. Sewer Collection System Overflows
• 4. Interference or Pass Through
• YOU Provide s on your Annual Reports
• More administrative burden for you
• MUST have Effective communication between
  collection system and Pretreatment personnel
• s Verified via Pretreatment Audits and
  Compliance Inspections
• Better Have the Paperwork Documented

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Collection of Data? The who and hows

• 5. Correct Permits Representative Sampling
• 6. Full Compliance
• s Discovered via Pretreatment Audits and
  Compliance Inspections
• More administrative burden on the State
• More scrutiny on file reviews
• More friendly discussions between you and I on
  what representative sampling is?
• More nit-picking than usual?

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THE 3 ENHANCED MEASUREMENTS

• 7. Biosolids Voluntarily Meet EQ Limits
• YOU Provide s on your Annual Report
• Voluntarily being the active term
• Arent most Cities meeting CFR 503 tables 1 3
  limits without local limit requirements?
• Some cities are landfilling and/or not
  generating and not land applying
• Wheres your requirement to supply data?
• Can EPA or the State force analyticals?
• Verified via Pretreatment Audits and Compliance
  Inspections

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8. of Zero Discharging SIUs

• YOU Provide s on your Annual Report
• More administrative burden for you
• Does the or of your SIUs achieving a no
  discharge status regardless of reason mean your
  Program is going beyond what is minimally
  required and is enhanced?
• Have some of your SIUs achieved no discharge
  voluntarily for cost effectiveness?
• How many of your SIUs have YOU required to have
  no discharge of process wastewater?
• s Verified via Pretreatment Audits and
  Compliance Inspections

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9. Controls on Emerging Pollutants

• YOU Provide s on your Annual Report
• More administrative burden for you
• BMPs for businesses not considered SIUs
  (restaurants, dentists, auto repair, machine
  shops, etc)
• P2 implementation requirements in permits
• Requirements to report progress (lbs, , energy,
  water)
• Ordinance prohibitions against flushing
  pharmaceuticals
• Hope youve started gathering your baseline
  data to show progress in the future!
• s Verified via Pretreatment Audits and
  Compliance Inspections

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ORIGINAL PERFORMANCE MEASURES TASK FORCE (AMSA)
ATTEMPTS WERE SUBMITTED TO EPA IN
94http//www.epa.gov/npdes/pubs/final14.doc

• These Measurements were basically ignored by the
  EPA but some are essentially the same
• Since EPAs Inspector Generals Office has now,
  in essence, placed the Office of Water on a
  compliance schedule with milestone dates to be
  met WE HAVE TO COME UP WITH SOMETHING!!!!!
• Do these 9 measures seem good performance
  measures to you?