Effluent Limit Guidelines

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Effluent Limit Guidelines
The Other Shoe Has Dropped
AMI Conference New
Orleans LA
October 24, 2002

John E. Starkey, P.E.
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ELG Process

• Review Regulatory classes
• Review impact on poultry plants
• Bill Gill Review Impact on Meat Plants
• Bill Gill Review ongoing process with EPA

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Why Are We so Lucky?
1. The CWA requires EPA to develop review
ELGs
2. Activists sued EPA in 89 to force ELGs,
Settled Suit in 92
3. Settlement includes ELGs 02 CAFOs 03
Meat Poultry Products
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What are ELGs
Minimum Performance standards for WWTFs in an
Industry Sector
Water Quality Limits supercede
Production Based Limits BPT Best Practicable
Technology BAT Best Available Technology NSPS
New Source Performance Standards PSES, PSNS
Pretreatment Standards
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BPT Best Practicable Control Technology
Currently Available
Can Set limits for Conventional, Toxic or
non-conventional pollutants
First, Considers Costs in relation to benefits
Other Factors Age, Technologies, Energy Use
Historically, Average of the Best
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BAT Best Available Control Technology
Economically Achievable
Geared toward Toxic or non-conventional pollutants
Generally same factors, EPA has more discretion
Based on actual or pilot Plant, or bench scale
studies
Historically, Best of the Best
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NSPS New Source Performance Standards
Best Available Demonstrated Control Technology
Typically, Most Stringent Limitations
Generally same factors, EPA has more discretion
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PSES PSNS Pretreatments Standards Existing
and New Sources
Intended to Prevent Disharges that Pass through
POTW Interfere With POTW
PSES - Technology Based Equivalent to BAT
PSNS - Equivalent to NSPS
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PSES PSNS Pretreatments Standards Existing
and New Sources
January 30 Proposal includes neither, largely
because of AMSA
EPA solicits comments on setting
limits Nitogen Oil Grease Modeled DAF w/
Flow Equalization
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BPT, BAT NSPS for Direct Dischargers
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Potential Consequences
Important to remember that ELGs are not set for
WQ reasons, but rather because EPA believes the
industry can achieve the limit
Increased Reliance on POTWs Increased Reliance
on Land Application Long Term Increased Foreign
Production?