kyEPA
                 United States
                 Environmental Protection
                 Agency
                  Office of Wastewater
                  Management (4203)
EPA-833-B-98-002
February 1999
Introduction to the National
Pretreatment Program
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              Disclaimer
Mention of trade names or commercial products in this
document or associated references does not constitute
an endorsement or recommendation for use.

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Introduction to the National Pretreatment Program
Table of Contents
TABLE  OF  CONTENTS
                                                                                 'age
       Preface 	 iii
       List of Acronyms 	 v
       Glossary of Terms	 vii

1.      POTWs and the Need for the Pretreatment Program	 1
             Sewage Treatment	 1
             Need for the Pretreatment Program	 2

2.      Overview of the National Pretreatment Program	 5
             The Clean Water Act 	 5
             The General Pretreatment Regulations	 6
             POTW Pretreatment Programs  	 7

3.      Pretreatment Standards	 11
             Prohibited Discharge Standards	 11
             Categorical Standards 	 12
             Local Limits 	 20
             Summary of Standards	 22

4.      POTW Pretreatment Program Responsibilities  	 23
             Legal Authority	 23
             Industrial Waste Surveys	 24
             Permitting	 25
             Inspections	 26
             Sampling	 27
             Enforcement	 28
             Data Management and Record Keeping  	 31
             Public Participation and POTW Reporting	 32

5.      Industrial User Pretreatment Program Responsibilities	 35
             Reporting Requirements	 35
             Self-Monitoring Requirements 	 39
             Record  Keeping Requirements  	 40

6.      Hauled Wastes	 43
             Nature of Hauled Wastes	 43
             Control  Programs	 43
             Concerns  	 45

7.      Pollution Prevention	 47
             Pollution Prevention and the Pretreatment Program  	 48
             Benefits of Pollution Prevention	 49
             Pollution Prevention Assistance	 50

8.      Bibliography 	 51


APPENDICES

A      Annotated Summaries of Existing Pretreatment Guidance Material	 A-1
B      Document Ordering Information	 B-1
C      EPA/State Primary Pretreatment Contacts/Addresses	 C-1

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Introduction to the National Pretreatmsnt Program
                                                                                        Preface
PREFACE
    The industrial boom in the United States during the 1950s and 60s brought with it a level of pollution never
before seen in this country. Scenes of dying fish, burning rivers, and thick black smog engulfing major
metropolitan areas were images and stories repeated regularly on the evening news. In December of 1970,
the President of the United States created the U.S. Environmental Protection Agency (EPA) through an
executive order in response to these critical environmental problems.

    In 1972, Congress passed the Clean Water Act (CWA) to restore and maintain the integrity of the nation's
waters. Although prior legislation had been enacted to address water pollution, those previous efforts were
developed with other goals in mind. For example, the 1899 Rivers and Harbors Act protected navigational
interests while the 1948 Water Pollution Control Act and the 1956 Federal Water Pollution Control Act merely
provided limited funding for State and local governments to address water pollution concerns on their own.


    The CWA required the elimination of the discharge of pollutants into the nation's waters and the
achievement of fishable and swimmable water quality levels. EPA's National Pollutant Discharge Elimination
System (NPDES) Permitting Program represents one of the key components established to accomplish this
feat.  The NPDES program requires that all point source discharges to waters of the U.S. (i.e., "direct
discharges") must be permitted.

    To address "indirect discharges" from industries to Publicly Owned Treatment Works (POTWs), EPA,
through CWA authorities, established the National Pretreatment Program as a component of the NPDES
Permitting Program. The National Pretreatment Program requires industrial and commercial dischargers to
treat or control pollutants in their wastewater prior to discharge to POTWs.

    In 1986,  more than one-third of all toxic pollutants entered the nation's waters from publicly owned
treatment works (POTWs) through industrial discharges to public sewers.1 Certain industrial discharges, such
as slug loads, can interfere with the operation of POTWs, leading to the discharge of untreated or inadequately
treated wastewater into rivers, lakes, etc. Some pollutants are not compatible with biological wastewater
treatment at POTWs and may pass through the treatment plant untreated. This "pass through" of pollutants
impacts the surrounding environment, occasionally causing fish kills or other detrimental alterations of the
receiving waters. Even when POTWs have the capability to remove toxic pollutants from wastewater, these
toxics can end up in the POTW's sewage sludge, which in many places is land applied to food crops, parks,
or golf courses as fertilizer or soil conditioner.

    The National Pretreatment Program is unique in that the General Pretreatment Regulations require all
large POTWs (i.e., those designed to treat flows of more than 5 million gallons per day) and smaller POTWs
with significant industrial discharges to establish local pretreatment programs.  These local programs must
enforce all national pretreatment standards and requirements in addition to any more stringent local
requirements necessary to protect site-specific conditions at the POTW. More than 1,500 POTWs have
developed and are  implementing local  pretreatment  programs  designed to  control discharges from
approximately 30,000 significant industrial users.

    Since 1983, the Pretreatment Program has made great strides in reducing the discharge of toxic pollutants
to sewer systems and to waters of the U.S. In the eyes of many, the Pretreatment Program, implemented as
a partnership between EPA, States, and POTWs, is a notable success story in reducing impacts to human
health and the environment. These strides can be attributed to the efforts of many Federal, State, local, and
industrial representatives who have been involved with developing and implementing the various aspects of
the Pretreatment Program.
        1  EPA, Environmental Regulations and Technology: The National Pretreatment Program, July 1986,
          p.4.
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  Preface
                                                            Introduction to the National Pretreatment Program
     EPA has supported the Pretreatment Program through development of numerous guidance manuals.
 EPA has released more than 30 manuals that provide guidance to EPA, States, POTWs, and industry on
 various pretreatment program  requirements  and policy determinations.  Through this guidance, the
 Pretreatment Program has maintained national consistency in interpretation of the regulations.

     Nevertheless, turnover in pretreatment program staff has diluted historical knowledge leaving new staff
 and other interested parties unaware of existing materials.  With this in mind, the intent of this guidance
 manual, Introduction to the National Pretreatment Program, is to:

     (1) provide a reference for anyone interested in understanding the basics of pretreatment program
     requirements, and

     (2) provide a roadmap to  additional and  more detailed guidance materials for those  trying  to
     Implement specific elements of the Pretreatment Program.

     While the Pretreatment Program has demonstrated significant reductions in pollutants discharged to
 POTWs, Congress1 goals of zero discharge of toxic pollutants and fishable/swimmable water quality have not
 been realized. EPA is currently working to establish more cost-effective and common sense approaches to
 environmental protection  (e.g., using watershed, streamlining, and reinvention  concepts),  creating new
 responsibilities for all those involved in the National Pretreatment Program. Many current challenges remain,
 while many new ones likely lie ahead. This guidance manual is  intended to provide an  understanding of the
 basic concepts that drive the Program, the current status of the Program and program guidance, and an
 insight into what the future holds for all those involved with implementing the Pretreatment Program.

     As noted above, this guidance manual is organized to provide an overview of program requirements and
 to refer the reader to more detailed  EPA guidance that exists on specific program elements. To accomplish
 this, the guidance manual incorporates two key features: 1) the first page of each chapter contains a list of
 EPA references applicable to the topics discussed in that chapter, and 2) abstracts of each reference are
 provided in Appendix A with document ordering information provided in Appendix B. Addresses of EPA and
 State pretreatment staff are provided in Appendix C. Additionally, Chapter 8 contains a bibliography of these
 guidance materials, and other materials that may be useful to the reader and describes how to obtain them..
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Introduction to the National Pretreatment Program
LIST  OF ACRONYMS
Acronym  Full Phrase

AA        Approval Authority
AO        Administrative Order
BAT      Best Available Technology Economically Achievable
BCT      Best Conventional Pollutant Control Technology
BMP      Best Management Practices
BMR      Baseline Monitoring Report
BOD5     5-day Biochemical Oxygen Demand
BPJ      Best Professional Judgment
BPT      Best Practicable Control Technology Currently Available
CA        Control Authority
CFR      Code of Federal Regulations
CIU       Categorical Industrial User
CSO      Combined Sewer Overflow
CWA     Clean Water Act (formerly referred to as the Federal Water Pollution Control Act or Federal Water
          Pollution Control Act Amendments of 1972) Pub. L. 92-500, as amended by Pub. L. 95-217, Pub.
          L 95-576, Pub. L. 96-483, Pub. L. 97-117, and Pub. L. 100-4, 33 U.S.C. 1251 etseg.
CWF      Combined Wastestream Formula
CWT      Centralized Waste Treater
DMR      Discharge Monitoring Report
DSE      Domestic Sewage Exclusion
DSS      Domestic Sewage Study
ELG      Effluent Limitations Guideline
EPA      Environmental Protection Agency
EPCRA   Emergency Preparedness and Community Right to Know Act
ERP      Enforcement Response Plan
FDF      Fundamentally Different Factors
FR        Federal Register
FWA      Flow Weighted Average
gpd       Gallons per Day
ID        Industrial User
LEL      Lower Explosive Limit
MAHL     Maximum Allowable Headworks Loading
MAIL     Maximum Allowable Industrial Loading
MGD     Million Gallons per Day
MSDS     Material Safety Data Sheet
NAICS    North American  Industry Classification System (replaces SIC coding system  in 1998)
NOV      Notice of Violation
NPDES   National Pollutant Discharge Elimination System
NRDC     Natural Resources Defense Council
NSPS     New Source Performance Standard
O&G      Oil and Grease

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 Acronym   Full Phrase

 O&M       Operations and Maintenance
 OCPSF    Organic Chemicals, Plastics, and Synthetic Fibers
 P2         Pollution Prevention
 PCI        Pretreatment Compliance Inspection
 PCS       Permit Compliance System
 PIRT       Pretreatment Implementation Review Task Force
 POTW     Publicly Owned Treatment Works
 PSES      Pretreatment Standards for Existing Sources
 PSNS      Pretreatment Standards for New Sources
 QA/QC     Quality Assurance/Quality Control
 RCRA      Resource Conservation and Recovery Act
 SIC       Standard Industrial Classification
 SIU       Significant Industrial User
 SPCC     Spill Prevention Control and Countermeasures
 SNC      Significant Noncompliance
 SSO      Sanitary Sewer Overflow
 SUO      Sewer Use Ordinance
 TCLP      Toxicity Characteristic Leaching Procedure
 TIE        Toxicity Identification Evaluation
 TOMP     Toxic Organic Management Program
 TRE       Toxicity Reduction Evaluation
 TRI        Toxic Release Inventory
 TSS       Total Suspended Solids
 TTO       Total Toxic Organics
 USC       United States Code
 UST       Underground Storage Tank
WET      Whole Effluent Toxicity
WWTP     Wastewater Treatment Plant

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Introduction to the National Pretreatment Program
GLOSSARY OF TERMS
    This glossary includes a collection of terms used in this manual and an explanation of each term. To the
extent that definitions and explanations provided in this glossary differ from those in EPA regulations or other
official documents, the definitions used herein are intended for use in understanding this manual only.

Act or "the Act" [40 CFR §403.3(b)]
    The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC1251
etseq.

Approval Authority [40 CFR §403.3(c)J
    The Director in an NPDES State with an approved State Pretreatment Program and the appropriate EPA
Regional Administrator in a non-NPDES State or State without an approved pretreatment program.

Approved POTW Pretreatment Program or Program [40 CFR §403.3(d)]
    A program administered by a POTW that meets the criteria established in 40 CFR Part 403 and which has
been approved by a Regional Administrator or State Director.

Approved State Pretreatment Program
    A program administered by a State that meets the criteria established in 40 CFR §403.10 and which has
been approved by a Regional Administrator

Approved/Authorized State
    A State with an NPDES permit program approved pursuant to section 402(b) of the Act and an approved
State Pretreatment Program.

Baseline Monitoring Report (BMR) [paraphrased from 40 CFR§403.12(b)J
    A report submitted by categorical industrial users (ClUs) within 180 days after the effective date of an
applicable categorical  standard, or at least 90 days prior to commencement of discharge for new sources,
which contains specific facility  information, including flow and pollutant concentration data.  For existing
sources, the report must also certify as to the compliance status of the facility with respect to the categorical
standards.

Best Available Technology Economically Achievable (BAT)
    A level of technology based on the best existing control and treatment measures that are economically
achievable within the given industrial category or subcategory.

Best Management Practices (BMPs)
    Schedules of  activities, prohibitions  of practices,  maintenance procedures, and other management
practices to prevent or reduce the pollution of waters of the U.S. BMPs also include treatment requirements,
operating procedures and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or
drainage from raw material storage.

Best Practicable Control Technology Currently Available (BPT)
    A level of technology represented by the average of the best existing wastewater treatment performance
levels within an industrial category or subcategory.

Best Professional Judgment  (BPJ)
    The method used by a permit writer to develop technology-based  limitations on a case-by-case basis
using all reasonably available and relevant data.
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  Glossary of Terms
                                                            Introduction to the National Pretreatment Program
  Slowdown
     The discharge of water with high concentrations of accumulated solids from boilers to prevent plugging
  of the boiler tubes and/or steam lines. In cooling towers, blowdown is discharged to reduce the concentration
  of dissolved salts in the recirculating cooling water.

  Bypass [40 CFR §403.17(a)]
     The intentional diversion of wastestreams from any portion of an Industrial User's treatment facility.

  Categorical Industrial User (CIU)
     An industrial user subject to National categorical pretreatment standards.

  Categorical Pretreatment Standards
     Limitations on pollutant discharges to POTWs promulgated by EPA in accordance with Section 307 of the
  Clean Water Act, that apply to specific process wastewater discharges of particular industrial categories T40
  CFR § 403.6 and 40 CFR Parts 405-471].

  Chain of Custody (COC)
     A record of each person involved in the possession of a sample from the person who collects the sample
 to the person who analyzes the sample in the laboratory.

 Chronic
     A stimulus that lingers or continues for a relatively long period of time, often one-tenth of the life span or
 more.  Chronic should be considered a relative term depending on the  life span of an organism.  The
 measurement of chronic effect can be reduced growth, reduced reproduction, etc., in addition to lethality.

 Clean Water Act (CWA)
     The common name for the Federal Water Pollution Control Act. Public law 92-500; 33  U.S.C. 1251 et
 Sfiflk; legislation which provides statutory authority for both NPDES and Pretreatment Programs.

 Code of Federal Regulations (CFR)
     A codification of Federal rules published annually by the Office of the Federal Register National Archives
 and Records Administration. Title 40 of the CFR contains the regulations for Protection of the Environment

 Combined Sewer Overflow (CSO)
     A discharge of untreated wastewater from a combined sewer system at  a point prior to the headworks of
 a publicly owned treatment works. CSOs generally occur during wet weather (rainfall or snowfall). During
 periods of wet weather, these systems become overloaded, bypass treatment works, and discharge directly
 to receiving waters.

 Combined Wastestream Formula (CWF) [paraphrased from 40 CFR §403.6(e)]
     Procedure for calculating alternative discharge limits at industrial facilities where a regulated wastestream
 from a categorical industrial user is combined with other wastestreams prior to treatment.

 Compliance Schedule
    A schedule of remedial measures included in a permit or an enforcement order, including a sequence of
 interim requirements (for example, actions, operations, or milestone events) that lead to compliance with the
 CWA and regulations.

 Composite Sample
    Sample composed of two or more discrete samples. The aggregate sample will reflect the average water
 quality covering the compositing or sample period.

 Concentration-based Limit
    A limit based upon the relative strength of a pollutant in a wastestream,  usually expressed in mg/l.
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Introduction to the National Pretreatment Program
Continuous Discharge
    A discharge that occurs without interruption during the operating hours of a facility, except for infrequent
shutdowns for maintenance, process changes or similar activities.

Control Authority [paraphrased from 40 CFR § 403. 12(a)]
    A POTW with an approved pretreatment program or the approval authority in the absence of a POTW
pretreatment program.

Conventional Pollutants
    BOD, TSS, fecal coliform, oil and grease, and pH

Daily Maximum Limitations
    The maximum allowable discharge of pollutants during a 24 hour period. Where daily maximum limitations
are expressed in units of mass, the daily discharge is the total mass discharged over the course of the day.
Where daily maximum limitations are expressed in terms of a concentration, the daily discharge is the
arithmetic average measurement of the pollutant concentration derived from all measurements taken that day.'

Detection Limit
    The minimum concentration of an analyte(substance) that can be measured and reported with a 99%
confidence that the analyte concentration is greater than zero as determined by the procedure set forth in 40
CFR Part 136, Appendix B.

Development Document
    Detailed report of studies conducted by the U.S. EPA for the purpose of establishing effluent guidelines
and categorical pretreatment standards.

Dilute Wastestream [paraphrased from 40 CFR §403.6(e)(1)(i)]
    For purposes of the combined wastestream formula, the average daily flow (at least a 30-day average)
from : (a) boiler blowdown  streams, non-contact cooling streams, storm water streams, and demineralized
backwash streams; provided, however, that where such streams contain a significant amount of a pollutant,
and the combination of such streams, prior to treatment, with an industrial  user's regulated process
wastestream(s) will result in a substantial reduction of that pollutant,  the Control Authority, upon application
of the industrial user, may  exercise its discretion to determine whether such stream(s) should  be  classified
as diluted or unregulated. In its application to the Control Authority, the  industrial user must provide
engineering, production, sampling and analysis, and such other information so the control authority can make
its determination; or (b) sanitary wastestreams where such streams are not regulated by a categorical
pretreatment standard; or (c) from any process wastestreams which were, or could  have been, entirely
exempted from categorical pretreatment standards pursuant to paragraph 8 of the NRDC v. Costle Consent
Decree (12 ERG 1 833) for one more of the following reasons (see Appendix D of 40 CFR Part 403):
     a.  the  pollutants of concern are not detectable in the effluent from the industrial user (paragraph
                                                                             .       ,.,  , t
    b.  the pollutants of concern are present only in trace amounts and are neither causing nor likely to cause
        toxic effects (paragraph (8)(a)(iii));
    c.  the pollutants of concern are present in amounts too small to be effectively deduced by technologies
        known to the Administrator (paragraph (8)(a)(iii)); or
    d.  the wastestream contains only pollutants which are compatible with the POTW (paragraph (8)(b)(l)).
 Effluent Limitations Guideline
    Any effluent limitations guidelines issued by EPA pursuant to Section 304(b) of the CWA.  These
 regulations are published to adopt or revise a national standard prescribing restrictions on quantities, rates,
 and concentrations of chemical, physical, biological, and other constituents which are discharged from point
 sources, in specific industrial categories (e.g., metal finishing, metal molding and casting, etc).

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  Qlossaty ofTerms
                                                            Introduction to the National Pretreatment Proa
  Enforcement Response Plan [paraphrased from 40 CFR §403.8(f)(5)]
     Step-by-step enforcement procedures followed by Control Authority staff to identify, document, and
  respond to violations.

  Existing Source
     Any source of discharge, the construction or operation of which commenced prior to the publication by
  the EPA of proposed categorical pretreatment standards, which will be applicable to such source if the
  standard is thereafter promulgated in accordance with Section 307 of the Act.

  Federal Water Pollution Control Act (FWPCA)
     The title of Public law 92-500; 33 U.S.C. 1251 §t se&.also known as the Clean Water Act (CWA) enacted
  October 18,1972.

  Flow Weighted Average Formula (FWA) [paraphrased from 40 CFR §403.6(e)]
     A procedure used to calculate  alternative limits  where wastestreams  regulated by a categorical
  pretreatment standard and nonregulated wastestreams combine after treatment but prior to the monitoring
  point.

  Flow Proportional Composite Sample
     Combination of individual samples proportional to the flow of the wastestream at the time of sampling.

  Fundamentally Different Factors [paraphrased from 40 CFR §403.13]
     Case-by-case variance from categorical pretreatment standards based on the factors considered by EPA
 in developing the applicable category/subcategory being fundamentally different than factors relating to a
 specific industrial user.

 General Prohibitions [40 CFR §403.5(a)(1)J
     No user shall introduce into a POTW any pollutant(s) which cause pass through or interference.

 Grab Sample
    A sample which is taken from a  wastestream on a one-time basis with no regard to the flow  of the
 wastestream and without consideration of time. A single grab sample should be taken over a period of time
 not to exceed  15 minutes.

 Indirect Discharge or Discharge [40 CFR §4Q3.3(g)]
    The introduction of pollutants into a POTW from any non-domestic source regulated under section 307(b)
 (c), or (d) of the Act.

 Industrial User (IU) or User [40 CFR §403.3(h)]
    A source of indirect discharge.

 Industrial Waste Survey
    The process of identifying and locating industrial users and characterizing their industrial discharge.

 Inhibition Concentration
    Estimate of the toxicant concentration that would cause a given percent  reduction .(e.g., IC25) in a
 nonlethal biological measurement of the test organisms, such as reproduction or growth.

 interference [paraphrased from 40 CFR §403.3(i)]
    A discharge which, alone or in conjunction with a discharge or discharges from other sources, both: (1)
 inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal;
 and (2) therefore is a cause of a violation of any requirement of the POTW's NPDES permit (including an
 Increase in the magnitude or duration of a violation) or of the prevention of sewage sludge use or disposal in
 compliance with ... [applicable] statutory provisions and regulations or permits issued thereunder (or more
stringent State or local regulations)...
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Introduction to the National Pretreatment Program
Glossary of Terms
Local Limits [paraphrased 40 CFR § 403.5(c)]
    Specific discharge limits developed and enforced by POTWs upon industrial or commercial facilities to
implement the general and specific discharge prohibitions listed in 40 CFR §§403.5(a)(1) and (b).

Monthly Average
    The  arithmetic average value of all samples taken  in a  calendar month for an  individual pollutant
parameter. The monthly average may be the average of all grab samples taken in a given calendar month,
or the average of all composite samples taken in a given calendar month.

National Pollutant Discharge Elimination System (NPDES)
    The national program for issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing
discharge permits from point sources to waters of the United States, and imposing and enforcing pretreatment
requirements, under sections 307,402, 318, and 405 of the CWA.

National Pretreatment Standard or Pretreatment Standard or Standard  [40 CFR §403.3(j)]
    Any regulation containing pollutant discharge limits promulgated by the EPA in accordance with section
307(b) and (c) of the Act, which applies to  Industrial Users. This term includes prohibitive discharge limits
established pursuant to  §403.5.

New Source  [40 CFR §403.3(k)]
    Any building,  structure, facility or installation from which there is or may be a discharge of pollutants, the
construction of which  commenced after the publication of proposed Pretreatment Standards under section
307(c) of the Act which will be applicable to such source if such standards are thereafter promulgated in
accordance with that section provided that:

    (a) The building,  structure, facility  or installation is constructed at a  site at which no other discharge
        source is located; or

    (b) The building, structure, facility or installation totally replaces the process or production equipment that
        causes the discharge of pollutants at an existing source;  or

    (c) The production  or wastewater generating processes of the building, structure, facility, or installation
        are substantially independent of an existing source at the same site.  In determining whether these
        are substantially independent, factors such as the extent to which the new facility is integrated with
        the existing plant, and the extent to which the new facility is engaged in the same general type of
        activity as the existing source, should be considered.

Construction on a site at which an existing source is located results in a modification rather than a new source
if the construction does not create a new  building, structure, facility, or installation meeting the criteria of
paragraphs (k)(1 )(ii), or  (k)(1 )(iii) of this section but otherwise alters, replaces, or adds to existing process or
production equipment.

Construction of a new source, as defined under this paragraph has commenced if the owner or operator has:

    (i)  Begun, or caused to begin as part of a continuous onsite construction program:

        (A) Any placement, assembly, or installation of facilities or equipment; or

        (B) Significant site preparation work including clearing, excavation, or removal of existing buildings,
            structures,  or facilities which is necessary for the placement, assembly, or installation of new
            source facilities or equipment, or

        (C) Entered into a binding contractual obligation for the purchase of facilities or equipment which are
            intended  to be used in its operation within a reasonable time.  Options to purchase or contracts

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            which can be terminated or modified without substantial  loss,  and contracts for feasibility,
            engineering, and design studies do not constitute a contractual obligation under this paragraph.

 90-Day Final Compliance Report  [40 CFR §403.12(d)]
     A report submitted by categorical industrial users within 90 days following the date for final compliance
 with the standards. This report must contain flow measurement (of regulated process streams and other
 streams), measurement of pollutants, and a certification as to whether the categorical standards are being
 met.

 Nonconventional Pollutants
     Any pollutant that is neither a toxic pollutant nor a conventional pollutant (e.g., manganese, ammonia, etc.)

 Non-Contact Cooling Water
     Water used for cooling which does  not come into direct contact with any raw material, intermediate
 product, waste product, or finished product. The only pollutant contributed from the discharge is heat.

 Non-Regulated Wastestream
     Unregulated and dilute wastestreams (not regulated by categorical standards).

 Pass Through [40 CFR §403.3(n)]
     A discharge which exits the POTW into waters of the United States in  quantities or concentrations which,
 alone or in conjunction with a discharge or discharges from other sources, is a cause of a violation of any
 requirement of the POTW's NPDES permit (including an increase in the magnitude or duration of a violation).

 Periodic Compliance Report [paraphrased from 40 CFR §403.12(e) & (h)]
     A report on compliance status submitted by categorical industrial users and significant noncategorical
 industrial users to the control authority at least semiannually (once every six months).

 Point Source [40 CFR 122.2]
     Any discernible, confined, and discrete conveyance, including but not limited to any pipe, ditch, channel,
 tunnel, conduit, well, discrete fixture, container, rolling stock concentrated animal feeding  operation vessel,
 or other floating craft from which pollutants are or may be discharged.

 Pollutant [40 CFR 122.2]
     Dredged spoil, solid waste, incinerator residue, filter  backwash, sewage, garbage, sewage sludge,
 munitions, chemical wastes, biological materials,  radioactive materials (except those regulated under the
 Atomic Energy Act of 1954, as amended  (42 U.S.C. 2011 et seq.)), heat, wrecked or discarded equipment,
 rock, sand, cellar dirt, and industrial, municipal and agricultural waste discharged into water.

 Pretreatment [paraphrased from  40 CFR §403.3(q)]
    The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of
 pollutant properties in wastewater prior to or in lieu of discharging or otherwise introducing such pollutants into
 a POTW.

 Pretreatment Requirements [40 CFR §403.3(r)]
    Any substantive or procedural  requirement related to Pretreatment, other than a National Pretreatment
 Standard, imposed on an Industrial User.

 Pretreatment Standards for Existing Sources (PSES)
    Categorical Standards and requirements applicable to industrial sources that began construction prior to
 the publication of the proposed pretreatment standards for that industrial category.(see individual standards
 at 40 CFR Parts 405-471.)
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Introduction to the National Prs treatment Program
Gtossary of Terms
Pretreatment Standards for New Sources (PSNS)
    Categorical Standards and requirements applicable to industrial sources that began construction after the
publication of the proposed pretreatment standards for that industrial category, (see individual standards at
40 CFR Parts 405-471.)

Priority Pollutant
    Pollutant listed by the Administrator of EPA under Clean Water Act section 307(a). The list of the current
126 Priority Pollutants can be found in 40 CFR Part 423 Appendix A.

Process Wastewater
    Any water which, during manufacturing or processing, comes into contact with  or results from the
production or use of any raw material, intermediate product, finished product, byproduct, or waste product.

Production-Based Standards
    A discharge standard expressed  in terms of pollutant mass allowed in a discharge per unit of product
manufactured.

Publicly Owned Treatment Works (POTW) [40 CFR §403.3(o)]
    A treatment works as defined by section 212 of the Act, which is owned by a State or municipality (as
defined by section 502(4) of the Act). This definition includes any devices or systems used in the storage,
treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature. It also
includes sewers, pipes or other conveyances only if they convey wastewater to a POTW Treatment Plant.
The term also means the municipality as defined in section 502(4) of the Act, which has jurisdiction over the
Indirect Discharges to and the discharges from such a treatment works.

Regulated Wastestream
    For purposes of applying the combined wastestream formula, a wastestream from an industrial process
that is regulated by a categorical standard.

Removal  Credit [paraphrased from 40 CFR §403.7]
    Variance from a pollutant limit specified in a categorical pretreatment standard to reflect removal by the
POTW of said pollutant.

Representative Sample
    A sample from a wastestream that is as nearly identical as possible in composition to that in the larger
volume of wastewater being discharged and typical of the discharge from the facility on a normal operating
day.

Sanitary Sewer Overflow (SSO)
    Untreated or partially treated sewage overflows from a sanitary sewer collection system.

Self-Monitoring
    Sampling and analyses performed by a facility to ensure compliance with a permit or other regulatory
requirements.

Sewer Use Ordinance (SUO)
    A  legal mechanism implemented by  a local government  entity which  sets  out, among others,
requirements for the discharge of  pollutants into a publicly owned treatment works.

Significant Industrial User (SIU) [paraphrased from 40 CFR §403.3(t)]
    (1) All users subject to Categorical Pretreatment Standards under 40 CFR  403.6 and 40 CFR chapter
I, subchapter N; and (2) Any other industrial user that: discharges an average of 25,000 gallons per day or
more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown
wastewater); contributes a process wastestream which makes up 5 percent or more of the average dry
weather hydraulic or organic capacity of the POTW treatment plant; or is designated as such by the Control
                                                                                          -xiii-

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                                                            Introduction to the National Pretreatment Program
 Authority as defined in 40 CFR 403.12(a) on the basis that the industrial user has a reasonable potential for
 adversely affecting the POTW's operation or for violating any pretreatment standard or requirement (in
 accordance with 40 CFR 403.8(f)(6)].

 Significant Noncompliance (SNC)  [40 CFR §403.8(f)(2)(vii)]
     Industrial user violations meeting one or more of the following criteria:
     1)  Chronic violations of wastewater discharge limits, defined here as those in which sixty-six percent
     or more of all of the measurements taken during a six month period exceed (by any magnitude) the
     daily maximum limit or the average limit for the same pollutant parameter;
     2)  Technical Review Criteria (TRC) violations, defined here as those in which thirty-three percent
     or more of all of the measurements for each pollutants parameter taken during a six-month period
     equal or exceed the  product of the daily maximum  limit or the average  limit multiplied  by the
     applicable TRC (TRC=1.4 for BOD, TSS, fats, oil, and grease, and 1.2 for all other pollutants except
     PH);
     3)  Any other violation of a pretreatment effluent limit (daily maximum or longer-term average) that
     the  Control Authority determines has caused, alone or in  combination with other dischargers,
     interference or pass through (including endangering the health of POTW personnel or the general
     public);
     4)  Any discharge of a pollutant that has caused imminent endangerment to human health, welfare
     or to the environment or has resulted in the POTW's exercise  of its emergency authority under
     paragraph (f)(1 ){vi)(B) of this section to halt or prevent such a discharge;
     5)  Failure  to meet, within 90 days after the schedule date, a compliance schedule  milestone
     contained in a local control mechanism or enforcement order for starting construction, completing
     construction, or attaining final compliance;
     6)  Failure to provide, within 30 days after the due date, required reports such as baseline monitoring
     reports, 90-day compliance reports, periodic self-monitoring reports, and reports on compliance with
     compliance schedules;
     7)  Failure to accurately report noncompliance;
     8) Any other violation or group of violations which the Control Authority determines will  adversely
     affect the operation or implementation of the local pretreatment program.

 Slug Discharge [40 CFR §403.8(f)(2)(v)]
     Any discharge  of a non-routine,  episodic nature,  including but not limited to, an accidental spill or a
 noncustomary batch discharge.

 Specific Prohibitions [40 CFR §403.5(b)]
     The following pollutants shall not be introduced into a POTW:
     1)  Pollutants which create a fire or explosion hazard in the POTW, including but not limited to,
    wastestreams with a closed cup flashpoint  of less than 140 degrees  Fahrenheit or 60 degrees
     Centigrade using the test methods specified in 40 CFR Part 261.21;
    2)  Pollutants which will cause corrosive structural damage to the  POTW, but in no case discharges
    with pH lower than 5.0, unless the works is specifically designed to accommodate such discharges;
    3)  Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
    resulting in interference;
    4)  Any pollutant, including oxygen demanding pollutants(BOD, etc.) Released in a discharge at a
    flow rate and/or concentration which will cause interference with the POTW;
    5)  Heat in amounts which will inhibit biological activity in the POTW resulting in interference, but in
    no case heat in such quantities that  the temperature at the POTW treatment plant exceeds
    40°C(104°F) unless the Approval Authority, upon request of the POTW, approves alternative
    temperature limits;
    6)  Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
    cause Interference or pass through;
    7)  Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a
    quantity that may cause acute worker health and safety problems;
    8) Any trucked or hauled pollutants,  except at discharge points designated by the POTW.
-xlv-

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Introduction to the National Pretreatment Program
Glossary of Terms
Standard Industrial Classification (SIC)
    A system developed by the U.S. Office of Management and Budget that is used to classify various types
of business entities.  Effective in 1998, the SIC scheme is replace by the North American Industry
Classification System (NAICS), although EPA has not yet implemented this change.

Storm Water
    Rain water, snow melt, and surface runoff and drainage.

Time Proportional Composite Sample
    A sample consisting of a series of aliquots collected from a representative point in the discharge stream
at equal time intervals over the entire discharge period on the sampling day.

Toxic Pollutant
    Any pollutant listed as toxic under section 307(a)(1) of the CWA, or in the case of sludge use or disposal
practices, any pollutant identified in regulations implementing section 405(d) of the CWA.

Toxicity Reduction Evaluation
    A site-specific study conducted in a stepwise process  designed to identify the causative agent(s) of
effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and then
confirm the reduction in effluent toxicity.

Toxicity Test
    A procedure to determine the toxicity of a chemical or an effluent using living organisms. A toxicity test
measures the degree of effect on exposed test organisms of a specific chemical or effluent.

Toxicity Identification Evaluation
    Set of procedures to identify the specific chemicals responsible for effluent toxicity.

Unregulated Wastestream
    For purposes  of applying  the combined wastestream formula, a wastestream not regulated by a
categorical standard nor considered a dilute wastestream.

Upset [paraphrased from 40 CFR §403.16(a)]
    An exceptional incident in which there is unintentional and temporary noncompliance with categorical
Pretreatment Standards because of factors beyond the reasonable control of the Industrial User.  An Upset
does not include noncompliance to the extent caused by operational error, improperly designed  treatment
facilities, inadequate treatment facilities, lack of preventative maintenance, or careless or improper operation.

Water Quality Criteria
    Comprised  of both numeric and narrative criteria.  Numeric criteria are scientifically derived ambient
concentrations developed  by EPA or States for various pollutants of concern to protect human health and
aquatic life.  Narrative criteria are statements that describe the desired water quality goal.

Water Quality Standard
    A statute or regulation that consists of the beneficial designated use or uses of a waterbody, the numeric
and narrative water quality criteria that are necessary to protect the use or uses of that particular waterbody,
and an antidegradation statement.

Whole Effluent Toxicity
    The total toxic effect of an effluent measured directly with a toxicity test.
                                                                                             -XV-

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 6tossa>yofTem7s
Introduction to the National Pretreatment Propram
-xvi-

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 Introduction to the National Pretreatment Program
                                                     POTWs and the Need for the Pretreatment Program
1.       POTWs   AND   THE    NEED    FOR   THE
          PRETREATMENT  PROGRAM
                                          Chapter 1. Applicable EPA References
                               Environmental Regulations and Technology; The National Pretreatment Program
                               National Pretreatment Program: Report to Congress
                               Report to Congress on the Discharge of Hazardous Wastes to POTWs
   The average American uses
roughly 100 to 200 gallons of
water a day, with less than one
percent of that water  actually
being consumed.2  The rest is
used  for  activities  such  as
washing, preparing food, watering
lawns, heating and cooling, transporting wastes, and fire protection. The public is very conscious about the
quality of water that comes out of theirtap each day, quickly notifying authorities of changes in appearance, odor,
and taste. These same Americans, on average, discharge about the same amount of wastewater to local sewage
treatment plants daily.3  This wastewater (commonly referred to as "domestic sewage") receives much less
attention than drinking water, likely the result of an "out of sight, out of mind" attitude.

   Most people take it for granted that once down the drain, wastes will be handled appropriately. In fact, this
attitude has carried over to industry as well, as can be seen by reading the labels of many household products.
These labels often recommend that waste or excess product be disposed of down the drain.  Other toxic or
hazardous products are actually designed to be disposed of down the drain (e.g., drain clog remover). Recall
the phosphate detergent problems of the late 1960s and early 70s; large doses of phosphate, found in most
detergents at the time, were passing through municipal treatment plants and  overloading lakes, causing large
algal blooms to form and subsequently reducing available light, food  and oxygen for fish and other aquatic
organisms. While great  strides have been taken to address the phosphate  problem, it is  possible that other
problematic pollutants are being dumped down the drain at the expense of human health and the environment.

SEWAGE TREATMENT

   Publicly owned treatment works (POTWs) collect wastewater from homes, commercial buildings, and
industrial facilities and transport it via a series 'of pipes, known as a collection system, to the treatment plant.
Collection systems may flow entirely by gravity, or may include lift stations that pump the wastewater via a force
main to a higher elevation where the wastewater can then continue on via gravity. Ultimately, the collection
system delivers this sewage to the treatment plant facility. Here, the POTW removes harmful organisms and
other contaminants from the sewage so it can be discharged safely into the receiving stream. Without treatment,
sewage creates bad odors, contaminates water supplies, and spreads  disease.  Today, more than 16,000
sewage treatment plants exist in the U.S. treating more than 32 billion gallons per day of wastewater.4

   Generally, POTWs are designed to treat domestic sewage only. Simply defined, the typical POTW treatment
process consists of primary and secondary treatment, along with some form of solids handling. Primary treatment
is designed to remove large solids (e.g., rags and debris) and smaller inorganic grit. Typical primary treatment
operations  include  screening and settling.  Secondary treatment removes organic contaminants using
microorganisms to consume biodegradable organics. Activated sludge, trickling filters, and rotating biological
contactors are examples of common secondary treatment operations.  Depending on effluent discharge
              The Nalco Water Handbook, ed. Frank N. Kemmer (New York: McGraw-Hill Book Company,
              1988), pp. 35.1.

              Ibid, p. 36.1.

              1996 Clean Water Needs Survey Report to Congress: Assessment of Needs for Publicly
              Owned Wastewater Treatment Facilities, Correction of Combined Sewer Overflows, and
              Management of Stormwater and Nonpoint Source Pollution in the United States.
 Chapter 1
                                                                                       -1-

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   POTWs and tha Need for the Pretreatment Program
             Introduction to the National Pretreatment Program
 requirements, POTWs may perform other "advanced treatment" operations such as nitrification (to convert
 ammonia and nitrite to the less toxic nitrate), denitrification (to convert nitrate to molecular nitrogen), physical-
 chemical treatment (to remove dissolved metals and organics), and disinfection (to kill any remaining pathogens).
 After treatment is complete, effluent is discharged to the receiving stream, typically a creek, river, lake, estuary
 or ocean.  Some POTWs may apply treated effluent directly to golf courses, parkland, or croplands.

     Both primary and secondary treatment processes generate waste  solids, known as sewage sludge or
 faiosolids.  Sludges from the treatment process may be either used productively (i.e., as  fertilizer or soil
 conditioner) or disposed of in a landfill or incinerated in a dedicated sewage sludge incinerator with the ash also
 disposed of in a landfill.
    As described abqve, POTWs are designed to treat typical household
 wastes and biodegradable commercial and biodegradable  industrial
 wastes. The Clean Water Act (CWA) and EPA define the contaminants
 from these sources as conventional pollutants. Conventional pollutants
 are Identified in Figure 1 and include those specific pollutants that are
 expected to be present in domestic discharges to POTWs. Commercial
 and Industrial facilities may, however, discharge toxic pollutants that the
 treatment plant is neither designed for nor able to remove.

 NEED FOR THE PRETREATMENT PROGRAM
                   Biochemical Oxygen Demand (BOD)
                   Total Suspended Solids
                   Fecal Coliform
                   PH
                   Oil and Grease (O&G)
                 Figure 1. Conventional Pollutants
    As noted above, POTWs are not designed to treat toxics in industrial waste. As such, these discharges, from
 both  Industrial and commercial sources, can cause serious problems.  The undesirable outcome of these
 discharges can be prevented using treatment techniques or management practices to reduce or eliminate the
 discharge of these contaminants.  The act of treating wastewater prior to discharge to a POTW is commonly
 referred to as "pretreatment."  The National Pretreatment Program, published  in Title 40 Code of Federal
 Regulations (CFR) Part 403, provides the regulatory basis to require non-domestic dischargers to comply with
 pretreatment standards (effluent limitations) to ensure that the goals of the CWA are attained.  As noted in 40
 CFR §403.2, the objectives of the National Pretreatment Program are to:

    a.  Prevent the introduction of pollutants into POTWs which will interfere with the operation of a POTW,
        including interference with its use or disposal of municipal sludge;

    b.  Prevent the introduction of pollutants into POTWs which will pass through the treatment works or
        otherwise be incompatible with such works; and
    c.  Improve opportunities to recycle and
        reclaim  municipal  and  industrial
        wastewaters and sludges.

The two key terms used in EPA's objectives for the
National Pretreatment Program, "interference" and
"pass through," are defined in Figure 2.

    As outlined in EPA's objectives, toxic pollutants
may pass through the treatment plant  into the
receiving stream, posing serious threats to aquatic
life, to human recreation, and to consumption offish
and shellfish from these waters. Pass through can
make waters unswimmable or unfishable in direct
contrast to the goals of the CWA.   Or, these
discharges can interfere with the biological activity
Interference - a discharge which, alone or in conjunction with
a discharge or discharges from other sources, both:

        Inhibits or disrupts the POTW, its treatment
        processes or operations, or its sludge processes, use
        or disposal, and

        therefore is a cause of a violation of any NPDES
        permit requirement or of the prevention of sewage
        sludge use or disposal in compliance with any
        applicable requirements.

Pass Through - a discharge which exits the POTW into waters
of the U.S. in quantities or concentrations which, alone or in
conjunction with a discharge or discharges from other sources,
is a cause of a violation of any NPDES permit requirement.
                                                Figure 3. Interference and Pass Through
-2-
                                                                                           Chapter 1

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                                                            POTWs and the Need for the Pretreatment Program
of the treatment plant causing sewage to pass through the treatment plant untreated or inadequately treated.

    Even where the POTW has the capability to remove these toxics, the pollutants may end up in the sewage
sludge thereby limiting sludge disposal options or escalating the cost of disposal.  Incinerated contaminated
sludge may release toxic emissions into the atmosphere. Toxic metals removed in primary treatment, while itself
not an inhibitory process, can impact sludge digestion, a  process that does utilize bacteria to stabilize sludge
solids. For example, chromium can inhibit reproduction of aerobic digestion micrQorganisms, thereby disrupting
sludge treatment and producing sludges  that must be disposed of with special treatment.  Uncontaminated
sludge, on the other hand, can be used as fertilizer or soil  conditioner, thereby improving the productivity of our
land.  Many municipalities apply sewage sludge to pastureland or parkland, that they could not do if the sludge
were contaminated.

    Volatile organics discharged to sewers can accumulate in the head space of sewers, increasing the likelihood
of explosions that can cause significant damage. Probably  the most well known impact from industrial discharges
to POTWs in the U.S. is the explosion in Louisville, KY that occurred in 1981 as the result of excessive discharges
of hexane into the collection system, eventually igniting and destroying more than 3 miles of sewers and causing
$20 million in damage.  Discharge limitations and management practices to control slug  discharges have
significantly reduced the likelihood of future catastrophes  such as the explosion in Louisville.

    Discharges of  toxic organics can also  result in the release of poisonous gas. This occurs most often when
acidic wastes react with other wastes in the discharge. For example, cyanide and acid, both present in many
electroplating operations, react to form highly toxic hydrogen cyanide gas. Similarly, sulfidesfrom leather tanning
can combine with acid to form hydrogen sulfide, another  toxic gas. These can be highly dangerous to POTW
collection system  operators exposed to such conditions in the performance of their duties.  Other problems
associated with toxic discharges are summarized in Figure 3 and further document the urgency of keeping toxics
out of collection systems and POTWs.
    The National Pretreatment Program is charged with
 controlling the 126 Priority Pollutants from industries that
 discharge into sewer systems as described in the CWA
 (see Figure 4). These pollutants fall into two categories;
 metals and organics:

     »•    Metals, including lead, mercury, chromium, and
         cadmium cannot be destroyed or broken down
         through treatment or environmental degradation.
         Toxic metals can cause different human health
         problems such as lead poisoning and cancer.
         Additionally, consumption  of  contaminated
         seafood and agricultural food crops has resulted
         in  exposures exceeding  recommended safe
         levels.
   - air pollution can occur from volatilization of toxic
     chemicals in the POTW collection system or treatment
     plant, or through incineration of sewage sludge

   - corrosion of collection system and treatment plant from
     acidic discharges or discharges containing elevated
     levels of sulfate (forming toxic and corrosive hydrogen
     sulfide)

   - groundwater pollution can occur from leaks in the
     collection system or pollutants from contaminated
     sewage sludge.
Figure 3. Problems Associated With Toxic Discharges
     ••   Toxic organics, including solvents, pesticides, dioxins, and polychlorinated biphenyls (PCBs) can be
         cancer-causing and lead to other serious ailments, such as kidney and liver damage, anemia, and heart
         failure. In 1996, EPA's Office of Science and Technology (OST) identified 2,193 waterbodies with fish
         and wildlife advisories, up more than 25 percent from 1995.5

     Reductions in pollutants can ensure that  industrial development vital to the economic well-being of a
 community  is compatible with a healthy environment.  As will be noted in Chapter 2, many POTWs are
 responsible for ensuring that industrial and commercial facilities do not cause problems resulting from their
 discharges   In 1991, EPA estimated that 190 to 204 million pounds of metals and 30 to 108 million pounds of
                  EPA Office of Science and Technology, Listing of Fish and Wildlife Advisories (LFWA)
                  database, 1998.
   Chapter 1

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  POTWs and tha Need for the Pretreatment Program
organics were removed each year as a result of pretreatment program requirements.6  This is substantiated by
many POTWs that report significant reductions in the loadings of toxics to their treatment plants that is directly
attributable to implementation of the National Pretreatment Program
   Figure 5.  Priority Pollutants
     001 Accnaphthene
     002 Acrolein
     003 Acrylonitrile
     004 Benzene
     005 Benzidine
     006 Carbon tetrachloride
     007 Chlorobenzenc
     008 1,2,4-trichlorobenzene
     009 Hexachlorobenzene
     010 1,2-dichloroethane
     Oil 1,1,1-trichloreothane
     012 Hexachloroethane
     013 1,1-dichloroethane
     014 1,1,2-trichloroethane
    015 1,1,2,2-tetrachloroethane
    016Chloroethane
    018 Bis(2-chloroethyl) ether
    019 2-chloroethyl vinyl ethers
    020 2-chloronaphthalene
    021 2,4,6-trichlorophenol
    022 Parachlorometa cresol
    023 Chloroform
    024 2-chlorophenol
    025 1,2-dichlorobenzene
    026 1,3-dichlorobenzene
    027 1,4-dichlorobenzene
    028 3,3-dichlorobenzidine
    029 1,1-dichloroethylene
    030 1,2-trans-dichloroethylene
    031 2,4-dichlorophenol
    032 l,2-dichloropropane
    033 1,2-dichloropropylene
    034 2,4-dimelhyIphenol
    035 2,4-dinitrotoIuene
    036 2,6-dinitrotoluene
   037 1,2-diphenylhydrazine
   038 Ethylbenzene
   039 Fluoranthene
   040 4-chIorophenyI phenyl ether
   041 4-bromophenyl phenyl ether
   042 Bis(2-chloroisopropyl) ether
   043 Bis(2-chloroethoxy)  methane
  044 Methylene chloride
  045 Methyl chloride
  046 Methyl bromide
  047 Bromoform
  048 Dichlorobromomethane
  051 Chlorodibromomethane
  052 Hexachlorobutadiene
  053 Hexachlorocyclopentadiene
  054 Isophorone
  055 Naphthalene
  056 Nitrobenzene
  057 2-nitrophenol
  058 4-nitrophenol
  059 2,4-dinitrophenol
  060 4,6-dinitro-o-cresol
  061 N-nitrosodimethylamine
  062 N-nitrosodiphenylamine
  063 N-nitrosodi-n-propylamine
  064 Pentachlorophenol
 065 Phenol
 066 Bis(2-ethylhexyl) phthalate
 067 Butyl benzyl phthalate
 068 Di-N-Butyl Phthalate
 069 Di-n-octyl phthalate
 070 Diethyl  Phthalate
 071 Dimethyl phthalate
 072 benzo(a) anthracene
 073 Benzo(a)pyrene
 074 Benzo(b) fluoranthene
 075 Benzo(b) fluoranthene
 076 Chrysene
 077 Acenaphthylene
 078 Anthracene
 079 Benzo(ghi) perylene
 080 Fluorene
 081 Phenanthrene
 082 Dibenzo(,h) anthracene
 083 Indeno (1,2,3-cd) pyrene
 084 Pyrene
085 Tetrachloroethylene
086 Toluene
087 Trichloroethylene
  088 Vinyl chloride
  089 Aldrin
  090 Dieldrin
  091 Chiordane
  092 4,4-DDT
  093 4,4-DDE
  094 4,4-DDD
  095 Alpha-endosulfan
  096 Beta-endosulfan
  097 Endosulfan sulfate
  098 Endrin
  099 Endrin aldehyde
  lOOHeptachlor
  101 Heptachlor epoxide
  102Alpha-BHC
  103 Beta-BHC
  104Gamma-BHC  ,
  105Delta-BHC
 106PCB-1242
 107PCB-1254
 108PCB-1221
 109 PCB-1232
 110PCB-1248
 111 PCB-1260
 112PCB-1016
 113 Toxaphene
 114 Antimony
 115 Arsenic
 116 Asbestos
 117 Beryllium
 118 Cadmium
 119 Chromium
 120 Copper
 121 Cyanide, Total
 122 Lead
 123 Mercury
 124 Nickel
 125 Selenium
126 Silver
127 Thallium
128 Zinc
1292,3,7,8-TCDD
                U.S. Environmental Protection Agency, National Pretreatment Program: Report to Congress,
                1991 •
                                                                                                    Chapter 1

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2.   OVERVIEW      OF       THE       NATIONAL
       PRETREATMENT PROGRAM
                                              Chapter 2. Applicable EPA Guidance
                                    Control Authority PretreatmentAudit Checklist and Instructions
                                    Guidance for Conducting a Pretreatment Compliance Inspection
                                    Guidance for Reporting and Evaluating POTW Noncompliance with
                                       Pretreatment Implementation Requirements
                                    Guidance Manual for POTW Pretreatment Program Development -
                                    Pretreatment Compliance Inspection and Audit Manual For Approval
                                       Authorities
                                    Procedures Manual for Reviewing a POTW Pretreatment Program
                                       Submission
THE CLEAN WATER ACT

    On October 18,1972, the 92nd
Congress  of  the  United  States
passed the Federal Water Pollution
Control Act Amendments of 1972,
declaring  the  restoration  and
maintenance  of  the  chemical,
physical, and biological  integrity of
the Nation's water as  a National
objective (see Figure 5).   While
procedures for implementing this act
(more commonly referred to as the Clean Water Act (CWA)) have been re-evaluated and modified over time,
the 1972 objective has remained unchanged in its 25 year history.

    The 1972 Amendments to the CWA established a water quality regulatory approach along with EPA-
promulgated industry-specific technology-based  effluent limitations.  The  National Pollutant Discharge
Elimination System (NPDES) permit program was established under the CWA to control the discharge of
pollutants from point sources and served as a vehicle to implement the industrial technology-based standards.
To implement pretreatment requirements, EPA promulgated 40 CFR Part 128 in late 1973, establishing
general  prohibitions  against
treatment  plant  interference and
pass through and  pretreatment
standards for the discharge  of
incompatible pollutants from specific
industrial categories.
    In 1975, several environmental
 groups  filed  suit against  EPA
 challenging  EPA's  criteria  for
 identifying  toxic  pollutants,  EPA's
 failure  to  promulgate  effluent
 standards, and  EPA's failure to
 promulgate pretreatment standards
 for numerous industrial categories.
 As a result of this litigation, EPA
 promulgated   the  General
 Pretreatment  Regulations  at 40
 CFR Part 403 on June 26, 1978,
 replacing  the 40 CFR  Part  128
 requirements.  Additionally, as  a
 result of the suit, EPA agreed to
 regulate  the discharge   of  65
 categories of pollutants (making up
 the 126 priority pollutants presented
 in  Figure  4) from  21  industrial
                                  To restore and maintain the chemical, physical, and biological integrity of the
                                  Nation's waters:
(1)     it is the national goal that the discharge of pollutants into the
       navigable waters be eliminated by 1985;
(2)     it is the national goal that wherever attainable, an interim goal of
       water quality which provides for the protection and propagation of
       fish, shellfish, and wildlife and provides for recreation in and on the
       water be achieved by July 1,1983;
(3)     it is the national policy that the discharge of toxic pollutants in toxic
       amounts be prohibited;
(4)     it is the national policy that Federal financial assistance be provided
       to construct publicly owned waste treatment works;
(5)     it is the national policy that Area wide waste treatment management
       planning processes be developed and implemented to assure adequate
       control of sources of pollutants in each State;
(6)     it is the national policy that a major research and demonstration effort
       be made to develop technology necessary to eliminate the discharge
       of pollutants into the navigable waters, waters of the contiguous
       zone, and the oceans; and
(7)     it is the national policy that programs for the control of nonpoint
       sources of pollution be developed and implemented in an expeditious
       manner so as to enable the goals of this Chapter to be met through the
       control of both point and nonpoint sources of pollution.
                                 Figure 6. Section 101 of the Clean Water Act (CWA)
 categories.   The list of priority
 pollutants is still in effect today (the original list actually had 129 pollutants, three of which have since been
 Chapter 2
                                                                                           -5-

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 removed from that list) while the list of regulated industrial categories has grown to more than 51 distinct
 industries. A discussion of industry specific requirements are provided in Chapter 3.

 THE GENERAL PRETREATMENT REGULATIONS

     The General Pretreatment Regulations establish responsibilities of Federal, State, and local government
 Industry and the public to implement Pretreatment Standards to control pollutants which pass through or
 interfere with POTW treatment processes or which may contaminate sewage sludge. The regulations which
 have been revised numerous times since originally published in 1978, consist of 18 sections and several
 appendices. A copy of the overall framework for the General Pretreatment Regulations is provided in Figure
 6.
     The    General   Pretreatment
 Regulations apply to all nondomestic
 sources which introduce pollutants into
 a POTW.  These sources of "indirect
 discharge" are more commonly referred
 to as industrial users (IDs).  Since lUs
 can be as simple as an unmanned coin
 operated  car wash to as complex as an
 automobile manufacturing  plant or a
 synthetic  organic chemical producer,
 EPA developed four criteria that define
 a Significant  Industrial  User  (SIU).
 Many  of the General  Pretreatment
 Regulations apply to SlUs  as opposed
 to lUs, based on the fact that control of
 SIUs  should   provide   adequate
 protection of the POTW.

These four criteria are as follows:

    »•  an IU that  discharges an
       average of 25,000  gallons
       per day or more of process
       wastewaterto the POTW;

    »  an IU that contributes  a
       process  wastestream
       making up  5  percent or
       more  of the average dry
       weather   hydraulic  or
       organic  capacity  of the
       POTW treatment plant;

   >   an IU designated  by the
       Control Authority as such
       because of its reasonable
       potential to adversely affect
       the POTW's operation or
       violate  any  pretreatment
       standard or requirement; or

   »•   an IU subject to Federal categorical pretreatment standards.
   §403.1
   § 403.2
   § 403.3
   § 403.4
   § 403.5
   § 403.6

   § 403.7
   § 403.8

   § 403.9

   §403.10

   §403.11

   §403.12
   §403.13

  §403.14
  §403.15
  §403.16
  §403.17
  §403.18
 Purpose and applicability
 Objectives of general pretreatment regulations
 Definitions
 State or local law
 National pretreatment standards: Prohibited discharges
 National pretreatment standards: Categorical pretreatment
 standards
 Removal credits
 Pretreatment program requirements: Development and
 implementation by POTW
 POTW pretreatment programs and/or authorization to revise
 pretreatment standards: Submission for approval
 Development and submission of NPDES State pretreatment
 programs
 Approval procedures for POTW pretreatment programs and
 POTW granting of removal credits
 Reporting requirements for POTW's and industrial users
 Variances from categorical pretreatment standards for
 fundamentally different factors
 Confidentiality
Net/Gross calculation
Upset provision
Bypass
Modification of POTW pretreatment programs
  Appendix A:
  Appendix B:
  Appendix C:
  Appendix D:

  Appendix E:
  Appendix F:
  Appendix G:
    Program Guidance Memorandum
    [Reserved]
    [Reserved]
    Selected Industrial Subcategories Considered Dilute for
    Purposes of the Combined Wastestream Formula
    Sampling Procedures
    [Reserved]
    Pollutants Eligible for a Removal Credit
Figure 6.  The General Pretreatment Regulations
                                                                                           Chapter 2

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Introduction to the National Pretreatment Program
    Unlike other environmental programs that rely on Federal or State governments to implement and enforce
specific requirements, the  Pretreatment Program  places  the majority of the responsibility on  local
municipalities. Specifically, section 403.8(a) of the General Pretreatment Regulations states that any POTW
(or combination of treatment plants operated by the same authority) with a total design flow greater than 5
million gallons per day (MGD) and smaller POTWs with SlUs must establish a local pretreatment program.
As of early 1998,1,578 POTWs are required to have local programs. While this represents only about 15
percent of the total treatment plants nationwide, these POTWs account for more than 80 percent  (i.e.,
approximately 30 billion gallons a day) of the national wastewater flow.

    The General Pretreatment Regulations define the term "Control Authority" as a POTW that administers
an approved pretreatment program since it is the entity authorized to control discharges to its system. Section
403.10(e) provides States authority to implement POTW pretreatment programs in lieu of POTWs.  Five
States have elected to  assume  this responsibility (Vermont,  Connecticut, Alabama, Mississippi, and
Nebraska). In these instances, the State is defined as  the Control Authority.

    As described  above, all Control Authorities must establish a local pretreatment program to control
discharges from non-domestic sources.  These programs must be approved by the "Approval Authority" who
is also responsible for overseeing  implementation and enforcement of these programs.  As noted in Figure
7, a total of 44 States/Territories are authorized to implement State NPDES Permit Programs, but only 27 are
authorized to be the Pretreatment Program Approval Authority (i.e, those with approved State pretreatment
programs excluding the five §403.10(e) States).  In all other States and Territories (including the 403.10(e)
States), EPA is considered to be the Approval Authority.

POTW PRETREATMENT PROGRAMS

    The actual requirement for a POTW to develop and implement a local pretreatment program is a condition
of its NPDES permit.  Once the Approval Authority determines that a POTW needs a pretreatment program,
the POTW's NPDES permit is modified to require development of a local program and submission of the
program to the Approval  Authority for review and approval. Consistent with §403.8(f), POTW pretreatment
programs must contain the six minimum elements presented in Figure 8.

    In addition to the six  specific elements, pretreatment program submissions must include:

    •   a statement from the City Solicitor (or the like) declaring the POTW has adequate authority to
        carry out program requirements;
    •   copies of statutes, ordinances, regulations,  agreements, or other authorities the POTW relies
        upon to administer the pretreatment program including a statement reflecting the endorsement
        or approval of the bodies  responsible for supervising and/or funding the program;
    •   a brief description and organizational chart of the organization administering the program; and
    •   a description of funding levels and manpower available to implement the program.

    Pretreatment  program submissions found to be complete  proceed to the public  notice process, as
described in Chapter 4,  Public Participation and POTW Reporting.  Upon program approval, the Approval
Authority is responsible for modifying the POTW's NPDES permit to require implementation of the approved
pretreatment program. Once approved, the Approval Authority oversees  POTW  pretreatment program
implementation via receiving annual reports and conducting periodic audits and inspections. As of early 1998,
of the 1,578 POTWs required to develop pretreatment programs, 97 percent (1,535) have been approved.

    The National  Pretreatment Program regulates  lUs through three types of regulatory entities: EPA,
Approval Authorities, and Control  Authorities.  As noted above,  Approval Authorities oversee Control
Authorities while Control Authorities regulate lUs. General responsibilities of each of these three regulatory
entities are presented in  Figure 9.
 Chapter 2
                                                                                            -7-

-------
Approved State
State NPDES Permit Program
Alabama
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wvomlnq
10/19/79
11/01/86
05/14/73
03/27/75
09/26/73
04/01/74
05/OT/95
06/28/74
11/28/74
10/23/77
01/01/75
08/10/78
06/28/74
09/30/83
08/27/96
09/05/74
10/17/73
06/30/74
05/01/74
10/30/74
06/10/74
06/12/74
09/19/75
04/13/82
10/28/75
10/19/75
06/13/75
03/11/74
11/19/96
09/26/73
06/30/78
09/17/84
06/10/75
12/30/93
12/28/77
09/14/98
07/07/87
03/11/74
06/30/76
03/31/75
11/14/73
05/10/82
02/04/74
01/30/75
Approved State Pretreatment
Program
10/19/79*
11/01/86
09/22/89
„
06/03/81*
__
05/01/95
03/12/81
08/12/83
..
..
06/03/81
__
09/30/83
08/27/96
09/30/85
04/16/85
07/16/79
05/13/82*
06/03/81
»
09/07/84*
_„
04/13/82
__
06/14/82
„
07/27/83
11/19/96
03/12/81
„
09/17/84
04/09/82
12/30/93
08/10/83
09/14/98
07/07/87
03/16/82*
«
04/14/89
09/30/86
05/10/82
12/24/80

•-Denotes 403.1 0(e) State Approval
Figure 8. State Program Approval Status
                                                                                           Chapter 2

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/ntrpducffon to the National Pretreatment Program
                                                 Overview of the National Pretreatment Program
               1.
Legal Authority
               The POTW must operate pursuant to legal authority enforceable in Federal, State or local courts, which
               authorizes or enables the POTW to apply and enforce any pretreatment regulations developed pursuant
               to the CWA. At a minimum, the legal authority must enable the POTW to:
                        I.        deny or condition discharges to the POTW;
                        ii.        require compliance with pretreatment standards and requirements;
                        iii.       control IU discharges through permits, orders, or similar means;
                        iv.       require IU compliance schedules when necessary to meet applicable
                                 pretreatment standards and/or requirements and the submission of reports
                                 to demonstrate compliance;
                        v,        inspect and monitor lUs;
                        vi.       Obtain remedies for IU noncompliance; and
                        vii.      comply with confidentiality requirements.
               2.
Procedures
               The POTW must develop and implement procedures to ensure compliance with pretreatment
               requirements, including:
                                 identify and locate all lUs subject to the pretreatment program;
                                 identify the character and volume of pollutants contributed by such users;
                                 notify users of applicable pretreatment standards and requirements;
                                 receive and analyze reports from lUs;
                                 sample and analyze IU discharges and evaluate the need for IU slug
                                 control plans;
                                 investigate instances of noncompliance; and
                                 comply with public participation requirements.
I.
ii.
iii.
iv.
v.
               3.
Funding
               The POTW must have sufficient resources and qualified personnel to carry out the authorities and
               procedures specified in its approved pretreatment program.

               4.       Local limits

               The POTW must develop local limits or demonstrate why these limits are not necessary.

               5.       Enforcement Response Plan (ERP)

               The POTW must develop and implement an ERP that contains detailed procedures indicating how the
               POTW will investigate and respond to instances of IU noncompliance.
               6.
ListofSIUs
               The POTW must prepare, update, and submit to the Approval Authority a list of all Significant
               Industrial Users (SIUs).
     Figure 9. Six Minimum Pretreatment Program Elements
Chapter 2
                                                                                                               -9-

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  Overview oftha National Pretreatment Program
Introduction to the National Pretreatment Program
                  EPA
                          Headquarters
                          *•        Oversees program implementation at all levels
                          >        Develops and modifies regulations for the program
                          »•        Develops policies to clarify and further define the program
                          *•        Develops technical guidance for program implementation
                          >•        Initiates enforcement actions as appropriate
                          Regions
                          »•        Fulfill Approval Authority responsibilities for States without a
                                   State pretreatment program
                          *        Oversee State program implementation
                          »•        Initiate enforcement actions as appropriate.

                 Approval Authorities (EPA Regions and delegated States)
                          >•        Notify POTWs of their responsibilities
                          >        Review and approve requests for POTW pretreatment program
                                   approval or modification
                          >•        Review requests for site-specific modifications to categorical
                                   pretreatment standards
                          >•        Oversee POTW program implementation
                          >        Provide technical guidance to POTWs
                          *•        Initiate enforcement actions, against noncompliant POTWs or
                                   industries.

                 Control Authorities (POTWs, States, or EPA Regions)
                          >•         Develop, implement, and maintain approved pretreatment
                                   program
                          >•         Evaluate compliance of regulated lUs
                          >         Initiate enforcement action against industries as appropriate
                          >         Submit reports to Approval Authorities
                          »•         Develop local  limits (or demonstrate why they are not needed)
                          *•         Develop and implement enforcement response plan.
                 Industrial Users
                                  Comply with applicable pretreatment standards and reporting
                                  requirements.
               Figure 10. Roles and Responsibilities
-10-
                                                                                                          Chapter2

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Introduction to the National Pretreatment Program
                                         Pretreatment Standards
3.    PRETREATMENT  STANDARDS
    As described in Chapters 3 and 4,
the National  Pretreatment  Program
identifies specific requirements that
apply   to   all  (Us,   additional
requirements that apply to  all SlUs,
and certain requirements that  only
apply to GIUs.  The objectives of the
National  Pretreatment  Program are
achieved by applying and enforcing
three types of discharge standards:

  *• prohibited discharge standards
  » categorical standards
  > local limits.

PROHIBITED DISCHARGE
STANDARDS

    All IDs, whether or not subject to
any other  National, State, or local
pretreatment  requirements,  are
subject to the  general and specific
prohibitions  identified  in 40  CFR
§§403.5(a)  and  (b),  respectively.
General   prohibitions   forbid  the
discharge of any  pollutant(s) to a
POTW that cause pass through or
interference  (Figure 10).  Specific
prohibitions forbid eight categories of
pollutant discharges as follows:
          Chapters. Applicable EPA Guidance    '   ;!|
, Guidance Manual For Implementing Tola! Toxfc Organlcs (TTO);i,'     '' i
    Pretreatment Standards    ,",   i         ,  ;•     ,  <   ^
Guidance Manual for Preparation and Review of Removal Credit |,     „',
    Applications             '' "	     '"" 1|! ,;     ^
Guidance Manual for Preventing Interference at POTWs   ,  <      <^\
Guidance Manual for the Identification of Hazardous Wastes Delivered to,
    Publicly Owned Treatment Works by Truck, Rail, or Dedicated Pipe i'1'
Guidance Manual for the Use of Productiori^Based Pretreatment t ,
    Standards and the Combined Wastestream Formula,      j','',   '^ j
Guidance Manual on the Development and Implementation of Local    ,,
    Discharge Limitations Under the Pretreatment Program   *  r   *_''
Guidance to Protebt POTW Workers FfomTdiic And Reactive Gases Arid
                     l
Prelim Usefs Guide, Documentation foi^he^EPA Computer   ,   ,  4^ i
    'Program/Model for Developing Local Limits for Industrial Pretreatme§ti::|
    Programs at Publicly Owned Treatment Works          ,     i '"| '*;"
Supplemental Manual On the Development And Implementation of Local ,,\ /•
    ' Discharge Limitations Under The Pretre'atment Program: Resfdentialf, .*•
    and Commercial Toxic Pollutant Loadings And POTW Rembval,   ,','"]J
    Efficiency Estimation      '                t /-      ,,!,"'"'

                  Industry-Specific Guides                ,^r<
Aluminum, Copper, And Nonferrous Metals Forming And Metal Powders  j ,f
    Pretreatment Standards: A Guidance Manual        i  ,'     , "jt
Guidance Manual For Battery Manufacturing Pretreatment Standards  "'
Guidance Manual for Electroplating and Metal Finishing Pretreatment    i,:,
  ,  Standard                <    '-   '        'i !  '  Tr  .j-^-;
Guidance Manual For Iron And Steel Manufacturing Pretreatment "    "   I
    Standards                   _          ! t 'r    ,  ,   j '"^
Guidance Manual for Leather Tanning and Finishing Pretreatment,     >''''j1
    Standards                "          :  • n.t'.   ' ''   '•> ,"!i
Guidance Manual for Pulp; Paper, and Paperboard and Builders' Paper  /ijil i
    and Board Mills Prelreatment Standards        ,!      ,   .'i-1'1"^
    (1)  discharges containing pollutants which create a fire or explosion hazard in the POTW, including
        but not limited to, wastestreams with a closed cup flashpoint of less than 140°F (60°C) using the
        test methods specified in 40 CFR §261.21;
    (2)  discharges containing pollutants causing corrosive structural damage to the POTW, but in no
        case discharges with  a pH lower than 5.0, unless  the POTW is specifically designed to
        accommodate such discharges;
    (3)  discharges containing pollutants in amounts causing obstruction to the flow in the POTW resulting
        in interference;
    (4)  discharges of any pollutants released at a flow rate and/or concentration which will cause
        interference with the POTW;
    (5)  discharges of heat in amounts which will inhibit biological activity in the POTW resulting in
        interference, but in no case heat in such quantities that the temperature at the POTW treatment
        plant exceeds 40°C(104°F) unless the Approval Authority, upon request of the POTW, approves
        alternative temperature limits;
    (6)  discharges of petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in
        amounts that will cause interference or pass through;
Chapters
                                                                                             -11-

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 Pratroatment Standards
                                                              Introduction to the National Pretreatment Program
     (7)  discharges which  result in  the
         presence of toxic gases, vapors,
         or fumes within the POTW in a
         quantity that  may  cause acute
         worker   health  and  safety
         problems; and
     (8)  discharges of  trucked or  hauled
         pollutants, except at discharge points
         designated by the POTW.
Pass through - A discharge which exits the POTW into waters of
the US in quantities or concentrations which, alone or in
conjunction with a discharge or discharges from other sources, is a
cause of a violation of any requirement of the POTW's NPDES
permit (including an increase in the magnitude or duration of a
violation.

Interference - A discharge which, alone or in conjunction with a
discharge or discharges from other sources, both (1) inhibits or
disrupts the POTW, its treatment processes or operations, or its
sludge processes, use or disposal; and (2) therefore is a cause of a
violation of any requirement of the POTW's NPDES permit or of
the prevention of sewage sludge use or disposal.
                                             Figure 10.  Interference and Pass Through
    Compliance with the general and specific
prohibitions is mandatory for all Ills, although
a facility may have an affirmative defense in
any  action brought  against  it  alleging a
violation of the general  prohibitions or of
certain specific prohibitions [(3), (4), (5), (6)
and (7) above] where the IU can demonstrate it did not have reason to know that its discharge, alone or in
conjunction with a discharge or discharges from other sources, would cause pass through or interference, and
the IU was in  compliance with a  technically-based local limit  developed to  prevent pass  through or
interference.
    These prohibited discharge standards are intended to provide general protection for POTWs. However,
 their lack  of specific pollutant limitations creates the need for additional controls,  namely categorical
 pretreatment standards and local limits.

 CATEGORICAL STANDARDS

    Categorical pretreatment standards (i.e., categorical standards) are national, uniform, technology-based
 standards that apply to discharges to POTWs from specific industrial categories (i.e., indirect dischargers)
 and limit the discharge of specific pollutants. Categorical pjetreatment standards for both existing and new
 sources (PSES and PSNS, respectively) are promulgated by EPA pursuant to Section 307(b) and (c) of the
 CWA. Limitations developed for indirect discharges are designed to prevent the discharge of pollutants that
 could pass through, interfere with, or otherwise be incompatible with POTW operations. Effluent limitations
 guidelines  (ELGs),  developed in conjunction with categorical standards, limit the discharge from facilities
 directly to waters of the U.S. (i.e., direct dischargers) and do not apply to indirect dischargers. ELGs include
 Best  Practicable Control Technology Currently  Available (BPT), Best  Conventional Pollutant Control
 Technology (BCT), and  Best Available Technology Economically Achievable (BAT) limitations and New
 Source Performance Standards (NSPS). ELGs (i.e., BPT, BCT, BAT, and NSPS) do not apply to indirect
 dischargers. The significant difference between categorical standards and effluent limitations guidelines is
 that categorical standards account for any pollutant removal that may be afforded through treatment at the
 POTW while effluent limitations guidelines do not.

    Industries identified as major sources of toxic pollutants are typically targeted for effluent guideline and
 categorical standard development. If limits are deemed necessary, EPA investigates affected I Us and gathers
 information  regarding  process operations and  treatment  and  management  practices,  accounting for
 differences in facility size and age, equipment age, and wastewater characteristics. Subcategorization within
 an industrial category is evaluated based on variability in processes employed, raw materials used, types of
 items produced, and characteristics of wastes generated. Availability and cost of control technologies, non-
water quality environmental impacts, available pollution prevention measures7, and economic impacts are then
 identified prior to EPA's presentation of findings in proposed development documents and publishing a notice
of the proposed regulations in the Federal Register. Based on public comments on the proposed rule, EPA
promulgates (i.e., publishes) the standards (Figure 11).
               EPA's Considerations of Pollution Prevention in EPA's Effluent Guideline Development
               Process may be consulted for more information on this topic.

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Introduction to the National Pretreatment Program
                                          Pretreatment Standards
     As noted above, categorical  pretreatment
standards are  developed  both  for  existing
(PSES) and new sources (PSNS). Facilities are
classified as either PSES or PSNS based on the
definition of "new source" set out  in 40 CFR
§403.3(k)  of   the   General   Pretreatment
Regulations  (see  Figure  12).   Dischargers
subject to PSES are required to comply  with
those standards by a specified date, typically no
more than three years after the effective date of
the categorical standard. Users subject to PSNS,
however, are required  to achieve compliance
within the shortest feasible time, not to exceed  FiSure n-  Development Process of Effluent Guidelines
90  days  from  commencement  of discharge.
PSNS are often more stringent than PSES based on the opportunity for new sources to install the best
available demonstrated technology and operate the most efficient production processes.
    Congress established an  initial list of
21 categorical industries under Section 306
of the CWA of 1972. As a result of various
court decrees and settlement agreements
resulting from  litigation, and from EPA's
internal work plan development process,
EPA has developed effluent guidelines (for
direct  dischargers)  and/or  categorical
pretreatment  standards    (for   indirect
dischargers) for 51  industrial  categories.
Of  these  industrial   categories,   EPA
implements pretreatment standards for 32
categories, and either requires compliance
solely  with  40  CFR  Part  403  General
Pretreatment  Regulations   or does  not
address  pretreatment  standards  for the
remaining categories.   Plans for EPA's
expansion and  modification of the list is
detailed  in the  Effluent Guidelines Plan,
published in the FederalReg/sferbiennially
as required in section 304(m) of the CWA.
A list of the industrial categories that have
categorical standards is provided as Figure
13.
                                              Figure 13. Definition of New Source (40 CFR 403.3(k))
    Categorical  pretreatment  standards
developed can be concentration-based or
mass-based. Concentration-based standards are expressed as milligrams of pollutant allowed per liter (mg/l)
of wastewater discharged and are issued where production rates for the particular industrial category do not
necessarily correlate with pollutant discharges. Mass-based standards are generally expressed on a mass
per unit of production (e.g., milligrams of pollutant per kilogram of product produced, pounds of pollutant per
million cubic feet of air scrubbed, etc.) and are issued where water conservation is an important component
in the limitation development process. For a few categories where reducing a facility's flow volume does not
provide a significant difference in the pollutant  load discharged,  EPA has established both mass- and
concentration-based standards. Generally, both a daily maximum limitation and a long-term average limitation
(e.g., average daily values in a calendar month) are established for every regulated pollutant.
New Source is defined at 40 CFR §403.3 (k)(l) to mean any building, structure, facility
or installation from which there is or may be a discharge of pollutants, the construction of
which commenced after publication of proposed Pretreatment Standards under Section
307(c) of the Act which will be applicable to such source if Standards are thereafter
promulgated in accordance with that section, provided that:
(i) the building, structure, facility, or installation is constructed at a site at which no
   other source is located; or
(ii) the building, structure, facility, or installation totally replaces the process or
   production equipment that causes the discharge of pollutants at an existing source; or
(iii) the production or wastewater generating processes of the building, structure, facility
   or installation are substantially independent of an existing source at the same site. In
   determining whether these are substantially independent, factors such as the extent
   to which the new facility is integrated with the existing plant, and the extent to
   which the new facility is engaged in the same general type of activity as the existing
   source should be considered.
(2) Construction on a site at which an existing source is located results in a modification
rather than a new source if the construction does not create a new building, structure,
facility, or installation meeting the criteria of paragraphs (k)(l)(ii), or (k)(l)(iii) of this
section but otherwise alters, replaces, or adds to existing process or production
equipment.
(3) Construction of a new source as defined under this paragraph has commenced if the
owner or operator has:
(i) begun, or caused to begin as part of a continuous onsite construction program:
(ii) any placement, assembly or installation of facilities or equipment, or
(B) significant site preparation work, including clearing, excavation, or removal of
   existing buildings, structures, or facilities which is necessary for the placement,
   assembly, or installation of new source facilities or equipment; or
(ii) entered into a binding contractual obligation for the purchase of facilities or
   equipment which are intended to be used in its operation within a reasonable time.
   Options to purchase or contracts which can be terminated or modified without
   substantial loss, and contracts for feasibility, engineering, and design studies do not
   constitute a contractual obligation under this paragraph.
Chapters
                                                                                                         -13-

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 Pratreatm&nt Standards
Introduction to the National Pretreatment Program
                    Figure 13.  Summary of Categorical Pretreatment Standards
Category
Aluminum Forming
Battery Manufacturing
Builders' Paper and
Board Mills
Carbon Black
Manufacturing
Coil Coating
Copper Forming
Electrical and Electronic
Components
Electroplating
Faedlots
Fertilizer Manufacturing
Glass Manufacturing
Grain Mills
nk Formulating
norganlc Chemicals
Manufacturing
ron and Steel ,
Manufacturing
.eathar Tanning and
Finishing
Metal Finishing
40CFR
Part
467
461
431
458
465
468
469
413
412
418
426
406
447
415
420
425
433
Subparts
A-F
A-G
A
A-D
A-D
A
A-D
A-B, D-H
B
A-G
H.K-M
A
A
A-BO
A-F, H-J, L
A-l
A
Type of
Standard
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
Overview of Pretreatment Standards
Limits are production-based, dally maximums and monthly
averages. Subpart C prohibits discharges from certain operations.
Limits are production-based, daily maximums and monthly
averages. No discharge is allowed from any process not
specifically identified in the regulations.
Limits are production-based daily maximums. These facilities may
certify they do not use certain compounds in lieu of performing
monitoring to demonstrate compliance.
Limits are for Oil & Grease only (no limit duration specified).
Limits are production-based, daily maximums and monthly
averages.
Limits are production-based, daily maximums and monthly
averages.
Limits are concentration-based, daily maximums and 30 day
averages or monthly averages (varies per subpart and pollutant
parameter). Certification is allowed in lieu of monitoring for certain
jollutants when a management plan is approved and implemented.
Limits are concentration-based (or alternative mass-based
equivalents), daily maximums and four consecutive monitoring
days averages. Two sets of limits exist, depending on if facility
discharges more or less than 10,000 gallons per day of process
wastewater. Certification is allowed in lieu of monitoring for certain
jollutants when a management plan is approved and implemented.
Discharge of process wastewater is prohibited, except when there
s an overflow resulting from a chronic or catastrophic rainfall
event.
.imits may specify zero discharge of wastewater pollutants
Subpart A), production-based daily maximums and 30-day
averages (Subparts B-E) or concentration-based (Subparts F-G)
with no limit duration specified.
Limits are either concentration- or production-based, daily
maximums and monthly averages.
Discharge of process wastewater is prohibited at a flow rate or
mass loading rate which is excessive over any time period during
he peak load at a POTW.
Regulations specify no discharge of process wastewater pollutants
o the POTW.
Limits vary for each subpart with a majority of the limits
concentration-based, daily maximums and 30-day averages, or
may specify no discharge of wastewater pollutants. Numerous
subparts have no pretreatment standards.
.imits are production-based, daily maximums and 30 day
averages.
.imits are concentration-based, daily maximums and monthly
averages. In certain instances, production volume dictates
applicable pretreatment standards.
Limits are concentration-based, daily maximums and monthly
averages. Certification is allowed for certain pollutants where a
management plan is approved and implemented.
-14-
                                                                                              Chapter 3

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Introduction to the National Pretreatment Program
PretreatmBnt Standards
                    Figure 13. Summary of Categorical Pretreatment Standards
Category
Metal Molding and
Casting
Nonferrous Metals
Forming and Metal
Powders
Monferrous Metals
Manufacturing
Organic Chemicals,
Plastics, and Synthetic
Fibers
Paint Formulating
Paving and Roofing
Materials (Tars and
Asphalt)
Pesticide Chemicals
Petroleum Refining
Pharmaceutical
Manufacturing
Porcelain Enameling
Pulp, Paper, and
Paperboard
Rubber Manufacturing
Soap and Detergent
Manufacturing
Steam Electric Power
Generating
Timber Products
Processing
40CFR
Part
464
471
421
414
446
443
455
419
439
466
430
428
417
423
429
Subparts
A-D
A-J
B-AE
B-H, K
A
A-D
A, C, E
A-E
A-D
A-D
A-G, I-L
E-K
0-R
N/A
F-H
Type of
Standard
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
Overview of Pretreatment Standards
Limits are primarily production-based, daily maximums and
monthly averages. Discharges from certain processes are
prohibited (Subparts A-C).
Limits are production-based, daily maximums and monthly
averages. In some instances, the regulations prohibit the
discharge of wastewater pollutants.
Limits are production-based, daily maximums and monthly
averages. The majority of the Subparts have both existing and
new source limits, with others having solely new source
requirements.
Limits are mass-based (concentration-based standards multiplied
by process flow), daily maximums and monthly averages.
Standards for metals and cyanide apply only to metal- or cyanide-
bearing wastestreams.
Regulations specify no discharge of process wastewater pollutants
to the POTW.
Limits are for Oil & Grease only (no limit duration specified).
Limits are mass-based (concentration-based standards multiplied
by process flow), daily maximums and monthly averages. Subpart
C specifies no discharge of process wastewater pollutants but
provides for pollution prevention alternatives. Subpart E specifies
no discharge of process wastewater pollutants.
Limits are concentration-based (or mass based equivalent), daily
maximums.
Limits are concentration-based, daily maximums and monthly
averages. These facilities may certify they do not use or generate
cyanide in lieu of performing monitoring to demonstrate
compliance.
Limits are concentration-based (or alternative production-based),
daily maximums and monthly averages. Subpart B prohibits
discharges certain operations.
Limits are production-based daily maximums and monthly
averages. These facilities may certify they do not use certain
compounds in lieu of performing monitoring to demonstrate
compliance. Facilities subject to Subparts B and E must also
implement Best Management Practices as identified.
Limits are concentration- or production-based, daily maximums and
monthly averages.
Regulations specify no discharge of process wastewater pollutants
to the POTW.
Limits are either concentration-based, daily maximums, or
"maximums for any time", or compliance can be demonstrated
through engineering calculations.
All PSNS (and PSES for Subpart F) prohibit the discharge of
wastewater pollutants. PSES for Subparts G and H are
concentration-based, daily maximums (with production-based
alternatives).
Chapters
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Pratraatment Standards
                                                            Introduction to the National Pretreatment Program
    Categorical standards apply to regulated wastewaters, i.e. wastewater from an industrial process that is
regulated for a  particular pollutant by a categorical pretreatment standard.  Therefore, demonstrating
compliance with categorical pretreatment  standards is  intended to  be based  on measurements of
wastestreams containing only the regulated process wastewater. However, recognizing isolation of regulated
wastestreams from nonreguiated wastestreams was not always practicable nor desirable, EPA developed the
combined wastestream formula (CWF) and flow weighted
average (FWA) approach for determining compliance with
combined wastestreams.
    Pursuant to 40 CFR §403.6(e), the CWF is applicable
where a regulated wastestream  combines with one or
more  unregulated or dilute wastestreams (Figure 14)
prior to treatment. Where nonreguiated wastestreams
combine with process streams after pretreatment, the
more stringent approach (whether CWF or FWA) is used
to adjust the limits8 (Figure  15).  The CWF and FWA
approaches differ primarily  in  their allowances for
nonreguiated wastestreams. While the CWF provides a
"full  credif  (i.e.,  same pollutant levels  as  regulated
wastestreams) for unregulated  wastestreams yet no
creditfor dilute wastestreams, the FWArequires sampling
and analysis of the untreated, nonreguiated wastestreams
to determine the credit to be granted (not to exceed that
allowed for the regulated wastestreams).
     Regulated       Unregulated
                                                                                      Dilute
                 Pretreatment
                  Monitoring~x\ _
                   location/
                                                                                          CWF
Figure 14. Combined Wastestream Formula
                                                               Regulated      Unregulated
                                                         Unregulated
                                                                     Pretreatment
                                Dilute
    Application of the CWF and FWA requires proper identification, classification, and quantification of the
three wastestream types (Figure 16.) Note: in circumstances where boiler blowdown, noncontact cooling
water,  stormwater,  or demineralized  wastestreams
contain a significant amount of a regulated pollutant, and
the treatment of the wastewater with  the regulated
wastestream results  in substantial  reduction of  the
regulated pollutant, the Control Authority can classify the
wastestream as unregulated rather than  as a  dilute
wastestream.     Clarification  on   category-specific
wastestream  classifications  may  be  provided  by
consulting the applicable regulation(s) and associated
development documents, since wastestream types  are
addressed  in  the effluent guideline  and  categorical
standard development process.   When in doubt,  the
Control Authority can always require the CIU to monitor
the wastestream(s) in question to quantify the presence
(or lack thereof) of categorically regulated pollutants.
Reasonably accurate flow data must also be obtained for
each wastestream type flowing through the monitoring
point to ensure categorical pretreatment standards  are
adjusted accordingly.  Proper application  of the CWF or
FWA will result in:
                                                                                         CWF
                                                                                          or
                                                                                         FWA
                                                    Figure 15. CWF vs. FWA
       alternative limits being established for each regulated pollutant in each regulated processes;
       both daily maximum and long-term average (i.e., 4-day, 30-day, or monthly) alternative limits
       being calculated for each regulated pollutant;
              Where commingled wastestreams combine with nonreguiated wastestreams after
              treatment, the CWF adjusted limitations are further adjusted by use of the CWF or FWA to
              address the untreated, nonreguiated wastestreams (Figure 17.) For more detailed
              discussion of FWA, see Federal Register preamble language, 51 FR21454 (June 12,1986).

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Introduction to the National Pretreatment Program
                          Pretreatment Standards
    >•   4-day average limits being adjusted to equivalent monthly average limits when two or more
        categorical pretreatment standards apply to the facility and one of the applicable standards is 40
        CFR Part 413; and
    *•   calculated alternative limits remaining above the analytical  detection limit for that pollutant.
        NOTE: If adjusted limit(s) are below the detection limit, the Control Authority shall instruct the IU
        to either:

            separate the dilute wastestreams from the regulated wastestreams prior to the combined
            treatment facility, or
            segregate all wastestreams entirely.

EPA's Guidance Manual for the  Use of Production Based Pretreatment  Standards  and the Combined
Wastestream Formula should be consulted for more information on the proper application and adjustment of
categorical pretreatment standards.

Regulated
Wastewater from an
Industrial process that Is
regulated for a particular
pollutant by a categorical
pretreatment standard
Nonregulated
Unregulated
Wastestreams from an industrial process that are not regulated for a
particular pollutant by a categorical pretreatment standard and are not
defined as a dilute wastestream, e.g.:
» a process wastestream for which categorical standards
have been promulgated but for which the deadline for
compliance has not yet been reached
» a process wastestream that currently is not subject to
categorical pretreatment standards
» a process wastestream that is not regulated for the
pollutant in question but is regulated for other pollutants.
Dilute
Wastestreams which have no more than trace or
non-detectable amounts of the regulated pollutant.
Defined in 40 CFR § 403.6(e)(1) of the General
Pretreatment Regulations to include sanitary
wastestreams, demineralized backwash streams, boiler
blowdown, noncontact cooling water, storm water, and
process wastestreams from certain standards based on
the findings that these waslewaters contained none of
the regulated pollutant or only trace amounts of it.

Figure 16. Wastestream Types
    Although categorical standards are established based on a particular industrial category, EPA provides
several options for unique circumstances that justify adjustment of categorical standards for an individual
facility:
    Removal Credits  40 CFR  §403.7 details the
    conditions by which a  Control Authority  may
    demonstrate  consistent removal  of pollutants
    regulated  by categorical  standards at  their
    POTW, and  in so doing, may extend removal
    credits to industries on a pollutant-specific basis
    to prevent redundant treatment. Removal credits
    are available for a pollutant if the  pollutant is
    regulated by the sewage sludge use or disposal
    option  employed  by  the POTW  making  the
    application request, or if the pollutant is listed in
    40  CFR Part  403,  Appendix G.   Also,  the
    availability of removal credits is not limited to
    Appendix G pollutants for POTWs that dispose of
    sewage sludge in municipal solid waste landfills.
    Steps for developing such a request are detailed
    in EPA's Guidance Manual for the Preparation
    and Review of Removal Credit Applications.
                                                         Regulated
Unregulated
                                  Dilute
    Unregulated    I Pretreatment
                           CWF
Figure 17. Multiple use of the CWF/FWA
Chapters
                                                                                              -17-

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Protrealment Standards
                                                              Introduction to the National Pretreatment Proaram
    Fundamentally Different Factors Variance Section 301 (n) of the CWA authorizes adjustments of
    categorical pretreatment standards for existing sources who demonstrate they have factors which are
    fundamentally different from the factors EPA considered  during standards development (40 CFR
    §403.13).  Variance requests  must be based solely on information and data submitted during the
    development of the categorical standards (Figure  18) and the adjusted effluent limitations must
    neither be more nor less stringent than justified by the fundamental difference nor result in a nonwater
    quality environmental impact markedly more adverse than the impact considered by EPA when
    developing the categorical standard.

    Successful requests must detail factors well outside the range considered by EPA in establishing the
    standard and not merely factors deviating from the average. Further, differences must not be similar
    to a significant number of other facilities in the category. A facility must request a variance in writing
    no later than 180 days after  publication of a categorical Pretreatment Standard in the Federal
    Register.
                                                 voluma of process
                                                wastewater discharged
                 nature ana quality of pollutants
                  In process wastestreams
                                                               nonwater quality environmental Impacts
                                                                of controlling and treating process
                                                                      wastestreams
                                      energy requirements for
                                      control and treatment
                                          technology
                                                             cost of compliance with required
                   relation of age, size, land availability and
                   confgurallon to equipment and facilities,
                   process changes, processes employed,
                   and engineering aspects of application of
                          control technology
            Figure 18. Factors to Consider for an FDF Variance Request
   Net/Gross Adjustment  Categorical pretreatment standards can be adjusted to reflect the presence of
   pollutants in a ClU's intake waters (40 CFR §403.15). To obtain a net/gross credit, the CIU must submit
   a formal written request to the Control Authority that demonstrates:

       >•   its intake water is drawn from the same body of water that the POTW discharges into (this
           can be waived if the Control Authority finds no environmental degradation will result);
       >   the pollutants present in the intake water will not be entirely removed by the treatment system
           operated by the CIU; and
       >•   the pollutants in the intake water do not vary chemically or biologically from the pollutants
           limited by the applicable standard.

   Inherent in this provision is the requirement that the CIU employ a treatment technology capable of
   meeting the categorical pretreatment standard(s). Net/gross adjustments should not be granted to
   ClUs that have no treatment. Further, credits are only granted to the extent necessary to meet the
   applicable standard(s), up to a maximum value equal to the influent value.
                                                                                            Chapter 3

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                                                                              Pretreatment Standards
    Innovative Technology In accordance with 307(e) of the CWA, existing ClUs choosing to install an
    innovative treatment system may receive approval from the Control Authority for up to a two year
    extension to their applicable categorical pretreatment standards compliance deadline, provided:

       >   the innovative treatment has a reasonable potential to result in significantly greater pollutant
           removal or equivalent removal at a substantially lower cost than the technologies considered
           by EPA when developing the categorical standard;
       >   the innovative technique has the potential for industry-wide application; and
       >•   the proposed compliance extension will not cause or contribute to the violation of the POTW's
           NPDES permit.

    While policy has been established for universal categorical variance requests, occasionally, a Control
Authority may merely need assistance to classify a C1U and/or to determine applicable categorical limitations.
Provisions in the General Pretreatment Regulations allow POTWs and I Us to request an  EPA category
determination for a specific ID within 60 days after the effective date of the standard in question [40 CFR
§403.6(a)].  Even after the formal timeframe for requesting a categorical determination, EPA (and states) will
assist POTWs and lUs with categorization issues. Such requests, however, do not affect applicable reporting
requirements, including timely requests submitted under 40 CFR §403.6(a). Additionally, EPA has addressed
universal CIU questions posed by Control Authorities in various memoranda and guidance:

    Research and  Development (R&D)  Facilities  Unless specifically addressed in the  categorical
    regulation or associated development document, R&D facilities where there is no commercial sale
    of products from the facility, are not subject to  categorical standards.9 Should an R&D facility need
    pollution controls to comply with prohibited discharge standards and/or local limits, the development
    documents may serve as guidance on the performance of pollution control technologies.

    Certification Statements In lieu of requiring self-monitoring, some standards allow ClUs to certify that
    they  do not use, generate or  discharge a regulated pollutant [e.g. Pulp,  Paper and Paperboard
    facilities can  certify that chlorophenolic compounds are  not used (40 CFR Part  430) and
    Pharmaceutical Manufacturing facilities can certify that cyanide is not used or generated (40 CFR Part
    439)]. Facilities providing such certifications are still considered ClUs, and therefore are subject to
    other pretreatment standards and requirements.

    Lack of specific categorical effluent  limitations lUs subject to PSES or PSNS that merely require
    compliance with 40 CFR Part 403 are not considered ClUs. However, these users may still be
    classified as SlUs and are still  subject to the general and specific prohibitions and any local limits.

    Total Toxic Oraanics (TTO)  Seven categorical regulations currently limit the discharge of TTO:

       *   40 CFR Part 413 - Electroplating
       ••   40 CFR Part 433 - Metal Finishing
       >•   40 CFR Part 464 - Metal Molding and Casting
       »   40 CFR Part 465 - Coil Coating
       »•   40 CFR Part 467 - Aluminum Forming
       *   40 CFR Part 468 - Copper Forming
       >   40 CFR Part 469 - Electrical and Electronic Components (Phase I  and II)

    For each of these standards, TTO refers to the sum of the masses or concentrations of certain toxic
    organic pollutants found in the regulated discharge at a concentration greater than 0.01  milligrams
    per liter (mg/l).  However, the toxic organic pollutants regulated by the TTO limit are specific to each
    industrial category.   Further,  industrial categories may provide  some  flexibility  with regard  to
    monitoring and/or reporting requirements as follows:
               June 26,1987 letter from Ms. Rebecca W. Hanmer, Deputy Assistant Administrator for
               Water.
Chapters
                                                                                            -19-

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 Ffatreatment Standards
                                                             Introduction to the National Pretreatment Program
        *•   40 CFR Parts 413 and 433 allow development and implementation of a Toxic Organic
            Management Plan (TOMP) in lieu of routine monitoring while 40 CFR Part 469 allows
            development and implementation of a Solvent Management Plan.  Upon approval of
            these plans by the Control Authority, the CIU can demonstrate compliance with TTO
            requirements by certifying that the facility is adhering to this Plan to prevent organics
            from being discharged to the POTW. A specific certification statement must be signed
            and provided to the Control Authority on a regular basis.

        »•   40 CFR Parts 464, 465, 467, and 468 allow an option to demonstrate compliance with
            an Oil and Grease limit in lieu of demonstrating compliance with a TTO limit. The option
            chosen by the CIU must be utilized for all reports required (i.e., BMR, 90-day compliance
            report, and periodic compliance reports).

    EPA's Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreatment Standards should
    be consulted for more information on  TTO.

LOCAL LIMITS

    Prohibited discharge standards are designed to protect against pass-through and interference generally.
Categorical pretreatment standards,  on the other hand,  are designed to ensure  that lUs implement
technology-based controls to limit the discharge of pollutants. Local limits, however, address the specific
needs and concerns of a POTW and its receiving waters. Federal regulations at 40 CFR §§403.8(f)(4) and
122.210)(4) require Control Authorities to evaluate the need for local limits and, if necessary, implement and
enforce specific limits as part of pretreatment program activities.

    Local limits are developed for pollutants (e.g. metals, cyanide, BODS, TSS, oil and grease, organics) that
may cause interference,  pass through, sludge contamination, and/or worker health and  safety problems if
discharged in excess of the receiving POTW treatment plant's capabilities and/or receiving water quality
standards. Typically, local limits are developed to regulate the discharge from all lUs, not just to ClUs, and
are usually imposed at the "end-of-pipe" discharge from an IU (i.e., at the point of connection to the  POTW's
collection  system).  In evaluating the need for  local limit development, it  is recommended that Control
Authorities:
    conduct an industrial waste survey to identify
    all lUs that might be subject to the pretreatment
    program;
    determine  the character  and  volume  of
    pollutants contributed to the POTW by these
    industries;
    determine which pollutants have a reasonable
    potential  for pass through, interference,  or
    sludge contamination;
    conduct a technical evaluation to determine the
    maximum allowable  POTW treatment  plant
    headworks (influent) loading for at  least
    arsenic, cadmium, chromium, copper, cyanide,
    lead, mercury, nickel, silver, and zinc (Figure 19);
    identify additional pollutants  of concern;
    determine contributions from unpermitted sources to determine the maximum allowable treatment plant
    headworks loading from "controllable" industrial sources (Figure 20);
    implement a system to ensure these loadings will not be exceeded.
  Maximum Allowable Headworks Loading Method
  (MA.HL)  Pollutant by pollutant, treatment plant data are
  used to calculate removal efficiencies, before applying the
  most stringent criteria (i.e., water quality, sludge quality,
  NPDES permit, or pollutant inhibition levels) to back
  calculate the MAHLs. Subtracting out contributions from
  domestic sources, the available industrial loading is then
  either evenly distributed among the lUs, or allocated on an
  as needed basis to those lUs discharging the pollutant above
  background levels.
Figure 19. MAHL
                                                                                         Chapter 3

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Introduction to the National Pretreatment Program
                                                                              Pretreatment Standards
                                                 Maximum Allowable Industrial Load (MAIL) The
                                                 MAIL is the total daily mass that a POTW can accept from
                                                 all permitted lUs and ensure the POTW is protecting against
                                                 pass through and interference.
Other local limit approaches available to Control
Authorities include:

    Collection System Approach  Pollutants found
    to  be  present  which  may  cause  fire  and
    explosion hazards or other worker health and   Figure 20. MAIL
    safety  concerns,  are evaluated  for  their
    propensity to volatilize and are modeled to evaluate their expected concentration in air. Comparisons are
    made with worker health exposure criteria and lower explosive limits. Where values are of concern, the
    Control Authority may set limits or require development of management practices to control undesirable
    discharges. The collection system approach may also consider the prohibition of pollutants with specific
    flashpoints to prevent discharges of ignitable wastes. EPA's Guidance to Protect POTW Workers from
    Toxic and Reactive Gases and Vapors details strategies for developing such local limits.

    Industrial User Management Practice Plans These plans typically consist of narrative local limits
    requiring IDs to develop management practices (e.g., chemical management practices, best
    management practices, and spill prevention plans) for the handling of chemicals and wastes. The
    need for and suggested contents of such plans may be found in EPA's Control of Slug Loadings to
    POTWs: Guidance Manual, and Spill Prevention, Control, and Countermeasure (SPCC) Information
    Guide.

    Case-bv-Case Discharge Limits These numeric local limits are based on best professional judgement
    (BPJ) and  available pollution prevention and, treatment technologies  which are known to  be
    economically feasible.  This approach is  most often used when insufficient data are available to
    employ the methods outlined above.

    Local Specific Prohibitions POTW specific prohibitions may be imposed in addition to the prohibitions
    detailed in  40 CFR § 403.5 (a) & (b) to address hydraulic, pollutant specific, and/or aesthetic
    concerns; e.g.:

        >•  noxious or malodorous liquids, gases, or solids creating a public nuisance
        *  wastestreams which impart color and pass through the POTW treatment plant
        »•  storm water, roof runoff, swimming pool drainage
        *  wastewaters containing radioactive wastes or isotopes
        >  removed substances from pretreatment of wastewater.

 Regardless of the approaches taken by a Control Authority, local limits should correct existing problems,
 prevent potential problems, protect the receiving waters, improve sludge use options, and protect POTW
 personnel. Additional existing EPA guidance on the subject includes:

    >•   Guidance for Preventing Interference at POTWs
    >•   Guidance Manual on the Development and Implementation of Local Discharge Limitations Under
        the Pretreatment Program
    >   Supplemental Manual on the Development and Implementation of Local Discharge Limitations
        Under the Pretreatment Program: Residential and Commercial Toxic Pollutant Loadings and
        POTW Removal Efficiency Estimation
    *   Toxicity Identification Evaluation: Characterization of Chronically Toxic Effluents.

 Additionally, many EPA Regions and States have developed local limits guidance to address regional and
 state issues.
 Chapter 3
                                                                                             -21-

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Prstreaimeni Standards
SUMMARY OF STANDARDS

     A summary of all of the pretreatment standards,  including general and specific prohibitions, categorical
pretreatment standards, and local limits, is provided as Figure 21.
     Development
                     General and Specific Prohibitions     Categorical Pretreatment Standards
                                                                                                    Local Limits
                     csutDiisnea at tnc Federal level
                                                   Established at the Federal level
                                                                                          Developed by Control Authorities
     Reference
                    40CFR403.S{a)&(b)
                              40 CFR Parts 405-471
                                       Requirements for development found in
                                       40 CFR §§403.5(c) & 403.8(f)(4)
     Applicability
AHIUs
                              CIUs
                                       Commonly all lUs or all SIUs, but
                                       depends on allocation method used
                                       when developing limits.
     Purpose
•rovide for general protection of the
POTW. May be superseded by
•nore stringent categorical
pretreatment standards or local
imits.
Minimum standards based on available
treatment technology and pollution prevention
measures for controlling nonconventional and
toxic pollutants that may cause pass through,
interference, etc. at the POTW. May be
superseded by more stringent local limits.
Provide site specific protection for a
POTW and its receiving waters. May
be superseded by more stringent
categorical standards.
     «1 standards arc considered pretreatment standards for the purpose of section 307(d) of the Clean Water Act. A POTW is responsible for
     identifying standard^) applicable to each industrial user and applying the most stringent requirements where multiple provisions exist.
     CJompUince with imposed standards can be achieved through implementation of best management practices, development of a pollution prevention
     jtogram. and/or installation of pretreatment.
    Figure 21.  Summary of Standards

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 Introduction to the National Pretmatment Program
                                                                         gram Responsibilities
4.   POTW     PRETREATMENT      PROGRAM
       RESPONSIBILITIES
                                            Chapter 4, Applicable EPA Guidance
                                  CERCLA Site Discharges to POTWs Guidance Manual
                                  Control of Slug Loadings To POTWs: Guidance Manual
                                  Guidance For Developing Control Authority Enforcement Response
                                     Plans
                                  Guidance Manual for PQTWs to Calculate the Economic Benefit of
                                     Noncorhpliance
                                  Industrial User inspection and Sampling Manual For POTWs
                                  Industrial User Permitting Guidance Manual
                                  Model Pretreatment Ordinance
                                  Multijurisdictional Pretreatrnent Programs: Guidance Manual
                                  NPDES Compliance Inspection Manual
                                  POTW Sludge Sampling and Analysis Guidance Document
                                  Pretreatrnent Compliance Monitoring and Enforcement Guidance
                                  RCRA Information on Hazardous Wastes for Publicly Owned
                                     Treatment Works
                                  UJS. EPA Pretreatrnent Compliance Monitoring and Enforcement
                                     System: Version 3.0, User's Guide
   Chapter 2 describes the basis for
POTWs  to  develop  pretreatment
programs that implement Federal
pretreatment  standards   and
requirements,  in  addition  to
protecting any local concerns.  This
Chapter  provides  an overview of
these POTW programs, highlighting
each of the specific program areas
that are to be addressed.

LEGAL AUTHORITY

   As  discussed  in Chapter 2,
POTWs  seeking  pretreatment
program  approval must  develop
policy and procedures for program
implementation  and establish  the
legal authority  to  implement and
enforce program requirements. The
General Pretreatment Regulations do not provide Control Authorities with the legal authority to carry out their
pretreatment programs;  rather the regulations do set  forth the minimum requirements for POTWs with
pretreatment programs.

    A Control Authority's legal authority actually derives from State law. Therefore, State law must confer the
minimum Federal  legal authority requirements on a Control Authority. Where deficient, State law must be
modified to grant the minimum requirements.

    In order to apply regulatory authority provided by State law, it is generally necessary for the Control Authority
to establish local regulations to legally implement and enforce pretreatment requirements. Where the Control
Authority is a municipality, legal authority is detailed in a Sewer Use Ordinance (SUO), which is usually part of
city or county code. Regional Control Authorities frequently adopt similar provisions in the form of "rules and
regulations."   Likewise,  State   agencies
implementing a State-wide program under 40
CFR  §403.10(e)  set   out  pretreatment
requirements as State regulations, rather than
as an SUO. [Local regulations cannot give the
Control Authority greater authority than that
provided by State law.] EPA's 1992 guidance,
EPA Model Pretreatment Ordinance provides
a model for POTWs that are required to
develop pretreatment programs.

    As POTW service  areas expand, new
contributions   may  arise  from
"extrajurisdictional" lUs located outside of the           POTW
Control  Authority's legal jurisdiction  (see
Figure 22).  Multijurisdictional arrangements
require special legal/contractual mechanisms
                                                City A
CityB
                                        Figure 22. Multijurisdictional Programs
  Chapter 4
                                                                                       -23-

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    POTW Pretraatment Pn
                                                                Introduction to the National Pretreatment Program
  to ensure adequate authority to implement and enforce program requirements in these other jurisdictions. Some
  state statutes may provide for general extraterritorial powers (i.e., a Control Authority is automatically allowed to
  regulate extrajurisdictional lUs contributing to their system). However, the extent to which authorities (i.e., to
  permit,  inspect, enforce, monitor, etc.) are granted may be somewhat limited, thereby, restricting a Control
  Authority's ability to implement and enforce a program. Where obtaining authority from the State to  regulate
  extrajurisdictional IDs is not feasible, other options may be pursued:

      •   Districts The creation of an independent organization (by affected municipalities or the State) which
          is authorized to administer and enforce an approved pretreatment program for the entire area in
          which it provides services is common  in areas where multiple POTWs each serve various
         jurisdictions.

      •   Agreements   Affected Control Authorities may opt to enter  into agreements requiring each
          municipality to implement and enforce the approved pretreatment program covering all lUs within
         their jurisdiction. The Control Authority must  retain the means to regulate extrajurisdictional  lUs
         where the contributing jurisdiction's efforts are inadequate.  It is essential that agreements clearly
         define the roles of each party.

      •   Annexation Where extrajurisdictional lUs lie in unincorporated areas, a Control Authority may annex
         or utility annex the service area.

      •   Contracts A Control  Authority may enter into  a contract with an extrajurisdictional IU, although
         contracts generally limit the enforcement capabilities of the Control Authority. As such, contracts
         should only be pursued when  all other means fail.

     Since procedures for obtaining jurisdiction,  creating sanitary districts, annexing service areas, etc. vary
 among states, Control Authority personnel should consult with their legal staff to thoroughly examine  options
 allowed.  This may include requesting State legislative changes if necessary.  EPA's 1994 Multijurisdictional
 Pretreatment Programs - Guidance Manual provides more information on these jurisdictional issues, including
 sample language for agreements and contracts.

 INDUSTRIAL WASTE SURVEYS

    As part of program development and maintenance, the Federal regulations [40 CFR §403.8(f)(2)(l)]  require
 Control Authorities to identify and  locate all lUs that might be subject to the pretreatment program. While the
 General Pretreatment Regulations do not specify how a Control Authority is to accomplish this, it is beneficial to
 conduct an initial in-depth survey, then institute measures to update the list continuously. Control Authorities must
 ensure that the entire service area is reviewed. This may include lUs located outside the jurisdictional boundaries
 of the POTW. In these instances, it may be appropriate to solicit assistance from other jurisdictions in developing
 the list of potential dischargers.  The types of resources that may be consulted in compiling and updating the
 master list include:

        Water and sewer billing records
        Applications for sewer service
        Local telephone directories
        Chamber of Commerce and local business directories
        Business license records
        POTW and wastewater collection personnel and field observations
        Business associations
        Internet

    Once lUs are identified, the Control Authority must classify these users to determine if pretreatment standards
and requirements should apply to these facilities. Typically, the Control Authority develops and distributes an
Industrial Waste Survey (IWS) questionnaire to the identified lUs. The IWS questionnaire requests information
regarding IU activities and the nature of wastes discharged.  The Control Authority may opt to send a detailed
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IWS questionnaire initially or conduct the survey in two phases (i.e., send a screener requesting basic information
to eliminate obvious facilities and then send a detailed IWS to those facilities with greater potential to be SlUs).
Key to the IWS is to identify facilities that are subject to categorical standards (i.e., ClUs) or otherwise have the
potential to impact the POTW (i.e., SlUs).

    A POTW's IU inventory should include the name, location, classification, applicable standards, basis for limits
imposed, volume of discharge, control mechanism status, compliance dates and other special requirements for
each  IU. The IWS should provide most of the information required to develop the inventory, although some
supplementary information might be required from other sources, such as the permit application or monitoring
data.

    The IU inventory must be updated as needed [40 CFR §403.8(f)(2)(l)] and provided to the Approval Authority
as part  of the annual report requirement (see POTW Reports section in this Chapter). The on-going task of
maintaining  a complete list of lUs requires the Control Authority to implement a system to track existing IU
information and/or classification changes and new user information.  Some Control Authorities may proactively
opt to institute a "utility connect questionnaire" program.  These types of forms are completed when a customer
applies  for new utility service (e.g., water, sewerage, or electricity).

PERMITTING

    The General Pretreatment Regulations require all lUs be controlled through permit, order, or similar means
to ensure compliance with applicable pretreatment standards and requirements.  Section 403.8(f)(1 )(iii)(A-E)
clarifies this requirement to specify that all SlUs be issued a permit or equivalent individual control mechanism
which contains, at a minimum:

   . > .  statement of duration (not to exceed five years);
    *   statement of nontransferabililty (unless outlined provisions are met);
    »•   effluent limitations based on applicable standards;    •<
    »•   self-monitoring, sampling, reporting, notification, and record keeping requirements;
    >•   statement of applicable civil and criminal penalties; and
    »   a schedule of compliance (where appropriate).

    EPA's 1989 Industrial User Permitting Guidance Manual details procedures for drafting IU discharge permits.
SIU permits issued are site specific and tailored to the unique circumstances of the IU. Permit conditions must
establish clear and explicit requirements for the permittee, to include using such terms such as "shall" and "must"
in lieu of vague terms such as "recommend" or "may". The Control Authority must document its decision-making
process when developing permits to ensure defensibility and enforceability. Adherence to sound, documented
procedures will prevent any arbitrary and capricious claims by the permittee. Whether developing or reissuing
a permit, the permitting process consists of three phases:

    >   Phase I - Collection and verification of information
        >   Phase II - Data interpretation and fact sheet development
            >   Phase III - Permit development and issuance.

    As  part of Phase I, Control Authorities may review and verify information contained in the permit application,
 perform an  inspection of the IU for confirmation of facts, tally data, and potentially sample and analyze the lU's
wastestream. Knowledgeable Control Authority personnel, effective communication,  and SIU cooperation are
 essential to collection of complete and accurate information.

    Phase II requires that the Control Authority interpret data and other information and document the permit
 decision-making rationale, preferably in a permit fact sheet.  Although the contents of a fact sheet will vary by
 permittee, fact sheets should provide a justification of all permitting decisions. Typical components of a fact sheet
 are provided in Figure 23. Completed fact sheets should be included as part of the permit and provided to the
 Permittee to document the soundness of permitting decisions.
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    POTW Pretreatment Program Responsibilities
                                                                  Introduction to the National Pretreatment Program
      After all permitting decisions are made, the Control
  Authority must Incorporate those decisions into a permit.
  The permit, signed by the specified Control Authority
  official is provided to the Permittee for comment and
  after comments are addressed, a final permit is issued
  to the IU.   While many comments  may be easily
  addressed/resolved     by  the  Control  Authority,
  occasionally resolution must be obtained through a
  formal adjudicatory hearing  process where both the
  Permittee and Control Authority present their case to a
  third party.

      Many POTWs also control contributions from non-
  SIUs using various means, such as through general
  permits issued to an  entire industrial  sector.  These
  types of control  mechanisms  may  not necessarily
  require compliance with  specific pollutant limitations.
  For example:

  >•   grease  trap  maintenance  and  record keeping
     requirements  for food establishments;
    For CIUs:
    • the basis for the categorical determination(s)

    • the identity and flow volume of all wastestreams
      generated and discharged to the POTW, and classified
      accordingly (i.e., regulated, unregulated, or dilution)

    • data used and/or justification for estimates used to
      determine categorical limitations

    • basis for limits imposed for categorical parameters.

    For SIUs/CIUs:
      basis for limits imposed for non-categorical parameters

      rationale for compliance schedules, special plans required,
      special conditions, etc.

      basis for monitoring and reporting frequencies.
  Figure 23. Components of Permit Fact Sheet
 >•   maintenance and record keeping requirements for photo processors' silver reclamation units;

 »•   best management practices for mercury recovery by hospitals and dentists.

     Industrial sector general permitting programs are common where a real or potential POTW problem is linked
 to a particular pollutant discharged (e.g., collection system blockages caused by the discharge of excess oils and
 grease from food establishments). POTWs do have authority to enforce their SUO or rules or regulations against
 nonrStUs without the need for any type of individual control mechanism. Control Authorities do have the authority
 to require non-SIUs to comply with pretreatment standards and requirements contained in their local regulations
 and then take appropriate actions against lUs as noncompliance is identified.
 INSPECTIONS

     Control  Authorities are required to inspect and
 sample all SIUs a minimum of once per year pursuant
 to 40 CFR §403.8(f)(2(v).  The frequency with which a
 Control Authority actually inspects an SIU  may vary
 depending on issues such as the variability of an SlU's
 effluent, the impact of their discharge on the POTW,
 and their compliance history. Inspection considerations
 (see Figure 24) will hinge  upon the type of inspection
 performed (i.e., scheduled, unscheduled or demand).
 EPA's 1994 Industrial User Inspection and  Sampling
 Manual for POTWs provides a detailed reference for
 Inspection procedures and protocols.

    Scheduled inspections are useful when the Control
Authority wants to gather specific information from the
facility that necessitates  meeting with  specific SIU
contacts. However, since  scheduled inspections may
Interrupt normal operations (e.g.,  altered production
schedule as a result of preparative work undertaken by
the III), unscheduled inspections may more accurately
reflect IU compliance status when the inspection is performed for that reason.
      Provide current data on Ills
      Confirm or determine IUs' compliance status
      Determine completeness and accuracy of the lU's
      performance/compliance records
      Assess the adequacy of the lU's self-monitoring and
      reporting requirements
      Assess the adequacy of monitoring locations and lU's
      sampling techniques
      Assess the adequacy of imposed limitations and
      pollutants of concern
      Develop rapport with IUs
      Evaluate operation and maintenance and overall
      performance of an lU's pretreatment system
      Assess the potential for spills and slug loadings
      Evaluate the effectiveness of slug control plan
      Reveal issues requiring action
      Identify noncompliance needing resolution
      Suggest pollution prevention opportunities
      Collect samples
      Obtain data to support enforcement actions
Figure 24. Inspection Considerations
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 Introduction to the National Pretreatment Program
POTW Pretreatment Program Responsibilities
    POTWs must evaluate, at least once every two years, whether each SIU needs a plan to control slug
discharges (i.e., a discharge of a non-routine, episodic nature, including but not limited to an accidental spill or
non-customary batch discharge).  To accurately evaluate the slug potential, Control Authorities likely will have
to examine the SIU during normal operating conditions. If undetected, slug discharges can have serious impacts
on the POTW.  EPA's 1991 Control of Slug Loadings to POTWs Guidance Manual provides a description of
procedures for development, implementation, and review of slug control plans.

    Demand inspections are non-routine in nature and occur in response to a concern (e.g., POTW collection
problems downstream from an IU, elevated enforcement actions against an IU, suspicious IU behavior, or an
informer complaint).

    Routine Control Authority inspections of SlUs typically consist  of three activities; preparation, on-site
assessment, and follow-up.

    Preparation - Control Authority personnel should review POTW records for  SlUs to be inspected to
    familiarize themselves with the facility. Information reviewed may include compliance status, compliance
    schedule activities, reports and plans, upcoming report and plan due dates, enforcement activities, permit
    applications, waste surveys, previous inspection summaries,  categorical regulations, water use/billing
    records, and POTW collection system  maps. Control Authority personnel should also be familiar with any
    specific issues and concerns regarding the POTW treatment plant or collection system problems receiving
    the SlU's discharge.

    On-site Assessment - Control Authority personnel typically discuss IU operations with IU contacts and
    perform a walkthrough of the facility to: update IU information regarding contacts, processes, production
    rates, pretreatment, and other waste management activities; review records required to be kept by the IU;
    visually verify the need for a slug control plan; and review pretreatment system  maintenance, categorical
    standards applicable to processes employed, metering and sampling  equipment, sampling procedures,
    chemicals used, processes employed, management practices, containment structures, locations of floor
    drains, etc.  Many POTWs have developed a standard inspection questionnaire to facilitate the interview
    process and promote consistency during the inspection.

    Follow-up - An inspection report should be prepared as soon as possible after the inspector returns to the
    office. Unanswered questions, required permit modifications, and/or necessary enforcement actions should
    be processed in a timely manner.

    Non-routine inspections (e.g., demand) may not encompass all the activities and steps specified above, but,
like routine inspections, these  activities may provide the Control Authority an opportunity to collect samples of
the lU's discharge.

SAMPLING

    The General Pretreatment Regulations require Control Authorities to monitor each SIU at least annually and
each SIU to self-monitor semi-annually. As with inspections, the Control Authority should assess site-specific
issues, such as SIU effluent variability,  impact of this effluent on the POTW, and the SlU's compliance history
to determine appropriate sampling frequencies (i.e., if more frequent monitoring is necessary). A more detailed
discussion of IU monitoring requirements is provided in Chapter 5. For more detailed information on sampling
frequencies, consult EPA's 1994 Industrial User Inspection and Sampling Manual for POTWs.

    Sampling is the most appropriate method for verifying compliance with pretreatment standards. Monitoring
location(s) are designated by the Control Authority and must be such that compliance with permitted discharge
limits can be determined. Where possible, the Control Authority should not designate monitoring locations that
are confined spaces or that are difficult to access or difficult to place the automated sampling equipment.
Monitoring locations should:

    f   be appropriate for waste stream conditions;
    >•   be representative of the discharge;
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   POTW Pretroatment Program Responsibilities
Introduction to the National Pretreatment Program
     >  have no bypass capabilities; and
     »•  allow for unrestricted access at all times.

     Control Authorities should measure flow to allow for collection of flow-proportioned composite samples, which
 are required, unless flow-proportional  sampling is  not feasible.   Flow-proportional composite samples are
 preferred over time composite samples particularly where the monitored discharge is intermittent or variable.
 Desired analyses dictate  the  preparation  protocols,  equipment, and collection bottles to use  to avoid
 contamination of samples or loss of pollutants through improper collection. Sampling for such pollutants as pH,
 cyanide, oil and grease, flashpoint, and volatile organic compounds require manual collection of grab samples.
 Similar to composite samples, grab samples must be representative of the monitored discharge and are to be
 collected from actively flowing wastestreams.  Fluctuations in flow  or the nature of the discharge may require
 collection of and hand-compositing of more than one grab sample to accurately access compliance. To ensure
 defensibility of data, Control Authorities should develop and implement standard operating procedures and
 policies detailing sample collection and handling protocols in accordance with 40 CFR Part 136.

    Adherence  to proper sample collection and handling protocols, 40 CFR Part 136 approved analytical
 methodologies, and record keeping requirements [40 CFR §403.12(o)(1)] (see Figure 25) can be verified through
 review of field measurement records, chain of custodies, and lab  reports. Field  measurement records may
 require information regarding sample location, condition of and programmed settings for sampling equipment,
 wastewater meter readings, and information for such  parameters as pH and temperature which require analysis
 In the field.  Chain of custody forms serve as a link between  field personnel and the laboratory and contain
 information regarding sample matrix, type, and handling. Lab reports should contain the minimum information
 specified  in 40  CFR §403.12(o)(1)(ii-iv) as well as any additional information  necessary to demonstrate
 compliance with 40 CFR Part 136 requirements (e.g., analytical methodology, sample preparation date and time,
 time of analysis). Use of standardized forms which prompt recording of information necessary for demonstrating
 compliance with applicable requirements, will aid  in ensuring it  can be used  as admissible evidence in
 enforcement proceedings or in judicial actions.

  Figure 25.  Sample Collection Techniques
Parameter
pit
BOD
TSS
NHjasN
Oil and Grease
Cyanide, total
Metals (total) excl.Cr",
B. tndHg
£24 (volatilcs organic*)
625 (semi-volatile
organics)
Sample type
Grab
Composite
Composite
Composite
Grab
Grab
Composite
Grab
Composite
Container
Polyethylene or Glass
Polyethylene or Glass
Polyethylene or Glass
Polyethylene or Glass
Glass
Polyethylene or Glass
Polyethylene or Glass
Amber glass, w/ teflon septum
lid and zero headspace
Amber glass w/ teflon lined lid
Preservative
N/A
chilled to 4°C
chilled to 4°C
chilled to 4°C, H,S04 to pH<2
chilled to 4°C, HC1 or HUSO, to pH<2
chilled to 4°C, NaOH to a pH >12, and 0.6g of
ascorbic acid if residual chlorine is present
HNO3 to pH<2
chilled to 4°C (additional laboratory
preservation required)
chilled to 4°C (additional laboratory
preservation required)
Holding time
analyze immediately
48 hours
7 days
28 days
28 days
14 days
6 months
7 or 14 days, depending on
specific organic
7 days for sample prep; 40
days for extract
ENFORCEMENT

    In  addition to requirements  for permitting,  sampling, and  inspecting I Us,  the  General Pretreatment
Regulations also require Control Authorities to review IU reports and plans, and  respond to instances of IU
noncompliance in a timely, fair, and consistent manner. Enforcement of pretreatment requirements is a critical
element of the Pretreatment Program, but in the past extenuating  circumstances may have prevented POTWs
from taking adequate enforcement. For example, political and economic pressures from local officials could keep
POTW personnel from taking appropriate actions. After this was identified as a major concern, EPA promulgated
regulations in 1990 (55 FR 30082) that require all POTWs with approved pretreatment programs to adopt and
implement an Enforcement Response Plan (ERP). These ERP regulations, at 40 CFR §403.8(f)(5), establish
a framework for  POTWs to formalize procedures  for investigating and  responding to  instances of  IU
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  Introduction to the National Pretreatment Program
                   POTW Pretreatment Program Responsibilities
noncompliance. With an approved ERP in place, POTWs can enforce against IDs on a more objective basis and
minimize outside pressures.

    To evaluate IU compliance, Control Authorities must first identify applicable requirements for each IU.  In
general, IU reports (discussed in Chapter 5) and POTW monitoring activities are the basis for POTW evaluation
of IU compliance. Discharge permit limit exceedances, discrepancies, deficiencies, and lateness are ail violations
that must be resolved.

    To ensure enforcement response is appropriate and that the Control Authority actions are not arbitrary or
capricious, EPA strongly recommends that an Enforcement Response Guide (ERG) be included as part of the
approved ERP. The ERG identifies responsible Control Authority officials, general time frame for actions,
expected IU responses, and potential escalated actions based on:

    >•   the nature of the violation
            pretreatment standards
            reporting (late or deficient)
            compliance schedules
    »   magnitude of the violation
    >•   duration of the violation
    f   frequency of the violation (isolated or recurring)
    >•   (potential) impact of the violation (e.g., interference, pass through, or POTW worker safety)
    »•   economic benefit gained by the violator
    >•   attitude of the violator
The types of questions that dictate whether an
ERP is adequate are presented in Figure 26.
Factors that should be considered in determining
appropriate   enforcement   responses  to
noncompliance events are discussed in detail in
EPA's  1989  Guidance for Developing Control
Authority Enforcement Response Plans.

    The General Pretreatment Regulations set
as an enforcement priority, facilities that meet
the  criteria  for  "Significant  Noncompliance
(SNC)" as  defined  in 40 CFR §403.8(f)(2)(vii)
and depicted in Figure 27. A decision to seek
formal  enforcement is generally triggered by an
unresolved instance of SNC, failure to achieve
 Q:  Is a Control Authority response required for all violations
     identified?
 Q:  Is the IU notified by the Control Authority when a violation is
     found?
 Q:  Is the IU required to respond to each violation with an
     explanation and, as appropriate, a plan to correct the violation
     within a specified time period?
 Q:  Where noncompliance continues and/or the IU response is
     inadequate, does the Control Authority's response become
     more formal and commitments (or schedules, as appropriate)
     for compliance established in an enforceable document?
 Q:  Is the enforcement response selected related to the
     seriousness of the violation?
 Q:  Where the violation constitutes SNC, and is ongoing, is the
     minimum response an administrative order?
Figure 26. How Complete is Your ERG?
compliance in a specified time period through
less formal means, or the advice of legal counsel. SNC evaluations are to be conducted in six-month increments;
names of I Us found to be in SNC must be published in the local newspaper (see Public Participation in this
Chapter).

    Formal enforcement must be supported by well-documented records of the violations and of any prior efforts
by the Control Authority to obtain compliance. Where effluent limitations have been exceeded, records must be
reviewed to verify compliance with 40 CFR Part 136 test methods. If the IU has received conflicting information
from the Control Authority regarding its compliance status, its status must be clarified in writing. Although not
required, the Control Authority may consider a "show cause" meeting with the IU before commencing formal
enforcement action. Similarly, the regulations do allow, in certain instances, an affirmative defense for violations.

    The range  of enforcement mechanisms available  to a Control Authority depends on the specific legal
authorities it has been given by city, county, and State legislatures. These mechanisms may range from a simple
telephone call to suits seeking significant criminal penalties. Common enforcement mechanisms include:
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   POTWPretrsatment Program Responsibilities
                Introduction to the National Pretreatment Program
 >•   Informal notice to IU - This may consist of
     a telephone call or "reminder" letter to an
     appropriate IU  official to notify them of a
     minor violation and to seek an explanation.
     Such informal notice may be used to correct
     minor instances of noncompliance.

 >   Informal meetings - Used to obtain an lU's
     commitment   to   comply   with   their
     pretreatment obligations or to inform the IU
     of  stronger   enforcement  mechanisms
     available for unresolved and/or continued
     noncompliance.

 >•   Warning  letter or  Notice of Violation
     (NOV) - Written notice to the IU in response
     to a violation of pretreatment standards or
     requirements. These notices should request
     an explanation of the noncompliance and
     measures that will  be taken  to eliminate
     future violations.

 *   Administrative orders and compliance
     schedules  - Thetse require an IU to "show
     cause" to the Control Authority  as  to why
     formal  enforcement action  should  not be
     taken and/or sewer service discontinued, or
     actions  that will be taken to comply with
     pretreatment standards or  requirements.
     Orders  as such may be negotiated  (i.e.,
     Consent Order) or issued at the reasonable
     discretion of  thej. Control  Authority  (i.e.,
     Compliance Order).  For more egregious or
     serious violations, the Control Authority may
     issue a Cease and Desist Order.

 >    Administrative fines   -  Assessed by
     Control Authorities against lUs for violations
     and intended to recapture  partial  or full
     economic benefitforthe noncompliance and
     to deter future violations.
    An IU is in SNC if its violation meets one or more of
    the following criteria (40 CFR 403.8(f)(2)(vii):

 (A) Chronic violations of wastewater discharge limits, defined here
 as those in which sixty-six percent or more of all of the
 measurements taken during a six-month period exceed (by any
 magnitude) the daily maximum limit or the average limit for the
 same pollutant parameter;

 (B) Technical Review Criteria (TRC) violations, defined here as
 those in which thirty-three percent or more of all of the
 measurements for each pollutant parameter taken during a six-month
 period equal or exceed the product of the daily maximum or the
 average limit multiplied by the applicable TRC (TRC = 1.4 for
 BOD5, TSS, fats, oil, and grease, and 1.2 for all other pollutants
 except pH);

 (C) Any other violation of a pretreatment effluent limit (daily
 maximum or longer-term average) that the Control Authority
 determines has caused, alone or in combination with other
 discharges, interference or pass through (including endangering the
 health of POTW personnel or the general public);

 (D) Any discharge of a pollutant that has caused imminent
 endangerment to human health, welfare or to the environment or has
 resulted in the POTW's exercise of its emergency authority under
 40 CFR § 403.8(f)(l)(vi)(B) of this section to halt or prevent such a
 discharge;

 (E) Failure to meet, within 90 days after the schedule date, a
 compliance schedule milestone contained in a local control
 mechanism or enforcement order for starting construction,
 completing construction, or attaining final compliance;

 (F) Failure to provide, within 30 days after the due date, required
reports such as baseline monitoring reports, 90-day compliance
reports, periodic self-monitoring reports, and reports on compliance
with compliance schedules;'

(G) Failure to accurately report noncompliance;

(H) Any other violation or group of violations which the Control
Authority determines will adversely affect the operation or
implementation of the local pretreatment program.
                                                Figure 27. Definition of Significant Noncompliance (SNC)
    Civil suits   -  Formal  process of filing
    lawsuits against lUs to correct violations and to obtain penalties for violations. Civil penalty amounts are
    generally limited through State or municipal laws. However, 40 CFR §403.8(f)(1)(vi) requires that Control
    Authorities have the legal authority to seek or assess civil or criminal penalties of at least $1,000 per day for
    each violation. A civil suit for injunctive relief may be used when the IU is unlikely to successfully execute
    the steps that the Control Authority believes are necessary to achieve or maintain compliance, when the
    violation is serious enough to warrant court action  to deter future similar violations,  or when the danger
    presented by an lU's lengthy negotiation of a settlement is intolerable.

    NOTE:  Surcharges are not penalties or fines. Surcharges are intended to recoup the cost of treatment
    of wastes by the POTW and must not be used to allow discharges of toxic pollutants that cause
    interference or pass through.
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  Introduction to the National Pretreatment Program
        PQTW Pretreatment Program Responsibilities
>   Criminal prosecution - This type of enforcement is a formal judicial process where sufficient admissible
    evidence exists to prove beyond  a reasonable doubt that a person  has willfully or negligently violated
    pretreatment standards  or that a  person  has knowingly made a false statement regarding any  report,
    application, record, or other document required by the General Pretreatment Regulations. As noted  above,
    Control Authorities must have the legal authority to seek or assess civil or criminal penalties of at least  $1,000
    per day for each violation. Examples of criminal violations include falsification of data and tampering with
    sampling results or equipment.

»   Termination of service (revocation of permit) - These actions may be pursued by Control Authorities to
    immediately halt an actual or threatened discharge to the POTW that may represent an endangerment to the
    public health, the environment, or the POTW.  Use of these remedies may also be used  in bringing
    recalcitrant users into compliance.

    Regardless of the response taken, the Control Authority should document and track all contact, notices, and
meetings with lUs and ID responses. Control Authority responses and IU responses (or lack thereof) should be
documented and include a record of any direct contact with the IU to attempt to resolve the noncompliance.
Control Authorities must take timely and effective enforcement against violators. Unresolved IU noncompliance
may result in the Approval Authority enforcing directly against the IU and/or the Control Authority. EPA may also
take enforcement action where it deems action by the State or the Control Authority is inappropriate. An Approval
Authority will routinely review the overall performance of a Control Authority in monitoring lUs, identifying
violations, and in enforcing regulations. Performance will be evaluated based on POTW self-monitoring data,
written enforcement response plans, audits, inspections, and pretreatment program reports.  Therefore, it is
essential for Control Authorities to effectively manage program information to demonstrate proper implementation.

    Section 505 of the CWA allows citizens to file suit against a Control Authority that has failed to implement its
approved pretreatment program as required by its NPDES permit.  The Control Authority may be fined as well
as required to enforce against violations of pretreatment standards and requirements in a court order.

DATA MANAGEMENT AND RECORD  KEEPING

    Any IU subject to pretreatment program reporting requirements is required to maintain records resulting from
monitoring in a readily accessible  manner for  a minimum of 3 years (longer if during periods of any ongoing
litigation). While the means for maintaining files is usually at the discretion of the POTW, all pretreatment
activities should be documented and the documents maintained. Types of IU records that the Control Authority
should maintain are summarized in Figure 28.
    Tracking  due  dates,  submissions,   deficiencies,
notifications,   etc.  and  calculating  effluent  limitation
noncompliance may be facilitated by a computerized data
management system. Similarly, many Control Authorities use
standardized forms (e.g., inspection questionnaires, chains-
of-custody, field measurement records) and procedures (e.g.,
sampling, periodic compliance report reviews) to  promote
consistency and organization of program data.

    In addition to  specific  IU records,  Control Authorities
should also maintain general program files that document
specific program development and implementation activities
that are  not lU-specific (see Figure 29).  All information
should be filed  in an orderly  manner and be readily
accessible for inspection and copying by EPA and  State representatives or the public.  The pretreatment
regulations specify that all information submitted to the Control Authority or State must be available to the public
     Industrial waste questionnaire
     Permit applications, permits and fact sheets
     Inspection reports
     IU reports
     Monitoring data (including laboratory
     reports)
     Required plans (e.g., slug control, sludge
     management, pollution prevention)
     Enforcement activities
     All correspondence to and from the IU
     Phone logs and meeting summaries.
Figure 28. Types of IU Records Retained
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   POTWPretreatment Program Responsibilities
           Introduction to the National Pretreatment Program
 without restriction, except for  confidential  business
 Information.
 PUBLIC PARTICIPATION AND POTW REPORTING
    >  Legal authority (e.g., SUO)
    >•  Program procedures
    >  Program approval and modifications
    >•  Copy of POTW NPDES permit(s)
    *•  Local limits development
    »  ERP
    »•  Correspondence to and from EPA/State
    *  Annual reports to the Approval Authority
    >  Public notices
    *•  Funding and resource changes
    >•  Applicable Federal and State regulations
    *•  IU compliance and permitting records
     Section 101(e)  of the CWA establishes public
 participation as one of its goals, in the development,
 revision, and enforcement of any regulation, standard,
 effluent limitation, plan, or program established by EPA
 or any State.  The General Pretreatment Regulations
 encourage public  participation  by  requiring public
 notices and/or hearings for program approval, removal credits, program modifications, local limits development
 and modifications, and IDs in SNC.
Figure 29. Types of POTW Records Retained
    POTW pretreatment  program  approval requests
 require  the Approval Authority  to publish a  notice
 (Including a notice for a public hearing) in a newspaper
 of general circulation within the jurisdiction served by
 the POTW. All comments  regarding the request as well
 as any request for a public hearing must be filed with
 the Approval Authority within the specified comment
 period, which generally last  30 days.  The Approval
 Authority is required  to  account  for  all comments
 received when  deciding  to approve or  deny  the
 submission. The decision is then provided to the POTW
 and other interested parties, published in the newspaper
 with all comments received available to the public for
 inspection and copying.

    Once a local pretreatment program is approved, the
 Control  Authority must implement  that  program  as
 approved.  Before there is a  significant change in the
 operation of a POTW pretreatment program, a program
 modification must be initiated.

    For substantial program modifications (see Figure
 30), the  Control  Authority is required to  notify  the
 Approval Authority of the desire to modify its program
 and the basis for the change.  These changes become
 effective  upon  approval.   Approval  Authorities  (or
 POTWs) are required to public notice the request for a
 modification, but are not required to public notice the
 decision if no comments are received and the request is
 approved without changes.
  1.   Modifications that relax POTW legal authorities (as
      described in 40 CFR §403.8(f)(l)), except for
      modifications that directly reflect a revision to 40
      CFR Part 403, and are reported pursuant to 40 CFR
      §403.18(d) - Approval procedures for nonsubstantial
      modifications;
  2.   Modifications that relax local limits, except for
      modifications to local limits for pH and reallocations
      of the Maximum Allowable Industrial Loading of a
      pollutant that do not increase the total industrial
      loadings for a pollutant, which are reported pursuant
      to 40 CFR §403.18(d) - Approval procedures for
      nonsubstantial modifications;
  3.   Changes to POTW's control mechanism, as described
      in40CFR§403.(f)(l)(iii);
  4.   A decrease in the frequency of self-monitoring or
      reporting required of industrial users;
  5.   A decrease in the frequency of industrial user
      inspections or sampling by the POTW;
  6.   Changes to the POTW's confidentiality procedures;
      and
  7.   Other modifications designated as substantial
      modifications by the Approval Authority on the basis
      that the modification could have a significant impact
      on the operation of the POTW's Pretreatment
      Program; could result in an increase in pollutant
      loadings at the POTW; or could result in less stringent
      requirements being imposed on Industrial users of the
      POTW.
Figure 30.   Substantial Modifications of POTW
            Pretreatment Programs (40 CFR §403.18)
    Nonsubstantial modifications must also be submitted to the Approval Authority for review and approval, but
these changes do not require public notice. And unlike substantial modifications, nonsubstantial modifications
become effective 45 days after submission unless the Approval Authority notifies the POTW otherwise.

    The POTW is also required to provide annual publication, in the largest daily newspaper in the municipality
In which the POTW is located, of lUs that at any time during the previous twelve months were in SNC.
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 Introduction to the National Pretreatment Program
POTWPrefreatment Program Responsibilities
    In accordance with 40 CFR §403.12(1), Control Authorities are required to submit annual reports to the
Approval Authority documenting program status and activities performed during the previous calendar year. At
a minimum, these reports must contain the following information:

    1.  List of all POTW's lUs including names, addresses, pretreatment standards applicable to each user,
       IDs subject to categorical pretreatment standards or a brief explanation of deletions and a list of
       additions (with the aforementioned information) keyed to a previously submitted list;

    2.  A summary of the status of the IU  compliance during the reporting period;

    3.  A summary of compliance and enforcement activities (including inspections) conducted by  the
       POTW during the reporting period;

    4.  A summary of changes to the POTW's pretreatment program that have not been previously reported
       to the Approval Authority; and

    5.  Any other relevant information requested by the Approval  Authority.

    The first report is due within  one year after program approval and at least annually thereafter.  Approval
Authorities may require additional information, or require that the reports be submitted in a specific format and/or
at an increased frequency (e.g., semi-annually).
  Chapter 4
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                                                                                                          Chapter 4

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Introduction to the National Pretreatment I
                                                    Industrial User Pretreatment Program Responsibilities
5.   INDUSTRIAL     USER    PRETREATMENT
       PROGRAM  RESPONSIBILITIES
       Chapter B, Applicable EPA Guidance
Guidance Manual For Implementing Total Toxic Organics (TT6)
  "' , Pretreatment Standards   " r- 1,,,,     ,,  ' , . ,1 ' ,, ..,-•-
Guidance Manual for the Identification of Hazardous Wastes
   Delivered to Publicly Owmeci Treatment Works by Truck, Rail, i
   Dedicated Pipe  -   "^      •;>,  ''',	 '„,'  •  >•/  ,'j
Guidance Manual for the Use of Productfon-Baspd Pretrea.tment
   Standards and ,the Combined Wasteslream, ftormula
Industrial User Inspection and 'Sampling Manual for POTWs
RGRA Information on Hazardous Wastes for Publicly Owned
   Treatment Works  ,
    Industrial Users (lUs) are required to
comply with all applicable pretreatment
standards   and   requirements.
Demonstration  of  compliance requires
certain ILJs to submit reports, self-monitor,
and maintain records.  A summary of the
reporting requirements are provided in
Figure 32, with details of each of these
requirements discussed below.

REPORTING REQUIREMENTS

    Minimum   Federal   Pretreatment
Program reporting requirements  for lUs
are specified in 40 CFR §403.12. Since
Control  Authorities are responsible for
communicating applicable standards and
requirements to I Us and for receiving and
analyzing reports, it is  essential for
Control Authority personnel to understand
IU reporting and notification requirements
contained in the  General Pretreatment
Regulations.  These  requirements are
summarized below.

Categorical Industrial User (CIU) Reporting Requirements

    Baseline Monitoring Report (BMR) f40 CFR S403.12(b)1

    Each existing  IU that  is subject to a categorical pretreatment standard (identified as a Categorical
Industrial User, or CIU) is required to submit a BMR within 180 days after the effective date of the standard.
If a category determination has been requested, the BMR is not due until 180 days after a final administrative
decision has been made concerning the industry's inclusion in the category. The BMR must contain the
following information:
               Industry-Specific Guides
Aluminum, Copper, And Nonferrous Metals Forming And Metal
   "Powders Pretreatment Standards: "A Guidance Manual      "
Guidance Manual For Battery Manufacturing Pretreatment Standards
Guidance Manual for Electroplating and Metal Finishing Pretreatment
    Standard     "    '"" " '      „,&''•'•  ."'  ',, "F
Guidance Manual For Iron And Steel Manufacturing Pretreatment
    Standards                         -      ^   ,-.&
Guidance Manual for Leather Tanning and Finishing Pretreatment
    Standards    .                   .          1&-
• Guidance Manual for Pulp, Paper, and Paperboard and Builders'  .;
    Paper and Bpard_M|lls Pretreatment Standards '          " .
        name and address of the facility and names of the operator and owners
        list of all environmental control permits held by or for the facility
        description of operations, including the average rate of production, applicable Standard Industrial
        Classification (SIC) codes, schematic process diagrams, and points of discharge to the POTW from
        regulated processes
        flow measurements (average daily and maximum daily) for regulated  process wastestreams and
        nonregulated wastestreams, where necessary
        pollutant measurements [daily maximum, average concentration, and mass (where applicable)]and
        applicable standards
        certification, by a qualified professional,  reviewed by a  representative  of the  CIU, of whether
        applicable pretreatment standards are being met and, if not, a description of the additional operation
        and maintenance (O&M) or pretreatment facilities that are needed to comply with  the standards
        a schedule by which the IU will provide the additional O&M or pretreatment needed to comply with
        the applicable pretreatment standards.
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  In addition to the certification noted above, BMRs must be signed and certified as detailed in 40 CFR
  §403.12(1) and as described later in this Chapter.  If a CIU has already submitted the specific information
  required in a permit application or data disclosure form and this information is still current, it need not be
  reproduced and resubmitted in the BMR.  The BMR is a one-time report, unless changed Federal categorical
  standards require submission of a new BMR.

     At least 90 days prior to commencement of discharge, new sources are required to submit the above
  Information, excluding the certification and compliance schedule, and information on the method that the
  source intends to use to meet the applicable pretreatment standards.

     Compliance Schedule Progress Report T40 CFR S403.12(cW3^

     A CIU that is not in compliance with applicable categorical standards by the time the standards are
  effective often will have to modify process operations and/or install end-of-pipe treatment to comply. Federal
  regulations require that the Control Authority develop and impose a compliance schedule for the CIU to install
  technology to meet applicable standards.  As part of the BMR, a CIU that is unable to comply with the
  categorical standards must include a schedule for attaining compliance with the discharge standards. In no
  case can the final or completion date in the schedule be later than the final compliance date specified in the
  categorical standards. If deemed appropriate, the Control Authority may require compliance earlier than the
  final compliance date specified in the Federal regulations.

     Compliance schedules are to contain increments of progress in the form of dates (not to exceed nine
  months per event) for commencement and completion of major actions leading to construction and operation
  of a pretreatment system and/or in-plant process modifications.  Major activities could  include hiring an
  engineer, completing preliminary analysis and evaluation, finalizing  plans, executing a contract for major
  components, commencing construction, completion of construction, or testing operation.

     In addition, the CIU must submit progress reports to the Control Authority no later than  14 days following
 each date in the compliance schedule (and final date for compliance), that include:

     >•   a statement of the ClU's  status with respect to the compliance schedule
     »   a statement of when the CIU expects to be back on schedule if it is falling behind, and the reason for
        the delay and steps being taken by the IU to return to the established schedule.

     The Control Authority should review these reports as quickly as possible. When a CIU is falling behind
 schedule, the Control Authority should maintain close contact with the CIU. If the CIU fails to demonstrate
 good faith in meeting the schedule, the Control Authority may consider initiating appropriate enforcement
 action to correct the problem(s).

     90-Day Compliance Reports  F40 CFR S403.12frn

     Section 403.12(d) of the General Pretreatment Regulations requires a CIU to submit a final compliance
 report to the Control Authority. An existing source must file a final compliance report within 90 days following
 the final compliance date specified in a categorical regulation or within 90 days of the compliance date
 specified by the Control Authority, whichever is earlier. A new source must file  a compliance report within 90
 days from commencement of discharge to the POTW. These reports must contain:

     "   flow measurements (average daily and maximum daily) for regulated process wastestreams and
        nonregulated wastestreams, where necessary
    »•   pollutant measurements [daily maximum, average concentration, and mass (where applicable)] and
        applicable standards
    »•   certification,  by a qualified professional,  reviewed by  a representative  of the CIU, of whether
        applicable pretreatment standards are being met and, if not, a description of the additional operation
        and maintenance (O&M) or pretreatment facilities that are needed to comply with the standards. In
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Introduction to the National Pretreatment Program
                                                                                 gram Responsibilities
        addition to the certification noted above, 90-day final compliance reports must be signed and certified
        as detailed in 40 CFR §403.12(1) and as described later in this Chapter.
    Upset Reports f40 CFR §403.161

    ClUs are allowed  an affirmative defense for
noncompliance with categorical standards if they
can demonstrate that the noncompliance was the
result  of  an  upset  (Figure 31).   Conditions
necessary  to demonstrate an upset has occurred
are detailed in 40 CFR §403.16 and require the CIU
to submit  at least an oral report to the Control
Authority within 24 hours of becoming aware of the
upset and containing the following information:
 Upset is defined as an exceptional incident in which there is
 unintentional and temporary noncompliance with categorical
 standards due to factors beyond the reasonable control of the
 CIU. An upset does not include noncompliance to the extent
 caused by operational error, improperly designed or
 inadequate treatment facilities, lack of preventative
 maintenance, or careless or improper operation.
Figure 31. Definition of Upset (40 CFR §403.16)
    »•   a description of the indirect discharge and the cause of the noncompliance
    f   the date(s) and times of the noncompliance
    >   steps being  taken and/or  planned to reduce, eliminate,  and prevent  reoccurrence of the
        noncompliance.

 If this notification is provided orally, a written report must also be submitted within five days.  In any
 enforcement action, the  IU has the burden of proof in establishing that an upset has occurred.  EPA is
 responsible for determining the technical validity of this claim.

 Categorical  and Significant Industrial User (Sim Reporting Requirements

    Periodic  Compliance Reports T40 CFR S4Q3.12 (e) & (h)1

    After the final compliance date, ClUs are required to report, during the months of June and December,
 the self-monitoring results of their wastewater discharge(s).  The Control Authority must also require
 semi-annual  reporting from SlUs not subject to categorical standards. EPA established a minimum frequency
 of once every six months, determining this to be adequate for small SlUs or other facilities that have little
 potential  to cause pass-through or interference or to contaminate the sewage sludge. EPA assumed that
 larger lUs and those that have more potential to cause problems would be required by the Control Authority
 to sample and  report more often. All results for self-monitoring performed must be reported to the Control
 Authority, even if the IU is monitoring more frequently than required. Periodic compliance reports must include:

    »  nature and concentration of pollutants limited by applicable categorical standards or required by the
        Control Authority
    >  flow data (average and maximum daily) as  required by the Control Authority
    >  mass of pollutants discharged (applicable to ClUs where mass limits have been imposed)
    >  production rates (applicable to ClUs where equivalent limits have been imposed or where limits
        imposed are expressed in allowable pollutant discharged per unit of production).

 A Control Authority may choose to monitor lUs in lieu of the IU performing the self-monitoring.

    Additionally, 40 CFR §403.12(e) and (h) require compliance with 40 CFR Part 136 (Guidelines for
 Establishing Test Procedures for the Analysis of Pollutants).   To demonstrate compliance with  these
 requirements,  lUs may have to submit information regarding sample handling and analytical procedures to
 the Control Authority.  Development of standardized forms for use by lUs and their testing labs can facilitate
 documentation and submission of all required information and can streamline the IU and Control Authority
 review process.
  Chapter 5

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  Industrial User Pretreatment Program Responsibilities


      Bypass T40 CFR S4Q3.171
Introduction to the National Pretreatment Program
      The General Pretreatment Regulations define "bypass" as the intentional diversion of wastestreams from
  any portion of a users treatment facility. If a bypass results in noncompliance, even if it was due to essential
  maintenance, the IU must provide a report to the Control Authority detailing a description of the bypass and
  the cause, the duration of the bypass, and the steps being taken and/or planned to reduce, eliminate and
  prevent reoccurrence of the bypass.

      Oral notice must be provided to the Control Authority within 24 hours of the detection of an unanticipated
  bypass, with a written follow-up due within 5 days.  For an anticipated bypass, the IU must submit notice to
  the Control Authority, preferably 10 days prior to the intent to bypass.

      Notification of Potential Problems F40 CFR $403.12(fl1

      Al! lUs are required to notify the Control Authority immediately of any discharges which may cause
  potential problems.  These discharges include spills, slug  loads, or any other discharge which may cause a
  potential problem to the POTW.

      Noncornpllance Notification F4Q CFR S403.12(q)(2)l

      If monitoring performed by an IU indicates noncompliance, the IU is required to notify the Control Authority
  within 24 hours of becoming aware of the violation. In addition, the IU must repeat sampling and analysis and
  report  results of the resampling within 30 days. The repeat sampling is not required if the Control Authority
  samples the IU at least once per month or if the Control Authority samples the IU  between the time of the
  original sample and the time the results of the sampling are received.

     Notification of Changed Discharge F40 CFR S403.12(n]

     All lUs are required to promptly notify the Control Authority in advance of any substantial changes in the
 volume or character of pollutants in their discharge.

     Notification  of Discharge of Hazardous Wastes (40 CFR S403.12fD)]

     lUs discharging more than 15 kilograms per month of a waste, which if otherwise disposed of would be
 a hazardous waste pursuant to the RCRA requirements under 40 CFR Part 261 are required to provide a one
 time written notification of such discharge to the Control Authority, State, and EPA.  lUs discharging any
 amount of waste, which if disposed of otherwise, would  be an acutely hazardous waste pursuant to RCRA
 must also provide this notification. This written notification  must contain the EPA hazardous waste number
 and the type of discharge (i.e., batch, continuous). If the IU discharges more than 100 kilograms per month
 of the hazardous waste, the written notification must also include:

     >   an identification of the hazardous constituent in the lU's discharge,
     *   an estimate of the mass and concentration of the constituents in the lU's discharge, and
     >•   an estimate of the mass and concentration of constituents in the lU's discharge in  a year.

 lUs must also provide a certification accompanying this notification that a waste reduction program is in place
 to reduce the volume and toxicity of hazardous wastes to the greatest degree economically  practical Within
 SO days of the effective date of the listing of any additional  hazardous wastes pursuant to RCRA lUs must
 provide a notification of the discharge of such wastes.

    Signatory and Certification Requirements [40 CFR §403.12(h]

    Pursuant to 40 CFR §403.12(1), BMRs, 90-day compliance reports and periodic compliance reports from
CUs must be signed by  an authorized representative of the facility and contain a certification statement
attesting to the integrity of the information reported.  The reports should be signed by one of the following-
                                                                                         Chapter 5

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                                                        Industrial User Pretreatment Program Responsibilities
                                                       m

    >•   a responsible corporate officer if the IU is a corporation
    »•   a general partner or proprietor if the IU is a partnership or sole proprietorship
    >•   a duly authorized representative of the above specified persons if such authorization is in writing,
       submitted to the Control Authority and specifies a person or position having overall responsibility for
       the facility where the discharge originates or having overall responsibility of environmental matters
       for the facility.


As required in 40 CFR §403.6(a)(2)(ii), the certification statement must read as follows:

    "I certify under penalty of law that this document and all attachments were prepared under my
    direction or supervision in accordance with a system designed to assure that qualified personnel
    properly gather and evaluate the information submitted.  Based on my inquiry of the person or
    persons who manage the system, or those persons directly responsible for gathering the information,
    the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
    I am aware that there are significant penalties for submitting false information, including the possibility
    of fine and imprisonment for knowing violations."

While Federal regulations only require Control Authorities to require these signatures and certifications from
ClUs, many POTWs have found it important to impose these requirements for all IU reports. To facilitate
compliance, many Control Authorities have  developed forms that include the certification statement and
signatory requirements for use by all iUs.

SELF-MONITORING REQUIREMENTS

    All SlUs, including ClUs must conduct self-monitoring as part of several different reporting requirements
as noted above. For ClUs, this includes the BMR, 90-day compliance report and periodic compliance reports
(40 CFR §§403.12(b),(d), and (e), respectively). Non-categorical SlUs are required to self-monitor as part
of the periodic reporting requirements (40 CFR §403.12(h)). As noted in 40 CFR §§403.12(g)(4), sample
collection and analysis for all required pretreatment program reports must be conducted using 40 CFR Part
136 procedures and amendments thereto. Refer to Chapter 4 of this manual and EPA's 1994 Industrial User
Inspection and Sampling Manual for POTWs for additional information on sample collection  and analysis
procedures.

    Based on the specific pollutants regulated by categorical standards, different types of samples may have
to be collected.  For BMR and 90-day compliance reports, a minimum of four grab samples must be collected
for pH, cyanide, total phenols,  oil and grease, sulfide, and volatile organics.  If these pollutants are not
regulated by the specific categorical standard, monitoring is not required. Twenty-four hour flow-proportional
composite samples must  be collected for all other pollutants.  The Control Authority  may waive flow-
proportional composite sampling if an IU demonstrates that flow-proportional is not feasible. In these cases,
time-proportional composite samples may be collected.

    Self-monitoring for periodic compliance reports must be conducted in accordance with the lU's discharge
permit requirements.  The Control Authority must ensure that these  permits specify sampling location(s),
required sampling frequencies, sample types to be collected, sampling and analytical procedures (40 CFR
Part 136), and  associated reporting requirements.  At a minimum, ClUs must monitor for all categorically
regulated pollutants at least once every six months,  although, permits issued by the local Control Authority
may require more frequent monitoring.

    In certain instances, ClUs subject to TTO standards may implement alternatives in lieu of monitoring all
regulated toxic organic compounds. A listing of categories that contain TTO standards is provided in Chapter
3.  For example, the electroplating and metal finishing standards allow IUs to monitor only for those toxic
organic compounds that are  reasonably expected to be present. Additional TTO guidance related to the
 Chapter 5
                                                                                             -39-

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  Industrial User Pretreatment Program Responsibilities
                                                            Introduction to the National Pretreatment Proaram
 electroplating and metal finishing categories can be found in EPA's 1984 Guidance Manual for Electroplating
 and Metal Finishing Pretreatment Standards.

     For certain industries (i.e., electroplating, metal finishing,  and electrical and  electronic components)
 Control Authorities have the option  of allowing  the  CIU to  prepare  and implement a  Toxic  Organic
 Management Plan (TOMP) in lieu of periodic monitoring. In those instances, the TOMP should identify all
 potential sources from which toxic organic materials could  enter the wastestream and propose control
 measures to eliminate the possibility. Where a TOMP is allowed, an IU can demonstrate compliance through
 adherence to the TOMP and submission of periodic certification statements attesting to the fact that:

         "no dumping of concentrated  toxic organic pollutants has occurred and that the facility's
         TOMP is being implemented."

 TOMPs cannot be used in lieu of monitoring for BMRs and 90-day compliance reporting requirements.

    The categorical standards for some industries (i.e., aluminum forming, copper forming, coil coating, and
 metal molding and casting) allow lUs to monitor oil and grease (O&G) as an alternative to TTO monitoring.
 This option may be used to fulfill TTO monitoring requirements of the BMR, 90-day compliance report, and
 periodic compliance reports and allows the IU to determine whether it wants to demonstrate compliance with
 the TTO or the O&G standards.  A detailed description of TTO monitoring requirements is provided in EPA's
 1985 Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreatment Standards.

 RECORD KEEPING REQUIREMENTS

    IUs are required to maintain records of their monitoring activities [40 CFR §403.12(o)]. Information, at a
 minimum, shall include the following:

    >   sampling methods, dates and times
    >•   identity of the person(s) collecting the samples and of the sampling location(s)
    »•   the dates the analyses were performed and the methods used
    >   the identity of the person(s) performing the analyses and the results of the analyses.

These records shall be retained for at least 3 years, or longer  in cases where there is pending litigation
Involving the Control Authority or IU, or when requested by the Approval Authority. These records must be
available to the Control Authority and Approval Authority for review and copying.  Historically, most Control
Authorities do not dispose of any records, rather older records are archived at an off-site location.
                                                                                       Chapter 5

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Introduction to the National Pretreatment Program                       Industrial User Pretreatment Program Responsibilities





                             Figure 32. Industrial User Reporting Requirements
REiSuiKED5KEPCIRT AND,, ^
'• ^ CITATION '• 1
==^=^^=^^=^=
Baseline Monitoring Report
(BMR)
40CFR§403.12(b)(l-7)
Compliance Schedule
Progress Reports
40 CFR §403.1 2(c)(l-3)
90-Day Compliance Report
40CFR§403.12(d)
Periodic Compliance Report
40 CFR §403.1 2(e)
Notice of Potential Problems
40 CFR §403.12(J)
Noncompliance Notification
40CFR§403.12(g)(2)
Periodic Compliance Reports
for Noncategorical Users
40 CFR §403.12(h)
Notification of Changed
Discharge
40 CFR §403.120)
Notification of Hazardous
Wastes Discharge
40CFR§403.12(p)
Upset
40 CFR §403.16
Bypass
40 CFR §403. 17
^APPWn.
TO/
CIUs
All lUs
CIUs
CIUs
All lUs
All lUs
Non-Cat.
SIUs
All lUs
All lUs
CIUs
All lUs
A »REPORT0UEDATE ^ 5
-r * , I
Existing Source - Within 1 80 day s of
effective date of the regulation or an
administrative decision on category
determination.
New Source - At least 90 days prior to
commencement of discharge.
Within 14 days of each milestone date on
the compliance schedule; at least every 9
months.
Within 90 days of the date for final
compliance with applicable categorical
pretreatment standard; for new sources, the
compliance report is due within 90 days
following commencement of wastewater
discharge to the POTW.
Every June and December after the final
compliance date (or after commencement
of a discharge for new sources) unless
frequency is increased by the Control
Authority.
Notification of POTW immediately after
occurrence of slug load, or any other
discharge that may cause problems to the
POTW.
Notification of POTW within 24 hours of
becoming aware of violation.
Every six months on dates specified by the
Control Authority.
In advance of any substantial changes in
the volume or character of pollutants in the
discharge.
For new discharges, within 180 days after
commencement of discharge.
24 hours of becoming aware of the upset
(5 days where notification was provided
orally)
10 days prior to date of the bypass or oral
notice within 24 hours of the IU becoming
aware of the bypass with written
notification within 5 day
«-', ^PURPOSE OF REPORT^*'
, ,J ^ 	 ^£ 	 ,"£ 	 «~ "*
- To provide baseline information on
industrial facility to Control Authority
- To determine wastewater discharge
sampling points
- To determine compliance status with
categorical pretreatment standards
- To track progress of the industrial
facility through the duration of a
compliance schedule.
- To notify Control Authority as to
whether compliance with the
applicable categorical pretreatment
standards has been achieved
- If facility is noncompliant, to specify
how compliance will be achieved.
- To provide the Control Authority with
current information on the discharge of
pollutants to the POTW from
categorical industries.
- To alert the POTW to the potential
hazards of the discharge.
- To alert the POTW of a known
violation and potential problems which
may occur.
- To provide the POTW with current
information on the discharge of
pollutants to the POTW from industrial
users not regulated by categorical
standards.
- To notify POTW of anticipated
changes in wastewater characteristics
and flow which may affect the POTW.
- To notify POTW, EPA, and State of
discharges of hazardous wastes under
40 CFR Part 261.
- To notify the POTW of unintentional
and temporary noncompliance with
categorical standards.
- To notify the POTW of noncompliance
and potential problems which may
occur
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Industrial User Pretreatment Pn
                                                                                                        Chapter 5

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Introduction to the National Pretreatment Program
                                                                                   Haufeof Wastes
6.    HAULED  WASTES
                                                     Chapter 6, Applicable EPA Guidance
                                                 CERCLA Site Discharges to POTWs Guidancei Manual
                                                 Guidance Manual for the Identification of Hazardous
                                                     Wastes Delivered to Publicly Owned Treatment
                                                     works 'by TrucH, $aii, or Dedicated pipe
                                                 Industrial :User Inspection and Sampling Manual for
                                                     POTWS      J  !    i
                                                 industrial user Permitting Guidance Manual   _  ,
                                                 RCRA information oHWazardous wastes'ito Publicly
                                                                             ;
                                                 Guidance Manual for the Control of Waste Hauled to
                                                             ned Treatment Works  {    J'
    In addition to receiving wastes through the
collection system, many POTWs accept trucked
wastes, and in a few instances, wastes received via
train.   As  specified in 40  CFR §403.1 (b)(1),
pollutants from non-domestic sources which are
transported to the POTW by truck or rail are also
subject to the General Pretreatment Regulations.
Hauled wastes, like wastes received through the
collection system, have the potential to impact the
POTW, making regulatory control of these wastes
necessary.    Recent  studies  have shown  an
increasing frequency of uncontrolled discharges to
POTWs from waste haulers.   Because of their
unique nature, waste haulers are not regulated in the same way as other types of lUs. Since no specific
Federal regulatory controls exist, some POTWs have developed hauled waste control programs. For more
information  on hauled waste, refer to EPA's 1998 Guidance Manual for the Control of Waste Hauled to
Publicly Owned Treatment Works.

NATURE OF HAULED WASTES

    Wastes are hauled to POTWs for several  reasons.  By far, the majority of hauled waste is domestic
septage (Figure 33). Since these wastes are domestic in nature, treatment at a POTW is the most appropriate
disposal method.  Other types of wastes are also regularly hauled to POTWs for a variety of reasons, such
as:
       the   facility   is   located   outside  the
       jurisdictional boundaries of the POTW (e.g.,
       located in rural areas) and is not connected
       to the collection system,

       the  wastes  may  be  known  to  cause
       collection system problems,  but  can be
       treated at the  POTW  (e.g.,  grease trap
       cleanout wastes),
                                                 Domestic septage is defined as either the liquid or solid
                                                 material removed from a septic tank, cesspool, portable
                                                 toilet, Type III marine sanitation device, or similar treatment
                                                 works that holds only domestic sewage. Domestic septage
                                                 does not include liquid or solid material removed from these
                                                 systems that receives either commercial wastewater or
                                                 industrial wastewater and does not include grease removed
                                                 from a restaurant grease trap.  [40 CFR Part 503.9(f)]
                                                Figure 33. Definition of Domestic Septage
    »•   the facility is connected to the sewer but does not have the capacity to discharge the volume of waste
        generated (e.g., groundwater remediation activities at an IU),

    >•   a POTW rejects acceptance of a waste from an IU forcing the IU to haul the waste to a different
        POTW that agrees to accept the waste.

Common to all these wastes is the fact that the POTW does not know for certain the nature and concentration
of these wastes, as hauled, without implementing some type of control or surveillance program.

CONTROL PROGRAMS

    Section 403.5(b)(8) of the General Pretreatment Regulations specifically prohibits the introduction of any
trucked or hauled pollutants to the POTW, except at discharge points designated by the POTW. This is the
 Chapter 6
                                                                                           -43-

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 only pretreatment requirement specifically addressing hauled wastes.   However, many POTWs have
 determined that additional controls are necessary to further limit these discharges and to prevent adverse
 impacts from these discharges.  These control programs include practices such as permitting, sampling,
 manifesting, surveillance, and other forms of hauler documentation.  In many instances, these control
 programs have shifted the hauling of waste from one POTW to other POTWs that are not implementing such
 a program. Most often, it is the smaller POTWs that do not have hauler control programs, including many
 POTWs that are not even required to implement Pretreatment Programs. The effect of this change from larger
 to smaller POTWs and from more to less control is that there has been an increase in negative impacts to
 POTWs and receiving streams. Two apparent options for addressing this concern are for: (1) the smaller and
 non-pretreatment POTWs to initiate waste hauler control programs; or (2) the larger POTWs to institute sound
 Control programs that will adequately regulate these wastes yet not drive these haulers to search for other less
 sound disposal alternatives. POTW waste hauler control programs should address the following six elements:

     Impact to POTW - Prior to acceptance of a new waste from a hauler, the POTW needs to evaluate the
 potential impacts to the POTW from this waste. POTWs may require haulers or generators of hauled waste
 to perform a treatability study to demonstrate the effectiveness of treatment on this waste.  POTWs must
 evaluate the impacts of these waste when evaluating the adequacy of local limits as well as when developing
 or revising local limits.

     Permitting - A permit is the most direct and efficient method of regulating waste haulers. Permits provide
 the  opportunity to monitor and regulate haulers based on the nature of the hauled waste and the potential
 Impacts  of that waste on the POTW.  Unique permit conditions may include: right of refusal, daily flow
 limitations, discharge time limitations, and manifesting requirements.

     Discharge Point - As specified in the General Pretreatment Regulations, hauled waste can only be
 discharged at points designated by the POTW. This option is to provide the POTW with the ability to control
 and observe these discharges at specified locations thereby minimizing the potential for adverse impacts.

     Monitoring - The POTW should institute a monitoring program to evaluate the nature and concentration
 of discharges. Both POTW monitoring and hauler self-monitoring may be appropriate. Many POTWs require
 that all loads of hauled waste must be sampled, but analyses are only performed on  a predetermined
 percentage of these wastes or when problems occur.  Unanalyzed samples are refrigerated and kept for
 several weeks or months until the POTW is certain that the waste has not  impacted the POTW.  The
 frequency of sampling may also be dependent on  the variability of the waste. Each load from a hauler that
 delivers highly variable loads  may have to be sampled and analyzed; whereas, a much smaller percentage
 may be appropriate for more consistent waste types. As noted earlier, all Federal, State, and local discharge
 limitations apply to these wastes. The POTW may also consider inspecting the waste generators to confirm
 the source of these wastes.

    Hauler Documentation - The POTW should require waste haulers to document the source of wastes
 being discharged, potentially including  manifests. Manifests should include general hauler information,
 information on the waste generator (e.g., name, address, and  phone number), the type of wastes collected,
 volumes, known or suspected pollutants, and certification that the  load is not a  hazardous waste. A useful
 technique is to contact the waste generators to verify the information on the manifest.

    Legal Authority - If not  already in place, the POTWs local ordinance (and approved pretreatment
 program) should be modified to add language specifying all of the controls that are applicable to waste
 haulers.  This will ensure that waste haulers and POTW personnel will know the procedures, expectations,
 liabilities, etc. associated with the control program.

    In addition to the specific controls described above, POTWs should implement procedures to identify and
 eliminate illegal discharges. Procedures may include periodic sewer line sampling, surveillance of suspected
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                                                                                      Chapter 6

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Introduction to the National Pretreatment Program
                                                                                  Hauled Wastes
illegal discharge points, education of industries regarding hauled waste, increased enforcement, and public
awareness of illegal dumping.

CONCERNS

    Every hauled waste discharge has the potential to impact the POTW.  Unlike discharges from lUs
connected to the POTW, the makeup of a load of hauled waste is virtually unknown without some type of
monitoring, be it visual or analytical. Even loads of domestic septage can cause problems at a POTW. The
majority of waste haulers are reputable business people who provide a valuable service to the public and
industry; however, the unique attributes of hauled waste can be devastating when unethical haulers dump
incompatible wastes at POTWs. Domestic septage can be partially digested, higher in metals concentrations
than normal domestic wastes, or contain small amounts of household contaminants (e.g., cleaners). Similarly,
disinfectants used in portable toilets have the potential to impact POTW operations.

    Receipt of hauled hazardous waste (as defined in the Resource Conservation and Recovery Act (RCRA))
may not only impact POTW operations, but subject the POTW to additional reporting requirements. The
Domestic Sewage Exclusion, specified in 40 CFR §261.4(a)(1 )(ii), provides that hazardous wastes mixed with
domestic sewage are exempt from the RCRA waste regulations. However, hazardous wastes received by
truck or rail (or dedicated pipe) are not exempt from the regulations.  POTWs that accept hazardous wastes
from these sources are granted "permit by rule" status under RCRA (40 CFR §270.60(c)) provided that certain
requirements are met. The two most significant conditions are that the POTW must be in compliance with all
of its NPDES permit requirements and the waste must comply with all Federal, State, and local pretreatment
requirements. Nationwide, very few POTWs are knowingly accepting hauled hazardous waste.

    POTWs should  be aware that hauled process wastes from facilities subject to  Federal categorical
pretreatment standards are still subject to those standards. This condition highlights the need for POTWs to
have a clear understanding of the source of the waste since applicable standards may be based on the origin
of that waste.

    Another potential problematic waste is  that from remedial site clean-up operations. Groundwater
contaminated with gasoline or diesel fuel is by far the most common type of waste from these operations.
While these wastes may contain flammable and toxic compounds (e.g., benzene and toluene), another
concern is that large volumes of this waste at a small POTW may actually "flush" the treatment plant, thereby
interfering with treatment operations.  Similar concerns also exist for landfill leachate, another commonly
hauled wastestream.  Remedial wastes may also come from Comprehensive  Environmental  Response,
Compensation, and Liability Act (CERCLA) sites, also known as Superfund sites. For CERCLA guidance,
refer to EPA's 1990 CERCLA Site Discharges to POTWs Guidance Manual.

    Other concerns for POTWs that accept hauled wastes include:

    >•   Illegal dischargers may be discharging toxic pollutants that can pass through or interfere with the
        POTW operations;
    *•   Grease trap wastes can coat and inhibit POTW treatment operations;                       :
    >•   Local limits may not account for pollutants in hauled wastes;
    >   Hauled wastes may contain pollutants for which local  limits do not exist; thus, the impacts of this
        waste are not readily identifiable;
    >•   Hauled wastes may be unmixed and/or highly concentrated.
 For further information on the acceptance of hazardous waste at POTWs, refer to the Guidance Manual for
 the Identification of Hazardous Wastes Delivered to Publicly Owned Treatment Works by Truck, Rail, or
 Dedicated Pipe.
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                                                                                          -45-

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                                                                                                       Chapter 6

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Introduction to the National Pretreatment Program
                                                                              Pollution Prevention
7.   POLLUTION  PREVENTION
                                                 Chapter 7. Applicable EPA Guidance
                                            Guides to Pollution Prevention: Municipal Pretreatment Program
                                            NPDES Compliance Inspection Manual
   As the nation's environmental laws and
regulations  have developed over the past
three decades, a new paradigm has shifted
the approach to waste management. Initially,
EPA focused  on managing the pollution
generated through treatment and disposal in
an environmentally safe manner.  However, we have learned that conventional treatment and disposal can
transfer pollutants from one medium to another with no net reduction.10 In striving to meet new and often more
stringent environmental laws, industries have found ways to reduce or prevent pollution at the source.
Recognizing that source reduction is more desirable than treatment and disposal, EPA now emphasizes
preventing or eliminating the generation of waste. The Pollution Prevention Act of 1990 (PPA) established
pollution prevention (referred to as "P2") as a national objective.

   Pollution prevention is indirectly defined in the PPA as source reduction. Source reduction is any practice
that reduces or eliminates the creation of pollutants. Thus, the amount of any hazardous substance, pollutant,
or contaminant entering any waste stream  or otherwise released into the environment (including fugitive
emissions) is reduced prior to recycling, treatment, or disposal. Source reduction can be achieved through
equipment or technology modifications, process or procedural modifications, reformulation or redesign of
products, substitution of raw materials, or improvements in housekeeping, maintenance, training, or inventory
control.

   The PPA established a pollution prevention hierarchy as national policy, declaring that:

   »•   Pollution should be  prevented or reduced at the source.
   »•   Pollution that cannot be prevented should be recycled in an environmentally safe manner.
   >   Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner.
   *   Disposal or other release into the environment should be employed only as a last resort and should
       be conducted in an  environmentally safe manner.

   Thus, under the Pollution Prevention Act, recycling, energy recovery, treatment, and disposal are not
included within the definition of pollution prevention. However, some practices commonly described as "in-
process recycling" may qualify as pollution prevention. Although recycling is not pollution prevention, as
indicated in the hierarchy, it is the next desirable practice where pollution cannot be prevented or reduced.
Recycling conducted in an environmentally sound manner shares many of the advantages of prevention for
it can reduce the need for treatment or disposal and conserve energy and resources.

   EPA's Office of Pollution Prevention and Toxic Substances (OPPTS) developed a pollution prevention
strategy for incorporating pollution prevention concepts into EPA's ongoing environmental protection efforts.
The specific objectives of the strategy are to provide guidance and direction for efforts to incorporate pollution
prevention within EPA's existing regulatory and nonregulatory programs, and  to set forth an initiative to
achieve specific objectives in pollution prevention within a reasonable time frame. EPA's numerous activities
include the following:
       10  For example, a wet scrubber is used to remove most of the metal emissions to the air. The
           metals are captured in the scrubber water. This water must be treated to remove the metals
           prior to discharge. The treatment process produces a sludge that contains most of the metals
           that were once in the water.  The sludge is disposed in a landfill. The metals have been
           dispersed to the air, water, and land.
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                                                                                          -47-

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     >   Coordinating development of regulations that will help identify the potential for multi-media prevention
         strategies and that reduce end of pipe compliance costs
     >   Examining the use of pollution prevention in enforcement actions and negotiations
     >•   Investigating the feasibility of overcoming  identified regulatory  barriers  to  encourage  cost
         effective(source reduction) strategies
     »•   Working with State and local governments and trade associations to promote pollution prevention
         among small and medium size business that often lack the capital to make changes
     »•   Investing in outside programs, usually States, by providing grant funds for the reduction of target
         chemicals, the agricultural and transportation industry, etc.
     >•   Providing scientific and technical knowledge necessary to implement pollution  prevention initiatives
         on a cross media basis, pursuant to the Pollution Prevention Research  Strategic Plan.

 POLLUTION PREVENTION AND THE PRETREATMENT PROGRAM

     Although pollution prevention is not a required element  of the National Pretreatment Program, source
 reduction is not new to the Program. The Pretreatment Program is designed to prevent toxic pollutants from
 being discharged to POTWs through controls on the sources  that discharge these pollutants. Thus, pollution
 prevention may be considered an extension of current pretreatment program implementation activities. For
 example, Pretreatment Programs have the authority to require and enforce waste management practices in
 order to meet NPDES permit requirements and eliminate interference with treatment facilities. Requiring slug
 control plans and  developing  compliance  schedules for improved operation and  maintenance (O&M
 procedures are examples of pollution prevention  activities that have long been required by many Control
 Authorities. Other pretreatment program implementation tools available to make  pollution prevention a more
 integral part of a pretreatment program include:

     >   Inspections - Pretreatment personnel are usually quite familiar with processes performed at their
        local industrial facilities and have exposure to a variety of industries performing the same or similar
        processes; therefore, they can easily disseminate (nonconfidential) information about actual pollution
        prevention measures implemented as well as identify new P2 opportunities.
     >•   Permits - Where local regulations allow, questions about pollution prevention measures and plans
        can be made part of the permit application process.  Also, a permittee may be required to undergo
        a pollution prevention assessment and /or develop a pollution prevention plan as a condition of the
        permit.
     >   Local limits - POTWs near or above maximum allowable headworks loadings may institute POTW
        wide-pollution prevention programs to reduce specific pollutants.
     >•   Enforcement negotiations - A pollution prevention audit may be required through a consent or
        compliance order, or implementation of pollution prevention measures may be required as part of a
        settlement.

    Several Control Authorities have implemented these pollution prevention activities. For example, the City
 of Palo Alto, CA established a silver local limit for photoprocessors and Best Management Practices (BMPs)
 for automotive facilities.  To reduce mercury loadings from dental offices, Western Lake Superior  Sanitary
 Sewer District (WLSSD) in Duluth, MN developed and implemented pollution  prevention BMPs. These and
 many other POTWs that have successfully integrated pollution prevention into their pretreatment programs
 have become recognized environmental leaders in their communities.

    While pollution prevention activities can be unique to each POTW,  the following are key elements of
 successful pollution prevention programs:

    >   Integrate pollution prevention into existing activities - POTWs that view pollution prevention as
        an enhancement (instead of an additional requirement) to their existing pretreatment programs make
        small modifications to existing pretreatment activities efficiently and effectively.
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                                                                                       Chapter 7

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Introduction to the National Prstreatment Program
                                                                                 Pollution Prevention
    *•  Start small - POTWs that slowly phase in new pollution prevention activities overcome impediments
       such as limited resources and resistance. Implementing small changes gradually can be done with
       minimal resources. This approach enables pollution prevention activities to become an accepted
       integral part of the pretreatment program.
    *•  Define attainable goals and measure success - Short-term, narrowly focused efforts have a
       greater chance of succeeding. For example, POTWs have targeted a specific pollutant and group
       of industries, established specific pollution prevention activities, and monitored the progress and
       success of these activities. With each new success recorded, the benefits of pollution prevention are
       illustrated and the demand for further activities will grow.
    »•  Provide incentives - Incentives are effective tools for persuading users to investigate pollution
       prevention opportunities. POTWs have used a wide range of tools such as public recognition of
       pollution prevention achievements and reduction of regulatory requirements.

BENEFITS OF POLLUTION PREVENTION

    For both IDs and POTWs, pollution prevention has many benefits (Figures 34 and 35) that can be broadly
categorized under tangible economic rewards  and public goodwill and support. For example,  pollution
prevention:
        Creates cost savings
        Enhances process efficiency
        Avoids or reduces regulatory costs
        Reduces future liabilities
        Improves protection of worker health
        Improves public image.
Decrease pollutant loadings to water, air, and sludge
Decrease pollutant loadings to POTW that result in lower
O&M costs and reduces or eliminates need for capital
expenditures for POTW treatment plant expansions
Enables continued or expanded growth in the community
without harm to the environment.
                                               Figure 34. Benefits of Pollution Prevention to POTWs
    Although  the  numerous  benefits   make
pursuing pollution prevention attractive, implementation of source reduction in some situations may not be
possible.  Before implementing a pollution prevention practice, the benefits and barriers of the potential
opportunity must be evaluated. Common impediments include the following:

    >•   Technology
           Decrease product quality
           Unable to change raw materials because of currently available technology

    >•   Financial
           Incur high costs associated with implementing alternatives (i.e., new equipment or materials, or
           personnel and training)
           Loss due to downtime during switch overs and start ups
           Foreign competitors may have an economic advantage if they are not obligated to comply with
           US regulations
           Binding contracts with existing waste haulers and Treatment, Storage and Disposal (TSD)
           facilities may exist

  " >   Organizational
           Lack of or poor communication between persons possessing the knowledge and ideas for
           improvements and those that can actually implement the changes
           Limited personnel or internal resources available to investigate and/or make changes
           Lack of coordination and cooperation among divisions in the corporation
Chapter 7
                                                                                             -49-

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  Pollution Praventton
         Behavioral
             Alternatives may be considered inconvenient by personnel (e.g., dry sweeping then a wet wash
             dowq as opposed to just a wet wash down)
     >•   Regulatory
         -   Concentrating a pollutant for recycling
             may classify it as a hazardous waste
             (e.g., silver).  As such,  an industrial
             user  may  choose  to  discharge the
             pollutant rather than  be  subject  to
             regulations  regarding  the  handling,
             treatment and disposal of a hazardous
             waste.

 POLLUTION PREVENTION ASSISTANCE

     With  the  creation  of the  PPA  came  an
 abundance  of   pollution  prevention   related
 assistance.    This  includes  direct   technical
 assistance, training  courses,  and a  variety  of
 publications. POTWs can find further information
 on  integrating  pollution  prevention  into  their
 pretreatment programs in EPA's 1993  Guides  to
 Pollution  Prevention - Municipal  Pretreatment
 Programs. Specific industry trade associations and
 university  technology   transfer  and   outreach
 departments  usually  are  aware   of  pollution
 prevention assistance materials, specific pollution
 prevention  opportunities,  and  the  costs  and
 success  of implementing these.   Some  further
 sources  that disseminate pollution  prevention
 information include:

 >    Pollution    Prevention    information
     Clearinghouse (PPIC) - a free, nonregulatory
     clearinghouse available  to the public which
     focuses on source reduction and  recycling for
     industrial toxic wastes.
•  Regulatory
  -  Elimination of regulated wastewater discharges, and
    hence, monitoring requirements
  -  Reduced paperwork requirements for waste hauling
    and treatment
  -  Compliance with RCRA reports on waste reduction
    (i.e., companies generating RCRA wastes are required
    to certify that they have a program to reduce the
    volume and toxicity of hazardous waste generated)
  -  Compliance with land disposal restrictions and bans

•  Environmental
  -  Minimization of material emissions to all media
    resulting in reduced health risks to workers and the
    community

•  Financial
  -  Reduced landfill and treatment costs due to less waste
    being generated (includes reduced transportation costs
    as well)
  -  Reduced raw material and manufacturing costs (e.g., by
    preventing spills or leaks, improving equipment
    maintenance and inventory control techniques, reuse,
    etc. raw materials are handled more efficiently and do
    not have the chance to become waste. With a greater
    percentage of raw material going into process, raw
    material use goes down in relation to volume of
    product produced)
 -  Increased manufacturing efficiency and productivity
    and improved product quality with fewer offspec
   products

 Compliance and public relations
 - Achieving compliance with local limits and categorical
   standards
 - Reducing waste and implementing best management
   practices can improve public and community relations.
                                                  Figure 35. Benefits of Pollution Prevention to lUs
    State Programs - provide technical assistance
    to conduct pollution prevention assessments,
    develop guidance manuals on conducting these assessments, actually conduct these assessments,
    provide assistance in developing POTW-wide pollution prevention plans, provide training for industry,
    State and POTW personnel, and offer grants for pollution prevention projects.

    Envirosense - an on-line computer system (internet address: es.inel.gov) of summary information for
    PPIC documents, includes pollution prevention news, upcoming events, and mini-exchanges (discrete
    pollution prevention topic areas, pollution prevention databases, and message center).

    National Institute of Standards and Technology (NIST) - an office of the Department of Commerce,
    NIST develops technology to improve product quality,  modernize manufacturing  processes,  ensure
    product reliability, and facilitate rapid commercialization of products based on new scientific discoveries.
    NIST web sites for different industry sectors are available.  For example, the metal finishing web site (i.e.,
    the National Metal Finishing Resource Center) is found at "www.nmfrc.org."
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                                                                                             Chapter 7

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Introduction to the National Pretreatment Program
Bibliography
8.  BIBLIOGRAPHY
TITLE
Aluminum, Copper, And Nonferrous Metals Forming And
Metal Powders Pretreatment Standards: A Guidance
Manual
CERCLA Site Discharges to POTWs Guidance Manual
Control Authority Pretreatment Audit Checklist and
Instructions
Control of Slug Loadings To POTWs: Guidance Manual
Environmental Regulations and Technology: The National
Pretreatment Program
Guidance for Conducting a Pretreatment Compliance
Inspection
Guidance For Developing Control Authority Enforcement
Response Plans
Guidance for Reporting and Evaluating POTW
Noncompliance with Pretreatment Implementation
Requirements
Guidance Manual For Battery Manufacturing
Pretreatment Standards
Guidance Manual for Electroplating and Metal Rnishing
Pretreatment Standard
Guidance Manual For Implementing Total Toxic Organics
(TTO) Pretreatment Standards
Guidance Manual For Iron And Steel Manufacturing
Pretreatment Standards
Guidance Manual for Leather Tanning and Finishing
Pretreatment Standards
Guidance Manual for POTW Pretreatment Program
Development
Guidance Manual for POTWs to Calculate the Economic
Benefit of Noncompliance
Guidance Manual for Preparation and Review of Removal
Credit Applications
Guidance Manual for Preventing Interference at POTWs
Guidance Manual for Pulp, Paper, and Paperboard and
Builders' Paper and Board Mills Pretreatment Standards
Guidance Manual for the Identification of Hazardous
Wastes Delivered to Publicly Owned Treatment Works by
Truck, Rail, or Dedicated Pipe
Guidance Manual for the Use of Production-Based
Pretreatment Standards and the Combined Wastestream
Formula
Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the
Pretreatment Program
Guidance on Evaluation, Resolution, and Documentation
of Analytical Problems Associated with Compliance
Monitoring
DATE
December 1989
August 1990
May 1992
February 1991
July 1986
September 1991
September 1989
September 1987
August 1987
February 1984
September 1985
September 1985
September 1986
October 1983
September 1990
July 1985
September 1987
July 1984
June 1987
September 1985
December 1987
June 1993
EPA Number
800-B-89-001
540-G-90-005
-
21W-4001
625-10-86-005
300-R-92-009
-
—
440-1-87-014
440-1-84-091-G
440-1-85-009-T
821-B-85-001
800-R-86-001
-
833-B-93-007
833-B-85-200
833-B-87-201
-
-
833-B-85-201
833-B-87-202
821-B-93-001
NTIS Number
PB91-145441
PB90-274531
-
-
PB90-246521
PB94-1 20631
PB90-185083/AS
PB95-1 57764
PB92-1 17951
PB87-1 92597
PB93-167005
PB92-1 14388
PB92-232024
PB93-186112
-
-
PB92-1 17969
PB92-231638
PB92-149251
PB92-232024
PB92-129188
-
ERIC Number
W119
W150
-
-
W350
W273
-
W304
W195
W118
W339
W103
W117
W639
-
-
W106
W196
W202
U095
W107
—
Chapter 8
                                                      -51-

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 BtbiSogrsphy
Introduction to the National Pretreatment Program
TITLE
Guidance to Protect POTW Workers From Toxic And
Raactive Gases And Vapors
Guides to Pollution Prevention: Municipal Pretreatment
Programs
Industrial User Inspection and Sampling Manual For
POTWs
Industrial User Permitting Guidance Manual
Model Prolraatment Ordinance
M'UlttjurfsdJctlonal Pretreatment Programs: Guidance
Manual
National Prelreatment Program: Report to Congress
NPDES Compliance Inspection Manual
POTW Studga Sampling and Analysis Guidance
Document
Praitm User's Guide, Documentation for the EPA
Computer Program/Model for Developing Local Limits for
Industrial Pretreatment Programs at Publicly Owned
Treatment Works, Version 5.0
Pretreatment Compliance Inspection and Audit Manual
For Approval Authorities
Proifoatrnent Compliance Monitoring and Enforcement
Guidance and Software (Version 3.0)
Procedures Manual for Reviewing a POTW Pretreatment
Program Submission
RCRA Information on Hazardous Wastes for Publicly
Owned Treatment Works
Report to Congress on the Discharge of Hazardous
Wastes to Publicly Owned Treatment Works
Supplemental Manual On the Development And
Implementation of Local Discharge Limitations Under The
'rotrealment Program: Residential and Commercial
Toxic Pollutant Loadings And POTW Removal Efficiency
EttimaUon
DATE
June 1992
October 1993
April 1994
September 1989
June 1992
June 1994
July 1991
September 1994
August 1989
January 1997
July 1986
(Manual)
September 1986
(Software)
September 1992
October 1983
September 1985
February 1986
May 1991
EPA Number
812-B-92-001
625-R-93-006
831-B-94-001
833-B-89-001
833-B-92-003
833-B-94-005
21-W-4004
300-B-94-014
833-B-89-100
—
833-B-86-100
(Software)
831-F-92-001
833-B-83-200
833-B-85-202
530-SW-86-004
21W-4002
NTIS Number
PB92-1 73236
-
PB94-1 70271
PB92-123017
PB93-122414
PB94-203544
PB91-228726
-
-
—
PB90-1 83625
(Software)
PB94-1 18577
PB93-209880
PB92-1 14396
PB86-184017&
PB95-1 57228
PB93-209872
ERIC Number
W115
-
W305
W109
W108
W607
W694
-
-
—
W277
(Software)
W269
W137
W351
W922&
W692
W113
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                                                                                                              Chapter 8

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Introduction to the National Pretreatment Program
Bibliography
OTHER REFERENCE MATERIAL
CERCLA Site Discharges to POTWs CERCLA Site Sampling Program: Detailed Data Report, EPA 540-2-90-008

CERCLA Site Discharges to POTWs Treatability Manual, EPA 540-2-90-007

Considerations of Pollution Prevention in EPA's Effluent Guideline Development Process, EPA 820-R-95-008

Domestic Septage Regulatory Guidance: A Guide to the EPA 503 Rule, EPA 832-B-92-005

Effluent Guidelines, Leather Tanning, and Pollution Prevention: A Retrospective Study, EPA 820-R-95-006

Environmental Regulations and Technology: The Electroplating Industry, EPA 625/10-80-001

Environmental Regulations and Technology: The Electroplating Industry, EPA/625/10-85/001

EPA'S Whole Effluent Toxicity (WET) Control Policy (Information Sheet and Nonpoint Source Bulletin Board System
Instructions), EPA 833-F-94-005

Everything You Wanted to Know About Environmental Regulations...But Were Afraid to  Ask: A Guide for Small
Communities, Region 7 EPA 907-R-92-002

Fact Sheet: Effluent Guidelines: Protecting Our Nation's Waters from Industrial Discharges, EPA 821-F-93-005

Guidance on Evaluation, Resolution, and Documentation of Analytical Problems Associated with Compliance Monitoring,
EPA821-B-93-001

Guidance to POTWs for Enforcement of Categorical Standards (Memorandum), November 5,1984, EPA

Introduction to Water Quality-Based Toxic Control for the NPDES Program, EPA 831-S-92-002

NPDES Basic Permits Writer's Course Manual, EPA 833-B-97-001
Plain English Guide to the EPA Part 503 Biosolids Rule, EPA 832-R-93-003

Pretreatment Compliance Monitoring  and Enforcement Guidance, September 1986, EPA

Pretreatment Implementation Review Task Force: Final Report to the Administrator, January 30,1985, EPA

Spill Prevention, Control, and Countermeasure (SPCC) Information Guide, EPA 903-B-93-001

State and Local Government Guide to Environmental Program Funding Alternatives, EPA 841-K-94-001

Toxicity Identification Evaluation: Characterization of Chronically Toxic Effluents, Phase 1, EPA 600-6-91-005-F

U.S. EPA NPDES Permit Writers' Manual, EPA-833-B-96-003

User Documentation: POTW Expert, Version 1.1, EPA 625-1-19-000-1

Utility Manager's Guide to Water and Wastewater Budgeting, EPA 832-B-94-010
 Chapter 8
                                                                                                 -53-

-------

-------
                        APPENDIX A
ANNOTATED SUMMARIES OF EXISTING PRETREATMENT GUIDANCE MATERIAL

-------

-------
Introduction to the National Pretreatment Program
Annotated Summaries of Existing Pretreatment Guidance Material
ALUMINUM, COPPER, AND NONFERROUS METALS FORMING AND METAL POWDERS
PRETREATMENT STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER (WH-552) AND (EN-336)
DECEMBER 1989

AVAILABILITY:   WRC, NTIS, ERIC, NCEPI

APPROXIMATE NUMBER OF PAGES:       180
                               Aluminum, Copper. Ami
                               Nonferrotis Metals Forming
                               And Metal Powders
                               Pretreatment Standards
                               A Guidance Manuai
SUMMARY:
                                                                        JKmmna&B&SmS
       The intent of this guidance manual is to provide guidance to POTWs on the
       implementation and enforcement of the categorical pretreatment standards for the aluminum forming
       (40 CFR Part 467), copper forming (40 CFR Part 468), and nonferrous metals forming and metal
       powders (40 CFR Parts 471) categories.  The manual  provides an explanation of (1) the three
       categories (including associated subcategories), (2) the treatment technologies upon which the
       regulations were based, (3) the requirements of the General Pretreatment Regulations, and (4)
       examples of the application of categorical pretreatment standards to the forming industry.
TABLE OF CONTENTS:

       1.      Introduction
       2.      Categorical Pretreatment Standards for the Aluminum, Copper, and Nonferrous Metals
               Forming and Metal Powders Categories (40 CFR Parts 467, 468, and 471)
       3.      Treatment Techniques
       4.      Requirements of General Pretreatment Regulations
       5.      Application of Production-Based Categorical Pretreatment Standards

CURRENT APPLICABILITY:

       This guidance manual is still applicable, although revisions to the Nonferrous Metals Forming and
       Metal Powders regulations that occurred on March 17, 1989  (54FR11348) and April  4,  1989
       (54FR13606) were not incorporated into the guidance manual. Those revisions only affect nickel-
       cobalt (Subpart C) and zirconium/hafnium (Subpart I) forming operations.
Appendix A
                                                                                          A-1

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 CERCLA SITE DISCHARGES To POTWs GUIDANCE MANUAL
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER REGULATIONS AND STANDARDS, OFFICE OF WATER
 AUGUST 1990
                                      CERCUt SI1. HKtlHOU to POTVrt
 AVAILABILITY:   Nils, ERIC, NEPI

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
110
        The purpose of this guidance manual is to provide Feasibility Study (FS)
        writers, USEPA Remedial Project Managers (RPMs), state officials, and POTW personnel with the
        current regulatory framework and technical and administrative guidance that is necessary to evaluate
        the remedial alternative of discharging wastes from CERCLA sites to POTWs. The guidance provides
        information on identifying and characterizing CERCLA discharges, identifying POTW discharge sites,
        evaluating pjetreatment requirements and alternatives, a description of RCRA requirements, and how
        to estimate pretreatment limits. Case studies are provided as examples of how to evaluate the POTW
        discharge alternative.
TABLE OF CONTENTS:

       1.      Introduction
       2.      Identify and Characterize CERCLA Wastewater Discharges
       3.      Identify Potential POTWs
       4.      Involve POTWs in the Evaluation Process and Screen POTWs
       5.      Evaluate Pretreatment Requirements
       6.      Identify and Screen Pretreatment Alternatives
       7.      Detailed Analysis of the POTW Discharge Alternative
       8.      Clean Water Act and the National Pretreatment Program
       9.      RCRA Requirements
       10.     Estimate Pretreatment Limits
       11.     Hypothetical Case Studies


CURRENT APPLICABILITY:

       This guidance  manual is applicable to the current pretreatment program although the General
       Pretreatment Regulations and RCRA requirements have both been modified slightly subsequent to
       the publication of this manual. As such, the discussion of applicable regulations should be verified
       with copies of the actual Federal regulations.
                                                                                   Appendix A

-------
Introduction to the National Pretreatment Program
                                               Annotated Summaries of Existing Pretreatment Guidance Material
CONTROL AUTHORITY PRETREATMENT AUDIT CHECKLIST AND INSTRUCTIONS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND COMPLIANCE
MAY 1992
                                                                            ttwnuJcywtttwtnv wmfiomwr AIW? A
AVAILABILITY:    WRC

APPROXIMATE NUMBER OF PAGES:
                                     110
SUMMARY:
        This  guidance manual is intended to provide guidance  for  those
        responsible for conducting Pretreatment Audits. The manual provides an
        overview of  the  Audit  process, identifies the purpose  of  the  Audit,
        recommends the experience necessary for inspectors to perform an Audit, and finally describes the
        procedures involved in conducting an Audit. A key element  of the guidance manual is the Audit
        checklist that is to be  used  to document findings and  to ensure that  all necessary program
        components are evaluated during the inspection. The guidance manual also includes instructions to
        the inspector for completing each question on the checklist.  The instructions identify the specific
        component that is being evaluated and provides factors to consider when evaluating the component.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Control Authority Pretreatment Audit Checklist
        3.      Audit Checklist Instructions

CURRENT APPLICABILITY:

        This guidance manual  is still applicable to the current pretreatment program.  While many EPA
        Regions and States (i.e., Approval Authorities) have adopted their own Audit checklists, the basis for
        this guidance manual is still appropriate and is still used by many Approval Authorities.
Appendix A
                                                                                          A-3

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
                      Introduction to the National Pretreatment Program
 CONTROL OF SLUG LOADINGS TO POTWs: GUIDANCE MANUAL
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER (EN-335)
 21W-4001
 FEBRUARY 1991
 AVAILABILITY:   NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
180
        This guidance document,  developed in response to the Report  to
        Congress on the Discharge of Hazardous Wastes to Publicly Owned Treatment Works, details
        procedures for controlling accidental spills or irregular high strength batch discharges and updates
        the September 1988 version of the manual. The guidance provides detailed information on how to
        evaluate ILJs to determine whether they need slug control  plans and will also help POTWs decide
        which measures are necessary for different ILJs and in particular situations.
 TABLE OF CONTENTS:

        1.      Introduction
        2.      Prevention of IU Slug Loadings
        3.      POTW Slug Response Program

 CURRENT APPLICABILITY:

        The general approach outlined in this manual is applicable, although the reader should note that since
        publication, the General Pretreatment Regulations have been revised, at 40 CFR §403.8(f)(2)(v), to
        require Control Authorities to evaluate the need for a slug control plan at all SlUs at least once every
        two years, and where deemed necessary, require development of a plan. The regulations also
        specify minimum elements of these slug control plans.
A-4
                                                                                     Appendix A

-------
Introduction to the National Pretreatment Program
          Annotated Summaries of Existing Prefreatment Guidance Materiaf
ENVIRONMENTAL REGULATIONS AND TECHNOLOGY: THE NATIONAL PRETREATMENT
PROGRAM
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND PERMITS
EPA/625/10-86/005
JULY 1986
                                         Environmental
                                         Regulation* and
                                         TechnolOQV

                                         The National
                                         Pretteoiinom Progr
AVAILABILITY:   NTIS, ERIC

APPROXIMATE NUMBER OF PAGES:
30
SUMMARY:
       This document provides an overview of the National Pretreatment Program, focusing on the need for
       pretreatment, the National Pretreatment Program Regulations (as specified in 40 CFR Part 403),
       municipal Pretreatment Program implementation components, applicable ID discharge standards, and
       a discussion of what the future holds for the Pretreatment Program.
TABLE OF CONTENTS:

        1.      Introduction: What is Pretreatment?
        2.      The Need for Pretreatment
        3.      Overview of the National Pretreatment Program
        4.      National Pretreatment Standards
        5.      Local Pretreatment Programs
        6.      The Future of the Pretreatment Program
        7.      References

CURRENT APPLICABILITY:

        This document provides an overview of the Pretreatment Program as it was back in 1986. Since that
        time, the Program has evolved, both from a regulatory and technical perspective. While much of the
        discussion of basic Program information is accurate, a great deal of the technical discussion (i.e.,
        National Pretreatment Standards and Local Pretreatment Programs) is out-of-date. Additionally, the
        discussion of the future of the program is outdated.
Appendix A
                                                                                           A-5

-------
 Anflotatod Summaries of Existing Pretreatment Guidance Material
                                                           Introduction to the National Pretreatment Proaram
                                                                              GUBANH FOR COMHJCWa A

                                                                             TRUTUEMT COUKUNCC WSFCCTWH
                                                                                 MWtMtUltM
 GUIDANCE FOR CONDUCTING A PRETREATMENT COMPLIANCE INSPECTION
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER ENFORCEMENT AND COMPLIANCE
 SEPTEMBER 1991

 AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI

 APPROXIMATE NUMBER OF PAGES:       160

 SUMMARY:

       This  guidance manual is intended  to provide guidance for those
       responsible for conducting Pretreatment Compliance Inspections (PCIs).
       The manual provides an overview of the PCI process, identifies the purpose of the PCI, recommends
       the experience necessary for inspectors to perform a PCI, and finally describes the procedures
       involved in Conducting a PCI.  A key element of the guidance manual is the PCI checklist that is to
       be used to document findings and to ensure that all necessary program components are evaluated
       during the inspection. The guidance manual also includes instructions to the inspector for completing
       each question on the PCI checklist. These instructions  identify the specific issue that is being
       evaluated, identifies where to look for the most likely source of information that will  contain the
       necessary data needed to evaluate the Control Authority's program, and how to evaluate the
       adequacy of the program.

TABLE OF CONTENTS:
       1.      PCI General Instructions
       2.      POTW PCI Checklist
       3.      PCI Reference Material

CURRENT APPLICABILITY:

       This guidance manual is still applicable to the current pretreatment program.  While many EPA
       Regions and States (i.e., Approval Authorities) have adopted their own PCI checklists, the basis for
       this guidance manual is still appropriate and is still used by many Approval Authorities.
                                                                                     Appendix A

-------
Introduction to the National Pretreatment Program
          Annotated Summaries of Existing Pretreatmsnt Guidance Material
GUIDANCE FOR DEVELOPING CONTROL AUTHORITY ENFORCEMENT RESPONSE PLANS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER (EN-338)
SEPTEMBER 1989
                                    SEW
                                         Outdance For Developing
                                         Control Authority
                                         Enforcement Response Plans
AVAILABILITY:    WRC

APPROXIMATE NUMBER OF PAGES:

SUMMARY:
130
       This guidance document is intended to provide municipal pretreatment
       personnel with recommendations for assessing enforcement authorities,
       determining appropriate enforcement roles for personnel, and deciding upon enforcement remedies
       for specific violations. The purpose of this guidance manual is to help Control Authorities use their
       own enforcement expertise to develop a flexible and appropriate Enforcement Response Plans
       tailored to their particular situations.
TABLE OF CONTENTS:

       1.      Introduction
       2.      Developing an Enforcement Response Plan
       3.      Evaluating the Sewer Use Ordinance
       4.      Developing an Enforcement Response Guide
       5.      The Enforcement Responses

CURRENT APPLICABILITY:

       The general approach outlined in this manual is applicable. The reader should note that subsequent
       to publication of this manual, the General Pretreatment Regulations were modified to require Control
       Authorities to develop an Enforcement Response Plan as a component of their approved pretreatment
       programs. The procedures described in this manual are consistent with the regulatory requirements.
Appendix A
                                                      A-7

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Annotated Summaries of Existing Pretreatment Guidance Material
                     Introduction to the National Pretreatment Program
 GUIDANCE FOR REPORTING AND  EVALUATING POTW NONCOMPLIANCE WITH
 PRETREATMENT REQUIREMENTS
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER ENFORCEMENT AND PERMITS
 SEPTEMBER 1987
AVAILABILITY:    NTIS, ERIC

APPROXIMATE NUMBER OF PAGES:

SUMMARY:
18
       This guidance  explains the basis  for the definition of Reportable
       Noncompliance and its criteria, provides examples of how to apply the criteria, explains how to report
       noncompliance for POTW pretreatment program implementation on the Quarterly Noncompliance
       Report (QNCR) and suggests appropriate responses to noncompliance. EPA Regions and States
       should use this guidance to identify POTWs that are failing to implement their approved programs and
       should report them on the QNCR.
TABLE OF CONTENTS:
       1.      Introduction
       2.      Applying the Criteria
       3.      Reporting on the QNCR
       4.      Examples of Reporting on the QNCR
       5.      Compliance Evaluation
       6.      Response to Noncompliance
       7.      Summary
CURRENT APPLICABILITY:

       This guidance manual is applicable to the current pretreatment program.
                                                                                  Appendix A

-------
Introduction to the National Pretreatment Program
Annotated Summaries of Existing Pretreatment Guidance Material
GUIDANCE MANUAL FOR BATTERY MANUFACTURING PRETREATMENT STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER
AUGUST 1987

AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI

APPROXIMATE NUMBER OF PAGES:       140
                                iSuidanpft Manual
                                for Battery
                                Manufacturing
                                Pretreatmtmt Standards
SUMMARY:
        The intent of this  guidance manual is to provide information to assist
        Control Authorities and Approval Authorities in implementing the National
        Categorical Pretreatment Standards for the Battery Manufacturing (40 CFR Part 461) Point Source
        Category.  The manual should assist Control Authorities on the application and enforcement of the
        categorical pretreatment standards for the battery manufacturing category. The manual also provides
        assistance on the  application of the combined wastestream formula to battery manufacturers with
        regulated and unregulated wastestreams and other General Pretreatment Regulations.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Battery Manufacturing Categorical Standards
        3.      Treatment Technologies
        4.      Requirements of the General Pretreatment Regulations
        5.      Application of Battery Manufacturing Categorical Pretreatment Standards

CURRENT APPLICABILITY:

        The specific categorical pretreatment standard discussion in this guidance manual is still applicable,
        although some of the General Pretreatment Regulations have changed since publication of this
        manual.
 Appendix A
                                                                                            A-9

-------
GUIDANCE MANUAL FOR ELECTROPLATING AND METAL FINISHING PRETREATMENT
STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER EFFLUENT GUIDELINES DIVISION AND PERMITS DIVISION
FEBRUARY 1984

AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI

APPROXIMATE NUMBER OF PAGES:       80

SUMMARY:                                                                ;
                                                                          SBft   Guidance SKmu3
                                                                                for Electroplating
                                                                                Kid Mnwl flntahlng
                                                                                Pntreatnifmt Standard*
        This guidance document provides information to assist Control Authorities
        and Approval Authorities in implementing the National Categorical Pretreatment Standards for the
        Electroplating and Metal Finishing Point Source Categories.  The intent of this manual is to help
        Control Authorities respond to routine inquiries from regulated manufacturers and also to respond to
        specific categorical determination  requests submitted by lUs.  This manual  also describes the
        relationship between the Electroplating and Metal Finishing regulations as well  as  Metal Finishing
        and other categorical standards (e.g., Iron and Steel).

        The manual also addresses the application  of the combined wastestream formula to integrated
        facilities with regulated and unregulated wastestreams, the use of removal credits and fundamentally
        different factors variance requests, and how certification procedures may be used to demonstrate
        compliance with total toxic organic provisions.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Electroplating Categorical Pretreatment Standards
        3.      Metal Finishing Categorical Pretreatment Standards
        4.      Treatment Technologies
        5.      Requirements of the General Pretreatment Regulations

CURRENT APPLICABILITY:

        This guidance manual is still applicable, although the 1988 and 1990 revisions to the General
        Pretreatment Regulations are not reflected. This manual can be used to identify applicable standards
       for metal finishing and electroplating operations.
                                                                                      Appendix A

-------
Introduction to the National Pretreatment Program
                                              Annotated Summaries of Existing Pretreatment Guidance Material
GUIDANCE  MANUAL  FOR  IMPLEMENTING  TOTAL Toxic  ORGANICS (TTO)
PRETREATMENT STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PERMITS DIVISION
SEPTEMBER 1985

AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI
                                         Quittance Manual
                                         for ImpHmemlng
                                         Total Toxic Orsontai (TTO)
                                         Pretreatmont Standards
APPROXIMATE NUMBER OF PAGES:
90
SUMMARY:
        This guidance manual is intended to assist POTWs and  categorical
        industrial users who are subject to implementing or complying with Total Toxic Organic (TTO)
        pretreatment standards.  The manual identifies industrial categories subject to TTO limits and
        describes methods for implementing these standards and how TTO alternatives may be useful in lieu
        of IU monitoring. The manual identifies the specific toxic organics that are regulated in each of the
        six categorical standards, specific TTO limitations and applicable compliance dates.
 TABLE OF CONTENTS:

        1.      Introduction
        2.      Reporting Requirements
        3.      Industrial Categories With TTO Requirements
        4.      Guidance for the Preparation of a Toxic Organic Management Plan
        5.      Use of the Combined Wastestream Formula
        6.      Removal Credits
        7.      TTO Monitoring Guidance

 CURRENT APPLICABILITY:

        This guidance manual is still applicable to the current pretreatment program and can be used to apply
        TTO limitations to categorical industrial users. The specific list of industries that have TTO standards
        has been expanded since publication of this manual.  As such, users should reference the most
        current Code of Federal Regulations (CFR) before implementing those requirements. The discussion
        of analytical monitoring techniques is out of date and  does not reflect the most recent approved
        analytical methods.
  Appendix A
                                                                                          A-11

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
                                                            Introduction to the National Pretreatment I
                                                                                             lam
 GUIDANCE  MANUAL FOR IRON  AND  STEEL  MANUFACTURING  PRETREATMENT
 STANDARDS
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER INDUSTRIAL TECHNOLOGY DIVISION
 SEPTEMBER 1985
                                                           '»ii

 AVAILABILITY:   WRC, NTIS, ERIC, NCEPI

 APPROXIMATE NUMBER OF PAGES:       60

 SUMMARY:
                                                                Guithmc* Manual
                                                                (or
                                                                Iran anil Steel Manufacturing
                                                                Preireatmem Standards
        The intent of this guidance manual is to provide information to assist
        Control Authorities and Approval Authorities in implementing the National Categorical Pretreatment
        Standards for the Iron and Steel Manufacturing (40 CFR Part 420) Point Source Category  The
        manual is designed to assist Control Authorities on the application and enforcement of the categorical
        Pretreatment standards for the iron and steel manufacturing category.  The manual also provides
        assistance on the application of the combined wastestream formula to iron and steel manufacturers
        with regulated and unregulated wastestreams and other General Pretreatment Regulations.

TABLE OF CONTENTS:
        1.
        2.
        3.
        4.
Introduction
Iron and Steel Categorical Pretreatment Standards (40 CFR Part 420)
Treatment Technologies
Requirements of the General Pretreatment Regulations
CURRENT APPLICABILITY:

       The specific categorical pretreatment standard discussion in this guidance manual is still applicable
       although some of the General Pretreatment Regulations have changed since publication of this
       manual.
                                                                                     Appendix A

-------
                                              Annotated Summaries of Existing Pretreatment Guidance Material
GUIDANCE MANUAL FOR LEATHER  TANNING  AND  FINISHING PRETREATMENT
                                                                        j
STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE  OF WATER REGULATIONS AND STANDARDS  AND  OFFICE OF  WATER
ENFORCEMENT AND PERMITS
SEPTEMBER 1986
                                        GuWancs Manual for
                                        toother Tanning »nd
                                        Finfehinj) f>>*tr»atm*nt
                                        Standard*
AVAILABILITY:    WRC, NTIS, ERIC

APPROXIMATE NUMBER OF PAGES:

SUMMARY:
70
       The intent of this guidance manual is to assist Control Authorities and Approval Authorities in
       implementing the National Categorical Pretreatment Standards for the Leather Tanning and Finishing
       Point Source Category (40 CFR Part 425). The manual is designed to assist POTWs with routine
       inquiries from  regulated facilities and provide general information on application of categorical
       standards to industrial discharges (e.g., addresses application of the combined wastestream formula
       and information on removal credits and variances).
TABLE OF CONTENTS:

        1.      Introduction
        2.      Leather Tanning and Finishing Categorical Pretreatment Standards
        3.      Treatment Technologies
        4.      Requirements of the General Pretreatment Regulations

CURRENT APPLICABILITY:

        This guidance manual is still appropriate for use, although the user should be aware that there have
        been modifications to the 40 CFR Part 425 Leather Tanning categorical standards and 40 CFR Part
        403 General Pretreatment Regulations since publication of this manual.
 Appendix A

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
                                                           Introduction to the National Pretreatment I
 GUIDANCE MANUAL FOR POTW PRETREATMENT PROGRAM DEVELOPMENT
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER ENFORCEMENT AND PERMITS
 OCTOBER 1983
                                     6HA
 AVAILABILITY:    NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
                                         *»;.* ^-^-..v-,-,u
                                         aM!*MWTMiS3a  ^
                                         for POTW Protrt«tnnnt
                                         Proflram Oavtlopment

260
                  nr                                                      , , i •       '
        This manual provides guidance to municipal personnel for the development *
        and implementation of a local pretreatment program. The manual also provides information to the
        official who will supervise the local program. The purpose of this manual is twofold: (1) to  help
        municipal personnel in developing a pretreatment program and implementing the program on an
        ongoing basis, and (2) to assist municipal personnel in preparing the program submission to obtain
        approval from the EPA.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Industrial Waste Survey
        3.      Legal Authority
        4.      Technical Information
        5.      Design of Monitoring Program
        6.      Program Implementation Procedures
        7.      Program Organization, Costs, and Revenue Sources
        8.      Approval and Implementation


CURRENT APPLICABILITY:

       The general approach for developing a pretreatment program remains applicable; however  most of
       the references to regulatory information  presented are obsolete.  Since the cornerstone  of a
       pretreatment program is its adherence to the Federal requirements, most of the manual focuses on
       complying with specific regulatory requirements. Users of this document should be aware that the
       regulatory cites in the manual have likely been updated, modified, or expanded since publication of
       the manual.
                                                                                    Appendix A

-------
Introduction to the National Pretreatment Program
                                              Annotated Summaries of Existing Pretreatment Guidance Material
GUIDANCE MANUAL FOR POTWS TO CALCULATE THE ECONOMIC  BENEFIT OF
NONCOMPLIANCE
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND PERMITS
SEPTEMBER 1990
AVAILABILITY:    WRC

APPROXIMATE NUMBER OF PAGES:
                                                                                       ..,,- ' .uuM-t"*^
40
SUMMARY:
       This manual provides guidance to municipalities for determining the
       amount of "economic benefit" an industry or firm is expected to have gained by not complying with
       pretreatment standards and requirements on time.  The methodology presented for calculating
       economic benefit is a simplified  manual version of EPA's BEN  computer program, and  is
       recommended for use in the event the BEN computer program is unavailable.  The guidance is
       consistent with EPA's Clean Water Act Penalty Policy for Civil Settlement Negotiations (February,
       1986).  EPA strives to obtain settlement penalties for Clean Water Act violations that remove, at a
       minimum, the economic benefit to an industrial user from its noncompliance. Consistent national
       application of this policy by municipalities will ensure that members of the regulated community have
       a strong economic incentive to comply with environmental laws in a timely manner.
 TABLE OF CONTENTS:
        1.      Introduction
        2.      Procedure to Calculate Economic Benefit
        3.      Other Considerations in Developing a Settlement Penalty
 CURRENT APPLICABILITY:

        This guidance manual is applicable to the current pretreatment program.
 Appendix A

-------
Agitated Summaries of Existing Pretreatment Guidance Material	Int^iontothe National Pretreatment Program

GUIDANCE  MANUAL  FOR  PREPARATION AND  REVIEW  OF  REMOVAL CREDIT
APPLICATIONS                                                            »B»
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PERMITS DIVISION (EN-336)
JULY 1985
                                                                                •££#5...—  aa&« ssr
                                                                                3sr.~™
                                                                                      nual for'"
                                                                                Preparation and Reviow
                                                                                of Removal
                                                                                Credit Applications
 AVAILABILITY:   NCEPl, NEPI

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
                                     130
        This guidance manual is intended to explain the removal credits regulations, and assist categorical
        industrial users and POTWs who are preparing the application. The manual also presents guidance
        for Approval Authorities who are reviewing the applications to ensure consistency and providing
        continued oversight of the removal credits implementation after approval. The guidance is divided
        into two major parts. Part 1 includes a detailed description of the application requirements, alternative
        procedures available to POTWs to comply with application requirements, and sampling and analytical
        requirements for obtaining plant removal data. Part 2 consists of guidance for reviewing removal
        credit applications, including guidance for evaluating alternative methods of demonstrating consistent
        removal and, criteria and procedures for modification or withdrawal of a POTWs removal credits.
TABLE OF CONTENTS:
        1.
        2.
        3.
        4.
        5.
        6.
        7.
              Introduction
              Background
              Removal Credit Application Requirements
              Alternative Procedures Available to Satisfy Application Requirements
              Sampling and Analytical Requirements
              Review of Removal Credit Applications
              Modification or Withdrawal of Removal Credits
CURRENT APPLICABILITY:

       This guidance manual for preparing and reviewing a removal credit application is generally applicable
       to the current pretreatment program; however, the specific removal credit regulations have been
       modified several times since publication of this manual. Also, promulgation of the 40 CFR Part 503
       Standards for the Use or Disposal of Sewage Sludge modified the applicability of these requirements
       to certain pollutants.
                                                                                      Appendix A

-------
Introduction to the National Pretreatment Program
Annotated Summaries of Existing Pretreatment Guidance Material
GUIDANCE MANUAL FOR PREVENTING INTERFERENCE AT POTWs
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PERMITS DIVISION (EN-336)
SEPTEMBER 1987

AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI

APPROXIMATE NUMBER OF PAGES:       110
                                Guidance Manual for
                                preventing Interference
                                at POTWs
SUMMARY:
       This intent of this manual is to provide guidance to POTWs on preventing fr'SMMg'^^
       and handling interference problems caused by pollutants from nondomestic
       sources. Guidance is also provided on distinguishing interference caused by nondomestic sources
       from problems resulting from poor operation and maintenance of the POTW. The manual includes
       three major sections which correspond to the order a POTW should address interference.  The first
       section identifies the types of interferences and substances which are known to cause problems. The
       second section deals with the identification of  the  industrial  sources of interference-causing
       substances. The final section on mitigation discusses ways in which municipalities can address
       interference problems.
TABLE OF CONTENTS:
        1.      Introduction
        2.      Detecting Interference
        3.      Source Identification
        4.      Mitigation
        5.      References
CURRENT APPLICABILITY:

        This guidance manual is applicable to the current pretreatment program.
 Appendix A
                                                                                          A-17

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
                                                            Introduction to the National Pretreatment Prog
 GUIDANCE MANUAL FOR PULP, PAPER, AND PAPERBOARD AND BUILDERS' PAPER AND
 BOARD MILLS PRETREATMENT STANDARDS                                    **»
 U.S. ENVIRONMENTAL PROTECTION AGENCY                                   ;
 OFFICE OF WATER EFFLUENT GUIDELINES DIVISION
 JULY 1984
                                                                 Ouidui'caManuil
                                                                 for Pulp. Pap«r,
                                                                 •nd Paparboard and
                                                                 Bullderi' Pop«r und
                                                                 Board Mtllt PrMraatmwn
                                                                 Standard)
 AVAILABILITY:   WRC, NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
                      50
        The fntent of this guidance manual is to provide  information to assist
        Control Authorities and Approval Authorities in implementing the National Categorical Pretreatment
        Standards for Pulp, Paper, and Paperboard (40 CFR Part 430) and Builders' Paper and Board Mills
        (40 CFR Part 431) Point Source Categories. The manual is designed to assist Control Authorities
        in responding to routine inquiries from regulated mills. The manual also provides assistance on the
        application of the combined wastestream  formula to  integrated  facilities with regulated and
        unregulated wastestreams and on certification  procedures  to minimize sampling and  analysis
        requirements.
TABLE OF CONTENTS:
        1.
        2.
        3.
        4.
Introduction
Pulp, Paper and Paperboard Categorical Pretreatment Standards
Treatment Technologies
Requirements of the General Pretreatment Regulations
CURRENT APPLICABILITY:

       EPA promulgated revised categorical pretreatment standards for Pulp, Paper, and Paperboard
       facilities on April 15, 1998. These new regulations include a completely new subcategorization
       scheme, although, specific regulatory requirements were modified for only two of the subcategories
       (new Subparts B - Bleached Papergrade Kraft and Soda, and E - Papergrade Sulfite). Also, some
       of the general pretreatment regulations have changed since publication of this manual.
                                                                                     Appendix A

-------
Introduction to the National Pretreatment Program
                                              Annotated Summaries of Existing Prefreatment Guidance Material
GUIDANCE MANUAL FOR THE IDENTIFICATION OF HAZARDOUS WASTES DELIVERED TO
PUBLICLY OWNED TREATMENT WORKS BY TRUCK, RAIL, OR DEDICATED PIPE        6Em
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND PERMITS
JUNE 1987

                                                                              RCRA Information
                                                                              an Haxardoufi Wastes
                                                                              (or Publicly Qwiwd
                                                                              Treatment Works
AVAILABILITY:   NTIS, ERIC

APPROXIMATE NUMBER OF PAGES:
                                    140
SUMMARY:
                                                                                         •MM
       The intent of this guidance manual is to offer administrative and technical recommendations to
       POTWs seeking to (1) preclude the receipt of hazardous wastes by these transportation methods;
       and (2) discuss the responsibilities of POTWs choosing to accept hazardous wastes by these
       transportation  methods. To accomplish this, the manual provides the statutory and regulatory
       definitions and status of wastes that POTW operators typically may encounter.  In addition, the
       manual provides a discussion of legal, administrative, and technical methods to preclude the receipt
       of hazardous wastes and provides a description of potential liabilities that POTWs may incur as a
       result of accepting hazardous wastes.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Description of RCRA Regulated Wastes
        3.      Responsibilities of POTWs Choosing Not to Accept Hazardous Wastes
        4.      Responsibilities of POTWs Choosing to Accept Hazardous Wastes

CURRENT APPLICABILITY:

        The general approach presented in this guidance manual for identifying hazardous wastes is still
        applicable, although, the definition of hazardous  waste and the types  of wastes  classified as
        hazardous have changed since publication of this manual.
Appendix A
                                                                                         A-19

-------
 Annotatad Summaries of Existing Pretreatment Guidance Material
GUIDANCE  MANUAL  FOR  THE  USE  OF  PRODUCTION-BASED  PRETREATMENT  ***
STANDARDS AND THE COMBINED WASTESTREAM FORMULA
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER
SEPTEMBER 1985
 AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPl

 APPROXIMATE NUMBER OF PAGES:       90

 SUMMARY:
                                                                               SSKi—

                                                                               Guidanc
                                                                               for the Uso of
                                                                               Production-Bused
                                                                               Protreatmflrtt Standard*
                                                                               and tho Combined
                                                                               Wostastroum Formula
        This guidance manual is intended to explain two important elements of the National Pretreatment
        Program: production-based categorical standards and the combined wastestream formula. The first
        section of the manual explains how to apply production-based categorical standards in a permit,
        contract, or similar mechanism.  The second part explains how to use the combined wastestream
        formula, providing definitions and examples.

        The manual uses an approach that is  highly consistent with that used in the NPDES program
        regarding the application of production-based standards, emphasizing the usefulness of converting
        a production-based standard to an equivalent mass per day limit. The option of using concentration
        limits is also discussed.  The guidance clarifies that permits should clearly spell out the equivalent
        limit, the production and flow rates upon which the limits are based, and the requirement to notify the
        Control Authority of changes in flow or production.

        The manual also clarifies the terms "regulated," "unregulated," and "dilution" used in the combined
        wastestream formula and describes how the formula should be applied when these streams exist.
TABLE OF CONTENTS;

       1.      Introduction
       2.      Use of Production-Based Categorical Pretreatment Standards
       3.      Use of Combined Wastestream Formula
       4.      References

CURRENT APPLICABILITY:

       This guidance manual is still applicable to the current pretreatment program and can be used to
       calculate and apply appropriate limits to categorical industrial users based on production-based
       standards and/or the combined wastestream formula.

-------
Introduction to the National Pretreatment Program
Annotated Summaries of Existing Pretreafment Guidance Arfaterfa/
GUIDANCE  MANUAL ON  THE  DEVELOPMENT AND IMPLEMENTATION  OF LOCAL
DISCHARGE LIMITATIONS UNDER THE PRETREATMENT PROGRAM
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND PERMITS
DECEMBER 1987

AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI

APPROXIMATE NUMBER OF PAGES:       340
                              Guidance Manual on tho
                             • Development and =
                              Implementation of Local
                              Discharge LI m! tat Ions Un
                              the PfQtroatment Prbgran
SUMMARY:
        This manual provides guidance to municipalities on the development and
        implementation of local  limitations to control conventional, nonconventional, and toxic pollutant
        discharges from nondomestic industrial users (IDs) to POTWs. This document is principally directed
        toward POTW personnel responsible for local pretreatment program implementation.  In addition, it
        is intended to assist POTWs which are not required to develop local programs but must develop local
        limits to prevent recurrence of problems and to ensure compliance with Federal, State and local
        requirements.
TABLE OF CONTENTS:
        1.      Introduction
        2.      Identifying Sources and Pollutants of Concern
        3.      Local Limits Development by the Allowable Headworks Loading Method
        4.      Local Limits Development to Address Collection System Problems
        5.      Industrial User Management Practices
        6.      Case-by-Case Permits - Best Professional Judgement (BPJ)
CURRENT APPLICABILITY:

       This guidance is generally applicable. The user should note that EPA is revising the guidance to
       address current technical issues and to update methodologies and literature data.
Appendix A
                                          A-21

-------
Anaotatod Summaries of Existing Pretreatment Guidance Material
                      Introduction to the National Pretreatment Program
(ABIDANCE ON EVALUATION, RESOLUTION, AND DOCUMENTATION OF ANALYTICAL
PROBLEMS ASSOCIATED WITH COMPLIANCE MONITORING
U,S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENGINEERING AND ANALYSIS DIVISION
JUNE 1993
AVAILABILITY:   NTIS
APPROXIMATE NUMBER OF PAGES:
50
SUMMARY:
       This guidance document addresses matrix interference issues related to the analysis of organic
       compounds regulated under the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) rule,
       although the approach is applicable to analysis of other organics and metals as well. This manual is
       useful for permit writers, permittees, laboratories, and other interested parties for identifying some of
       the analytical problems associated with the OCPSF rule and describing methods for resolution of the
       issues.  This document presumes knowledge of, or access to, the relevant analytical methods under
       discussion.
TABLE OF CONTENTS:

        1.      Checklist of Laboratory Data Required to Support a Claim that the Permittee was Unable to
               Measure Pollutants Due to Matrix Problems
        2.      Guidance for Analysts Attempting to Identify  and Quantify Pollutants in Wastewaters
               Discharged from Plants Manufacturing Organic Chemicals, Plastics, and Synthetic Fibers
        3.      Cost Estimates for Resolving Matrix Interferences
        4.      Guidance for Reviewing Data from the Analysis of Organic Compounds Using EPA 600- and
               1600-Series Methods
        5.      Case Histories of Claims of Matrix Interferences  Submitted Under the OCPSF Rule
        6.      Guidance on Contracting for Analytical Services

CURRENT APPLICABILITY:

        This manual is applicable to the current pretreatment program, specifically for facilities subject to the
        OCPSF categorical standards.
                                                                                     Appendix A

-------
 Introduction to the National Pretreatment Program
                                               Annotated Summaries of Existing Pretreatment Guidance Material
                                                                         I     Bjgg-r  ga"   5S.tts~
                                                                         '«B=A  GuktancBToProiertPOfW
                                                                              Wortosra From Toxic And
                                                                              RwcOveGiiM* And \fcpom
 GUIDANCE TO PROTECT POTW WORKERS FROM Toxic AND REACTIVE GASES AND
 VAPORS
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER (EN-336)
 EPA812-B-92-001
 NTIS No. PB92-173-236
 JUNE 1992

 AVAILABILITY:   WRC, NTIS, ERIC, NCEPI, NEPI

 APPROXIMATE NUMBER OF PAGES:        130

 SUMMARY:

       This guidance manual provides guidance to POTWs for carrying out EPA's regulations that prohibit
       reactive and gas/vapor-toxic discharges to POTWs. The manual is designed to also help POTWs
       identify, prevent, and mitigate hazards associated with toxic gases, vapors, and chemically-reactive
       substances encountered in the POTWs collection system and treatment plant, as well as at industrial
       facilities during POTW inspections. The purpose of the manual is to help POTWs understand reactive
       and gas/vapor-toxic hazards, to give POTWs a working knowledge of certain chemicals that can
       cause reactive and gas/vapor-toxic conditions within the POTW and at industries during inspections,
       and to recommend procedures to prevent or mitigate reactive and gas/vapor-toxic conditions.

TABLE OF CONTENTS:

       1.      Introduction
       2.      Defining Reactive and Gas/Vapor-Toxic Hazards
       3.      Monitoring to Identify Reactive and Gas/Vapor-Toxic Hazards
       4.      Screening Industrial Discharges
       5.      Problem Identification Process
       6.      Control of Potential Hazards

CURRENT APPLICABILITY:

       This guidance manual is still applicable to the current pretreatment program and can be used to help
       control reactive and gas/vapor-toxic conditions at POTWs.
Appendix A
                                                                                        A-23

-------
 Agnolated Summaries of Existing Pretreatment Guidance Material
                      Introduction to the National Pretreatment Program
 GUIDES TO POLLUTION PREVENTION - MUNICIPAL PRETREATMENT PROGRAMS
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF RESEARCH AND DEVELOPMENT, CENTER FOR ENVIRONMENTAL RESEARCH
 INFORMATION
 OCTOBER 1993
                                          Gufd** to Pollution
                                          Municipal Pretroatmonl
                                          PfDQfBdlS
AVAILABILITY:   NCEPl, NEPI

APPROXIMATE NUMBER OF PAGES:
80
 SUMMARY:
        This guidance document provides an overview of pollution prevention
        concepts, presents a way to identify and prioritize industries as candidates for pollution prevention
        and outlines a broadly applicable approach to integrating pollution prevention concepts into existing
        pretreatmeht programs. A comprehensive list of pollution prevention resources is included as well
        as a collection of industry specific summaries that identify pollution prevention opportunities.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Overview of Pollution Prevention Concepts
        3.      Targeting Pollution Prevention Efforts
        4.      Promoting Pollution Prevention Among Regulated and Unregulated Sewer Users
        5.      References

CURRENT APPLICABILITY:

        This guidance manual is applicable to the current pretreatment program.
A-24
                                                                                       Appendix A

-------
 Introduction to the National Pretrsatment Program
          Annotated Summaries of Existing Prefreafmenf Guidance Material
 INDUSTRIAL USER INSPECTION AND SAMPLING MANUAL FOR POTWs
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WASTEWATER ENFORCEMENT AND COMPLIANCE
 EPA831-B-94-001
 APRIL 1994
                                         Sampling HanuafPor POTW3
 AVAILABILITY:   NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
220
        This manual is intended to acquaint POTW personnel with the well-established inspecting and
        wastewater sampling procedures which have been used in the NPDES program for many years. The
        information presented will  guide the POTW inspector  by providing a framework for conducting
        inspections and wastewater sampling. The inspector is defined, for the purposes of this manual, as
        the field personnel who collects information that may lead to or support an enforcement action. The
        manual assumes the POTW inspector has a basic knowledge of wastewater treatment technologies,
        as well as all applicable Federal, State, and local pretreatment requirements. The manual is also
        intended to assist the POTW's legal counsel and lab personnel as a reference for the legal and
        technical aspects of pretreatment inspections and sampling activities.
 TABLE OF CONTENTS:
        1.      Introduction
        2.      Inspecting Industrial Users
        3.      Sampling Industrial Users
 CURRENT APPLICABILITY:

        This manual is applicable to the current pretreatment program.
Appendix A
                                                                                       A-25

-------
AjmoMod Summaries of Existing Pretreatment Guidance Material
Introduction to the National Pretreatment Program
 INDUSTRIAL USER PERMITTING GUIDANCE MANUAL
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER (EN-336)
 SEPTEMBER 1989

 AVAILABILITY:   WRC, NTIS, ERIC, NCEPl

 APPROXIMATE NUMBER OF PAGES:      300
              &EPf\  Industrial User
                   Permitting Guidance
                   Manna)
SUMMARY:
        This guidance manual is intended to provide a framework for drafting and     	
        issuing industrial user permits by POTWs  and States with approved
        pretreatment programs.  The purpose of the guidance is to assist new permit writers, experienced
        permit writers, and legal and administrative personnel who are involved in the implementation of an
        industrial user permitting program in preparing effective and enforceable industrial user permits. The
        pnanual provides background information on requirements of the issuance process and discusses the
        necessary legal authority required to implement an  effective program.  This manual  provides
        documentation of EPA's recommendations for industrial user permit contents and  structure and
        contains many examples of permit language. The manual is formatted as a reference manual (with
        key word index) that can be used throughout the permitting process. The manual is not intended to
        address all of the specific decisions that must be made during the permitting process; rather, the
        manual references additional documents that should supplement the permit writing process.
TABLE OF CONTENTS:

        1.      Background
        2.      Preliminary Decisions
        3.      Legal Authority for a Permit Program and Permit Issuance Procedures
        4.      Permit Applications
        5.      General Permitting Considerations
        6.      Components of the Cover Page
        7.      Effluent Limitations
        8.      Monitoring and Reporting Requirements
        9.      Standard Conditions
        10.     Special Conditions
        11.     Documentation of Permit Decisions
        12.     Permitting Waste Haulers
        13.     Overview of Requirements Regarding POTW Receipt of Hazardous Wastes

CURRENT APPLICABILITY:

        Since publication of this manual, EPA modified the General Pretreatment Regulations requiring that
        POTWs with approved pretreatment programs issue  permits or equivalent  individual control
        mechanisms to each SIU.  This modification, spelled out at 40 CFR §403.8(f)(1)(iii), requires that
        control mechanisms be enforceable and contain five specific elements (e.g., statement of duration;
        statement of non-transferability; effluent limits; self- monitoring, sampling, reporting, notification, and
        record keeping requirements; and a statement of applicable civil and criminal penalties). Prior to this
        1990 regulatory revision, POTWs were not required to issue individual control mechanisms to SlUs.
       The manual, while not formatted consistent with the regulatory requirements, does address all the
        required permit elements.
                                                                                     Appendix A

-------
Introduction to the National Pretreatment Program
Annotated Summaries of Existing Pretreatment Guidance Material
MODEL PRETREATMENT ORDINANCE                                         ^^   ^saS* J3£*>
U.S. ENVIRONMENTAL PROTECTION AGENCY                                        <**••»
OFFICE OF WASTEWATER ENFORCEMENT AND COMPLIANCE (EN-336)
EPA833-B-92-003
JUNE 1992
                                                                       f
AVAILABILITY:    WRC, NTIS, ERIC, NCEPI, NEPI                            !

APPROXIMATE NUMBER OF PAGES:       50

SUMMARY:

       This guidance provides a model ordinance for use by municipalities operating POTWs that are
       required to develop pretreatment programs to regulate industrial discharges to their systems. The
       guidance recommends not adopting the model verbatim, but using it as a guide for adopting new or
       revised legal authority to implement and enforce a pretreatment program that fulfills requirements set
       out in the CFR. Some provisions in the model are not strictly required by the General Pretreatment
       Regulations, but are included because they may be useful in ensuring that the municipality has
       adequate legal authority to effectively implement its local pretreatment program.

TABLE OF CONTENTS:

       1.      General Provisions
       2.      General Sewer Use Requirements
       3.      Pretreatment of Wastewater
       4.      Wastewater Discharge Permit Application
       5.      Wastewater Discharge Permit Issuance Process
       6.      Reporting Requirements
       7.      Compliance Monitoring
       8.      Confidential Information
       9.      Publication of Users in Significant Noncompliance
       10.     Administrative  Enforcement Remedies
       11.     Judicial Enforcement Remedies
       12.     Supplemental Enforcement Action
       13.     Affirmative Defenses to Discharge Violations
       14.     Wastewater Treatment Rates
       15.     Miscellaneous Provisions
       16.     Effective Date

CURRENT APPLICABILITY:

       This guidance is still applicable to the current pretreatment program.
Appendix A
                                          A-27

-------
 MULTIJURISDICTIONAL PRETREATMENT PROGRAMS: GUIDANCE MANUAL
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER (4203)
 EPA833-B-94-005
 JUNE 1994

 AVAILABILITY:   WRC, Nils, ERIC, NCEPI, NEPI

 APPROXIMATE NUMBER OF PAGES:       40

 SUMMARY:
       This guidance document is intended to address multijurisdictional program
       implementation and enforcement issues and offer some of the options that municipal entities may
       employ to satisfy Federal and State program requirements. The guidance is needed because, as a
       general rule, the powers of a municipal entity are limited to its geographic boundaries, and additional
       authority will be needed to regulate industrial users located beyond these boundaries.
TABLE OF CONTENTS:

       1.     Introduction
       2.     Solutions  to  Multijurisdictional  Approved Pretreatment  Program  Implementation and
              Enforcement Problems

CURRENT APPLICABILITY:

       This guidance is still applicable to the current pretreatment program.
                                                                                   Appendix A

-------
Introduction to the National Pretreatment Program
Annotated Summaries of Existing Pretreatment Guidance Material
NATIONAL PRETREATMENT PROGRAM: REPORT TO CONGRESS
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER (EN-336)
JULY 1991

AVAILABILITY:   NTIS, ERIC, NCEPl, NEPl

APPROXIMATE NUMBER OF PAGES:       480

SUMMARY:

       Section 519 of the Clean Water Act Amendments of 1987 required EPA to
       study certain elements of the National Pretreatment Program. Specifically, Section 519 required EPA
       to report the results of a study on: (1) the adequacy of data on environmental impacts of toxic
       industrial pollutants from POTWs; (2) the extent to which secondary treatment at POTWs removes
       toxic pollutants;  (3) the capability of POTWs to revise pretreatment requirements; (4) possible
       alternative regulatory strategies for protecting the operation of POTWs from industrial discharges and
       the extent to which each such strategy may be expected to achieve the goals of the CWA; (5) for
       each alternative strategy, the extent to which removal of toxic pollutants by  POTWs results in
       contamination of sewage sludge and the extent to which pretreatment requirements may prevent such
       contamination or improve  the ability to comply with sewage sludge requirements; and (6) the
       adequacy of resources to establish, implement, and  enforce multiple pretreatment limits for toxic
       pollutants for each such alternative strategy. This report presents the findings on each of these topics
       and provides recommendations on how to better control toxic pollutant discharges to meet the goals
       of the CWA.
TABLE OF CONTENTS:

       1.      Background and Introduction
       2.      Study Approach and Data Sources
       3.      Discharge of Toxic Pollutants to POTWs
       4.      Removal of Toxic Pollutants by Secondary Treatment
       5.      Capability of POTWs to Revise Pretreatment Standards
       6.      Adequacy of Data on the Environmental Effects of Toxic Discharges from POTWs
       7.      Effectiveness of the National Pretreatment Program
       8.      Evaluation of Alternative Regulatory Strategies
       9.      Findings and Recommendations

CURRENT APPLICABILITY:

       This report represents the status of the National Pretreatment Program based on data from 1989.
       Since that time, EPA has promulgated new and revised regulations related to pretreatment, effluent
       limitations guidelines and categorical standards, and sewage sludge management and disposal. As
       such, regulatory structures described in the report  may not necessarily reflect current program
       activities.  The report does provide an excellent overview of the history of the National Pretreatment
       Program and the nature and concentrations of discharges to POTWs from various industrial sectors,
       culminating in an assessment of the effectiveness of the Pretreatment  Program in controlling
       discharges and recommendations approaches to address future challenges.
Appendix A
                                          A-29

-------
 Annotated Summaries of Existing Pretraatment Guidance Material
                      Introduction to the National Pretreatment I
 NPDES COMPLIANCE INSPECTION MANUAL
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 ENFORCEMENT AND COMPLIANCE ASSURANCE
 SEPTEMBER 1994
 EPA3QO-B-94-014
                                         NPDES
                                         Cornputincs Inspoctlon
                                         Manual   ^^
 AVAILABILITY:   WRC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
525
        This manual provides guidance applicable to each type of inspection a
        National Pollutant Discharge Elimination System (NPDES) inspector may be required to conduct at
        an NPDES permitted facility. Chapter 9 of this manual is specific to the pretreatment program. Part
        A of the chapter presents a review of the program and summarizes  the general  pretreatment
        regulations (40 CFR 403) and categorical standards. Part B of the chapter discusses the scope of
        Pretreatment Compliance Inspections (PCIs) and audits, and lists the components of PCI and audit
        checklists. Part C of the chapter provides a list of pretreatment references.
 TABLE OF CONTENTS:

        1.      Introduction
        2.      Inspection Procedures
        3.      Documentation/Recordkeeping and Reporting
        4.      Facility Site Review
        5.      Sampling
        6.      Flow Measurement
        7.      Laboratory Procedures and Quality Assurance
        8.      Toxicity
        9.      Pretreatment
        10.    Sewage Sludge
        11.    Storm Water
        12.    Combined Sewer Overflows
        13.    Pollution Prevention
        14.    Multimedia Concerns

 CURRENT APPLICABILITY:

        This manual is applicable to the current pretreatment program as well as all other NPDES programs.
        With five different NPDES programs discussed (Permits, Pretreatment, Sewage Sludge, Storm Water,
        and Combined Sewer Overflows), it is likely that changes to various programs will occur making
        references to specific regulations out-of-date. The procedures specified for performing the various
        programmatic inspections, however, should remain accurate.
f\ -OU
                                                                                     Appendix A

-------
POTW SLUDGE SAMPLING AND ANALYSIS GUIDANCE DOCUMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PERMITS DIVISION
AUGUST 1989
                                         POTW Sludge SampllnsAfld
                                         Analysis Guldimc«D63lin«rt
AVAILABILITY:   NCEPI, NEPI

APPROXIMATE NUMBER OF PAGES:
80
SUMMARY:
       This  manual was  developed  to provide guidance  on appropriate
       procedures for POTWs to follow when collecting and analyzing municipal
       sludge samples. The manual provides guidelines for developing and implementing a sampling and
       analysis program. A description of sampling equipment, sampling frequency, sample preservation,
       labeling, packaging, transporting and holding times is included. Laboratory analytical techniques are
       summarized  for  various analytes.   The manual  discusses the  components  of a  quality
       assurance/quality control plan. Finally, the manual provides guidelines for gathering information on
       sludge quality, such as determination of volatile solids, and for determining compliance with permit
       conditions. The manual is intended for use by POTW operators, engineers, managers, chemists and
       permit writers.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Sludge Sampling
        3.      Analytical Procedures
        4.      Quality Assurance/Quality Control
        5.      Sampling and Analytical Costs
        6.      References

CURRENT APPLICABILITY:

        This guidance is generally applicable, although it does not cite the most current analytical methods
        and techniques as referenced in 40 CFR Part 136.  In addition, cost ranges for analyses are low,
        reflecting 1989 cost information.  Additionally, the guidance was published prior to the Part 503
        Sewage Sludge Use and Disposal regulations and as such, the current regulations are not referenced
        in the manual.
 Appendix A
                                                                                         A-31

-------
Annotated Summaries of Existing Pretreatment Guidance Material
 IB!•
                                                          Jntroductlon to the National Pretreatment Program
  PRELIM USERS GUIDE
  P^EL'M : PRETREATMENT LIMITATIONS MODEL, VERSION 5.0 - USER'S GUIDE
  U.S. ENVIRONMENTAL PROTECTION AGENCY
  OFFICE OF WASTEWATER MANAGEMENT
  JANUARY 1987
 AVAILABILITY:   NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
                                    150
        The computer program PRELIM 5.0 is designed to be used in conjunction
        with U.S. Environmental Protection Agency's (EPA's) 1987  Guidance Manual on the Development
        and Implementation of Local Discharge Limitations.  The  program  can be useful to POTWs for
        developing or revising local limits and  to Approval Authority personnel for reviewing  local limit
        submissions. The program simulates the methodology and calculations found in EPA's Local Limits
        Guidance manual (referenced above). Users of the program should be familiar with the procedures
        and methodologies for setting local limits. PRELIM  cannot  replace sound  judgement where
        interpretation of input or output data is needed. Moreover, the technical adequacy of the PRELIM
        output is primarily a function of the quality of the POTW specific data  input to the program.

        The User's Guide provides information on getting started, data sheets useful for data collection and
        organization, data entry procedures, and descriptions of data output sheets.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Getting Started
        3.      Data Sheets
        4.      Data Entry
        5.      PRELIM Output Equations


CURRENT APPLICABILITY:
                  ,, 'i-

       This guidance  manual is still applicable; however the literature data used in the program will be
       updated in conjunction with the revisions to the Local Limits Guidance. While many EPA Regions and
       Sates have developed spreadsheets for local limits development, the basis for this guidance manual
       is still appropriate and is still used by some Control Authorities.
                                                                                    Appendix A

-------
Introduction to the National Pretreatment Program
          Annotated Summaries of Existing Pretreatment Guidance Material
PRETREATMENT COMPLIANCE INSPECTION AND  AUDIT MANUAL FOR  APPROVAL
AUTHORITIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND PERMITS
JULY 1986

AVAILABILITY:    WRC, NTIS, ERIC, NCEPI, NEPI
                                          Pretreatmsnt Compliance
                                          Inspection and Audit Manual
                                          for Approval
APPROXIMATE NUMBER OF PAGES:
120
SUMMARY:
                                                                                      MM
       This guidance manual is  intended to provide  guidance for those responsible for conducting
       Pretreatment Audits and Pretreatment Compliance Inspections (PCIs).  The manual outlines the
       general procedures that an auditor or inspector should  follow to perform a well-organized and
       thorough review of Control Authority Pretreatment Program Implementation. The manual summarizes
       procedures for preparation and conduct of the PCI or audit, documentation and report preparation,
       follow-up responses to the Control Authority, and data entry into EPA's water data management
       system (i.e., the Permit Compliance System - PCS).  Key features of the guidance manual are the
       PCI and audit checklists that are to be used during the conduct of oversight activities.
TABLE OF CONTENTS:

       1.      Introduction
       2.      Overview and Background
       3.      PCI and Audit Procedures
       4.      Pretreatment Compliance Inspection (PCI) Checklist
       5.      Pretreatment Program Audit Checklist

CURRENT APPLICABILITY:

       EPA updated both the PCI and Audit Procedures/Checklists subsequent to this document. This
       document does contain applicable information pertaining to procedural activities (e.g., preparation,
       entry procedures,  and  report preparation) performed as part of a PCI/Audit.  Two references,
       Guidance for Conducting a Pretreatment  Compliance Inspection (September 1991) and Control
       Authority Pretreatment Audit Checklist and Instructions (May 1992) identify EPA's latest checklists
       and procedures for these Approval Authority oversight responsibilities.
                                                                                         A-33

-------
 Annotated Summarl&s ofExIsti
                                                           Introduction to the National Pretreatment Program
 PRETREATMENT COMPLIANCE MONITORING AND ENFORCEMENT GUIDANCE
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER ENFORCEMENT AND PERMITS (EN-336)
 SEPTEMBER 1986
                                                                 PTStr«mrmnt Compllonco
                                                                 Monltorfrtu und Enforccmant
                                                                 Qutdanco
 AVAILABILITY:    WRC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
                       160
        This manual is  intended  to assist  Control Authorities in  translating ggS3i!5f£5fEES
        regulatory requirements into a workable, effective pretreatment program.
        Control Authorities may be unable to implement all aspects of the guidance initially, but may adopt
        the recommended approaches on a phased basis. This guidance provides a detailed discussion of
        POTW program implementation activities, including establishing IU monitoring requirements, sampling
        and inspecting IDs, reviewing IU reports, setting enforcement priorities, and reporting progress to
        Approval Authorities. The guidance also establishes a definition of Significant Noncompliance (SNC)
        to be applied in evaluating IU performance for targeting implementation and enforcement activities.

        In conjunction with the Pretreatment Compliance Monitoring and Enforcement (PCME) Guidance,
        EPA developed a software program (called PCME with Version 3.0 the most recent) that is designed
        to assist Control Authorities in tracking IU compliance with applicable pretreatment standards. The
        menu driven PCME system provides an automated means for maintaining an inventory of all SlUs,
        recording analytical data, and tracking other program activities (i.e., report submission, IU inspections,
        and enforcement actions). PCME Software also calculates SNC using the Federal definition and has
        a report generation option for creating a Control Authority's Annual Pretreatment Program Summary
TABLE OF CONTENTS:
        1.
        2.
        3.1
        3.2
        3.3
        3.4
        3.5
Introduction
Industrial User Pretreatment Requirements
Industrial User Self-Monitoring Frequencies
General Control Authority Implementation Responsibilities
Enforcement Principles and Mechanisms
Responding to Industrial User Noncompliance
Control Authority Recordkeeping and Reporting to Approval Authority
CURRENT APPLICABILITY:

       Many of the concepts in this guidance manual are still applicable to the pretreatment program,
       although the 40 CFR Part 403 General Pretreatment Regulations have been modified several times'
       since publication. Additionally, PCME Software (Version 3.0) is current and can be used to track IU
       compliance with applicable requirements.
                                                                                     Appendix A

-------
Introduction to the National Pretreatment Program
          Annotated Summaries of Existing Pretreatment Guidance Material
PRETREATMENT FACILITY INSPECTION: A FIELD STUDY TRAINING PROGRAM
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER ENFORCEMENT AND PERMITS (EN-336)
SECOND EDITION, 1991

AVAILABILITY:

       OFFICE OF WATER PROGRAMS
       CALIFORNIA STATE UNIVERSITY
       SACRAMENTO, CA95819
       (916)278-6142
APPROXIMATE NUMBER OF PAGES:
780
SUMMARY:
       This manual is designed to assist pretreatment inspectors perform their jobs safely and fairly. The
       manual contains the information necessary to detail specific procedural and regulatory requirements
       that an inspector needs to be familiar with to carry out pretreatment inspections. In addition to
       providing guidance, this manual provides a home study training program, geared towards developing
       new qualified pretreatment facility inspectors, expanding the abilities of existing inspectors, and
       preparing inspectors for civil service examinations.
TABLE OF CONTENTS:

        1.      The Pretreatment Facility Inspector
        2.      Pretreatment Program Administration
        3.      Development and Application of Regulations
        4.      Inspection of a Typical Industry
        5.      Safety in Pretreatment Inspection and Sampling Work
        6.      Sampling Procedures for Wastewater
        7.      Wastewater Flow Monitoring
        8.      Industrial Wastewaters
        9.      Pretreatment Technology (Source Control)
        10.     Industrial Inspection Procedures
        11.     Emergency Response

CURRENT APPLICABILITY:

        This guidance manual  is still applicable to the pretreatment program, although the 40 CFR Part 403
        General Pretreatment  Regulations have been modified several times since publication. The author
        does anticipate updating this guidance on a periodic basis.
Appendix A
                                                     A-35

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
 PROCEDURES  MANUAL  FOR REVIEWING A  POTW PRETREATMENT  PROGRAM
 SUBMISSION      ;,"
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER ENFORCEMENT AND PERMITS
 OCTOBER 1983
                                     «EFA  Pifocijdu'rMM«nuiii
                                         for Revlowlnp a POTW
                                         Pratraatmint Program
                                         Submlwlon
 AVAILABILITY:   WRC, NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:

 SUMMARY:
140
        This guidance manual is intended to provide guidance to States and EPA
        Regions in reviewing local pretreatment program  submissions.  The manual  should provide a
        framework for the review of local programs as well as general criteria for evaluating these programs.
        A separate chapter of the manual is devoted to each of the essential elements of a successful
        pretreatment program, including legal authority, technical information, implementation procedures,
        and resources.  For each element, the manual  provides a summary of the applicable regulatory
        requirements, a discussion of key items that should be included in the submission, general guidelines
        and criteria for assessing the adequacy of the approaches proposed by the Control Authority, and a
        checklist to aid the reviewer in evaluating the completeness and adequacy.
TABLE OF CONTENTS:

        1.      Introduction
        2.      Legal Authority
        3.      Technical Information
        4.      Program Implementation Procedures
        5.      Organization, Staffing, Equipment, and Funding

CURRENT APPLICABILITY:

        This guidance manual sets out a framework for a pretreatment program that is consistent with current
        EPA approaches; however, most of the references to regulatory information presented are obsolete.
        Since the cornerstone of a pretreatment program submission is its adherence to the  Federal
        requirements, the bulk of this manual focuses on evaluating compliance with specific regulatory
        requirements. Users of this document should be aware that the regulatory cites in the manual have
        likely been updated, modified, or expanded since publication of the manual.

-------
 Introduction to the National Pretreatment Program
          Annotated Summaries of Existing Pretreatment Guidance Material
 RCRA INFORMATION ON HAZARDOUS WASTES FOR PUBLICLY OWNED TREATMENT
 WORKS
 U.S. ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF WATER ENFORCEMENT PERMITS
 SEPTEMBER 1985
                                         RCRA information
                                         on Hazardous Wastos
                                         for Publicly Owned
                                         Treatment Work?
 AVAILABILITY:   WRC, NTIS, ERIC

 APPROXIMATE NUMBER OF PAGES:
90
 SUMMARY:
        The intent of this manual is to provide guidance to municipal personnel in
        understanding hazardous waste requirements of the Resource Conservation and Recovery Act
        (RCRA) and the implications of these RCRA requirements for the wastewater treatment plant. This
        manual explains the relationship of RCRA to the National Pretreatment Program, and the RCRA
        notification requirement specified in the General Pretreatment Regulations. The manual focuses on
        Subtitle C requirements that regulate generators, transporters and disposers of hazardous waste
        which are therefore directly applicable to industries. Chapters two, three and four summarize RCRA
        requirements for generators and transporters of hazardous waste, outline POTW requirements under
        the General Pretreatment Regulations and explain how POTWs must regulate discharges of toxic
        pollutants, and describe obligations under RCRA for POTWs, focusing on those POTWs that accept
        hazardous waste by truck, rail or separate pipe.
TABLE OF CONTENTS:
        1.      Introduction
        2.      RCRA Obligations for Generators and Transporters of Hazardous Waste
        3.      POTW Authority to Regulate Toxic Waste Discharges Under the General Pretreatment
               Regulations
        4.      RCRA Requirements for POTWs
CURRENT APPLICABILITY:

       RCRA requirements applicable to POTWs referenced in this manual are still applicable. Similarly,
       the POTWs authority to regulate toxic wastes discharged are still accurate. Since publication of this
       manual, however, numerous changes to the RCRA regulations have occurred. Additionally, General
       Pretreatment Regulations have changed and now require I Us that discharge to the POTW wastes that
       would  be hazardous if disposed of otherwise to report this information to the POTW (40 CFR
       §403.12(p)).
Appendix A
                                                                                       A-37

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
                                                          Introduction to the National Pretreatment Program
REPORT TO CONGRESS ON THE DISCHARGE OF HAZARDOUS WASTES TO PUBLICLY
OWNED TREATMENT WORKS                                                *B*
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER REGULATIONS AND STANDARDS
EPA/53Q-SW-86-004
FEBRUARY 1986
                                                                              Report to Congress
                                                                              on the Discharge
                                                                              of Hazardous Wastes
                                                                              io Publicly Owned
                                                                              TraotmsHt Works
AVAILABILITY:   NTIS, ERIC
APPROXIMATE NUMBER OF PAGES:
                                    1,100
SUMMARY:
       Section 3018(a) of the Resource Conservation and Recovery Act (RCRA) required EPA to prepare
       a report concerning hazardous wastes identified or listed in RCRA which are not regulated under
       RCRA by reason of the exclusion for mixtures of domestic sewage and other wastes that pass
       through a sewer system to a POTW. The report includes the types, size and number of generators
       that dispose of wastes to POTWs, the types and quantities of wastes disposed, and the identification
       of significant generators, wastes, and waste constituents not regulated under existing Federal law or
       regulated in a manner sufficient to protect human health and the environment.
TABLE OF CONTENTS:

       1.      Introduction
       2.      Description of Hazardous Wastes and Pollutants Evaluated in the Study
       3.      TyPes, Quantities, and Sources of Hazardous Wastes Discharged to POTWs
       4.      Fate of Hazardous Waste and Pollutants in POTW Collection and Treatment Systems
       5.      Effects of Discharges of Domestic Sewage Study Pollutants to POTWs
       6.      Evaluation of Government Controls on Hazardous Waste Discharges to Sewers
       7.      Findings and Recommendations

CURRENT APPLICABILITY:

       This report presents the impacts of waste discharged to POTWs as a result of the Domestic Sewage
       Exclusion. With this exclusion still in effect, the findings of the study provide an accurate overview
       of the impacts of wastes on POTWs. However, data provided in the study regarding the nature and
       concentration of discharges from various  industrial sectors and the characteristics of facilities
       discharging to POTWs no longer provides an accurate depiction. The finding that the Domestic
       Sewage Exclusion should be retained represents the Agency's current policy.
                                                                                    Appendix A

-------
Introduction to the National Pretreatment Program
          Annotated Summaries of Existing Pretreatment Guidance Material
SUPPLEMENTAL MANUAL ON THE DEVELOPMENT AND IMPLEMENTATION OF LOCAL
DISCHARGE LIMITATIONS UNDER THE PRETREATMENT PROGRAM: Residential and
Commercial  Toxic Pollutant  Loadings and  POTW Removal Efficiency
Estimation
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER (EN-336)
21W-4002
MAY 1991
AVAILABILITY:   NTIS, ERIC

APPROXIMATE NUMBER OF PAGES:
120
SUMMARY:
       The intent of this  guidance  manual is  to supplement  EPA's 1987  Guidance Manual on the
       Development and Implementation of Local Discharge Limitations and assumes that the reader has
       a thorough understanding of local limits guidance. The guidance manual is a two-part document that
       provides information on (1) toxic pollutant loadings from residential and commercial sources and (2)
       the calculation of removal efficiencies achieved by POTWs.  Part 1 of the guidance provides
       background information on pollutant levels  in residential wastewater and in wastewaters  from
       commercial sources, and characterizes toxic pollutant discharges from these sources. Part 2 of the
       guidance expands on EPA's 1987 Local Limits Guidance Manual (referenced above) regarding the
       calculation of POTW removal efficiencies. Specifically, it provides more detailed guidance on the use
       of the decile approach for calculating removal efficiencies.
TABLE OF CONTENTS:

       1.      Residential and Commercial Sources of Toxic Pollutants
       2.      Removal Efficiency Estimation for Local Limits

CURRENT APPLICABILITY:

       This guidance manual is still applicable to the current pretreatment program, although the usefulness
       of Part 1 has diminished. Part 1 of the manual describes residential and commercial sources of toxic
       pollutants and the contributions that can be expected from these sources. While the initial intent of
       the manual was for POTWs to use these figures in the locallimits calculations, most EPA Regions
       and States now strongly recommend or require that site-specific data be collected.  Part 2 of the
       manual does provide EPA's recommended approach for calculating POTW removal efficiencies for
       developing technically-based local limits.  EPA expects to publish a revised Local Limits Guidance
       Manual in the near future.
Appendix A
                                                                                        A-39

-------
 Annotated Summaries of Existing Pretreatment Guidance Material
Introduction to the National Pretreatment Program
A-40
                                                                                                        Appendix A

-------
         APPENDIX B
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-------
Introduction to the National Pretreatment Program
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                                                                                         B-1

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 Document Ordering Information
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                                                                                       Appendix B

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Introduction to the National Pretreatment Program
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Appendix B                                                                                  8-3

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                           Appendix B

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                                                                                                     B-5

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 Document Ordering Information
Introduction to the National Pretreatment Program
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B-6
                                                                                     Appendix B

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Introduction to the National Pretreatment Program
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Appendix B
                                                   B-7

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 Docum&nt Orttorfng Information
Introduction to the National Pretreatment Proaram
B-8
                                                                                                    Appendix B

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                   APPENDIX C
EPA/STATE PRIMARY PRETREATMENT CONTACTS/ADDRESSES

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Introduction to the National Pretreatment Program
             EPA/State Primary Pretreatment Contacts/Addresses
                                            APPENDIX C

                    EPA/STATE PRIMARY PRETREATMENT CONTACTS/ADDRESSES

                                       U.S. EPA Headquarters

                                  U.S. Environmental Protection Agency
                                  Pretreatment and Multimedia Branch
                                      Permits Division (MC4203)
                                          401 M Street, SW
                                        Washington, DC 20460
                       Patrick Bradley
                       Robin Danesi
                       Brian Frazer
                       John Hopkins
                       Jan Pickrel
                       Jeff Smith
(202) 260-6963
(202) 260-2991
(202)260-0101
(202) 260-9527
(202) 260-7904
(202) 260-5586

Region 1
bradley.patrick@epa.gov
danesi.robin@epa.gov
frazer.brian@epa.gov
hopkins.john@epa.gov
pickrel.jan@epa.gov
smith.jeff@epa.gov
                            Mr. Justin (Jay) Pimpare, Pretreatment Coordinator
                                         U.S. EPA-Region!
                                    Municipal Assistance Unit (CMU)
                                        J.F.K. Federal Building
                                          Boston, MA 02203
                               phone: (617)918-1531  fax:(617)918-2064
                                    email: pimpare.justin@epa.gov
Mr. Jim Grier, Pretreatment Coordinator
CT Department of Environmental Protection
Bureau of Water Management
79 Elm St.
Hartford, CT 06106-5127
(860) 424-3839

Mr. Mike Harder, Engineering and Enforcement
CT Department of Environmental Protection
Bureau of Water Management
79 Elm St.
Hartford, CT 06106-5127
(860) 424-3701

Mr. Peter Dore, Chief
Industrial Wastewater Treatment Section
MA Dept. of Environmental Protection
Division of Water Pollution Control
One  Winter Street - 7th Floor
Boston, MA 02108
(617)292-5665

Mr. Jim Rogers, Environmental Specialist
Division of Water Resource Regulations
ME Department of Environmental Protection
Statehouse Station 17
Augusta,  ME 04333
(207) 287-7774
jim.r.rogers@state.me.us
        Mr. George Carlson, Jr.
        Surface Water Quality Bureau
        NH Department of Environmental Services
        P.O. Box 95
        6 Hazen Drive
        Concord, NH 03302-0095
        (603) 271-2052
        g_carlson@des.state.nh.us

        Mr. Bob DiSaia, Supervising Engineer
        Permits, Pretreatment & Planning Section
        Rl Dept. of Environmental Management
        Water Resources Division
        235 Promenade Street
        Providence, Rl  02908
        (401) 222-6519 ext. 7228
        Rdisaia@dem.state.ri.us

        Mr. Brian Kooiker, Chief
        Vermont Department of Environmental Conservation
        Permits, Compliance and Protection Division
        The Annex Building
        103 South Main Street
        Waterbury, VT 05676
        (802) 241-3822
        brian.kooiker@anrmail.anr.state.vt.us
Appendix C
                                                   C-1

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 EPA/Stata Primary Pretreatment Contacts/Addresses
                                                                Introduction to the National Pretreatment
                                                Region 2
                                Ms. Virginia Wong, Pretreatment Coordinator
                                           U.S. EPA-Region 2
                                        Water Compliance Branch
                                        290 Broadway - 20th Floor
                                        New York, NY 10007-1866
                                phone: (212)637-4241   fax:(212)637-4211
                                      email: wong.virginia@epa.gov

                                       Other EPA Region 2 Contact:
                                    Ms. Jacqueline Rios (212) 637-3859
 Ms. Mary Jo Aiello, Bureau Chief (CN-029)
 Bureau of Pretreatment and Residuals
 NJ Dept. of Env. Protection
 401 E. State Street, 4th Floor
 Trenton, NJ 08625
 (609) 633-3823
 malello@dep.state.nj.us

 Mr. Jim Murphy, Principal Environmental Engineer
 NJ Dept of Env. Protection
 401 E. State Street, 4th Floor
 Trenton, N J 08625
 (609) 633-3823
 jmurphy@dep,state.nj.us

 Mr. Robert Cronln, Director
 Bureau of Water Compliance Programs
 New York State Department of
 Environmental Conservation
 50 Wolf Road
 Albany, NY 12233-3506
 (518)457-5968
 Ms. Wanda Garcia, Permits Section Chief
 Environmental Quality Board
 Commonwealth of Puerto Rico
 P.O. Box 11488
 Santruce, PR 00910
 (787)751-1891

 Mr. Ben Nizario, Director
 Environmental Protection Division
 VI Department of Natural Resources
 Nisky Center, Suite 231
 North 45A Estate Nisky
 Charlotte Amalie
 St. Thomas, VI 00802
 (809) 774-3320
                                               Region 3
                                 Mr. John Lovell, Pretreatment Coordinator
                                          U.S. EPA - Region 3
                                  Office of Municipal Assistance (3WP24)
                                           1650 Arch Street
                                         Philadelphia, PA 19103
                               phone: (215) 814-5790  fax: (215)814-2302
                                       email: loyeil.john@epa.gov

                                     Other EPA Region 3 Contacts:
                                   Mr. Steve Copeland (215) 814-5792
Mr. James Collier, Chief
Water Hygiene Branch
Department of Consumer and Regulatory Affairs
2100 Martin Luther King Ave., SE, Suite 203
Washington, DC 20020
(202)404-1120
Mr. Joe Mulrooney
Delaware Department of Natural Resources
and Environmental Control
Division of Water Resources
Pollution Control Branch
89 Kings Highway
Dover, DE 19903
(302) 739-5731
                                                                                                 C-2

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Introduction to the National Prstfsatrnent Program
                                           Region 3 (cont.)
Mr. Gary F. Kelman, Head
Pretreatment Section
Maryland Dept of the Environment
Industrial Discharge Permits Division
Water Management Administration
2500 Broening Highway
Baltimore, MD 21224
(410)631-3630
gkelman@mde.state.md.us

Mr. R.B. Patel, Chief
Permits Section
PA Department of Env. Resources
Bureau of Water Quality Management
P.O. Box 2063
Harrisburg, PA 17120
(717)787-8184
patel.ratilal@a1.dep.state.pa.us
Mr. Burton R. Tuxford, Pretreatment Coordinator
VA Dept. of Environmental Quality
Office of Water Permit Support
629 E. Main Street; PO Box 10009
Richmond, VA 23240
(804) 698-4086
brtuxford@deq.state.va.us

Mr. David Montali, Pretreatment Coordinator
Water Resources Section
Department of Commerce, Labor and Environmental
Resources
Division of Natural Resources
1201 Greenbrier Street
Charleston, WV 25311
(304) 558-4086
                                              Region 4
                           Ms. Melinda Mallard Greene, Pretreatment Coordinator
                                         U.S. EPA-Region 4
                                  Water Permits & Enforcement Branch
                                            61 Forsyth St
                                        Atlanta, GA 30303-3415
                               phone: (404) 562-9771; fax (404) 562-9729
                                    email: mallard.melinda@epa.gov
Mr. Ed Hughs, Pretreatment Coordinator
Water Division
Alabama Department of Environmental Management
1751 Cong. WL Dickinson Drive
Montgomery, AL  36130
(334)271-7838
ekh@adem.state.al.us

Mr. Robert E. Heilman
Domestic Wastewater Section (MS #3540)
FL Department of Environmental Protection
Twin Towers Office Building
2600 Blair Stone  Road
Tallahassee, FL  32399-2400
(850) 922-4296
heilman_r@dep.state.fl.us

Mr. Jim Sommerville, Manager
GA Dept. of Natural Resources
Environmental  Protection Division
Atlanta Tradeport, Suite 110
4244 International Parkway
Atlanta, GA 30354
(404) 362-2624
jim_sommerville@mail.dnr.state.ga.us
Ms. Sandra Gruzesky, Pretreatment Section
KY Dept. of Environmental Protection
Division of Water/KPDES Branch
14 Reilly Road, Frankfort Office Park
Frankfort, KY 40601-1189
(502) 564-2225 ext. 459
gruzesky@nrdep.nr.state.ky.us

Mr. Harry M. Wilson 111, P.E.
Pretreatment Program
Office of Pollution Control
MS Department of Environmental Quality
P.O. Box 10385
Jackson, MS 39209-0385
(601)961-5122
Harry_Wilson@deq.state.ms.us

Mr. Tom S. Poe
Division of Water Quality
NC Dept. of Env. and Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
(919) 733-5083 ext. 522
tom_poe@h2o.enr.state.nc.us
Appendix C
                                                                                                 C-3

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  EPA/State Primary Pretreatment Contacts/Addresses
                                                                Introduction to the National Pretreatment Prvi
                                                                                                   ram
                                             Region 4 (cont.)
  Mr. Abe Rowson
  Wastewater Management Section
  SC Department of Health and Environmental
  Services
  2600 Bull Street
  Columbia, SC 29201-1706
  (803) 734-5273
  rowsonae@colom32.dhec.state.sc.us
 Mr. Chuck Durham
 TN Division of Water Pollution Control
 6th Floor, L & C Annex
 401 Church Street
 Nashville, TN 37243-1534
 (615)532-0638
 cdurham@mail.state.tn.us
                                                Region 5

                                Mr. Matt Gluckman, Pretreatment Coordinator
                                           U.S. EPA - Region 5
                                     Water Quality Branch (5-WQP-16J)
                                          77 West Jackson Blvd.
                                          Chicago, IL 60604-3507
                                phone: (312) 886-6089  fax: (312) 886-7804
                                     email: gluckman.matthew@epa.gov

                                       Other EPA Region 5 Contact:
                                     Ms. Carol Staniec (312) 886-1436
 Mr. Steve Nightengale
 Division of Water Pollution Control
 IL Environmental Protection Agency
 2200 Churchill Road
 P.O. Box 19276   '
 Springfield, IL 96792-9272
 (217) 782-0610

 Mr, Bill Blue, Pretreatment Coordinator
 IN DepL of Env. Management
 105 South Meridian St
 P.O. Box 6015
 Indianapolis, IN 46206-6015
 (317) 232-8279
 bbluo@dom.state.in.us

 Ms. Grace Scott
 Ml Dept. of Natural Resources
 Knappes Center, 2nd Floor
 300 Washtenaw Street
 P.O. Box 30028
 Lansing, Ml  48933
 (517)373-8566
 scottg@deq.state.mi.us
 Mr. Randy Dunnette, Pretreatment Coordinator
 MN Pollution Control Agency
 520 Lafayette Road
 St. Paul, MN 55155-4194
 (651)296-8006
 randall.dunnette@pca.state.mn.us

 Ms. Jennie Leshnock, State Pretreatment Coordinator
 Ohio Environmental Protection Agency
 P.O. Box 1049
 1800 Water Mark Drive
 Columbus, OH 43266-1049
 (614) 644-2028
jennie.leshnock@epa.state.oh.us

 Mr. Chuck Schuler, Pretreatment Coordinator
Wl Dept. of Natural Resources
Wastewater Management, WW/2
P.O. Box 7921
Madison, Wl  53707
(608) 267-7631
schulc@dnr.state.wi.us
Appendix C
                                                                                                 C-4

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Introduction to the National Pretreatment Program
      EPA/State Primary Pretreatment Contacts/Addresses
                                              Region 6

                                Mr. Lee Bohme, Pretreatment Coordinator
                                          U.S. EPA - Region 6
                                    NPDES Permits Branch (6WQ-PO)
                                  Fountain Place, 12th Floor, Suite 1200
                                          1445 Ross Avenue
                                         Dallas, TX 75202-2733
                               phone: (214) 665-7532  fax: (214) 665-6490
                                       email: bohme.lee@epa.gov

                                      Other EPA Region 6 Contacts:
                                     Mr. Mike Tillman (214) 665-7531
                                    Mr. Al Hernandez (215) 665-7522
Mr. Allen Gilliam, Pretreatment Coordinator
AR Department of Pollution Control and Ecology
P.O. Box8913
8001 National Drive
Little Rock, AR 72219-8913
(501)682-0625
gilliam@adeq.state.ar.us

Mr. Ronnie Bean, Pretreatment Coordinator
Water Pollution Control Division
Louisiana Dept. of Env. Quality
P.O. Box82215
Baton Rouge, LA 70884-2215
(504) 765-2779
ronhie_b@deq.state.la.us

Mr. Steve Bumgarn, Water Quality Specialist
Surface Water Quality Bureau
New Mexico Dept. of the Environment
1190 Saint Francis Drive, Room N-2050
Santa Fe, NM  87502
(505) 827-2823
Ms. Andrea Heath, Pretreatment Coordinator
Water Quality Division
Oklahoma Dept. of Environmental Quality
P.O. Box1677
Oklahoma City, OK 73101-1677
(405)702-8193
andrea.heath@deqmail.state.ok.us

Ms. Jill Russell, Pretreatment Team Leader
Water Quality Division
Texas Natural Resource Conservation Commission
P.O. Box 13087, Capitol Station
Austin, TX 78711-3087
(512)239-4564
jrussel@tnrcc.state.tx.us
                                               Region 7
                             Mr. Paul Marshall, P.E., Pretreatment Coordinator
                                          U.S. EPA - Region 7
                                         726 Minnesota Avenue
                                         Kansas City, KS 66101
                               phone: (913) 551-7419  fax: (913) 551-7765
                                      email: marshall.paul@epa.gov
                                      Other EPA Region 7 Contact:
                                     Mr. Mike Turvey (913) 551-7424
Mr. Steve Williams, Environmental Specialist
Iowa Department of Natural Resources
Wallace State Office Building
900 East Grand
Des Moines, IA 50319
(515)281-8884
swillia@max.state.ia.us
Mr. Steve Gaspers, Pretreatment Specialist
Industrial Programs Section, Bureau of Water
KS Department of Health and Environment
Forbes Field, Bldg 283
Topeka, KS  66620-0001
(913)296-5551
Appendix C
                                            C-5

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  Mr. Richard Kunfz, P.E., Pretreatment Coordinator
  Missouri Department of Natural Resources
  P.O. Box 176
  205 Jefferson Street
  Jefferson City, MO 65102
  (673) 751-6996
  rkuntz@mai!.state.mo.us
 Mr. Rudy Fiedler, Pretreatment Coordinator
 NE Department of Environmental Quality
 P.O. Box 98922
 State Office Building
 Suite 400, The Atrium
 Lincoln, NE 68509-8922
 (402)471-4209
                                                Region 8

                                Mr. Curt McCormick, Pretreatment Coordinator
                                           U.S. EPA-Region 8
                                        NPDES Branch (8P2-W-P)
                                        999 18th Street, suite 500
                                         Denver, CO 80202-2466
                                phone: (303) 312-6377   fax: (303) 312-7084
                                      email: mccormick.curt@epa.gov
                                       Other EPA Region 8 Contact:
                                      Mr. Bruce Kent (303) 312-6133
 Mr. Rick Koplitz, Pretreatment Coordinator
 Colorado Department of Health
 4300 Cherry Creek Drive South
 Denver, CO 80222-1530
 (303) 692-3618
 rtek.koplltz@state.co.us

 Mr. Joe Strasko, Permits Officer
 MT Department of Health and Environmental
 Sciences
 Water Quality Bureau
 Cogswell Bldg., Room A-206
 Helena, MT 59620
 (466)444-2406

 Mr. Gary Bracht, Chief
 Permits Section
 North Dakota State Health Dept.
 P.O. Box 5520
 Bismarck, ND  58502-5520
 (701) 328-5227
 gbracht@ranch.state.nd.us
 Ms. Paula Huicenga, Natural Resources Engineer
 SD Department of Environment and Natural
 Resources
 Joe Foss Bldg.
 523 E. Capitol
 Pierre, SD 57501
 (605) 773-3351
 paulah@denr.state.sd.us

 Mr. Nathan Guinn, Pretreatment Coordinator
 Utah Department of Environmental Quality
 Division of Water Quality
 288 North 1460 West
 Salt Lake City, UT 84114-4870
 (801)538-6146
 nguinn@deq.state.ut.us

 Ms. Leah Krafft, Environmental Senior Analyst
WY Department of Environmental Quality
Water Quality Division
Herschler Bldg., 4th  Floor West
Cheyenne, WY 82002
(307)777-7093
lkraff@missc.state.wy.us
Appendix C
                                                                                                 C-6

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Introduction to the National Pretreatment Program
      EPA/State Primary Prefreatmenf Contacts/Addresses
                                              Region 9

                                 Mr. Keith Silva, Pretreatment Coordinator
                                         U.S. EPA - Region 9
                               Clean Water Act Compliance Office (WTR-7)
                                         75 Hawthorne Street
                                       San Francisco, CA 94105
                               phone: (415) 744-1907  fax: (415) 744-1235
                                      email: silva.keith@epa.gov
Mr. Mark Charles
Surface Water Enforcement
Office of Water Quality
AZ Department of Environmental Quality
3033 North Central Avenue
Phoenix, AZ 85012-2809
(602) 207-4567
Mr. Denis Lau, Chief
Clean Water Branch
Hawaii Department of Health
P.O. Box 3378
500 Ala Moana Blvd.
Honolulu, HI 96801-3378
(808) 586-4309
Mr. James W. Kassel, Chief
Regulation Unit
California State Water Resources Control Board
Division of Water Quality
P.O. Box 100
901 P Street
Sacramento, CA 95814-0100
(916)657-0775
kassj@dwq.swrcb.ca.gov

Mr. Joseph Livak
Bureau of Water Pollution Control
NV Division of Environmental Protection
Capital Complex
333 West Nye Lane
Carson City, NV 89710
(702) 687-4670 ext. 3143
                                             Region 10
                               Ms. Sharon Wilson, Pretreatment Coordinator
                                         U.S. EPA-Region 10
                                     NPDES Permits Unit (OW-130)
                                          1200 Sixth Avenue
                                       Seattle, WA 98101 -1128
                               phone: (206) 553-0325  fax: (206) 553-0165
                                     email: wilson.sharon@epa.gov
Mr. Robert Dolan
Environmental Engineer
AK Department of Environmental Conservation
555 Cordova St. Anchorage, AK 99501
(907) 269-7559

Mr. Jerry Yoder
Division of Environmental Quality
ID Department of Health and Welfare
State House Mail
1410 North Hilton
Boise, ID 83720-9000
(208) 334-5898

Doug Knutson
Washington Department of Ecology
Northwest Regional Office, M/S NB-81
3190-160th Avenue SE
Bellevue WA 98008-5452
(425) 649-7025  FAX(425) 649-7098
dknu461 @ecy .wa.gov
Ken Merrill
WA Department of Ecology
Eastern Regional Office
N. 4601 Monroe Street, Suite 100
Spokane WA 99205
(509)456-6148; FAX(509) 456-6175
KMER461 ©ECY.WA.GOV

Mr. Chuck Hopkins, Pretreatment Coordinator
Water Quality Division
OR Department of Environmental Quality
811  SW 6th Avenue
Portland, OR 97204-1390
(503) 229-6528
hopkins.chuck@deq.state.or.us

Mr. David Knight, Pretreatment Coordinator
WA Department of Ecology
Northwest Regional Office, M/S NB-81
3190-160th Avenue SE
Bellevue WA 98008-5452
(360) 407-6277
dakn461 @ecy.wa.gov
Appendix C
                                          C-7

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       Freebom
 WA Department of Ecology
 Central Regional Office
 15 West Yakima Ave., Suite 200
 Yakjma WA 98902
 (5QS) 454-7277; FAX(509) 454-4339
 WFRE461 @ecy .wa.gov
Appendix C
C-8

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