United States Office of Wastewater EPA-833-B-98-003
Environmental Protection Management (4203) September 1999
Agency
Guidance Manual for the
Control of Wastes Hauled to
Publicly Owned Treatment
Works
U.S. Environmental Protection Agency
Office of Wastewater Management
401 M Street, S.W.
Washington, B.C. 20460
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DISCLAIMER
This project has been funded, at least in part, with Federal Funds from the U.S.
Environmental Protection Agency (US EPA) Office of Wastewater Management under Contract
Number 68-C4-0068, Work Assignment Numbers PS-3-13 (P) and PS-4-13 (P). The mention
of trade names, commercial products, or organizations does not imply endorsement by the
U.S. Government.
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CONTENTS
1. INTRODUCTION 1-1
1.1 Background 1-1
1.2 Purpose of Guidance Manual 1-2
1.3 Organization 1-3
2. COLLECTING WASTE HAULER INFORMATION, CHARACTERIZING HAULED
WASTE, AND EVALUATING POTENTIAL IMPACTS TO TREATMENT
PLANTS 2-1
2.1 Collect Waste Hauler Information 2-1
2.1.1 Identify Waste Haulers Potentially Discharging to the POTW 2-1
2.1.2 Require Waste Haulers to Submit Information 2-2
2.1.3 Maintain Data and Information 2-3
2.2 Characterize Hauled Waste 2-3
2.2.1 Domestic Waste 2-4
2.2.2 Non-Domestic Waste 2-4
2.3 Evaluate Potential Impacts to Treatment Plant 2-12
2.3.1 Potential Impacts to Treatment Plants 2-12
2.3.2 Determine Potential Impacts From Specific Waste Sources/Types 2-14
2.3.2.1 Determine Whether Waste Meets All Applicable Standards .... 2-17
2.3.2.2 Determine Whether Waste Has the Potential to Cause Pass
Through or Interference 2-19
2.3.2.3 Determine Whether Waste Has Other Problem Characteristics .. 2-21
3. DEVELOPING AND IMPLEMENTING CONTROLS 3-1
3.1 Legal Authority 3-1
3.1.1 General Authority to Impose Controls 3-1
3.1.2 Provisions Necessary for Controlling Waste Haulers 3-2
3.2 Active Controls 3-4
3.2.1 Controlled Designated Disposal Site 3-4
3.2.1.1 Access, Hours of Operation 3-6
3.2.2 Application of Standards and Limits 3-6
3.2.2.1 Local Limits 3-6
3.2.2.2 Categorical Standards 3-7
3.2.3 Permits 3-9
3.2.3.1 Permit Conditions 3-11
3.2.4 Monitoring Program 3-12
3.2.4.1 Sample Types 3-13
3.2.4.2 Sampling Frequency 3-14
3.2.4.3 Testing Parameters 3-16
3.2.5 Waste Tracking/Manifest System 3-18
3.2.6 Identification of Illegal Dischargers 3-18
3.3 Communication 3-19
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4.
3.3.1 Communication with Other POTWs 3-19
3.3.2 Communication with Waste Haulers 3-20
3.4 Review and Update Controls 3-20
CASE STUDIES 4-1
APPENDICES
Appendix A Glossary of Terms
Appendix B Bibliography
Appendix C List of State and Regional Pretreatment Coordinators
Appendix D Waste Transporter Authorization Application
Appendix E Summary of Industries Regulated by Categorical Standards and Process
Descriptions
Appendix F Reference Documents with Information on Flammability, Explosivity, and Health
Hazards of Chemicals
Appendix G Hauled Waste Ordinance Language
Appendix H Hauled Waste Manifest Forms
TABLES
Table 2.1 Example Waste Profile Form 2-5
Table 2.2 Comparison of Selected Pollutant Concentrations in Domestic Septage and
Domestic Wastewater 2-8
Table 2.3 Comparison of Selected Pollutant Concentrations in Domestic Septage and Sewage
Sludge 2-9
Table 2.4 Example Pollutant Concentrations in Landfill Leachate 2-11
Table 2.5 Field Monitoring and Laboratory Instalments 2-18
Table 3.1 Waste Hauler Ordinance Example Table of Contents 3-3
Table 3.2 Septage Hauler Monitoring Data 3-17
Table 3.3 Example Monitoring Parameters for Initial Characterization 3-17
FIGURES
Figure 2.1 Determining Hauled Waste Characteristics 2-7
Figure 2.2 New or Different Load Decision Flow Chart 2-16
Figure 3.1 Procedures of a Waste Hauler Permit Program 3-10
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Foreword
Hauled waste may cause adverse impacts to wastewater treatment plants because it is usually
more concentrated than typical domestic wastewater and may not be equalized when discharged.
Adverse impacts may include pass through, interference, sludge contamination, and hazards to
POTW personnel. To help prevent hauled wastes from causing problems, POTWs need to
adequately control the discharge of hauled waste to their treatment plants.
Many POTWs with pretreatment programs have already developed controls for hauled waste.
The control of hauled waste at these POTWs can result in the disposal of hauled waste to POTWs
without controls, usually smaller POTWs. This shift in disposal of hauled wastes to smaller
POTWs can result in negative impacts at those plants.
This guidance is designed to provide information for smaller POTWs, generally those without
pretreatment programs, on how to develop and implement hauled waste controls. The guidance
discusses collection of information on waste haulers, characterization of hauled waste received,
evaluation of potential impacts, and the development and implementation of controls. The
guidance also includes case studies of successful waste hauler programs and example forms.
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1. INTRODUCTION
1.1 Background
Publicly Owned Treatment Works (POTWs) receive wastewater from a variety of
domestic (household) and non-domestic sources [commercial businesses (restaurants, laundries,
dry cleaners, car washes, etc), and industries]. Smaller POTWs receive mostly domestic
wastewater, while larger POTWs generally receive a more complex mixture of wastewater from a
variety of sources. Most of these wastewater sources are connected to the sewer system and
discharge to the treatment plant through a system of pipes and interceptors. However, wastes
may also be transported by truck or rail to POTWs by waste haulers. Such hauled waste may
include domestic septage, chemical toilet waste, grease and sand trap waste, non-hazardous
commercial and industrial (categorical and non-categorical) waste, hazardous waste,
groundwater remediation site waste, and landfill leachate.
Because pollutants are usually more concentrated in hauled waste than in typical domestic
wastewater, and because hauled waste may not be equalized when discharged, hauled waste may
cause adverse impacts at treatment plants. These adverse impacts may include pass through to
the receiving water, interference with treatment plant processes and operations, sludge
contamination, and hazards to POTW personnel. To help prevent hauled wastes from causing
problems, POTWs need to adequately control the discharge of hauled waste.
Treatment Plant Damaged by Illegal Discharge
On March 23,1995 a truckload of waste contaminated with solvent was discharged to the Warehani, MA POTW.
The discharge resulted in the emission of toxic fumes to the treatment works in sufficient quantity to threaten
worker health and safety. One plant employee suffered upper respiratory problems.
The solvent-laden discharge caused a major disruption at the treatment plant when it contaminated 90,000 gallons
of sewage, killing half of the microorganisms used to treat the raw sewage.
The waste hauler was instructed by his supervisor to discharge the contents of the truck to the treatment works.
When he arrived at die receiving station, he filled out a form on which he made false statements concerning the
truck registration number and the waste source.
Source: Associated Press. February 1997
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POTWs that meet the criteria outlined in 40 CFR 403.S(a)1 are required to develop and
implement an approved pretreatment program. Under 40 CFR 403.5(b)(8), the discharge of
trucked or hauled pollutants is prohibited except at points designated by the POTW. In addition
to designating a discharge point, many POTWs have implemented other controls on the discharge
of hauled waste. These controls include applying limits to non-domestic hauled waste, issuing
permits to waste haulers, implementing tracking systems, sampling loads, and in some cases,
refusing all hauled waste. The control of waste haulers at POTWs with pretreatment programs
can result in the disposal of hauled waste shifting to facilities without pretreatment programs
("non-pretreatment" POTWs) or to places that are not environmentally suitable. Due to their
small capacities and treatment capabilities, these smaller POTWs are more easily disrupted by high
strength loads. Thus, the result of the shift is an increase in negative impacts to the non-
pretreatment POTWS and potentially to receiving water bodies.
Recent studies show an increase of uncontrolled discharges to POTWs without an efficient
program to regulate hauled waste (Thompson and Denow, 1997). Although the vast majority of
waste haulers are reputable business people who provide a valuable service, unscrupulous haulers
may try to dump incompatible wastes on unsuspecting POTWs. Only through efficient controls
can a POTW regulate the volume and makeup of the hauled waste it accepts and protect
treatment plant processes and staff.
1.2 Purpose of Guidance Manual
This guidance manual has been prepared by the U.S. Environmental Protection Agency
(EPA) Office of Wastewater Management to provide guidance on the control of waste hauled to
POTWs. This guidance presents practical information to treatment plant operators and local and
State officials on ways to control the discharge of hauled waste. It is not intended to provide
detailed engineering design information. The specific elements of a waste hauler control program
may vary for each POTW, depending on treatment plant capacity, flows and pollutant loadings,
sensitivity of plant processes, type and amounts of hauled waste accepted, funding, and local
1Any POTW (or combination of POTWs operated by the same authority) with a total design flow greater
than 5 million gallons per day and receiving from industrial users pollutants which pass through or interfere with
the operation of the POTW or are otherwise subject to pretreatment standards.
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issues and requirements. Information provided in this manual should be tailored as necessary for
its applicability to an individual POTW.
1.3 Organization
This guidance manual is organized into chapters corresponding to four basic steps to
control waste hauled to POTWs:
1) Collect information on waste haulers potentially discharging to the treatment plant
2) Characterize the hauled waste received in terms of pollutants and concentrations/
loadings
3) Evaluate potential impacts to the treatment plant
4) Develop, implement, and review and update controls, as necessary.
Steps 1, 2, and 3 are described in Chapter 2 which discusses how to collect waste hauler
information, how to characterize hauled waste, and how to evaluate the potential impact of hauled
waste on the treatment plant. Step 4 is discussed in Chapter 3 which includes information on
ensuring adequate legal authority to implement a control program, designating a discharge site,
applying appropriate discharge standards and restrictions, issuing permits, conducting sampling
and analysis, and implementing a tracking system. Chapter 4 provides case studies from actual
POTW programs.
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2. COLLECTING WASTE HAULER INFORMATION, CHARACTERIZING HAULED
WASTE, AND EVALUATING POTENTIAL IMPACTS TO TREATMENT PLANTS
This section discusses Steps 1, 2, and 3 for controlling hauled wastes; i.e., how to collect
waste hauler information, how to characterize hauled waste, and how to evaluate the potential
impact of the hauled waste on the treatment plant.
2.1 Collect Waste Hauler Information
The first step in implementing a hauled waste control program is to identify waste haulers
that may discharge to the POTW. This can be done by conducting a waste hauler survey. The
information gathered will be the basis for characterizing hauled wastes, evaluating the potential
impacts on treatment plant processes, and determining appropriate controls.
2.1.1 Identify Waste Haulers Potentially Discharging to the POTW
The National Pretreatment Regulations [40 CFR 403.5(b)(8)] state that the discharge of
hauled waste is prohibited except at points designated by the POTW. POTW staff can provide
information to and receive information from the majority of waste haulers at this designated
discharge site. However, all haulers may not be aware of or comply with this discharge site
requirement. Therefore, to help identify all potential waste haulers operating in the area
(including those in neighboring jurisdictions) and to identify their mailing addresses, POTW staff
should consult the following sources that might list waste hauler businesses:
• Business license records
• Chamber of Commerce rosters
• Local telephone directories
• Internet searches
• City and State industrial directories
State/County Health Departments.
In addition, POTW staff can obtain the names and addresses of haulers from the following
sources:
• Businesses identified as having grease traps, sand traps, etc.
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• State lists of hazardous waste generators and treatment, storage, and disposal facilities
(TSDFs).
2.1.2 Require Waste Haulers to Submit Information
An efficient method of gathering information is to require each owner/manager of a waste
hauler business to complete a questionnaire or permit application form, (see Appendix D for an
example application form). POTWs accepting hauled wastes may have obtained basic information
(e.g., name of business, type of waste, and volume) from the truck drivers delivering the waste.
However, the truck driver may not know all of the information requested on the questionnaire or
application form and may not be the appropriate person to sign the form. An authorized
representative of the company (e.g., decision-level manager or owner) who would know about or
be able to refer you to customer records should complete and sign the questionnaire or application
form.
A letter should accompany the questionnaire or application form stating the purpose of the
form and the deadline for its completion. To boost the response rate, a self-addressed, stamped
envelope can be included. Additional information on the waste hauler program and the names,
addresses, and phone numbers of appropriate POTW staff could also be included with the
questionnaire or application form.
Information Required From All Waste Haulers
Information that POTWs should have on record for all haulers prior to granting approval
to discharge includes:
Name of business
Name of owner
Address and phone number
Type(s) of waste hauled
Estimated number and volume of loads discharged per week for each waste type
List of non-domestic customers
Number and capacity of vehicles
Hours of operation
Names of other POTWs where hauled waste is discharged
Where other wastes are disposed (other than those listed above).
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Information Required for Each Generator of Non-Domestic Waste
If the hauler serves non-domestic customers (e.g., commercial businesses or industry),
more detailed information should be requested. Information for each waste generator should
generally include the following:
• Name, address, and phone number of the waste generator
• Name of business owner
• Any analytical/physical data collected by the generator or hauler
• Description of waste including waste type, the process generating the waste, frequency
and volume of hauled waste shipments, indication of whether the waste is subject to
federal categorical pretreatment standards, indication of whether the waste is
hazardous as defined in 40 CFR Part 261, and the reason for the waste being hauled to
the treatment plant.
Table 2.1 contains an example waste profile form to collect information from non-
domestic waste generators.
2.1.3 Maintain Data and Information
POTWs should establish a system for maintaining waste hauler information including
haulers and their wastes approved for discharge, receipts of hauled waste loads, sampling results
of hauled waste loads, and other relevant information. Maintaining such information will allow
the POTW to track the types and amounts of hauled waste received and may assist in identifying
the source of a waste load that caused problems. Data and information can be maintained in hard-
copy form, electronically, or both.
2.2 Characterize Hauled Waste
_, ,, . iU ^ , ... ,, should assess to properly characterize the
Before assessing the acceptability or ...
hauled waste:
hauled wastes, the treatment plant operator must
> What is the source?
have information on the waste characteristics;
• r- ,, ., ,, , , , ,• >• What is the general type of waste?
specifically the pollutant concentrations. & JF
Information on the source of the waste and the
There are 3 questions that the operator
>• What are the pollutant concentrations?
general type of waste can provide clues as to
possible pollutants and potential problems. Figure 2.1 provides an overview of the waste
characterization process.
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Wliat is the source, (i.e., residential, commercial business, industry)? If industrial waste,
what type of industry and what specific process created the wastes? If the information is
available, Material Safety Data Sheets (MSD) for specific chemicals and results of any Toxicity
Characteristics Leaching Procedures (TCLP) performed on sludges should be provided as
attachments to the Waste Profile Form (Figure 2.1).
What is the general type of waste, [i.e., domestic waste or non-domestic (non-hazardous
commercial or industrial waste, chemical toilet waste, groundwater remediation site waste, landfill
leachate, or hazardous waste)]? General characteristics of these various types of wastes are
discussed in the following sections.
What are the pollutant concentrations of Biochemical Oxygen Demand (BOD), Total
Suspended Solids (TSS), metals, toxic organics, flammable or explosive compounds? What are
the percent solids and pH?
2.2.1 Domestic Waste
The majority of waste hauled to POTWs is domestic septage, defined as the liquid or solid
material removed from a septic tank, cesspool, holding tank, or a similar system that receives only
domestic waste (household, non-commercial, non-industrial sewage). Compared to sewage
entering a POTW through a sewerage system, domestic septage is often partially digested and has
higher concentrations of solids and heavy metals, as shown in Table 2.2. In fact, as can be seen in
Table 2.3, domestic septage is more similar, in terms of pollutant concentrations, to sewage
sludge then it is to domestic wastewater.
2.2.2 Non-Domestic Waste
Non-domestic waste may include portable chemical toilet waste, non-hazardous
commercial or industrial waste, groundwater remediation site waste, landfill leachate, or
hazardous waste. Each of these waste types is described below.
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Table 2.1 Example Waste Profile Form
Generator Information (Correspondence will be sent to "Billing Name" address)
Genera tor Name: Billing Name:
Street: Street:
City: State: ZIP: City: State: ZIP:.
Phone: Fax: Phone: Fax:
Waste Description
Common Name of Waste: _
Process Generating Waste:
Is the process by which this waste is generated subject to Federal Categorical Pretreatment Standards? [ ] YES [ ] NO
If yes, identify' process:
Is the waste a characteristic or listed hazardous waste defined by 40 CFR Part 261? [ ] YES [ ] NO
Frequency of shipment:
Waste is: [ ] Industrial Process Waste [ ] Unused or Off-Spec Product
[ ] Commercial Process Waste [ ] UST or Spill-Related Waste
[ ] Food-Related Waste [ ] Other, please specify
MSB ATTACHED? [ ] YES [ ] NO Comment:
TCLP ATTACHED? [ ] YES [ ] NO Comment:
GENERATOR PROCESS KNOWLEDGE CERTIFICATION ATTACHED? [ ] YES [ ] NO
Physical Data (@70 F):
1) Color: _ 6) Is Waste Pumpable ? [ ] YES [ ] NO
2) Odor: _ 7) Flash Point [ ] <100 F [ ] 100-139 F [ ] 140-200 F [ ] >200 F
3) Number of Layers: _ 8) pLI [ ] <2 [ ] 1.2-7 [ ] 7.1-12.4 [ ] >12.4
4) Total Solids by Volume: _ % 9) Specific Gravity: [ ] <1 [ ] 1-1.5 [ ] >1.5
5) Does waste contain free liquids? [ ] YES [ ] NO If yes _ %
Waste Composition:
% Total 100%
Sample Information
Sample Provided? [ ] YES [ ] NO
If yes, complete the following: Date Collected: Time Collected:
Sampled by: Grab:
Composite: Sampling Location:_
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Concentration in pprn
INORGANIC CHARACTERISTICS
D004
D005
D006
D007
D008
D009
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
ORGANIC CHARACTERISTICS
DO 18 Benzene
DO 19 Carbon Tetrachloride
D021 Chlorobenzene
D022 Chloroform
D023 o-Cresol
D024 m-Cresol
D025 p-Cresol
D026 Cresol
D027 1,4-Dichlorobenzene
D028 1,2-Dichloroethaue
D029 1,1-Dichloroethylene
D030 2,4-Dinitrotolune
DO 10 Selenium
DO 11 Silver
Copper
Zinc
Nickel
D032 Hexachlorobenzene
D033 Hexachlorobutadiene
D034 Hexachloroethane
D035 Methyl Ethyl Ketone
D036 Nitrobenzene
D037 Pentachlorophenol
D038 Pyridine
D039 Tetrachloroethylene
D040 Trichloroethylene
D041 2,4,5-Trichlorophenol
D042 2,4,6-Trichlorophenol
D043 Vinyl Chloride
PESTICIDE/HERBICIDE WARRANTY
I hereby certify the following: The waste identified in Section B of this waste profile form does not contain Endrin,
Methoxychlor, 2,4-D Lindane, Toxaphene, 2,4,5-TP (Silvex), Chlordane. or Heptachlor (and its Epoxide). These
constituents are not used at the location where this waste was generated, nor are they known to be present in the materials of
which the above waste is comprised. Hence, mere is no reason to suspect their presence in the waste. Generator's Initials:
POLYCHLORINATED BIPHENYL (PCB) WARRANTY
I hereby certify the following: The waste identified in Section B of this waste profile form does not contain PCBs at
a concentration of 40 ppm when measured in each container or vessel; that the material is not contaminated with PCBs from
a source containing 50 ppm or greater PCBs; and hereby agree to indemnify and hold harmless from any cost, damages, or
liability resulting from the breach of mis warranty. Generator's Initials:
HAZARDOUS WASTE WARRANTY
I hereby certify the following: The waste identified in Section B of this waste profile form does not contain any
material at a concentration which would render it as hazardous as defined hi 40 CFR 261.3 when measured in each contain
or delivered to and hereby agree to indemnify and hold harmless from any cost, damages, or liability resulting from the
breach of this warranty. Generator's Initials:
FEDERAL CATEGORICAL PRETREATMENT STANDARD WARRANTY
I hereby certify the following: (Please circle and initial) The waste identified in Section B of this waste profile form
is/is not generated from a manufacturing process mat is subject to Federal Categorical Pretreatment standards; and hereby
agree to indemnify and hold harmless from any cost, damages, or liability resulting from the breach of this warranty.
Generator's Initials:
Name (Print).
Signature
Title.
Date
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Table 2.2 Comparison of Selected Pollutant Concentrations in
Domestic Septage and Domestic Wastewater
Pollutant
Iron
Zinc
Manganese
Barium
Copper
Lead
Nickel
Chromium (T)
Cyanide
Arsenic
Silver
Cadmium
Mercury
Domestic Wastewater (mg/1)
Range
0.0002-3.4
0.01-1.28
0.04-0.16
0.04-0.216
O.005-0.61
0.001-2.04
0.001 - 1.6
O.001- 1.2
0.01-0.37
0.0004 - 0.088
0.0007-1.052
0.00076-0.11
O.0001- 0.054
Average
0.989
0.212
0.087
0.115
0.109
0.116
0.047
0.034
0.082
0.007
0.019
0.0008
0.002
Domestic Septage(mg/l)
Range
0.2 - 2,740
<0.00 1-444
0.55 - 17.05
0.002 - 202
.01-260.9
0.025-118
0.01-37
0.01-34
0.001 - 1.53
0-3.45
0.003 - 5
0.005—8.1
0.0001 - 0.742
Average
39.28
9.971
6.088
5.758
4.835
1.21
0.526
0.49
0.469
0.141
0.099
0.097
0.005
Source: Supplemental Manual on The Development and Implementation of Local Discharge Limitations
Under the Pretreatment Program, EPA 1991
Portable/Chemical Toilet Waste
Waste from portable toilets, type III marine sanitation devices, and chemical toilets may be
hauled to the treatment plant for disposal. Hauled waste from chemical toilets may be
incompatible with POTW operations due to antibacterial and disinfecting agents used in the
chemical toilet. Therefore, the POTW should require the hauler to submit information on the
volume and concentrations of bacterial growth inhibitors in the hauled waste and evaluate how
much of this material can be safely handled by the POTW. For example, the Winnipesaukee River
Basin treatment plant requires anyone proposing to discharge portable toilet waste that contains
any chemical first receive approval from the POTW operator to discharge.
Non-Hazardous Commercial/Industrial Waste
Non-hazardous commercial/industrial waste is waste generated by non-domestic sources
that is not regulated as hazardous waste under 40 CFR Part 264. These wastes may include
process wastes, cooling water, boiler blow down, etc.
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Table 2.3 Comparison of Selected Pollutant Concentrations
in Domestic Septage and Sewage Sludge
Parameter
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Nitrogen as N
Phosphorus as P
pH
Grease
BOD
Total Solids
Concentration
Domestic Septage
(mg/kg)
4
->
j
14
140
35
0.15
—
15
2
290
2%
<1%
6-7
6-12%
6,480 mg/1
3.4%
Sewage Sludge
(mg/kg)
10
7
120
740
130
5
4
43
5
1,200
2-7%
1-3%
5-8
5-10%
2,000 mg/1
3-35%
Source: U.S. EPA Domestic Septage Regulatory Guidance, A Guide to the EPA 503 Rule.
September 1993
The National Pretreatment program established categorical pretreatment standards to
regulate the level of pollutants in wastes discharged to POTWs by specific industries. These
standards appear in 40 CFR Chapter I, Subchapter N, Parts 405-471. A summary of industries
regulated by categorical pretreatment standards and descriptions of the regulated processes are
provided in Appendix E. Categorical standards place limitations on the discharge of pollutants
from these industries including toxic pollutants and conventional and non-conventional pollutants.
Further information on categorical standards and their applicability to hauled waste is contained in
Section 3.2.2.2.
Industrial and commercial wastes which are not regulated by a categorical pretreatment
standard may also be incompatible with treatment plant operations. These wastes can include
wastes from the food processing industry, fats, oil and grease of animal or vegetable origin (e.g.,
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from restaurants), petroleum-based oils (e.g., from auto repair shops, car washes), and a variety
of metal and organic bearing wastes from a variety of industrial and commercial sources.
Although not subject to categorical standards, these wastes may be subject to local limits. Section
3.2.2.1 contains more information on the development and application of local limits.
Groundwater Remediation Site Waste
Waste from groundwater remediation sites is frequently hauled to POTWs. Most of these
remediation wastes have been treated and contain only trace amounts of toxics that can be
accepted at a POTW without causing problems. However, some remediation wastes may be
discharged at a rate or pollutant concentration that causes pass through or interference. For
example, groundwater remediation waste associated with fuel contaminated groundwater may
contain benzene, toluene, ethyl benzene, xylene, methyl tert-butyl ether, napthalene, petroleum
oils and grease, and lead. POTW operators should require remediation site operators to provide
information on the volume, pollutants, and pollutant concentrations of the waste they propose to
deliver to the POTW. Remediation wastes may also come from Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) sites - more commonly referred to as
"superfund" sites. For CERCLA guidance, refer to CERCLA Site Discharges to POTWs
Guidance Manual, EPA 1990 (EPA/542/6-90/005). POTWs are not required to accept wastes
from these cleanup operations and may require the same controls (permitting, application of local
limits, monitoring) on these discharges as would be required on any other wastewater discharge
from another source.
Landfill Leachate
Landfill leachate is a liquid which passes through or emerges from solid waste. Pollutant
concentrations in landfill leachate vary widely, as shown in Table 2.4. Factors which can affect
leachate quality include (Henry and Prasad, 1991 and Lu et al, 1985):
• Type and composition of wastes
• Age of wastes
• Climate and moisture composition of wastes
• Waste processing and compaction and other landfill operational aspects
• Temperature, pH, and redox condition in landfill
• Presence of large quantities of municipal sewage sludge or industrial sludge or wastes
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Thickness of refuse layer
Permeability, thickness, compaction, and slope of daily and final cover.
Table 2.4 Example Pollutant Concentrations in Landfill Leachate
Parameter
BOD
COD
TSS
Ammonia Nitrogen
Chloride
Sulphate
Total Iron
Alkalinity (as CaCO3)
Total Phosphorus
pH
Range
mg/I
2,000-30.000
3,000-45.000
200-1,000
10-800
100-3,000
100-1,500
50-600
1,000-10.000
1-70
5.3-8.5 s.u.
Source: Solid Waste Association of North America. Manager of Landfill
Operations Training Course. Course Manual. Publication MSW-D 2360
GMISC 0005. Silver Spring, MD. Revised June 1991.
On February 6, 1998, EPA proposed categorical pretreatment standards for landfills.
However, these pretreatment standards are applicable only for new and existing hazardous waste
landfills regulated under Subtitle C of the Resource Conservation and Recovery Act (RCRA).
Pretreatment standards were not proposed for new or existing non-hazardous waste landfills.
Hazardous Waste
Wastes are regulated as hazardous if they are listed as such in 40 CFR 261.31-33 or if they
exceed certain levels of ignilability, corrosivity, reactivity, or toxicity (as defined in 40 CFR
261.21-24). POTWs that accept hazardous wastes by truck, rail, or dedicated pipe within the
property boundary of the plant are considered to be hazardous waste treatment, storage, and
disposal facilities (TSDFs) and subject to RCRA regulations under 40 CFR Part 264. Refer to the
Guidance Manual/or the Identification of Hazardous Wastes Delivered to Publicly Owned
Treatment Works by Truck, Rail, or Dedicated Pipe, EPA 1987 for more information.
2.3 Evaluate Potential Impacts to Treatment Plant
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Even small volumes of toxic or hazardous waste have the potential to impact the treatment
plant. POTW personnel are responsible for assessing the potential impact of hauled waste based
on the waste's characteristics and the sensitivity of the treatment process. This section provides
information on potential treatment plant impacts and discusses the various determinations needed
to evaluate potential impacts from a specific waste load.
2.3.1 Potential Impacts to Treatment Plants
The discharge prohibitions in 40 CFR 403.5 apply to all discharges including domestic and
non-domestic hauled waste. Hauled waste has the potential to create a number of impacts at a
treatment plant including pass through2 or interference3, sludge contamination, and worker
hazards. Each of these impacts is discussed in greater detail below.
Pass Through and Interference
Hauled waste can cause slug loadings to POTWs. A slug loading can be attributed to
many different pollutants including BOD, ammonia, phosphorus, metals, and organics. These
loadings may cause interference (i.e., process upset) or pass through. The toxic effects of metals
and toxic organics contained in non-domestic waste hauled to POTWs can interfere with
secondary wastewater treatment processes and sludge treatment processes. In primary
wastewater treatment, solids are removed by sedimentation. These solids are referred to as
primary sludge. Primary sludge is often treated in digesters that utilize bacteria under anaerobic
conditions to render the sludge acceptable for disposal. Toxic metal compounds, particularly
those containing chromium, can destroy these bacteria or inhibit their reproduction, thereby
disrupting the sludge treatment process and producing sludge that cannot be disposed without
additional treatment.
"Pass through is defined as 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 an}' requirement of the POTWs NPDES permit (including an increase in the magnitude or duration of
a violation).
Interference is defined as a discharge which alone, or in conjunction with 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 NPDES permit requirement (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 statutes, regulations, or permits.
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Bacteria also are used in secondary treatment of wastewater to remove non-toxic organic
wastes. If toxic pollutants affect the bacteria at this stage, the secondary treatment system will
not remove as much of the pathogenic organisms or organic material. Failure of the secondary
treatment system can result in the discharge of incompletely treated wastewater into surface
waters. POTWs are held accountable for National Pollutant Discharge Elimination System
(NPDES) permit violations resulting from pass through and interference, even if the violation was
caused by a waste hauler. If adequate legal authority is available, POTWs should establish
regulations that allow them to enforce against waste haulers and the waste generators in cases
where hauled waste discharges cause pass through or interference.
Fats, oil, and grease of animal or vegetable origin collected from grease traps and
petroleum-based oils collected from commercial or industrial sources (e.g., from oil/water
separators) are sometimes hauled to POTWs. Fats, oil, and grease of animal or vegetable origin
can be solid or viscous at ambient temperatures and can cause blockages in pipes, clogging of
pumps, and coating and clogging of monitoring probes. In addition, oil and grease from grease
traps may have a pH less than 5. Unlike animal and vegetable oils that can, in a dispersed state,
be treated in aerobic and anaerobic biological systems, petroleum-based oils are degraded slowly
by microorganisms and can reduce treatment efficiency. Accumulation of oil and grease in
anaerobic digesters can reduce the effective capacity of the digesters. If contents are not kept
well mixed and heated, solid scum layers can form and cause blockage in pipes. Because of the
potential problems caused by the discharge of grease trap waste, some POTWs prohibit or place
restrictions on its discharge, both through the collection system and as hauled waste. Other
POTWs have the ability to remove oil and grease (e.g., through discharge to sludge drying beds
or sludge digestion processes) and therefore establish procedures for accepting grease trap waste.
When determining whether to accept grease trap waste, POTWs should consider the potential for
the waste to cause pass through and interference. At a minimum, POTWs must prohibit the
discharge of oil and grease in amounts that would cause pass through or interference.
Sludge Contamination
Domestic and non-domestic hauled waste can increase the sludge volume generated and
impair sludge settling and dewatering processes. Additionally, toxic metals or organics contained
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in non-domestic waste may settle out with the sludge. This contamination of sludge by toxic
metals or organic compounds may preclude some sludge use or disposal methods (e.g., land
application). If the sludge is disposed in a landfill, these pollutants may leach out and contaminate
adjacent surface and groundwaters. When incineration is used, toxic pollutants may be released
to the atmosphere.
Worker Hazards
Exposure to toxic or hazardous substances in hauled waste can pose dangers to the safety
and health of POTW employees that are in contact with the wastewater. Fires, explosions,
asphyxiation, and poisoning are the lethal effects of certain substances such as solvents, fuels,
strong acids, strong bases, heavy metal chloride and sulfate salts, sodium, calcium, and potassium
salts of strong bases, oxidizing agents, and reducing agents. Other health effects may include:
burns, nausea, vomiting, headaches, fatigue, dizziness, eye, throat, nose, lung, and skin irritations,
respiratory distress including shortness of breath and difficulty breathing, sore throat, and
coughing.
2.3.2 Determine Potential Impacts From Specific Waste Sources/Types
There are several factors to consider when determining whether a specific type of waste or
waste from a particular source has the potential to cause treatment plant impacts. These
determinations include whether the waste meets all applicable standards, whether the waste has
the potential to cause pass through or interference, and whether the waste has other problem
characteristics. Some wastes, such as domestic septage, exhibit relatively consistent properties
and fairly quick determinations can be made as to the likelihood of disruption based on volume
being received and potential concentration of pollutants. However, new or different waste loads
(particularly from non-domestic sources) may also arrive at a facility, and the task of determining
compatibility can be difficult. The flow chart provided in Figure 2.2 provides a representation of
the decision-making process involved in such a situation.
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FIGURE 2.2 NEW/DIFFERENT LOAD DECISION FLOW CHART
Permitted waste hauler requests
approval to discharge new or different
type of waste.
Do you have enough
information to determine
potential plant impacts?
POTW reviews manifest and any other
available information to characterize
waste. POTW samples and performs a
quick analysis if necessary.
Refuse to allow
waste to be
discharged
Determine where in system to
discharge waste and rate of discharge
Discharge waste
Monitor plant performance during
treatment, including sludge. Examine
plant for inhibitions, bad odors.
Document finding for next load of
similar contents.
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2.3.2.1 Determine Whether Waste Meets All Applicable Standards
Does the waste meet applicable numerical standards?
If the waste is subject to categorical
,.,.11,1 ... ... 4. Determine Whether Waste Meets
pretreatment standards, the waste must meet 4 „ . ,. ,, _
All Applicable Standards
the standards prior to discharge to the POTW.
Does the non-domestic waste meet
Further information on the application of
categorical standards to hauled waste is
contained in Section 3.2.2.2.
If the POTW applies local limits to non-
domestic hauled waste, then the waste must
applicable standards (local limits,
categorical pretreatment standards)?
Will the waste cause toxic fumes/gases,
explosive condition, flammable
condition, corrosive condition, other
hazard to health and safety of POTW
employees?
meet all applicable limits. If a non-
domestic waste load exceeds local limits, it should be rejected. More information on the
development and application of local limits is contained in Section 3.2.2.1.
Non-domestic hauled waste may contain pollutants for which there are no numerical local
limits developed. In such a situation, an evaluation of the potential to cause pass through or
interference should be conducted. A discussion of this evaluation is provided below.
Furthermore, hauled wastes can cause shocks to the treatment system, much like the effects of an
accidental spill or a slug load from the non-domestic users connected to the collection system.
Therefore, hauled wastes, particularly any new type of hauled waste, should undergo the
evaluation of the potential to cause pass through or interference.
Does the waste meet narrative prohibitions against discharges that cause toxic fumes/gases,
explosive condition, flammable condition, corrosive condition, other hazard to health and
safety of PO TW employees ?
All non-domestic waste loads should be subject to a visual observation that evaluates the
viscosity, odor, and color. Any unusual characteristics can be noted and further tests conducted if
necessary. The decision for further tests, however, should not be based on the visual observation
alone. The presence of some gases and volatile organics can be detected by smell, but others are
odorless. Some quick and simple monitoring devices that can provide an indication of corrosivity
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and explosivity are a pH meter and an explosivity meter. A pH test should be conducted on all
waste loads from non-domestic sources. An explosivity meter can also be used routinely on all
non-domestic loads, but should always be used on loads suspected of containing chemicals that
can create explosive gases. Both pH and explosivity monitoring devices can be installed at waste
load discharge locations. These devices as well as other field monitoring and laboratory
instruments available are listed in Table 2.5.
Table 2.5 Field Monitoring and Laboratory Instruments
INSTRUMENT
MEASURES
WASTEWATER
pH meter
Oxidation-reduction (redox) meter
Flashpoint (closed-cup) tester
Acidity/alkalinity
Oxidation-reduction potential (ORP), measured in
millivolts, is the electrical potential required to
transfer electrons from one compound or element to
another. Negative values indicate a tendency to
reduce compounds or elements and positive values
indicate a tendency to oxidize compounds or elements.
Determines the minimum ambient temperature at
which a substance gives off sufficient vapor to create
an ignitable mixture
AIR
Combustible Gas Detector and Oxygen meter
(CGD/Oxygen explosimeter)
Photoionization detector (PID)
Organic Vapor Analyzer (OVA)
Colorimetric tubes
Percentage of oxygen present and the concentration of
combustible gases/vapors present expressed as a
percentage of the lower explosive limit (LEL)
Measures the concentration of a variety of organic and
inorganic gases/vapors
Can monitor continuously for all detectable organic
vapors or can determine the identity and concentration
of specific organic vapors/gases
Measures concentration of specific gases
Source: Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors, EPA 812-B-92-001, June 1992.
The POTW should compile a list of flammable, explosive, corrosive, and toxic chemicals
and compare the chemical analysis of non-domestic waste against the list. If any of the pollutants
in the load are on the list, further tests/analyses could be conducted to determine if the pollutants
are present in concentrations that would pose a threat to the treatment plant processes or
workers. Various reference documents that can provide information on the flammability,
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explosivity, and health hazards of chemicals can be found in Appendix F. The National Fire
Protection Association, Inc. (NFPA) is a good source for the most current information on
flammable and combustible substances. The American Conference of Governmental and
Industrial Hygienists (ACGIH), the Occupational Health and Safety Administration (OSHA), and
the National Institute for Occupational Safety and Health (NIOSH) all publish information on
hazardous and toxic substances in the work environment. The ACGIH develops occupational
guidelines used by OSHA and NIOSH; these guidelines establish air contaminant exposure limits
known as Threshold Limit Values (TLVs) above which workers should not be exposed.
Exposure limits have been developed for approximately 650 toxic substances.
2.3.2.2 Determine Whether Waste Has the Potential to Cause Pass Through or
Interference
New sources of non-domestic hauled
waste or non-domestic waste containing pollutants
for which there are no local limits should not be
accepted until the following have been interference?
determined:
Determine Whether Wastes Has Potential
to Cause Interference/Pass-Through
> Will the waste cause a slug load or other
Will the waste cause the POTW to
violate any NPDES requirements?
9
Will the waste cause a slug load or other
interference?
Will the waste cause the POTW to violate any NPDES permit requirement (particularly
NPDES effluent limits) ?
Answers to these questions are often not easy to determine. Assessing a treatment plant's
ability to treat a particular waste or determining the actual impacts on the plant is often impossible
due to lack of readily available information. POTW personnel often adopt one of the following
two approaches:
Refuse - Refuse the waste if it contains pollutants not on an "accepted list" or wastes
that are outside specified boundaries (e.g., pH, specific pollutant concentrations).
Accept and Watch - Accept the waste and monitor and record any observable impacts.
If there are no adverse impacts, the POTW continues to accept the wastes. If there
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are any adverse impacts, the POTW rejects any further waste of that nature or
determines what actions may reduce or eliminate the impacts.
Many POTWs believe that the "refuse" approach is the safest way to ensure proper
operation of the treatment plant. If this approach is taken, the POTW should have some
suggested alternatives for the hauler to encourage proper disposal. The "accept and watch"
approach places the POTW in a vulnerable position should the waste cause interference or pass-
through (resulting in NPDES permit violations, damage to the treatment plant or receiving water,
or worker health and safety hazards). One way to minimize the risk in accepting non-domestic
waste is to require industry, prior to allowing the discharge, to perform a treatability study.
POTWs accepting non-domestic hauled waste should conduct a technical feasibility
analysis. This analysis is similar to and uses information from the local limits development
process. This analysis should determine whether:
• The POTW has the hydraulic and organic capacity to handle the additional hauled
waste. Determine the unused treatment plant capacity available to handle and treat
hauled waste loadings [the difference between the design or actual capacity (organic
and hydraulic) of the treatment plant and the current and projected sewer collection
system loadings]. Conduct this analysis on each individual unit process (including the
sludge handling and treatment unit processes). Determine the pollutant loading
increases to the effluent, sludge, and air. Compare these increased loadings/
concentrations to any environmental standards (NPDES permit limits, water quality
standards, sludge standards) to determine whether any standards will be exceeded.
This process is normally performed as part of local limits development. POTWs that
have not developed local limits should contact their Approval Authority (see Appendix
C for a list of contacts).
• The unit operations are suitable for treatment of the pollutants in the hauled waste.
Determine the pollutant concentrations and loadings that the unit operations can
receive without exhibiting interference. For example, at what loading of TSS, BOD,
or other pollutant does impairment of sludge settling or dewatering occur.
• The POTW has the ability to control feed rates of hauled waste to the treatment plant.
Determine the sensitivity of treatment plant processes to daily fluctuations in hauled
waste loadings. Systems acclimated to a specific type of waste (pollutants,
concentrations, loadings) can be shocked if waste with different characteristics is
introduced suddenly. Shocks can be prevented if the POTW has the ability to
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gradually mix this waste with its other incoming wastewater to minimize or eliminate
the fluctuations caused by this waste. The POTW needs to determine when and at
what rate the hauled waste can be discharged to the treatment system. Some POTWs
store the hauled waste and then discharge it during off peak loading times while other
POTWs discharge hauled waste during times of high hydraulic but low organic
loading.
2.3.2.3 Determine Whether Waste Has Other Problem Characteristics
Hauled waste may constitute a small
percentage of the volume and pollutant loadings
of a POTW and when the discharge feed rate is
carefully controlled, interference and pass
through may never occur. However, the hauled
waste may create operation and maintenance w ~ , ... , •
w Does the waste contain bioaccumulative
problems that result in increased treatment costs
Determine Whether Waste Has
Other Problem Characteristics
Will the waste cause other nuisances
such as objectionable odors, pump or
line clogging, or additional cleaning or
maintenance?
and persistent substances?
and greater deterioration of equipment and
facilities. A POTW should determine whether it is providing an environmentally sound treatment
service or whether it is acting as an agent that dilutes and transfers the pollutants to other media
such as the receiving stream, air, or sludge.
Will the waste cause other nuisances such as objectionable odors, pump or line cloggings,
foaming aeration tank/aerated digester, or additional cleaning/maintenance requirements?
A variety of problems have been associated with domestic and non-domestic hauled
wastes:
• Increased volume of grit, scum, and screenings
• Increased volume of primary and secondary sludge
• Increased phosphorus load
• Bulking of activated sludge
• Difficulty in sludge thickening and dewatering
• Excessive foaming.
Does the waste contain bioaccumulative and persistent substances that are not amenable to
treatment?
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If the waste contains bioaccumulative and persistent substances (e.g., mercury, PCBs), the
POTW may want to handle these wastes in a fundamentally different manner because even very
small amounts could cause a violation of a water quality standard, and these persistent substances
could accumulate in downstream sediments, flora, and fauna that may require future remediation.
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3. DEVELOPING AND IMPLEMENTING CONTROLS
To avoid complications caused by discharges of waste hauled to a POTW, all POTWs that
receive hauled wastes should implement a program to control hauled waste. Prior to
implementing a control program, POTWs should first review and revise their legal authorities, as
necessary, to ensure that adequate legal authority is available for all proposed controls. Legal
authority is discussed in greater detail in Section 3.1 Waste hauler control programs could
include active control mechanisms and communication. Active controls include designating
disposal sites, conducting monitoring, applying appropriate discharge limits, issuing permits,
implementing a tracking system, and identifying illegal discharges. Communication includes
communicating with waste haulers and with other POTWs. Active controls and communication
are discussed in more detail in Sections 3.2 and 3.3. Controls implemented by a POTW should be
tailored for the treatment works' specific operating conditions and needs and should be reviewed
and updated, as necessary.
3.1 Legal Authority
3.1.1 General Authority to Impose Controls
Legal authority needed to control the discharge of hauled waste includes the general
authority to impose controls (i.e., state law and local ordinances) and specific ordinance
provisions applicable to hauled waste.
The legal authority of a POTW or other local authority to administer controls on hauled
waste or to implement a hauled waste permit program is derived from State law and local
ordinances. If adequate legal authority to control hauled waste is not present, local ordinances
should be modified. State law determines what authorities a POTW may possess; thus, the
POTW must be aware of these laws when developing or seeking modifications to its local
ordinance. The local ordinance must describe all of the controls in sufficient detail so that waste
haulers and POTW personnel will understand the procedures, expectations, and liabilities
associated with the program. The POTW should request its attorney to assist in reviewing the
ordinance to ensure that it provides adequate authority and that the ordinance does not create any
unnecessary procedural or institutional obstacles which might hinder the discharge control
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programs. Depending on their legal authority, POTWs can regulate the waste generator, the
waste hauler, or both. If a POTW accepts non-domestic hauled waste from outside its
jurisdiction, it should ensure that it has the legal authority to regulate those waste generators
located outside its jurisdiction.
3.1.2 Provisions Necessary for Controlling Waste Haulers
The legal authorities required for an effective waste hauler control program are similar to
those for regulating sources connected to the POTW; however, there are certain additional
provisions which should be included in the POTW's sewer use ordinance. In particular, the
ordinance should contain the following provisions:
• Prohibition on the discharge of hauled waste, except at points designated by the
POTW.
• The hauled waste must meet all applicable federal, State, and local pretreatment
standards and requirements including categorical standards developed for the waste
generator's industrial category. If the POTW's legal authority allows it to do so, the
ordinance should also be expanded to allow the POTW to permit and regulate the
generator of non-domestic hauled wastes.
• The POTW may require commercial, industrial, and/or residential waste haulers to
obtain a permit.
The POTW may collect samples of each hauled load to ensure compliance with
applicable pretreatment standards.
• No load may be discharged without prior consent of the POTW.
• The POTW may require the hauler to provide a waste analysis of any load prior to
discharge.
• Requirement that waste haulers must use a manifest system.
• Penalties for violating the ordinance or permit.
Table 3.1 provides an example table of contents for a waste hauler ordinance. Examples
of waste hauler provisions are provided in Appendix G.
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Table 3.1 Example Table of Contents for Waste Hauler Ordinance
SECTION 1 - GENERAL PROVISIONS
1.1 Purpose and Policy
1.2 Administration
1.3 Definitions
SECTION 2 - HAULED WASTE PERMIT APPLICATION
2.1 Application Required
2.2 Re-Application Required
2.3 Application Signatories and Certification
SECTION 3 - HAULED WASTE PERMITS
3.1 Permit Required
3.2 Permit Contents
3.3 Permit Decisions
3.4 Permit Transfer
3.5 Permit Modifications
3.6 Permit Revocation
SECTION 4 - GENERAL HAULED WASTE/TRANSPORTER REQUIREMENTS
4.1 Prohibited Discharge Standards
4.2 Limitations for Authorized Disposal of Specific Wastes
4.3 POT W Hours of Operation/Contact Information
4.4 Liquid Waste Vehicles Maintenance/Operations
SECTION 5 - REPORTING REQUIREMENTS
5.1 Manifests Required
5.2 Self-Monitoring Reports
5.3 Reports of Changed Conditions
5.4 Reports o f Potentia 1 Problems
5.5 Notice of Violation/Repeat Sampling and Reporting
5.6 Analytical Requirements
5.7 Sample Collection
5.8 Timing
5.9 Record Keeping
SECTION 6 - COMPLIANCE MONITORING
6.1 Right of Entry: Inspection and Sampling
6.2 Search Warrants
SECTION 7 - CONFIDENTIAL INFORMATION
SECTION 8 - SUPPLEMENTAL REQUIREMENTS
8.1 Performance Bonds
8.2 Liability Insurance
8.3 Surety Bonds
8.4 Public Nuisances
8.5 Informant Rewards
SECTION 9 - MISCELLANEOUS PROVISIONS
9.1 Pretreatment Charges and Fees
SECTION 10 - EFFECTIVE DATE
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3.2 Active Controls
Active controls for hauled waste programs include designating and controlling access to
disposal site, applying limits and standards, issuing permits, monitoring, manifesting/tracking
waste, and identifying illegal discharges. Each of these is activities is discussed below.
3.2.1 Controlled Designated Disposal Site
Choosing a Site
Under Federal Regulations [40 CFR Part 403.5(b)(8)], POTWs must prohibit the
discharge of any trucked or hauled pollutants except at discharge sites designated by the POTW.
Therefore, POTWs accepting hauled waste must designate a specific discharge point. Some
POTWs specify discharge sites that are located at the treatment plant while others allow hauled
wastes to be discharged at remote sites within the collection system (e.g., manholes or pump
stations). POTW operators may have to make a difficult decision concerning discharge site
location. Factors to consider when designating the location of a discharge site include sensitivity
of the treatment plant to pollutant loadings from hauled waste discharged directly to the
headworks of the treatment plant, accessibility to the discharge site, and visibility of the site to
POTW personnel (i.e., the ease of surveillance). Generally, the further "upstream" a discharge
site is from the headworks of a facility, the longer the waste has to mix with other wastewater that
may equalize and dilute it, creating less chance for plant disruption. However, some treatment
plants have holding facilities that allow hauled waste to be collected and stored for discharge to
the plant when influent plant loadings are lowest. Other treatment plants provide equalization
basins that allow hauled waste to be mixed and equalized with influent wastewater, thus allowing
the operator to better control flow and loadings to the headworks. In addition to equalization,
remote sites may allow waste haulers easier access and may reduce the traffic flow within the
treatment plant. However, control over a remote site is more difficult and possibly more costly if
personnel need to be stationed at the site, or if the installation of gates or surveillance devices
(such as cameras) becomes necessary.
If hauled waste is discharged at the treatment plant, discharge to the headworks is
generally preferred. This allows for screening and grit and grease removal. Hauled waste
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receiving stations located at the treatment plant may include an unloading area, a receiving/
storage tank, and transfer pumps.
The following factors should be considered in designing the receiving station:
Speed Limits on POTWRoads—Speeds should be posted clearly to ensure the safety
of the haulers and POTW personnel.
Sight Lines—Blind curves and corners should be avoided. Particularly dangerous
areas should be clearly indicated with appropriate signs.
Wear on Roads—The constant wear from trucks may increase maintenance costs if
access roads are not properly designed.
Vehicle Access—Adequate space should be allowed for vehicles to back-up if a pull-
through station is not used. Providing access and explicit instructions for recreational
vehicles should also be considered, if these types of vehicles are expected to use the
station.
Security and Visibility—The receiving station should have limited access (e.g., have
locked gates and access cards). The receiving station should also be clearly visible to
POTW personnel or monitored through cameras to ensure that the POTW is aware
when a truck is entering to dump.
Surface and Slope of Discharge Area—The discharge area should be constructed of
a hard surface material and the discharge location should be graded so that it slopes
toward the catchment. This will help empty the entire truck as well as keeping the site
clean and dry, and will allow storm water coming into contact with the pavement
around the discharge location to be directed towards the catchment.
Receiving Tank—The receiving tank should have a sloped bottom equipped with a
drain sump to provide for complete draining and cleaning.
Pumps—The type of pump required may vary depending on the types of hauled waste
accepted. In general, pumps used to handle hauled waste handling should be non-
clogging and capable of passing 3-inch diameter solids.
Number of Catchments—Offering more than one catchment can help in reducing the
number of trucks waiting to discharge.
Odor—Due to the odorous nature of many hauled wastes, the discharge location
should be sited so as not to be problematic for plant personnel or nearby residents and
businesses.
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• Clean-Up—A water hose should be provided for clean-up of the unloading station, as
well as to wash off the truck. Chlorinated treatment plant effluent may be considered
for this use. Wash waters should be directed toward the catchment.
3.2.1.1 Access, Hours of Operation
Controlling access to a discharge site can greatly reduce the possibility of facility
disruption by illegal or incompatible discharges. Manual locking gates can be installed at the site
entrance. Several facilities are now equipped with an electronic card access system. Permitted
haulers are given an electronic "credit" card which serves as a key to the facility, and which may
also be used for waste hauler tracking and billing. One potential drawback to such a system is
that cards may be "lent" to unpermitted haulers.
When determining hours of operation and discharge time limitations, POTWs should
consider the times when POTW personnel are available and the times during the day that peak and
low flows occur within the collection system and within the treatment plant. This is especially
true for smaller POTWs where peak and low flows may be of particular concern. Twenty-four-
hour access is an option which may be appropriate for some facilities (e.g., facilities that are
staffed at all times). Twenty four hour access may increase the period of time between discharges
and increase flexibility for septage haulers.
3.2.2 Application of Standards and Limits
As discussed in Section 2.3.2, non-domestic hauled waste may be subject to local limits
and/or categorical pretreatment standards. The applicability of local limits and categorical
pretreatment standards to non-domestic hauled waste is discussed below.
3.2.2.1 Local Limits
POTWs with approved pretreatment programs are required to develop and enforce local
limits for pollutants of concern. Many non-pretreatment POTWs also developed local limits
independently or may have been required to develop local limits if pass through or interference
has occurred or is likely to occur. Local limits are intended to prevent interference, pass through,
sludge contamination, and worker health and safety problems. The process of local limits
development generally includes collecting monitoring data (e.g., influent, process effluent,
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effluent, sludge, domestic, hauled waste, and industrial user) to characterize existing pollutant
loadings, determining applicable environmental criteria, identifying pollutants of concern, and
determining the Maximum Allowable Headworks Loading (MAHL) for each identified pollutant
of concern. Maximum Allowable Industrial Loadings (MATLs) are then determined from the
MAHLs by allowing for a safety factor and subtracting loadings from uncontrolled discharges
(e.g., domestic and commercial loadings). Finally, the MAJLs are allocated to industrial users as
local limits.
Local limits do not apply to hauled domestic waste. However, pollutant loadings from
hauled domestic waste should be accounted for in local limits development. Pollutant loadings
from hauled waste should be determined and these loadings should be subtracted from the MAHL
(along with domestic wastewater and other uncontrolled loadings) when determining MAILs.
Alternatively, POTWs could allocate a portion of each MAIL to waste haulers and thus develop
limits applicable to hauled waste.
For more information on the development of local limits, in general, refer to the Guidance
Manual on the Development and Implementation of Local Discharge Limitations LJnder the
Pretreatment Program, EPA 1987 (833-B-87-202-1). For specific policies and procedures on
local limits development, POTWs should contact the Approval Authority in their State or EPA
Region. A list of contacts is contained in Appendix C.
3.2.2.2 Categorical Standards
Categorical pretreatment standards are contained in 40 CFR Parts 405-471. Categorical
Pretreatment Standards are standards published by the EPA for the different categories of
industrial users. These standards are published in accordance with Section 307(b) and (c) of the
Clean Water Act (CWA). EPA has issued categorical pretreatment standards that are: (1)
concentration - based, (2) production-based, or (3) both. A summary of industries regulated by
categorical pretreatment standards and descriptions of the processes performed by these industries
are provided in Appendix E.
-------
To determine if wastes collected by haulers are regulated by National categorical
pretreatment standards, the POTW should obtain information from both the waste hauler and the
waste generator. Questions that might be asked by the POTW to determine applicability of any
National categorical pretreatment standard might include the following:
• Why does the generator want to haul the wastewater to the POTW (e.g., a generator
located on a septic system)?
• Were the wastes generated from regulated processes subject to categorical
pretreatment standards? If so, what are the volumes of each process wastestream
making up the total hauled load? If a POTW is uncertain about the applicability of
categorical standards, it should request a description of activities conducted and
wastewater generated at the facility in question.
• What types of pollutants are known or suspected to be present in the hauled wastes?
At what estimated or known levels?
• If the hauled waste is subject to categorical pretreatment standards, is it in compliance
with the standards? Monitoring records should be obtained to verify compliance. If
the waste is subject to production-based standards, production data should also be
obtained.
• Did the waste hauler collect wastes from more than one location or source such that
domestic and industrial or different types of industrial wastes have been mixed within
the load? To allow the POTW to determine compliance with categorical pretreatment
standards, hauled waste loads subject to categorical standards should not be mixed
with other wastes prior to discharge.
• Is the waste hazardous under the RCRA? If so, is it a listed or a characteristic waste?
More information on accepting hauled hazardous waste is provided in EPA's
Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly
Owned Treatment Works by Truck, Rail, or Dedicated Pipe (June 1987).
Categorical pretreatment standards apply to waste generated by categorically regulated
processes, whether the waste is discharged through the sewer system or hauled to the POTW.
The generator of categorical waste is responsible for complying with all associated monitoring
and reporting requirements. POTWs with approved pretreatment programs and adequate legal
authority can act as the Control Authority and regulate the generators of categorical waste that is
hauled to the POTW. These POTWs should ensure that adequate legal authority is available to
regulate all categorical hauled waste generators discharging to the POTW, including those located
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outside the POTW's jurisdiction. POTWs that do not have an approved pretreatment program or
that do not have adequate legal authority to regulate hauled waste generators directly, should
notify the generators that monitoring reports must be submitted to the Control Authority (the
State or EPA in states without delegated pretreatment programs). In this case, the POTW should
obtain copies of all reports submitted to the Control Authority.
3.2.3 Permits
A permit system is the most direct and efficient method of regulating waste haulers that
discharge to a POTW. Implementing a permit system provides the opportunity to monitor and
regulate haulers based on the treatment works' operating conditions. Figure 3.1 presents an
overview of procedures involved in implementing a waste hauler permit system. If a POTW
accepts hauled industrial waste (including wastes regulated by categorical pretreatment
standards), it should also consider permitting the waste generator as well as the waste hauler.
All waste haulers within the immediate and surrounding service area should be considered
potential dischargers to the POTW system and should be notified of the permit system
requirements, including the prohibition against discharge of hauled waste except at designated
areas. Notification could be provided individually to each waste hauler that potentially could
discharge to the POTW, or notification could be accomplished through general procedures such
as publishing notices in newspapers or trade papers. However, if a POTW's local sewer use
ordinance prohibits the discharge of hauled waste without a permit, any hauler that discharges
without a permit is in violation and subject to all liability whether or not they received notification
of permit requirements.
As discussed in Section 2.1, each waste hauler should be required to complete a
questionnaire or permit application. The permit application form should be designed to provide
the POTW with all information necessary to identify, track, communicate with, and control waste
haulers. A sample waste hauler's permit application is presented in Appendix D.
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FIGURE 3.1 PROCEDURES OF A WASTE HAULER PERMIT PROGRAM
POTW notifies waste hauler of
permit system requirements
Waste hauler applies for a
discharge permit.
POTW approves permit application
and issues a discharge permit with
applicable limits and conditions.
Waste hauler collects
customer waste.
Waste hauler records entry
on manifest form
Waste hauler provides copy of manifest
and any sampling results collected by the
waste generator or hauler to POTW at
time of discharge
Waste hauler discharges to POTW
Yes
Waste hauler
does not apply
for permit
POTW prohibits
the discharge of
hauled waste
from the hauler
POTW samples
and inspects
waste hauler
loads
Load complies
with applicable
limits
No
POTW rejects
hauled waste
load
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3.2.3.1 Permit Conditions
The following is a list of conditions that a POTW should consider including in discharge
permits issued to waste haulers:
Right of Refusal to Accept Waste—The POTW should maintain the right to refuse
any hauled waste load.
Non-Domestic Loads—The waste hauler should be limited to discharging only
domestic waste if the POTW is not capable of treating hauled nondomestic wastes.
However, if a POTW can treat nondomestic wastes in general, or only certain
nondomestic wastes, then provisions for these discharges should be established. To
account for the nondomestic wastes it receives from waste haulers, the POTW should
require a list of customers from each hauler and the type(s) of waste(s) hauled from
each customer.
Prohibited Discharges—Waste haulers must always be prohibited from discharging
wastes which would violate any prohibited discharge standards of the General
Pretreatment Regulations [40 CFR 403.5 (a) and (b)] or any local prohibited
discharges. The POTW may wish to sample and analyze the hauled wastes or require
that the hauler perform such sampling and analysis to verify that such standards would
not be violated if the waste is discharged to the POTW. If the POTW does not have
permit-by-rule status, or is not otherwise equipped to treat RCRA hazardous waste,
the permit should prohibit the introduction of hazardous waste to the POTW.
National Categorical Pretreatment Standards—If waste haulers are allowed to
discharge nondomestic wastes to the POTW, then it should be determined whether the
sources of these waste are regulated by national categorical pretreatment standards. If
a hauler discharges categorical process wastewater, the permit must require
compliance with applicable categorical standards.
Local Limits—The permit should require compliance with any local limits established
by the POTW, including any specific limits applicable to hauled non-domestic waste.
Designated Disposal Site—The permit should clearly designate the disposal site and
state all facility rules for discharging such as clean-up requirements.
Number of Loads—If a POTW is susceptible to hydraulic or organic overloading, it
may wish to consider placing a limit on the maximum number of loads that a waste
hauler can discharge over a specified period of time.
Time Limitations—Specific days and/or hours that waste haulers are allowed to
discharge should be stated in the permit conditions.
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• Waste Tracking/Manifest System—The permit should contain a condition that
requires the waste hauler to provide documentation on the nature, origin, and volume
of the wastes being discharged. Refer to Section 3.2.5 for more information.
• Notification of Waste Type—The POTW may want to require that any waste be
approved prior to being hauled. The permit should require the hauler to notify and
receive approval from the POTW of new customers as well as changes in the nature of
wastewater originating from existing customers. Under 40 CFR 403.12(j), industrial
users are required to notify the POTW of any substantial changes in the volume or
character of pollutants discharged. POTWs should require this same notification from
waste haulers that discharge industrial wastewater.
• Standard Conditions—Many of the standard conditions placed in other industrial user
permits should also be contained in waste hauler permits. A few of these are:
modification of conditions, non-transferability, revocation of permit, and penalties/
fines. The POTW could also consider requiring waste haulers to post a performance
bond.
• Significant Industrial User—If a waste hauler meets the definition of significant
industrial user [40 CFR 403.3(t)] and the POTW has an approved pretreatment
program and adequate legal authority, the POTW should permit the waste hauler as a
significant industrial user and the permit must include all conditions required under 40
CFR403.8(f)(l)(iii)
For more information on permitting procedures, refer to the Industrial User Permitting
Guidance Manual EPA 1989.
3.2.4 Monitoring Program
Monitoring is necessary to gather information about the characteristics of hauled waste
that is discharged to the treatment plant, and to determine if waste should be rejected because of
potential negative impacts to the facility. Monitoring is also necessary to ensure that discharges
conform to appropriate standards and regulations. A monitoring program can provide
information on which load and what pollutants and concentrations caused problems in plant
operations. A monitoring program demonstrates to the waste haulers that the POTW is serious
about enforcing the standards and requirements of its hauled waste control program. For these
reasons, POTWs should seriously consider including monitoring as part of their waste hauler
control program, particularly if non-domestic wastes are accepted.
o 10
3-13
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The POTW or the waste hauler could sample the non-domestic waste at the location
where it is generated before it is pumped into the truck or rail car. A seal can be placed over the
truck's discharge point which, upon arrival to the POTW, can be inspected to ensure that no other
wastes had been introduced to the truck since sampling. Sampling may also be performed at the
discharge site.
3.2.4.1 Sample Types
Decisions on whether to accept a load of non-domestic waste may be based on incorrect
information if sampling is not performed properly. Proper techniques, as found in 40 CFR Part
136, must be used for sample collection, preservation, storage, and analysis if reliable results are
expected to be obtained. The following conditions are important to consider for any sampling
program.
There are two basic types of samples: grab samples and composite samples. For sampling
hauled waste, both sample types are collected manually. Selection of sample type to collect
depends on several key factors including:
Composition of the waste that is being received
• Pollutants to be analyzed
• Physical setup of the receiving station
• Purpose of the sample
• How well mixed the load is
Grab Sampling
A grab sample is a single discreet sample collected over a short period of time without
regard to the waste stream flow. Grab samples are useful in taking a "snapshot" of a discharge
and can provide information on the extreme pollutant concentrations of a load, whereas
composite sampling may mask the extreme pollutant levels. Grab samples may be used if both
flow and pollutant concentrations or loadings are constant and should only be employed if the
POTW operator has determined the waste contained in a hauler's truck is homogeneous. Grab
sampling is used when collecting composite samples is not appropriate. For example, grab
sampling is necessary for such parameters as pH, oil and grease, temperature, total phenol,
cyanide, sulfides, and volatile organics.
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Composite Sampling
Composite samples measure the average amount of pollutants discharged by a waste
hauler during the entire discharge period. A composite sample is a mixed or combined sample
that is formed by combining a series of individual and discrete grab samples collected over a
period of time or representing more than one specific location or depth.
Composite sampling of hauled waste consists of collecting time-proportional samples at
specified intervals during a discharge. For a non-homogeneous discharge, wastes are stratified in
the hauler's tank and the effluent quality will vary over the discharge period. For this situation,
the composite sample collected over the discharge period would be most appropriate. Grab
samples should be taken at least three times during the discharge and then composited: once at the
onset of the discharge, where a higher concentration of solids are likely to occur, once in the
middle of the discharge, and once at the end of the discharge where light oils are most likely to
appear.
3.2.4.2 Sampling Frequency
The POTW should consider a number of issues when establishing sampling frequency,
including:
Frequency necessary to obtain data representative of the nature and volume of the
hauled waste
Frequency necessary to deter unscrupulous haulers from delivering and discharging
incompatible wastes
Actual (or potential) impact of the hauled waste on the operation of the treatment
plant, receiving water body, and sludge disposal practices
The hauled waste source and the types and concentrations of pollutants contained in
the waste
Regulatory requirements of any permits, local ordinances, POTW policies, and federal
regulations
Seasonal variations in the volume and makeup of hauled waste
Availability of POTW staff
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• Trends in delivery times
• Compliance history of the waste hauler
• Expense of sampling and analysis imposed on both the waste hauler, the POTW, and
the resources (labor and equipment) available.
The POTW should establish a base sampling frequency and increase or decrease the
frequency on a case-by-case basis using the factors discussed above. A base sampling program
for non-domestic waste should, at a minimum, include:
• Visual observation and recording of any unusual odors, color, or other characteristics
• Monitoring of pH
• Collection of a grab or composite sample of the hauled waste.
While an effective deterrent,
sampling alone may not provide
loads, as it can provide information
only if analyzed. Treatment plant
operators may find the need to perform
Automatic pH Testing
A POTW in Fairfax County Virginia has recently installed a fully
, , , .. r • ,-11 automatic pH screening discharge facility. Wastes are discharged
complete protection from incompatible , , , ... • . , .. „
r r r to an underground temporary holding tank, and automatically
tested for pH. If the load is acceptable, waste haulers record the
reading from a meter into a daily log. If the pH is too high or too
low, the waste is held and POTW personnel are notified by an
alarm. The waste is tested once again, and if found to be
incompatible, pumped back into the track.
a quick analysis of a load before ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
discharging to the headworks for any number of pre-determined or suspect parameters. Analyzing
for pH is perhaps the most effective way to discover incompatible loads, and can be performed
rapidly, without great cost to the POTW or the waste hauler.
Example sampling programs that have been developed by POTWs are described below:
• Comprehensive sampling and analysis of all non-domestic hauled waste and
periodic sampling and analysis of domestic septage—All hauled wastes of Non-
domestic origin are sampled and analyzed and every tenth load of domestic septage
received from each hauler is sampled and analyzed.
• Comprehensive sampling of all hauled wastes and periodic or random analysis of
the collected samples—A sample is collected from each hauled waste load. These
samples are preserved and stored and a portion of the samples are analyzed. Each
hauler knows that all of his loads will be sampled but does not know which of his loads
will be analyzed. In addition, if a disruption in plant operations occurs, the stored
samples can be used to determine the exact makeup of the load which caused (or is
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suspected of causing) the disruption. If several loads were received, the stored
samples of all these loads can be analyzed to assist in identifying the waste hauler and
waste load that may have caused the disruption.
• Random sampling and analysis—Sample collection and analysis are conducted on a
random basis. For example, the POTW randomly selects a day to conduct sampling
and all waste loads that are received that day are sampled and analyzed, or the POTW
may collect and analyze samples every day but randomly selects the loads to be
sampled and analyzed (i.e., every fifth truck or seven random samples per day).
3.2.4.3 Testing Parameters
Testing parameters should be determined in two phases. First, if not already completed,
the POTW should characterize the wastes it commonly receives to obtain typical pollutant levels.
This initial characterization may take place over a period of several months to more than a year.
Secondly, pollutants of concern identified in the initial phase should be specified as the parameters
for a routine monitoring program.
Existing septage hauler monitoring data may be useful to identify pollutants potentially
discharged by waste haulers. Table 3.2 summarizes septage hauler monitoring data provided by
nine POTWs. Metals identified at highest average levels in septage haulers' loads included iron,
zinc, copper, lead, chromium, and manganese. The most frequently identified metals were
copper, nickel, chromium, and lead. Organics identified at highest average levels were acetone,
isopropyl alcohol, methyl alcohol, and methyl ethyl ketone. Based on these data, POTWs should
anticipate that hauled septage may contain relatively high levels of heavy metals and organic
solvents. However, the type and level of pollutant present will vary depending on the type of
hauled waste (e.g., domestic septage, landfill leachate, groundwater remediation site waste,
industrial wastes). POTWs should periodically monitor septage haulers' loads to determine site
specific pollutant concentrations and loadings for those metals listed above, as well as for
common organic solvents (especially ketones and alcohols) and any other identified pollutant of
concern. Table 3.3 provides example monitoring parameters for initial characterization of these
various types of hauled wastes.
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Table 3.2 Septage Hauler Monitoring Data
Pollutant
Iron
Zinc
Manganese
Barium
Copper
Lead
Nickel
Chromium (T)
Cyanide
Arsenic
Silver
Cadmium
Mercury
Domestic Septage(mg/l)
Minimum
0.2
O.001
0.55
0.002
.01
O.025
0.01
0.01
0.001
0
0.003
0.005
0.0001
Maximum
2,740
444
17.05
202
260.9
118
37
34
1.53
3.5
5
8.1
0.742
Average
39.28
9.971
6.088
5.758
4.835
1.21
0.526
0.49
0.469
0.141
0.099
0.097
0.005
Source: Supplemental Manual on The Development and Implementation of Local
Discharge Limitations Under the Pretreatment Program, EPA 1991
Table 3.3 Example Monitoring Parameters for Initial Characterization
Type of Hauled Waste
Leachate from nonhazardous waste disposal
sites
Leachate from hazardous waste disposal sites
Fuel contaminated wastewater
Groundwater remediation site (not associated
with fuel contamination)
Categorical industrial discharge
Septage
Initial Characterization
BOD, TSS, oil & grease, total Kjeldahl nitrogen (TKN),
ammonia, iron, manganese, pH, phenols, phosphorous,
chlorides, Total Dissolved Solids (TDS), all priority
pollutants except 2.3.7.8 tetrachlorodibenzo-p-dixon and
asbestos.
BOD, TSS, oil & grease, TKN, ammonia, iron, manganese,
pH. phosphorous, chlorides. TDS. all compounds on the
Superfund Target Compound List and any other known or
suspected contaminants identified by an investigation of site
or by gas chromatograph/mass spectrophotometer (GC/MS).
Benzene, toluene, ethyl benzene, xylene, methyl tert-butyl
ether, naphthalene, oil & grease, pH, and lead
Determine from the groundwater remediation investigation
All categorically regulated pollutants
1 sample for BOD, TSS. pH. oil & grease, and metals and
organics of concern
Source: New York State Department of Environmental Control (NYSDEC) Technical Operational Guidance (TOG s) for
Acceptance of'New Discharges, October 1994
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3.2.5 Waste Tracking/Manifest System
A manifest system, similar to those used for hazardous waste, is an efficient means to
record information on hauled waste. This type of control can be employed independently of a
permit system. Examples are provided in Appendix H of this document. This type of system
requires waste haulers to enter information on the waste manifest form for each load received.
The manifest form should include information such as:
• Name, address and phone number of hauler and each waste generator
• Types of wastes collected from each generator
• Approximate volume(s) received by the hauler
• Known or suspected pollutants, identified by the generator
• Certification by the generator that the waste is not hazardous and whether it is
generated from any process that is defined as a categorical process wastewater
• Results of any testing performed on the wastewater.
Prior to each discharge, the POTW should require a completed manifest form from the
waste hauler. Each manifest sheet should be completed in triplicate: one copy for the waste
hauler, one copy for the treatment plant operator, and one copy for the POTW's administrative/
billing purposes. The POTW should supply blank manifest forms to each waste hauler.
Treatment plant operators should periodically verify the information provided on the manifest
form by contacting the sources provided on the manifest.
3.2.6 Identification of Illegal Dischargers
Identification of a waste hauler as the source of pass through or interference can be a
difficult task. Hauled waste can be discharged to a manhole and the hauler gone before the waste
reaches the treatment plant. There are several examples where hazardous waste haulers have paid
industries for the seclusion their facility provides during such illegal discharge events.
Approaches to help alleviate the problem include:
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Periodic sampling of suspected sewer lines
Surveillance of waste haulers and suspected discharge points
Education of industries concerning the seriousness of these violations
Increased public awareness of illegal dumping
Increased enforcement.
Many states have enforcement programs to assist POTWs in detecting illegal dischargers.
Federal [EPA's Criminal Investigation Division (CID) or the FBI] or local law enforcement
officials can also be requested to assist in surveillance activities and enforcement. Video
surveillance of suspected manholes or storm drains is also a possible option. Some POTWs use
locking manholes to discourage illegal dumping at suspected sites.
Treatment Facilities Lose $1.28 Million
In 1996, six former and present officials of one of the nation's largest waste hauling firms were indicted on
Federal charges that they defrauded five publicly owned treatment works of nearly $1.28 million by illegally
dumping thousands of loads of waste.
The government charged that a large waste hauling firm illegally dumped some 4,591 loads of waste containing
wastewater treatment sludge or grease on 1,577 different days. The company said it had immediately launched
an investigation upon discovery of die illegal actions, fired the responsible employees, and made a $ 1.6 million
settlement to one of the cities.
Charges included Clean Water Act violations and mail fraud. The charges cany a maximum penalty of five
years probation and a fine of $50,000 per day for each day of violation. Had the firm correctly reported the
illegal loads, they would have had to pay the numerous POTWs it discharged to approximately $1.28 million.
The company claimed it had settled the case, agreeing to plead guilty to three charges involving mail fraud and
conspiracy, and pay a $3 million fine with an additional $1.5 million toward environmental restoration projects.
Source: The Associated Press - Lubbock Avalanche Journal, November 22, 1996
3.3 Communication
3.3.1 Communication with Other POTWs
To effectively control hauled waste, all POTWs within a geographic region should readily
share the information they receive on hauled waste with each other. When a POTW rejects a
load, the operator should consider contacting nearby facilities where the waste may be delivered,
and inform them why the load was rejected. If a waste load is rejected, the POTW could also
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request the hauler to provide information on when and where the rejected load was discharged.
POTWs should also communicate with one another to identify frequent violators. A list of
haulers with frequent violations, including type of violation, can be distributed among regional
POTWs.
3.3.2 Communication with Waste Haulers
POTW operators can establish a mailing list of all local waste haulers and provide them
with periodic information on changes in plant policy, reminders of existing plant policies that are
frequently abused, and changes in operating times and fees. POTWs are frequently the only
source of regulatory information for waste haulers.
3.4 Review and Update Controls
After control measures are implemented, they should be periodically reviewed for their
effectiveness and updated as necessary. Additionally, if the type or amount of hauled waste
received changes, the controls should be reviewed to determine if additional controls are needed.
For example, if a POTW has been receiving only domestic hauled waste and has implemented
procedures to control the discharge of that waste, the introduction of hauled non-domestic waste
may require the implementation of additional controls (e.g., increased monitoring).
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4. CASE STUDIES
The following case studies present some active controls and communication methods used
by larger POTWs with pretreatment programs. Smaller POTWs and non-pretreatment POTWs
can choose controls based on factors such as treatment plant capacity, flows and pollutant
loadings, sensitivity of plant processes, types and amounts of hauled waste accepted, funding, and
local issues and requirements. A POTW should tailor its program to address these factors.
4.1 Littleton-Englewood Colorado
Summary of Waste Hauler Program
The Littleton-Englewood wastewater
treatment plant (L-E WWTP), situated south of
Denver, Colorado, has a treatment capacity of
L-E WWTP has a better understanding of the volume
and content of the hauled waste it receives and has
suffered no disruptions since the inception of its waste
hauler program in November of 1996.
approximately 26 MOD. As part of an
expansion project for tertiary treatment, the facility upgraded its hauled waste program including
structural and programmatic levels. The facility allows only domestic hauled waste to be
discharged. Highlights of the POTW's upgraded hauled waste program are presented below.
Littleton-Englewood WWTP
Waste Hauler Control Program
X Informational mailing
X Electronic Cards
X Restricted Hours
X Sampling Program
X Two Discharge Standpipes
X Automatic Locking Gates
X Informational Signs
X Open Communication with
Regional POTWs and Haulers
Changes were initiated with a large
informational mailing to all area waste
haulers. To help alleviate revenue collection
problems, all haulers were required to furnish
bonds. A minimum $1,000 bond was set for
small haulers. Bonds for haulers with tainted
payment histories were set higher. Large
hauling firms were required to furnish a bond
equaling 2 month's business with the plant.
Bonding has been one of the most beneficial changes Littleton-Englewood has made. The plant
has found that problems surrounding the collection of payments have been drastically reduced.
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The POTW issues electronic cards to each hauler vehicle that has satisfied the POTW
bond requirements. The cards streamline the billing process and track who was discharging at a
particular time, reducing manpower needs at the discharge location. Each card provides
information on the owner of the truck and the truck's capacity. Each truck is charged for its full
capacity, regardless of the actual volume of waste in the truck. Therefore, Littleton-Englewood
avoided purchasing an expensive scale, or allowing the volume of the delivered waste to be
determined by the haulers. The card entry system also allows the facility to trace any loads which
upset the facility to a particular hauler. Haulers are also required to submit a generator sheet at
the time of discharge, indicating the source of the waste. The facility's hours for hauled waste
discharge are 7:00 am to 7:00 pm weekdays, and 7:00 am to 3:00 pm on weekends.
This new hauled waste discharge program has resulted in the loss of some waste hauler
customers. However, the POTW recovered the costs of accepting hauled wastes for the first time
and has a better understanding of the content of the hauled waste it receives.
Littleton-Englewood also revised their sampling program. The POTW randomly chooses
one day a month for sampling and samples every truck during that day. Of those samples, one is
brought to the onsite lab for analysis of metals, oil and grease, and pH. If a truck refuses to allow
a sample to be taken, its discharge privileges are revoked. The random sampling program has
kept haulers alert, the plant has suffered no disruptions from hauled waste since the new program
began in November of 1996.
Physical modifications to the facility included the installation of two discharge standpipes.
Waste flows directly from the discharge points to the plant headworks. Some modifications were
also made to allow gravity-feed trucks to discharge more easily. To capture polluted runoff, the
parking stalls are sloped to a drain that empties into the plant headworks. Automatic locking
gates were installed at the entrance and informational signs were placed in plain view of the
haulers.
Littleton-Englewood stays in close contact with neighboring POTWs. The exchange of
information discourages unscrupulous haulers from hauling waste that potentially causes problems
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to other facilities. Littleton-Englewood also stays in touch with its waste haulers. Letters are
often mailed and phone calls are made to haulers to explain changes in policy and operating hours,
as well as to provide reminders of facility requirements.
For more information contact: Mary Gardner at (303) 762-2605 or
mgardner@ci-englewood.co.us.
4.2 Metropolitan St. Louis Sewer District (MSD)
Summary of Waste Hauler Program
Background
Metropolitan St. Louis Sewer District (MSD), an independent public agency responsible
for sewers, sewage treatment, and the drainage of rainwater from St. Louis City and St. Louis
County , maintains a $6.5 billion network of pipes, drainage canals, and 8 WWTPs. Only the
largest of these plants, the Bissell Point plant (143 MGD), is designated to receive hauled waste.
To control such discharges, MSD enforces the provisions of local Ordinance #10082 (see
Appendix G).
All haulers seeking to haul and A/rCrn «? 4 u i /- ± i n
° MSD s Waste Hauler Control Program
discharge waste to MSD's Bissell Point plant
>• Permit Application
must first apply and obtain approval from
MSD. In addition to providing basic
information such as company name, address,
name and title of Chief Executive Officer,
• Transporter and Vehicle ID Number
>• Designated Discharge Point
>• Restricted Hours and Access
>• Manifest Forms
>• Sampling
>• Gate and Intercom Svsteni
business activities conducted, and a list of ^^^^^^^^^^^^^^^^^^^^^^^
transport vehicles (including make, model, tank volume, vehicle license information), the applicant
must also detail the types and estimated volumes of waste to be transported and discharged, its
operational service area(s), proof of insurance coverage including comprehensive general liability
and auto liability which includes the POTW as an additional insured party, and certification and
signature of a company official.
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Upon approval of the application, MSD assigns a unique transporter identification number
to the company and assigns permanent decals with unique vehicle identification numbers to each
of the hauler vehicles. These identification numbers and all application information is entered into
the pretreatment database system.
The Bissell Point waste receiving station consists of 4 "pull-through-bays" and 5 manholes
for discharge. The receiving station can accommodate 4-8 trucks at one time, depending on taick
size. Hours of operation are restricted to 7:00 AM and 5:30 PM, Monday thru Friday, excluding
holidays, and 7:00 AM and 12:00 noon on Saturday. During operational hours, MSD personnel
man the receiving station at all times.
Access to the receiving station varies based on the type of waste proposed to be
discharged. Discharge of domestic waste4 merely requires the hauler accurately completing a
carbon M-form. Discharge of waste from an industrial source requires completion of a double
carbon S-form (the double carbon allows the source to retain a copy of the form prior to the
hauler leaving the source's premises). S-form waste requires the source to complete an
application for special discharge and obtain approval from MSD prior to discharge at the station.
Where approval is denied, the applicant is required to inform MSD as to where the waste is finally
disposed.
4 MSD defines domestic hauled waste as grease and other food preparation wastes from
restaurants, institutional kitchens, employee cafeterias, and similar meal serving facilities, septage. sanitary
wastewater from sewer line or lift station overflows, sludge from wastewater treatment plants receiving
primarily domestic wastes, and wastes from car washes where only washing of the car body occurs.
4-4
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Upon arrival at the station, the hauler provides the MSD attendant with the appropriate
form based on the nature of the waste hauled. The attendant verifies that the proper form is
completed and verifies that the vehicle identification information corresponds to the vehicle
awaiting to discharge. Deficiencies may be easily resolved by the hauler providing any additional
information needed. Discrepancies, however, may require the MSD attendant to contact waste
sources indicated on the form. Where written pre-approval does not accompany the S-form, the
attendant may access the pretreatment database system to obtain the approval status and to
disallow a discharge where approval has not yet been authorized.
Every load intended for discharge, regardless of whether the load is accepted, is recorded
by the attendant on a daily receipt log sheet. Information recorded includes date, time and
receipt information. Entiy lines of this log sheet are pre-numbered, prompting the attendant to
record this unique number on the appropriate S- or M-form.
Upon satisfactory completion of the required paperwork, a hauler is directed into one of
the discharge bays for sample collection for analyses such as pH, conductivity, appearance, and
odor. The sample is collected with a tanker discharge hose, tank sample spigot, and/or by
accessing the waste through the top hatch. When the attendant (and supervisor if consulted)
believes the waste to be that described on the S- or M-form, the hauler may commence discharge;
otherwise, the load is refused. When the attendant observes a discharge in progress that suddenly
changes appearance, odor, etc., the attendant may halt the discharge and collect an additional
sample(s) for screening, potentially forbidding any continuation of the discharge.
All samples are retained as "verification" samples. Of the verification samples collected
daily, S-form waste and a percentage of M-form waste are selected for full verification analyses.
This enables MSD to verify that industrial waste (S-form) was that approved for discharge, to
maintain a database of domestic waste characteristics, and potentially to detect the illegal
discharge of industrial waste in an M-form discharge. Verification samples not analyzed are
retained for a period of time so samples can be analyzed in the event of plant upset or operational
problems.
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Receipt data are entered into the pretreatment database and are recorded manually on
monthly summary log sheets. The entered database data is queried monthly to provide the MSD
finance department with an electronic invoice of hauler data for billing purposes. Typically, a
hauler can expect to receive an invoice detailing the date, time, vehicle ID number, vehicle
volume, and amount due, within 10 days of the end of a month.
MSD intends to upgrade the receiving station to provide for additional security and data
tracking measures. Installation of a gate and intercom system will enable MSD attendants to
restrict vehicle entry until they have been able to verify that the vehicle is authorized to enter the
facility, and then keying in the vehicle ID number to open the gate. The camera will operate each
time the gate opens as an independent record of each vehicle entering the facility.
4.3 City of Fayetteville, North Carolina
Summary of Waste Hauler Program
The Public Works Commission (PWC), City of Fayetteville, North Carolina operates two
WWTPs designed to treat a total of 36 MOD of wastewater. The Cross Creek Water
Reclamation Facility (CCWRF), is designated to receive hauled domestic and industrial waste.
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Haulers seeking to transport and
discharge portable toilet waste and/or septic
tank waste must obtain a permit from the health
department and an approval letter from PWC.
PWC issues an access card to each "approved"
hauler vehicle. Such cards contain electronic
data (i.e., company name, approval number,
truck make and model, and truck tank capacity)
allowing the hauler to gain access to CCWKF
and allowing PWC to track haulers entering
CCWRF.
The discharge location for the hauled
waste depends on the nature of the waste and
the size of the truck. Haulers of portable
toilet waste are required to discharge at the
headworks of the plant. Due to the high
solids content of the waste hauled,
transporters of septic tank waste are required
to discharge at a different plant location that
drains directly to CCWRF digesters. Weight
restrictions on the paths/roads leading to these
two discharge locations require heavier
vehicles (e.g., those capable of transporting
>5000 gallons) to discharge to yet a different
Excerpts from Approval Letter
>• John Hauler is authorized to discharge only
residential septage directly from the service
trucks and without prior pretreatment. Grease
trap wastes or commercial or industrial wastes
will not be accepted without separate and prior
authorization. The discharge of wastewater must
be in compliance with Sections 31-44 and
31-46 of the City of Fayetteville Sewer Use
Ordinance.
>• It shall be necessary for the truck drivers to use
the proper access card each time waste is
discharged from the truck(s) at the septage
receiving station. Each load will be sampled and
each sample bottle will be properly labeled with
the PWC supplied labels.
X High strength wastes and wastes requiring
special handling may justify an additional fee for
each truckload discharged to the CCWRF.
Additional fees shall be levied at the prevailing
rate.
>• The area surrounding the point of discharge shall
be kept clean at all times. Each driver shall be
responsible for washing down the discharge area
with water prior to departure from the POTW.
>• Residential septage may be discharged at
the POTW from dawn to dusk. Any other
arrangement must receive prior authorization
from PWC.
X A copy of this authorization letter must be
maintained in the authorized vehicle discharging
to the POTW. The PWC may require proof of
authorization to discharge prior to any discharge
by any vehicle.
location that drains to the headworks of the plant. The first two discharge locations are equipped
with hoses for clean-up by the haulers upon completion of their discharge.
All haulers are required to self-sample the waste discharged. A container, provided by
PWC, is used by the hauler to collect a grab sample from the actively flowing discharge. The
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sample is then provided to PWC for analysis prior to leaving the plant. It is at the discretion of
PWC to conduct analyses on samples provided.
Haulers seeking to transport and discharge industrial waste must obtain a permit from
PWC prior to any discharge. While considered non-SIU permits, these documents contain
requirements and conditions similar to those imposed on PWC SIUs. Since hauled industrial
waste is general transported in large tanker trucks, hauled industrial waste is discharged at the
location that drains to the headworks of the plant. Wastes containing primarily oils and grease
may be accepted at the septic tank discharge location, provided the oil/grease waste is mixed with
septic tank waste prior to discharge to avoid fouling CCWRF equipment and plumbing.
For more information contact: Monica Hayes at (910) 223-4699 or
MWHayesPWC@aol.com.
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APPENDIX A
GLOSSARY OF TERMS
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GLOSSARY OF TERMS
Approval Authority: The Director in an NPDES State with an approved State pretreatment program and
the appropriate EPA Regional Administrator in a non-NPDES State or NPDES State without an approved
State pretreatment program. [40 CFR 403.3(c)]
Approved POTW Pretreatment Program: A program administered by a POTW that meets the criteria
established in 40 CFR 403.8 and 403.9 and which has been approved by a Regional Administrator or State
Director in accordance with 40 CFR 403.11. [40 CFR 403.3(d)]
Catchment: A structure, such as a basin, for collecting or draining water.
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 [40 CFR § 403.6 and 40 CFR Parts 405-471].
Clean Water Act (CWA): An act passed by the U.S. Congress to control water pollution. It was formerly
referred to as the Federal Water Pollution Control Act of 1972 or Federal Water Pollution Control Act
Amendments of 1972 (Public Law 92-500), 33 U.S.C. 1251 et. Seq., as amended by : Public Law 96-483:
Public Law 97-117; Public Laws 95-217, 97-117, 97-440 and 100-04.
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.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): This act was
passed in 1980 and is commonly known as "Superfund". CERCLA gives the Federal government the
power to respond to releases, or threatened releases, of any hazardous substance into the environment as
well as to a release of a pollutant or contaminant that may present an imminent and substantial danger to
public health or welfare.
Control Authority: A POTW with an approved pretreatment program or the approval authority (State or
EPA Region) in the absence of a POTW pretreatment program [40 CFR § 403.12(a)].
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Domestic Septage: The liquid or solid material removed from a septic tank, cesspool, holding tank, or
similar system mat receives only domestic waste (household, non-commercial, non-industrial sewage).
Facility Operator: Person or persons possessing day-to-day control over the operations at a Publicly
Owned Treatment Works.
Grab Sample: A sample which is taken from a wastestream without regard to the flow in the wastestream
and over a period of time not to exceed fifteen (15) minutes.
Hauled Wastes: Any wastes delivered by truck or rail car.
Hazardous Waste: As defined in RCRA: a solid waste, or combination of solid wastes, which because of
its quantity, concentration, or physical, chemical, or infectious characteristics may -
a) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible,
or incapacitating reversible, illness; or
b) pose a substantial present or potential hazard to human health or the environment when improperly
treated, stored, transported, or disposed of, or otherwise managed.
As defined in the regulations, a solid waste is hazardous if it meets one of four conditions:
1) Exhibits a characteristic of a hazardous waste (40 CFR Sections 261.20 though 262.24)
2) Has been listed as hazardous (40 CFR Sections 261.31 through 261.33)
3) Is a mixture containing a listed hazardous waste and a nonhazardous solid waste (unless the
mixture is specifically excluded or no longer exhibits any of the characteristics of hazardous waste)
4) Is not excluded from regulation as a hazardous waste.
Homogeneous: Uniform in structure or composition throughout.
Indirect Discharge: The introduction of pollutants into a POTW from any non-domestic source regulated
under Section 307(b), (c), or (d) of the Act. [40 CFR403.3(g)]
Industrial User: A source of indirect discharge. [40 CFR403.3(h)]
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Interference: A discharge, which alone or in conjunction with a discharge or discharges from oilier
sources, 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 the POTW's NPDES permit or of the
prevention of sewage sludge use or disposal in compliance with any of the following statutory/regulatory
provisions or permits issued thereunder, or any more stringent State or local regulations: Section 405 of the
CWA; the Solid Waste Disposal Act, including Title II commonly referred to as the Resource Conservation
and Recovery Act (RCRA); any State regulations contained in any State sludge management plan prepared
pursuant to Subtitle D of the Solid Waste Disposal Act; the Clean Air Act; the Toxics Substances Control
Act; and the Marine Protection, Research, and Sanctuaries Act. [40 CFR 403.3(1)]
Local Limits: Discharge limits imposed by municipalities upon industrial or commercial users that
discharge to the municipal sewage treatment system.
National Pretreatment Standard or Pretreatment Standard: Any regulation containing pollutant
discharge limits promulgated by EPA in accordance with Section 307(b) and (c) of the Clean Water Act,
mat apply to industrial users. This term also includes the prohibited discharge standards under 40 CFR §
403.5. [40 CFR 403.3(j)]
Non-pretreatment POTWs: POTWs not subject to the National Pretreatment Program or POTWs
without approved pretreatment programs.
Pass Through: 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. [40 CFR 403.3(n)]
Pathogen: a microorganism, such as a bacterium or fungus, mat causes disease.
pH - A measure of the acidity or alkalinity of a solution, expressed in standard units
Pretreatment: 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 to a POTW. [40 CFR 403.3(q)].
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Prohibited Discharge Standards: Prohibitions on the discharge of certain substances, as defined in 40
CFR403.5.
Publicly Owned Treatment Works (POTW): Any device or system used in the treatment (including
recycling and reclamation) of municipal sewage or industrial wastes of a liquid nature which is owned by a
State or municipality. This includes sewers, pipes or other conveyances only if they convey wastewater to
a POTW providing treatment.
Sludge (Biosolids): The solid, semi-solid, or liquid residue generated during the treatment of wastewater.
Slug load: Any discharge of a non-routine, episodic nature, including but not limited to, an accidental spill
or a noncustomary batch discharge. [40 CFR 403.8(f)(2)(v)]
Time Proportional Sample: A sample consisting of a series of aliquots collected from a representative
point in the discharge stream at equal times intervals over the entire discharge period on the sampling day.
Toxic Pollutant: Any pollutant listed as toxic under section 307(a)(l) 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.
Wastewater: The used water and water-carried solids from a community (including domestic,
commercial, and industrial sources) that flow to a treatment plant. Storm water, surface water, and
groundwater infiltration also may be included in the wastewater that enters a wastewater treatment plant.
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APPENDIX B
BIBLIOGRAPHY
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BIBLIOGRAPHY
Henry, Glynn and Durga Prasad. Anaerobic Treatment of Leachate. Paper presented at seminar on
leachate treatment and disposal, sponsored by the Pollution Control Association of Ontario and the Ontario
Ministry of Environment. Toronto, Ontario, 1991. As cited in Guidelines for Environmental Monitoring
at Municipal Solid Waste Landfills. Municipal Waste Reduction Branch of the British Columbia Ministry
of Environment, Lands and Parks. January 1996.
Lu, James C.S., Bert Eichenberger, and Robert J. Stems. Leachate from Municipal Landfills: Production
and Management. Noyes Publications. 1985. As cited in Guidelines for Environmental Monitoring at
Municipal Solid Waste Landfills. Municipal Waste Reduction Branch of the British Columbia Ministry of
Environment, Lands and Parks. January 1996.
U.S. EPA RCRA Information on Hazardous Wastes for Publicly Owned Treatment Works.
September 1985 (EPA/530-SW-86-001)
U.S. EPA Domestic Septage Regulatory Guidance, A Guide to the EPA 503 Rule. September 1993
(EPA832-0-92-005)
U.S. EPA Control of Slug Loadings to POTWs. February 1991(21W-4001)
U.S. EPA Guidance Manual on the Development and Implementation of Local Discharge Limitations
Under the Pretreatment Program. December, 1987(833-6-87-202)
U.S. EPA RCRA Information on Hazardous Wastes for Publicly Owned Treatment Works. September
1985 (833-B-85-202)
U.S. EPA Guidance Manual for the Identification of Hazardous Wastes to Publicly Owned Treatment
Works by Truck, Rail, or Dedicated Pipeline. June 1987
U.S. EPA CERCLA Site Discharges to POTWs. August 1990 (EPA/542/6-90/005)
B-l
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U.S. EPA Guide to Septage Treatment and Disposal. September 1994 (EPA/625/R-94/002)
U.S. EPA Supplemental Manual on the Development and Implementation of Local Discharge
Limitations Under the PretreatmentProgram. May 1991 (21W-4002)
U.S. EPA. Industrial User Permitting Guidance Manual. September 1989.
Thompson, Vanessa and Denow, Ken The Effects of the Pretreatrnent Program on Hauled Waste in
Wisconsin, Wisconsin Department of Natural Resources, May 5, 1997
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APPENDIX C
LIST OF STATE AND REGIONAL PRETREATMENT COORDINATORS
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PRETREATMENT COORDINATORS
Region I
Justin (Jay) Pimpare
U.S. EPA - Region 1
J.F.K. Federal Building / CMU
One Congress Street
Boston, MA 02114
(617) 918-1531
FAX (617) 918-2064
pimpare.justin@epa.gov
Enforcement Contact: Joe Canzano (617) 918-1763
canzano.joseph@epa.gov
Mr. Mike Harder, Director
Engineering and Enforcement
Department of Environmental Protection
Bureau of Water Management
79 Elm St
Hartford. CT 06106-5127
(860) 424-3701
Mr. Brian Kooiker, Chief
Direct Discharge Section
Vermont Dept. of Environ. Conservation
Permits, Compliance & Protection Division
The Annex Building
103 South Main Street
Waterbury, VT 05676
(802) 241-3822
brian.kooikerrgiannnail.anr.state.vt.us
Mr. Bob DiSaia, Supervising Engineer
Permits, Pretreatment & Planning Section
RI Dept. of Environmental Management
Water Resources Division
235 Promenade Street
Providence, RI 02908
(401) 222-6519: FAX (401) 521-4230
Rdisaia@dem.state.ri.us
Mr. Jim Grier, Pretreatment Coordinator
Department of Environmental Protection
Bureau of Water Management
79 Elm St.
Hartford, CT 06106-5127
(860) 424-3839
Mr. George F. 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; FAX (603) 271-7894
g_carlson@des. state. nh.us
Mr. Jim Rogers,*
Environmental Specialist
Division of Water Resource Regulations
ME Department of Environmental Protection
Land & Water Quality Bureau
Statehouse Station 17
Augusta, ME 04333
(207) 287-7774; FAX (207) 287-7191
jim.r.rogers@state.me.us
State Program not approved; EPA is approval authority
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Region II
Virginia Wong
U.S. EPA - Region 2
Water Compliance Branch
290 Broadway - 20th Floor
New York, NY 10007-1866
(212) 637-4241
FAX (212) 637-4211
wong.virginiafS)epa.gov
Other Contact: Phil Sweeney (212)637-3873
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
maiello@dep.state.nj .us
Jim Murphy.
Principal Environmental Engineer
NJ Dept. of Env. Protection
401 E. State Street, 4th Floor
Trenton. NJ 08625
(609) 633-3823
jmurphyfSldep.state.nj.us
Ms. Wanda Garcia,*
Permits Section Chief
Environmental Quality Board
Commonwealth of Puerto Rico
P.O. Box 11488
Santurce, PR 00910
(787)751-1891
Richard M Cukrovany, P.E.
Bureau of Watershed Compliance Programs
NYS Dept of Environmental Conservation
50 Wolf Rd.
Albany, NY 12233-3506
(518) 457-5968; FAX (518) 457-7038
Mr. Robert Cronin, Director*
Bureau of Watershed Compliance Programs
NYS Dept. of Environmental Conservation
50 Wolf Road
Albany, NY 12233-3506
(518) 457-5968; FAX (518) 457-7038
Mr. Ben Nizario, Director *
Environmental Protection Division
VI Department of Natural Resources
Nisky Center, Suite 231
North 45A Estate Nisky
Charlotte Amalie
St. Thomas. VI00802
(809) 774-3320
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Region III
John Lovell
U.S. EPA - Region 3
Office of Municipal Assistance (3WP24)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-5790
FAX (215) 814-2302
lovell.john@epa.gov
Other Contact: Steve Copeland (215)814-5792
Mr. James Collier, Chief*
Water Hygiene Branch
B.C. Dept of Consumer & Regulatory Affairs
2100 Martin Luther King Ave., SE
Suite 203
Washington, DC 20020
(202)404-1120
Mr. Joe Mulrooney *
Delaware Dept. of Natural Resources &
Environmental Control
Division of Water Resources
Pollution Control Branch
89 Kings Highway
Dover, DE 19901
(302)739-5731
Mr. Gary F. Kelman, Head - Pretreatment Section
Maryland Dept of the Environment
Industrial Discharge Permits Division
Water Management Administration
2500 Broeuing Highway
Baltimore. MD 21224
(410) 631-3630; FAX (410) 631-3163
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; FAX (717) 772-5156
patel.ratilal@al.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; FAX (804) 698-4500
brtuxford@deq.state.va.us
Mr. David Montali. Pretreatment Coordinator
Water Resources Section
WV Dept. of Commerce. Labor & Environmental
Resources
Division of Natural Resources
1201 Greenbrier Street
Charleston, WV 25311
(304) 558-4086: FAX (304) 558-5903
dmontali@mail.dep.state.wv.us
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Region IV
Melinda Mallard Greene
U.S. EPA - Region 4 (AFC/16th Floor)
Water Permits & Enforcement Branch
61 Forsyth Street
Atlanta, GA 30303-3415
(404) 562-9771
FAX (404) 562-9728
mallard.melindafSiepa.gov
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)488-4524; FAX (850) 921-6385
robert.heilmau@dep.state.fl.us
Mr. Ed Hughs
Pretreatment Coordinator, Water Division
Alabama Dept. of Environ. Management
1751 Cong. WL Dickinson Drive
Montgomery, AL 36130
334-271-7838; FAX 334-279-7950
ekh@adem.state.al.us
Mr. Jim Sommerville, Manager
Municipal Permitting
Georgia Dept. of Natural Resources
Environmental Protection Division
Atlanta Tradeport, Suite 110
4244 International Parkway
Atlanta, GA 30354
(404) 362-2680: FAX (404) 362-2691
jim_sommerville@mail.dnr.state.ga.us
Mr. Abe Rowson, Pretreatment Coordinator
SC Dept. of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201-1706
(803) 898-4160; FAX (803) 898-4215
rowsonae@columb32.dhec.state.sc.us
Mr. Tom S. Poe
Division of Water Quality
NC Dept. of Natural Resources and Community
Development
P.O. Box 29535
Raleigh, NC 27626-0535
(919) 733-5083 ext 522: FAX (919) 715-6048
tomj3oe@li2o.enr.state.nc.us
Mr. Harry M. Wilson III. P.E.
Pretreatment Program
Office of Pollution Control
MS Dept. of Environmental Quality
P.O. Box 10385
Jackson, MS 39209-0385
(601) 961-5122: FAX (601) 961-5703
harry _wilson@deq.state.ms.us
Ms. Sandra Gruzesky, Pretreatment Section
Kentucky Dept. of Environmental Protection
Division of Water/KPDES Branch
14 Reilly Road. Frankfort Office Park
Frankfort, KY 40601-1189
(502) 564-2225 ext 459: FAX (502) 564-3949
gruzesky @nrdep.nr. state.ky .us
Mr. Anthony James, Manager Wastewater
Management Section
SC Dept. of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201-1706
(803) 734-5268
Mr. Chuck Durham
TN Division of Water Pollution Control
6th Floor. L & C Annex
401 Church Street
Nashville, TN 37243-1534
(615) 532-0638; FAX (615) 532-0614
cdurham@mail.state.tn.us
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Region V
Matthew Gluckman
Pretreatment Coordinator
U.S. EPA - Region 5
NPDES Support & Technical Assistance Branch (WN-16J)
77 West Jackson Blvd.
Chicago, IL 60604-3507
(312) 886-6089
FAX (312) 886-7804
ghickman.matthew(§>epa.gov
Other Contact: Cathy Scudieri (312)353-2098
Pretreatment Enforcement Manager - Carol Staniec (312) 886-1436
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
Mohammed Islam
mohammed. islam@epa. state. oh.us
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. Kevin Cohoon
IN Dept. of Environmental Management
105 South Meridian St
PO Box 6015
Indianapolis. IN 46206-6015
(317)233-0570
kchoon/8>.dem. state, in.us
Mr. Chuck Schuler.
Pretreatment Coordinator
Wisconsin Department of Natural Resources
Watershed Management, WT/2
P.O. Box 7921
Madison, WI 53707
(608)267-7631
schulc(8>.dnr.state.wi.us
Mr. Bill Blue,* Pretreatment Coordinator
IN Dept. of Environmental Management
105 South Meridian St.
P.O. Box 6015
Indianapolis, IN 46206-6015
(317)232-8729
bblue@dem.state.in.us
Ms. Grace Scott
Michigan Dept. of Environmental Quality
Knapps Center, 2nd Floor
300 Washtenaw Street
P.O. Box 30028
Lansing, MI 48933
(517)373-8566
scottg(9.deq.state.mi.us
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Ms. Jodi Lynn Peace
Environmental Quality Analyst
SE Michigan Dist HQ
3 8980 West 7 Mile Road
Livonia, MI 48152
(734) 953-1433; FAX (734) 953-1467
peacej@state.mi.us
Ms. Nanette E. Jameson
Pretreatment Coordinator/Wastewater Spec.
NE Region HQ
Wisconsin Department of Natural Resources
1125 N. Military Ave; Box 10448
Green Bay, WI 54307-0448
(920) 492-5874; FAX (920) 492-5913
jamesn@dnr.state.wi.us
Mr. Randy Dunnette
Pretreatment Coordinator
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-4194
(651)296-8006
randall.dunnette@pca.state.mn.us
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Region VI
Lee Bohme
U.S. EPA - Region 6
NPDES Permits Branch (6WQ-PO)
Fountain Place, 12th Floor, Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-7532
FAX (214) 665-2191 / (214) 665-6490
bohme.lee@epa.gov
Other Contacts: Mike Tillman (214)665-7531
Enforcement Contact: Bob Goodfellow (214) 665-6632
Mr. Allen Gilliam, Pretreatment Coordinator
Arkansas Dept. of Pollution Control & Ecology
P.O. Box 8913
8001 National Drive
Little Rock, AR 72219-8913
(501) 682-0625; FAX (501) 682-0910
gilliam@adeq. state. ar .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; FAX (512) 239-4430
jrussell@tnrcc.state.tx.us
Ms. Rebecca Villalba
(512) 239-4784; FAX (512) 239-4430
rvillalb@tnrcc. state. tx.us
Mr. Ronnie Bean, Pretreatment Coordinator
Water Pollution Control Division
Louisiana Dept. of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
(504) 765-2779; (504) 765-0635
ronnie_bf«>,deq.state.la.us
Mr. Steve Bumgarn,*
Water Resources 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; FAX (505) 827-0160
Mr. Patrick King
Pretreatment Coordinator
Water Quality Service
Oklahoma Dept. of Environmental Quality
P. O. Box 1677
Oklahoma City, OK 73101-1677
(405) 702-8193; FAX (405) 702-8101
patrick.king@deqmail.state.ok.us
C-7
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Region VII
Paul Marshall, P.E.
U.S. EPA - Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7419
FAX (913) 551-7765
marshall.paul@epa.gov
Other Contact: 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; FAX (515) 281-8895
swillia(3>max.state.ia.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: FAX (402) 471-2909
Mr. Richard Kuntz, P.E.,
Pretreatment Coordinator
Missouri Department of Natural Resources
P.O. Box 176
205 Jefferson Street
Jefferson City, MO 65102
(573)751-6996
nrkuntz(8!mail. dnr. state. mo. us
Mr. Steve Caspers,*
Pretreatment Specialist
Industrial Programs Section
Kansas Department of Health & Environment
Bureau of Water
Forbes Field, Bldg 283
Topeka, KS 66620-0001
(785) 296-5551; FAX (785) 296-5509
C-8
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Region VIII
Curt McCormick
U.S. EPA - Region 8
NPDES Branch (8P-W-P)
999 18th Street, Suite 500
Denver, CO 80202-2466
(303) 312-6377
FAX (303) 312-7084
niccoi-niick.curt@epa.gov
Other Contact: Bruce Kent (303) 312-6133
kent.bruce@epa.epa.gov
Mr. Joe Strasko,*
Penults Officer
Montana Department of Health and Environmental
Sciences
Water Quality Bureau
Cogswell Bldg., Room A-206
Helena, MT 59620
(406) 444-2406
Mr. Gary Bracht, *
Chief, Permits Section
North Dakota State Health Department.
P.O. Box 5520
Bismarck, ND 58502-5520
(701) 328-5227
gbracht@ranch. state. nd. 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; FAX (307) 777-5973
Ikraff@missc. state. wy .us
Ms. Gwen Jacobs
Environmental Protection Specialist
USEPA Region VIII
Montana Operations Office
Federal Building
301 S. Park; Drawer 10096
Helena, MT 59626
(406) 441-1130 x235; FAX (406) 441-1125
jacobs.gwen(9.epa.gov
Mr. Rick Koplitz, *
Pretreatment Coordinator
Colorado Department of Health
4300 Cherry Creek Drive South
Denver, CO 80246-1530
(303) 692-3618; FAX (303) 782-0390
rick.koplitz@state.co.us
Ms. Paula Huizenga
Natural Resources Engineer
South Dakota Department of Environment & Natural
Resources
Joe Foss Bldg.
523 E. Capitol
Pierre, SD 57501
(605)773-3351
paula.huizenga@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; FAX (801) 538-6126
nguinn@deq.state.ut.us
C-9
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Region IX
Keith Silva
U.S. EPA - Region 9
Clean Water Act Compliance Office (WTR-7)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1907
FAX (415) 744-1235
silva.keith@.epa.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 x3143; FAX (702) 687-5856
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
dlau@eha.health.state.hi.us
Gordon Innes
California State Water RCB
Division of Water Quality
P.O. Box 100
901 P Street
Sacramento, CA 95814-0100
(916) 657-0775; FAX (916) 657-2388
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; FAX (602) 207-4467
Mr. James W. Kassel, Chief
Regulation Unit
CA State Water Resources Control Board
Division of Water Quality
P.O. Box 100
901 P Street
Sacramento. CA 95814-0100
(916) 657-0775; FAX (916) 657-2388
kassj@dwq.swrcb.ca.gov
C-10
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Region X
Sharon Wilson
U.S. EPA - Region 10
NPDES Permits Unit (OW-130)
1200 Sixth Avenue
Seattle, WA 98101-1128
(206) 553-0325
FAX (206) 553-0165/553-1280
wilson.sharon@epa.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; FAX (503) 229-6037
hopkins .chuck@deq. state, or. us
David J. Knight, Pretreatment Coordinator
Washington Department of Ecology
Southwest Regional Office
P. O. Box 47775
Olympia, WA 98504-7775
(360) 407-6277; FAX (360) 407-6305
dakn461 @ecy. wa. gov
Phelps Freeborn
WA Department of Ecology
Central Regional Office
15 West Yakima Ave., Suite 200
Yakima WA 98902
(509) 454-7277; FAX (509) 454-4339
wfre461@ecy.wa.gov
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
dknu46 l@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. Jerry Yoder *
Division of Environmental Quality
Idaho Department of Health and Welfare
State House Mail
1410 North Hilton
Boise. ID 83720-9000
(208) 334-5898
C-ll
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US EPA HEADQUARTERS CONTACTS
U.S. Environmental Protection Agency
Pretreatment and Multimedia Branch
Permits Division (MC4203)
401 M Street, SW
Washington, DC 20460
FAX (202) 260-1460
Patrick Bradley (202) 260-6963 bradley.patrick@epa.gov
Brian Frazer (202)260-0101 frazer.brian@epa.gov
John Hopkins (202)260-9527 hopkins.john@epa.gov
JanPickrel (202)260-7904 pickrel.jan@epa.gov
Jeff Smith (202) 260-5586 sinith.jeff@epa.gov
C-12
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APPENDIX D
WASTE TRANSPORTER AUTHORIZATION APPLICATION
EXAMPLE
-------
Metropolitan St. Louis Sewer District
Waste Transporter Authorization Apph'cation
(Please see instructions on the reverse side of this form)
Section A - Company Information
MSD Assigned
1. Company Name: Transporter ID:
2. Mailing Address:
ZIP Code:
Telephone: ( )
3. Name of Contact Person:
4. Name and Title of Chief Executive:.
5. Premise Address:
ZIP Code:
6. Activities at this premise:
7. Dispatcher Name:_
_Dispatcher Telephone: ( ]_
Section B - Waste Transport Vehicles
Vehicle
1
2
3
4
Make
Model
Tank
Volume
(gallons
)
Vehicle License Information
License
No.
State
Expiration
Date
St. Louis
County
HPN
MSD
Assigned
Vehicle ID
Number
Section C - Waste Information
1. Types and estimated annual volumes of wastes
to be transported and discharged to MSD:
Industrial Waste
Landfill Leachate
Sludge
Septic Tanks
Portable Toilets
Grease Traps
Other
2. Areas in which your company
will operate:
St. Louis City
St. Louis County, MO
Jefferson County, MO
St. Charles County, MO
Illinois
Other
Section D - Insurance Attach a certificate documenting that your company has adequate comprehensive
general liability and auto liability insurance which includes the District as an additional insured and includes
provisions for informing the District 10 days prior to the time of policy cancellations or renewals.
I have personally examined and am familiar with the information submitted in this document and attachments and
certify the information to be true, accurate, and complete. I further agree to operate under provisions of all
pertinent District Ordinances and realize failure to do so may result in my discharge privileges being revoked and
enforcement action being taken against me.
Name and Title of signing official:
Signature:
Date:
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APPENDIX E
SUMMARY OF INDUSTRIES REGULATED BY CATEGORICAL STANDARDS
AND PROCESS DESCRIPTIONS
-------
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
Feedlots
Fertilizer Manufacturing
Glass Manufacturing
Grain Mills
Ink Formulating
Inorganic Chemicals
Manufacturing
Iron and Steel
Manufacturing
Leather Tanning and
Finishing
Metal Finishing
Metal Molding and
Casting
40CFR
Part
467
461
431
458
465
468
469
413
412
418
426
406
447
415
420
425
433
464
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
A-D
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
PSES
PSNS
Overview of Pretreatment Standards
Limits are production-based, daily 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
pollutants 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 1 0,000 gallons per day of process wastewater.
Certification is allowed in lieu of monitoring for certain pollutants
when a management plan is approved and implemented.
Discharge of process wastewater is prohibited, except when there is
an overflow resulting from a chronic or catastrophic rainfall event.
Limits 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 the peak
load at a POTW.
Regulations specify no discharge of process wastewater pollutants to
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.
Limits are production-based, daily maximums and 30 day averages.
Limits 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.
Limits are primarily production-based, daily maximums and monthly
averages. Discharges from certain processes are prohibited
(Subparts A-C).
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Category
Nonferrous Metals
Forming and Metal
Powders
Nonferrous 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
471
421
414
446
443
455
419
439
466
430
428
417
423
429
Subparts
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
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
Overview of Pretreatment Standards
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).
E-2
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CATEGORICAL INDUSTRY DESCRIPTION
The following list provides a description of industrial categories that are regulated by National pretreatment standards and the
General Pretreatment Regulations. Numerical discharge standards have been developed for each of the categories listed.
ALUMINUM FORMING (AF)
Aluminum Forming is a physical process by which aluminum or aluminum alloys are changed from their original size and shape
to a desired size and shape. The processes by which such reformation is accomplished are described as rolling, extrusion, forging, and
drawing. An example of aluminum forming is the manufacture of aluminum wire by extrusion. The aluminum or an aluminum alloy is heated
and forced through a small hole (extrusion) changing its form from bulk to long, thin strands.
BATTERY MANUFACTURING (BP)
The Battery Manufacturing category encompasses the process by which a wide variety of consumer and industrial batteries are
produced. This category does not include stores that sell batteries, only facilities that manufacture them.
COIL COATING (CC)
The raw material of the coil coating process is long, thin strips of metal, known as coils. The Coil Coating category consists of
processes that clean, surface, and apply an organic (paint) coating to the coil. An example of a coil coating operation is the manufacture of
soft drink cans with names and logos painted on coils which are then sealed to form cans.
COPPER FORMING (CF)
Copper Forming is the physical reforming of copper by processes similar to those described above under Aluminum Forming.
ELECTRICAL AND ELECTRONIC PRODUCTS (EE)
The Electrical and Electronic Products category encompasses the manufacture of a broad array of electrical and electronic
products. Major regulated products include the manufacture of semiconductors (transistors) and cathode ray tubes, such as television picture
tubes.
ELECTROPLATING AND METAL FINISHING (EM)
Electroplating is a process by which metals in a solution are deposited on an object immersed in the solution by the use of electricity.
The immersed object is known as the basis. An example of electroplating is gold plating. Instead of making an object entirely out of gold,
it is made of another material and only coated with gold., This is done by immersing the object in a solution of gold. When electricity is passed
through the solution and object, the gold is deposited in a thin layer on the object.
In addition to the electroplating process, the Federal regulations also apply to five other related operations: electroless plating,
anodizing, coating, chemical etching and milling, and printed circuit board manufacturing. A facility should be considered regulated by the
Electroplating and Metal Finishing category if it does electroplating or any of the five operations listed above. Additionally, if a facility performs
a metal finishing operation (i.e., painting, polishing, decreasing, welding, etc.) in addition to one of the six operations described above, these
metal finishing operations would also be subject to Federal regulation and National pretreatment standards.
INORGANIC CHEMICALS MANUFACTURING (1C)
Inorganic Chemicals Manufacturing encompasses the manufacture of all chemical compounds not containing any carbon. The
number of such chemicals manufactured is vast, however, Federal regulations of inorganic chemicals manufacture has focused on 66
subcategories of chemicals. Known or suspected manufacturers of any inorganic compounds such as hydrochloric acid, sulfuric acid, chrome
pigments, or iodine should be identified by this category until additional information can be collected to determine the applicability of the
regulation.
IRON AND STEEL (IS)
The Iron and Steel category includes all processes used in the manufacture of iron and those additional processes used to
manufacture steel, including forming and casting processes used to create a finished product.
LEATHER TANNING AND FINISHING (LT)
The Leather Tanning and Finishing category includes facilities that convert animal hides and skins into leather. Facilities that
purchase leather for the manufacture of leather products are not to be included in this category.
METAL MOLDING AND CASTING (MM)
The raw materials in this category are aluminum, copper, iron, lead, magnesium, or zinc. These metals are melted and poured or
forced into a mold which, when cooled, produces a cast intermediate or final product. Foundries are an example of the type of industry that
would be grouped in this category.
E-3
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NONFERROUS METAL FORMING (NF)
The Nonferrous Metals Forming category includes two major groups: forming and production. The category includes forming of
all metals and alloys that do not contain iron as the primary metal and that are not covered by a specific regulation (i.e., aluminum forming and
copper forming). The forming processes used in this category are similar to those described under Aluminum Forming. T'he category also
includes the production of metal powders through mechanics means such as milling.
NONFERROUS METAL MANUFACTURING (NM)
This category is made up of facilities that produce metals from ore concentrates or that recover metals from recycled metallic
wastes, such as aluminum cans or lead batteries.
ORGANIC CHEMICALS, PLASTICS AND SYNTHETIC FIBERS (OC)
This category covers the manufacture of an exceptionally broad range of industrial organic chemicals (chemicals containing at least
one carbon molecule), plastics, and synthetic fibers. Generally, the manufacture of organic chemicals, plastics, and synthetic fibers can be
assumed to be covered by this category when the manufacturing facility is identified by SIC codes 2865, 2869, 2821, 2823, and 2824.
PESTICIDE CHEMICALS (PC)
The Pesticide Chemicals category includes the manufacture, formulation, and packaging of chemicals whose primary purpose is
to control or destroy undesirable plants and animals. The pesticide chemicals category is broader than most categories in that it includes
formulation and packaging of pesticides and is not limited to manufacture.
PETROLEUM REFINING (PR)
The Petroleum Refining category includes facilities that produce petroleum products such as gasoline, heating oil, diesel fuel, and
asphalt from crude oil by physical separation and/or chemical reaction processes.
PHARMACEUTICAL MANUFACTURING (PM)
The Pharmaceutical Manufacturing category includes the manufacture of all chemicals of feed or medicinal grade that have a
therapeutic value. The manufacture of such chemicals is included within the category regardless of whether it was produced by chemical
synthesis, fermentation, extraction from natural sources, or other processes.
PORCELAIN ENAMELING (PE)
Porcelain enameling is the process by which a ceramic or fused silicate finish is applied to a basis metal product. The Porcelain
Enameling, category regulates processes including the operations by which the metal basis is prepared for enameling and the operations by
which the ceramic or fused silicate is applied to the basis. Examples of basis materials include bathtubs, sinks, and other bathroom items.
PULP, PAPER AND PAPERBOARD AND BUILDERS' PAPER AND BOARD MILLS (PP)
These categories are defined as including industries identified by one of the following four SIC classifications: 2611 facilities
engaged in making pulp (a mixture of wood or other fibers with water which is used as a raw material for most paper manufacture): 2621 paper
mills (facilities that produce paper) that do not primarily manufacture building paper: 2631 mills manufacturing paperboard (e.g., cardboard,
chipboard, and pressboard); and 2661 building paper and board mills including production of paper and paperboard used in building.
STEAM ELECTRIC (SE)
The Steam Electric Power Generating category includes facilities engaged in the production of steam to generate electricity for
distribution and sale. This category does not pertain to facilities that generate electricity for onsite use.
TIMBER PRODUCTS PROCESSING (TP)
The Timber Products Processing category includes a broad range of facilities which produce lumber, wood, and basic board
materials. It includes saw mills, millwork and finishing plants, veneer and plywood plants, and wood processing plants (plants at which
creosote or other materials are saturated into the wood asa preservative). The category also includes facilities that manufacture particleboard,
hardwood, and insulation board.
E-4
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APPENDIX F
REFERENCE DOCUMENTS FOR FLAMMABILITY, EXPLOSIVITY, AND HEALTH
HAZARDS OF CHEMICALS
-------
REFERENCES
1990-1991 Tlireshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure
Indices, American Conference of Governmental and Industrial Hygienists (ACGIH), 1990.
Recommended Exposure Limits, National Institute for Occupational Safety and Health (NIOSH)
Permissible Exposure Limits, Occupational Health and Safety Administration (OSHA), 29 CFR 1910.1000-
1910.1101
Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors. EPA 812-B-92-001, June
1992
Guidance Manual on the Development and Implementation of Local Discharge Limitations Under the
Pretreatment Program, EPA, December 1987
Flammable, Combustible Liquids and Gases in Manholes, Sewers, and Similar Underground Structures,
1982byNFPA
NFPA 49 - Hazardous Chemicals Data, National Fire Protection Agency
Pocket Guide to Chemical Hazards (NIOSH 90-117). National Institute for Occupational Safety and Health
(NIOSH)
Safety and Health in Wastewater Systems. Manual of Practice 1. Water Pollution Control Federation (now
Water Environment Federation), 1983
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APPENDIX G
HAULED WASTE ORDINANCE LANGUAGE
EXAMPLE
-------
St. Louis MSD Ordinance
ORDINANCE NO. 10082
AN ORDINANCE, repealing Ordinance No. 8102, as adopted June 15, 1990, and adopting a new
ordinance in lieu thereof regulating the discharge to the facilities of The Metropolitan St. Louis Sewer
District of water or liquid waste which has been removed and transported from any pit, sump, holding tank,
septic tank, wastewater treatment facility or industrial facility.
Section One - Ordinance No. 8102, as adopted June 15,1990, is hereby repealed.
Section Two - Discharge of Hauled Waste
A. No person shall discharge or cause to be discharged to any public sewer or to any public sewer facility
or to any private sewer tributary to any public sewer any water and/or waste which has been removed
and transported from any pit, sump, holding tank, septic tank, wastewater treatment facility or
industrial facility except as authorized by this ordinance. Such water and/or waste is hereinafter
referred to in this ordinance as hauled waste.
B. Under no circumstance may hauled waste which is hazardous waste, as defined in 40 CFR 261 or
10 CSR 25-4.261, be discharged to District facilities.
C. Hauled waste of commercial or industrial origin or hauled waste of unusually high strength may be
discharged only if the original source of the waste has received written approval from the District. The
original source of such waste shall submit, to the District's Department of Environmental Compliance,
an application for Special Discharge, on a form provided by the District, along with such
supplementary information as the District may require. The District will review the application and
will determine acceptability for discharge of the waste based on the Application and Acceptance
Criteria for Special Discharges developed by the District.
Section Three - Waste Transporter Authorization
Only District authorized waste transporters may discharge hauled waste at District facilities.
A. Any person wishing to obtain authorization to discharge hauled waste at District facilities shall submit
a Waste Transporter Identification application on a form provided by the District complete with all
supplementary information as specified on the application fonn and in this section. If approved, the
applicant will be assigned a Waste Transporter Identification Number. The following supplementary
information shall be included with the application:
(1) Proof of comprehensive general liability and auto liability insurance which includes the District
as an additional insured and includes provisions for informing the District ten days prior to the
time of policy cancellations or renewals. Applicants shall maintain general liability insurance and
automobile liability insurance in such amounts as the District may, from time to time, deem
appropriate.
(2) A list of the vehicles applicant has in service for transportation of liquid waste. The list shall
include the make and model, the state of registration, the state vehicle license number and the
tank volume, in gallons, for each vehicle operated.
(3) Proof that waste transporter vehicles which are to discharge at District facilities are in
compliance with all applicable State of Missouri, City of St. Louis and/or St. Louis County laws
and regulations applicable to waste transporters within the jurisdictions within which applicant
-------
operates. Waste transporters operating within St. Louis County shall provide a St. Louis County
Department of Health Permit Number for each vehicle to be operated within St. Louis County.
(4) Volumes and types of waste transported each year for the last three years. A new business shall
submit an estimate of volumes for the first year.
B. Any person who has been granted authorization to discharge hauled waste at District facilities shall
annually provide proof to the Director of continued liability insurance and proof of continued
compliance with applicable State of Missouri, City of St. Louis and/or St. Louis County laws and
regulations.
C. The District may rescind a transporter's authorization to discharge hauled waste if the transporter is
found to be in violation of the provisions of this ordinance or other District ordinances.
Section Four - Waste Discharge Location
A. Any hauled waste which is acceptable to the District may be discharged only at the District's Hauled
Waste Receiving Station located at:
Bissell Point Wastewater Treatment Plant
10 East Grand Avenue
St. Louis, MO 63147
Hauled waste may be discharged at this location only between the hours of 7:00 AM and 5:30 PM,
Monday through Friday, excluding holidays, and between the hours of 7:00 AM and 12:00 noon on
Saturday.
B. Under emergency conditions, as determined by the Director, hauled waste may be discharged at such
alternate locations and under such conditions as the Director determines are appropriate.
Section Five - Hauled Waste Receipts and Samples
A. No person shall discharge or cause to be discharged hauled waste without presenting a completed
Hauled Waste Receipt form to the receiving station attendant at the time of discharge. The Hauled
Waste Receipt shall be on a fonii provided by the District and shall fully identify, to the satisfaction of
the attendant, the source and nature of the waste.
B. Hauled waste subject to the prior approval provisions of Section Two of this ordinance may be
discharged only upon verification by the attendant that such prior approval has been granted.
C. A sample of each load of hauled waste to be discharged shall be collected by the receiving station
attendant and appropriate screening analyses performed prior to discharge being allowed. The sample
will be retained and submitted to the District's Department of Environmental Compliance laboratory
for such further analyses as deemed necessary to determine its compliance with the requirements of the
District's sewer use ordinance and applicable local, state and federal regulations. In the event this
hauled waste is found to be in violation of said ordinance or regulations, approval to discharge this
water or waste to District facilities may be revoked and any damages incurred by the District will be
charged to the person discharging said water or waste.
Section Six - Conditions of Discharge
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Any person granted authorization under Section Three to discharge hauled waste at the point designated
herein and in possession of proper Hauled Waste Receipts assents to the conditions hereinafter stated and
agrees to be bound by his conditional obligations and duties, to wit:
(1) The transporter will comply with all District regulations and follow the directions of District
employees while on District premises.
(2) The transporter agrees to indemnify' and to save the District harmless from any and all damage
and expenses which may be suffered by it by reason of any or all of his acts done on its premises,
including but not as a limitation, the discharge of the aforesaid hauled waste which violates any
standard or standards of the District's sewer use ordinance.
(3) The transporter will, in the event of spills or leakage of hauled waste on the District's premises,
as a result of his acts or faulty equipment, appropriately clean, to the satisfaction of the attendant
on duty, the area involved.
Section Seven - District Refusal of Waste
The District has the right to refuse to accept the discharge of any hauled waste brought to the Hauled
Waste Receiving Station if, in the opinion of the attendant on duty, based on a review of the Hauled Waste
Receipt form, District records and the screening analyses:
(1) The waste does not meet the conditions under which a prior approval was granted, or
(2) The waste could cause operational and maintenance problems, be detrimental to the health of
District employees or cause violations of the District's NPDES Permit or any other City, State or
Federal environmental laws and regulations.
Section Eight - Discharge at Other Locations Unlawful
The discharge of hauled waste into any District facility, manhole or other location not approved for such
discharge shall be considered unlawful and the person responsible for such discharge shall be deemed guilty
of a misdemeanor and upon conviction thereof shall be fined not more than One Thousand Dollars
($1,000.00) or imprisoned in the County Jail or County Workhouse, as the case may be, for not more than
one (1) year, or by both such fine and imprisonment for each such violation.
Section Nine - Fees for Discharge of Hauled Waste
A. Waste Transporters shall pay a fee for hauled waste discharged pursuant to this ordinance based upon
the non-residential wastewater user charges in effect at the time of the discharge. The fee for each
discharge will be calculated based upon the full volume of the transport vehicle. Waste transporters
will be billed by the District monthly.
B. The original source of a hauled waste of unusually high strength, subject to the prior approval
provisions of Section Two of this ordinance, shall pay an additional fee, as agreed upon, between the
original source of the waste and the District. This additional fee shall be billed by the District to the
original source following receipt of the waste.
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Section Ten - Charge for Late Payment
If any charges billed are not paid by the due date indicated on any bill rendered, then an additional late
payment charge, based on the percentage established by ordinance for late payments of wastewater user
charges, is hereby imposed for each month or portion thereof the bill remains unpaid beyond the due date.
Section Eleven - Termination of Service for Nonpayment
A. When any waste transporter monthly charge has not been paid and has been delinquent for more man
fifteen days after the due date, then the District may refuse to accept any further waste discharges
from that transporter.
B. When any bill rendered to a source of hauled waste subject to the high strength w-aste charges in
Section Nine of this ordinance has not been paid and has been delinquent for more than fifteen days
after the due date, then the District may refuse to accept any further waste discharges from that
source.
Section Twelve - Severability
The invalidity of any section, clause, sentence or provision of this Ordinance shall not affect the validity of
any other part of this Ordinance which can be given effect without such invalid part or parts.
Section Thirteen - Effective Date
This ordinance shall become effective on June 1, 1997.
The foregoing Ordinance was adopted May 8, 1997.
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APPENDIX H
HAULED WASTE MANIFEST FORM
EXAMPLE
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NON-HAZARDOUS WASTE MANIFEST
1 . Generator's US EPA ID Number
2. Generator's Name and Mailing
3. Generator's Phone
4. Transporter Company Name
7. Designated Facility Name and
Site Address
( )
5. US EPA ID Number
8. US EPA ID Number
10. Waste Shipping Name and Description
14. Additional Descriptions for Materials Listed Above
6. Transporter's Phone
9. Facility's
Phone
1 1 . Containers
No. Type
12.
Total
Quantity
13. Unit
Wt./Vol.
1 5. Handling Codes for Wastes Listed Above
16. Special Handling Instructions and Additional Information
17. Printed/Typed Name of Generator
Signature
Month
Day Year
1 8. Transporter Acknowledgment of Receipt of Materials
Printed/Typed Name
Signature
19. Discrepancy Indication Space
Month
Day Year
20. Facility Owner or Operator : Certification of receipt of waste materials covered by this manifest except as noted in Item 19.
Printed/Typed Name
Month
Day Year
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