UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
EPA-330/1-81-004
A STEP-BY-STEP APPROACH
TO DEVELOPMENT OF
NPDES AND RCRA PERMITS
Do not remove. This document
should be retained in the EPA
July 1981 Region 5 Library Collection.
James R. Vincent
U.S. Environmental Protection Agency
Region 5, Library (PH2J)
'I2th
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
and
PERMITS DIVISION, OFFICE OF WATER ENFORCEMENT
Washington, D. C.
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t'.o. Environmental Protect;?;; A—;;;.y
US. Fr"i";.-." -i:|'pj«0tecti6if-"Agency
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CONTENTS
I INTRODUCTION 1-1
II NPDES PERMIT PROCEDURES II-l
PERMIT APPLICATION REVIEW II-4
BACKGROUND INFORMATION REVIEW II-6
FACILITY INSPECTION II-6
DEVELOP BCT LIMITS FOR CONVENTIONAL POLLUTANTS II-9
DEFINE BEST MANAGEMENT PRACTICES 11-13
DEVELOP BAT LIMITS FOR TOXIC POLLUTANTS .... 11-15
DEVELOP BAT LIMITS FOR NON-CONVENTIONAL POLLUTANTS .... 11-18
EVALUATE WATER QUALITY CONSIDERATIONS 11-20
DEVELOP MONITORING REQUIREMENTS 11-20
DEVELOP COMPLIANCE SCHEDULES 11-21
PREPARE A RATIONALE 11-21
III SAMPLE NPDES PERMITS AND RATIONALES III-l
SAMPLE EPA PERMIT III-2
SAMPLE STATE PERMIT III-5
IV NPDES GUIDANCE DOCUMENTS IV-1
CONSOLIDATED PERMIT REGULATIONS IV-1
EFFLUENT GUIDELINES IV-2
GUIDANCE MANUALS IV-2
V RCRA PERMIT PROCEDURES V-l
PERMIT APPLICATION REVIEW - PART A V-2
DETERMINE IF A PERMIT IS NEEDED V-2
REQUEST PART B OF THE PERMIT APPLICATION V-2
COMPILE BACKGROUND INFORMATION V-4
REVIEW PART B OF THE APPLICATION V-4
INSPECT THE FACILITY V-5
DETERMINE IF THE PERMIT SHOULD BE DENIED V-5
GENERATOR REVIEW V-6
TRANSPORTER REVIEW V-6
DETERMINE APPLICABLE STORAGE, TREATMENT
AND DISPOSAL STANDARDS V-6
CONTAINER STORAGE STANDARDS V-7
TANK STORAGE OR TREATMENT STANDARDS V-8
SURFACE IMPOUNDMENT STORAGE OR TREATMENT STANDARDS .... V-9
WASTE PILE STORAGE OR TREATMENT STANDARDS V-9
INCINERATOR STANDARDS V-9
DEFINE GENERAL PERMIT CONDITIONS V-10
PREPARE A COMPLETE MODULAR PERMIT V-10
PREPARE A STATEMENT OF BASIS OR PERMIT RATIONALE V-10
PREPARE A FACT SHEET V-10
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CONTENTS (Cont.)
VI RCRA SAMPLE PERMIT VI-1
PERMIT COVER SHEETS VI-1
HAZARDOUS WASTES TSD UNITS LIST VI-3
WASTES LIST VI-3
GENERAL CONDITIONS VI-3
STANDARD CONDITIONS VI-4
SURFACE IMPOUNDMENTS VI-5
WASTE PILES VI-5
INCINERATORS VI-5
SPECIAL ATTACHMENTS VI-6
OTHER REQUIREMENTS VI-6
STANDARD ATTACHMENTS VI-6
APPENDICES
A CONSOLIDATED PERMIT REGULATIONS
B 40 CFR REGULATIONS, EFFLUENT STANDARDS AND LIMITATIONS
C RCRA REGULATIONS
Tables
1 Outline of NPDES Permit Development Steps II-2
2 Outline of Rationale - EPA Permit III-4
3 Outline of Rationale - State Permit III-7
4 Outline of RCRA Permit Development Steps V-3
5 Sample Modular RCRA Permit Components VI-2
Figures
1 Flow Chart of Basic NPDES Permit Development Process .... II-3
2 Permit Application Review II-5
3 Background Information Review II-7
4 BCT Limits 11-10
5 Basic Management Practices 11-14
6 BAT Limits for Toxic Substances 11-16
7 BAT Limits for Non-Conventional Pollutants 11-19
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1-1
I. INTRODUCTION
This manual is designed to assist the permit writer in the step-by-step
development of NPDES or RCRA permit conditions and the associated rationale
or permit basis. It is intended to be supplemental to the various policy
and procedure manuals, guidance manuals, technical references, regulations
and other technical documents available to the permit writer. By frequent
reference to these documents and by actual examples of their application,
the manual enhances the utility of the available guidance. Development of
permit conditions using best engineering judgment (BEJ) or best professional
judgement (BPJ) procedures are covered in detail; this guidance is not avail-
able in other manuals.
The manual will be particularly useful to the new or inexperienced
permit writer. However, it will also be an aid to experienced NPDES permit
writers in ensuring that all permit aspects required by the recently revised
permit regulations are adequately addressed. The procedures are adaptable
to state permit development so both state and EPA pemit writers will find
them useful.
The manual is divided into two main sections covering NPDES and RCRA
procedures, respectively. Each section describes permit procedures in nar-
rative form and graphically by use of flow charts. Two sample NPDES permits
and their associated rationales are presented which give practical examples
of the application of NPDES BPJ procedures to actual cases. The sample
permits also contain examples of limits on toxic (priority pollutants) and
hazardous substances and best management practices. One permit is in an
EPA format and the other in a state format. A sample RCRA permit with condi-
tions applicable to container storage facilities and to tanks, surface im-
poundments and waste piles used for storage or treatment of hazardous
wastes, is also included. Appendices to the manual contain useful listings
of Consolidated Permit, NPDES and RCRA regulations.
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1-2
This manual is the result of several technical assistance projects
undertaken by NEIC over the past 18 months. In early 1980, NEIC was re-
quested by EPA Region VII to provide technical assistance to the States of
Iowa, Kansas, Missouri and Nebraska in the development of "second round"
NPDES permits that would require the use of BPJ procedures to establish
permit limits. The Consolidated Permit Regulations promulgated on May 19,
1980, contained new permit requirements which necessitated the development
of new procedures for preparation of draft permits. No guidance was avail-
able on BPJ procedures. To provide general guidance to permit writers en-
gaged in this project, the procedures discussed in Section II of this man-
ual were prepared.
As a result of the new Consolidated Permit Regulations, it was also
necessary to prepare new standard conditions applicable to all NPDES per-
mits. A set of these conditions are contained in the first sample permit
in Section III. Both sample permits were prepared as part of the Region
VII technical assistance project.
NEIC has also provided technical assistance to EPA Regions VI and IX
and to the State of Texas in the training of NPDES permit writers. Mater-
ials incorporated in the manual were used in these training sessions. NEIC
is participating in the Organic Chemicals Industry Team which is drafting
permits for a number of chemical plants using these BPJ procedures.
In support of the new RCRA permit program, the Office of Solid Waste
(OSW) and the Office of Water Enforcement and Permits (OWEP) are developing
a series of policy, procedural and technical guidance documents. NEIC is
assisting in the review and revision of draft guidance documents. A series
of week long training courses for RCRA permit writers in all 10 Regions and
Headquarters was presented during April to June, 1981, by OSW and OWE staff.
NEIC participated in the development and presentation of course materials.
The RCRA permit procedures in Section V and the Sample Permit in Section VI
were a product of this activity.
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1-3
The contents of this manual are based in part on federal regulations
that are subject to revision or revocation, especially the RCRA regulations
that are proposed or in interim final status. All such changes through May
1981 are believed to be reflected in the material presented herein. How-
ever, the reader is cautioned to verify the status of any specific regula-
tion before relying on it as being in final form.
The reader may wish to make personal contact with technical personnel
to obtain clarification of specific manual materials, to obtain additional
information or to verify the status of regulations or guidance documents.
Questions on the general manual contents or on permit procedures should be
directed to Mr. James Vincent at the NEIC (303/234-4656, FTS 234-4656).
Questions on the two sample MPDES permits may be directed to Ms. Carie Good-
man at NEIC (303/234-2336, FTS 234-2336). Information on NPDES permits
policy, regulations and best management practices may be obtained from Mr.
Harry Thron in the Permits Division, OWEP (202/426-7010, FTS 426-7010).
Effluent guidelines status information and technical assistance may be ob-
tained from Mr. Sid Jackson in the Effluent Guidelines Division (202/426-2586,
FTS 426-2586). Questions on the RCRA sample permit may be directed to Mr.
Vincent or alternately to Ms. Kay Holub, Permits Division, OWEP (202/755-0750,
FTS 755-0750). Ms. Holub will also provide information on the status of
RCRA regulations and guidance documents.
Much of the material in the RCRA sections of this manual are in draft
form and are based on regulations which are expected to be revised in coming
months. It is expected that the manual will be revised as appropriate as
revisions occur. Any comments that you might have to improve the usefulness
or accuracy of the manual when it is revised are most welcome and should be
addressed to:
Mr. James Vincent
Environmental Protection Agency
National Enforcement Investigations Center
Building 53, Box 25227
Denver Federal Center
Denver, CO 80225
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PART I
NPDES PERMIT PROCEDURES
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II-l
II. NPDES PERMIT PROCEDURES
There are a number of general procedural steps that must be followed
in the development of an NPDES permit. These are listed in brief form in
Table 1. Depending on such factors as industry type, complexity of the
facility, availability of effluent guidelines and water quality considera-
tions, various steps may be omitted for specific permits. For instance, if
effluent guidelines are available, determination of effluent limits is sim-
plified. For small facilities in compliance with their expiring permits, a
plant inspection may not be necessary. On the other hand, all permits will
require review of the application, determination of effluent limits and
preparation of a Fact Sheet. These procedures are listed to assist the
permit writer in ensuring that all aspects of the permit development process
are considered in the drafting of a specific permit.
It should be noted that these procedures deal only with the technical
aspects of permit preparation beginning with the technical review of the
permit application for completeness and ending with the preparation of the
draft permit and Fact Sheet. For the administrative procedures concerned
with public notice, hearings, appeals and final permit issuance, the permit
writer is referred to NPDES permit regulations (40 CFR Parts 122-125, Ap-
pendix A), and to the Permits Division Policy Book, March 1981.
The permit development steps are discussed in more detail below. The
relationships between the basic permit steps listed in Table 1 are shown
graphically in Figure 1, a flow chart of the basic permit development pro-
cess. Additional flow chart figures are used to provide more detail on
each step. These figures are indexed in Figure 1 and referenced in the
text that follows.
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II-2
Table 1
OUTLINE OF NPDES PERMIT DEVELOPMENT STEPS
1. Permit Application Review
6. Develop BAT Limits for Toxic Substances
Review application for completeness
Request supplemental information as needed
Request priority pollutant data if missing
Background Information Review
Compile file information
Compile reference information
Review available information for completeness
Request supplemental information if necessary
Facility Inspection
When facility is complex
When available information is inadequate to prepare
a permit
When there is a history of compliance problems
When extensive best management practices conditions
may be needed
Develop BCT Limits for Conventional Pollutants
Determine if effluent guidelines are applicable
Evaluate existing treatment system
Select treatment improvements that meet the BCT
cost test
Set BCT effluent limits
Define Best Management Practices (BMPs)
Determine if toxic or hazardous substances handled
Define potential for discharge of toxic or hazard-
ous substances from ancillary activities
Require a basic BMP plan if appropriate
Conduct a plant inspection if there are significant
surface runoff problems, a history of spills and
leaks or onsite storage, treatment or disposal of
hazardous wastes
Define specific BMP's as appropriate
Determine if toxic substances are used or pro-
duced or are present in the effluent
Select toxic pollutants to be limited
Determine if effluent guidelines are appli-
cable
Evaluate present treatment system and BCT
treatment system selected
Select treatment improvements if needed
Evaluate the economic achievability of the
improvements
Set BAT effluent limits for toxic substances
7. Develop BAT Limits for Non-Conventional Pollutants
Determine what non-conventional pollutants
will be limited
Determine if effluent guidelines are available
Evaluate the present treatment system and the
BCT and BAT improvements selected in Steps 4
and 6
Select treatment improvements if needed
Evaluate the economic achievability of the
improvements
Set BAT limits for non-conventional pollutants
8. Evaluate Water Quality Considerations
Determine applicable water quality criteria
Determine receiving water conditions
Determine if water quality based limits are
more stringent for any parameters
Set any appropriate water-quality-based limit!
9. Develop Monitoring Requirements
10. Develop Compliance Schedules
11. Prepare a Rationale and Fact Sheet
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S3IX01 jot
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II-3
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II-4
PERMIT APPLICATION REVIEW [Figure 2]
A key element in the preparation of a NPDES "second round" permit is a
complete permit application. In most cases, an applicant for renewal of an
expiring permit for an existing facility will have submitted the new Consol-
idated Permit Application Form 2c which incorporates all information re-
quired by the new permit regulations [40 CFR 122.53]. However, if the re-
newal application was submitted before April 30, 1980, a new application is
not required. If the facility is a primary industry, supplemental data on
priority pollutants in final effluents are required [122.53(d)(7)(ii) and
122.64(a)(2)].
The application requirements [122.53] allow some flexibility in limit-
ing the amount of effluent data required for simple facilities and for fa-
cilities with multiple outfalls with similar waste characteristics. The
permit writer should work with the applicant in these cases to minimize the
sampling and analytical requirements consistent with obtaining adequate
data to draft a complete permit.
Based on new data, the Permits Division has relaxed the effluent sam-
pling requirements for several industry categories during the last year and
may do so for other categories. The permit writer should consult the Per-
mits Division Policy Book or the Permits Division directly to verify the
latest application requirements before requesting supplemental information.
Information on the use or production of priority pollutants at a facil-
ity and adequate sampling data on priority pollutants in effluents are key
to preparation of adequate permit limits for toxic pollutants. Experience
has shown that priority pollutant data on the final effluent only may not
be adequate for complex facilities where there are many internal waste
streams which are then diluted by large volumes of cooling water prior to
the sampling point. Data on the waste characteristics of these internal
waste streams, particularly treatment unit effluents, may be needed to as-
sess the adequacy of existing pollution controls and the feasibility of
achieving greater reductions in the discharge of toxic (priority) pollutants.
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FIGURE 2
PERMIT APPLICATION REVIEW
II-5
No
Review Latest
Permit Application
^ \ the Old
orm' / "
i
No / Is a New \. Yes
~* ^^ Form Required' >^
.
Request a New
Application
i
^ New Application
Received
Yes
1
Yes
^X Does tl-
•* \ Include
\ Polluta
e Application N. NO
Pnunly /
it Data' /
1
x^ Is the Ap
\. Complete
i
i
Plication \ No
•' y
Data Received
Request
Pollutant
i
Dnonty
Data
Establish Schedule
for Completing
the Application
l
Request
Data
Missing
^ Go to FIGURE 3
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II-6
The authority for requesting such supplemental information is provided in
122.53(d)(13).
The applicant is required to submit production data only if a promul-
gated effluent guideline applies to the facility [122.53(d)(5)]. In many
cases where permit limits are to be developed by BPJ procedures, production
data may be needed so that proposed guidelines may be used, comparisons
made with production levels on which the previous permit was based or other
similar computations. A supplemental request would be needed in such cases.
The applicant will usually request confidential treatment of such data.
BACKGROUND INFORMATION REVIEW [Figure 3]
In addition to the permit application, several items of information
will be needed to prepare the permit. Many of these will already be in the
permit file or office. File information includes the current permit, the
rationale for the current permit (if one was prepared), Discharge Monitoring
Reports (DMR's), compliance inspection reports, and any correspondence con-
cerning compliance problems, changes in plant conditions and communications
with other agencies. Other information present in the office should include
effluent guidelines, related Development Documents, reference textbooks on
specific industry categories, the Treatability Manual, State Water Quality
Standards and receiving water quality data.
This information should be reviewed for completeness. As needed, sup-
plemental data may be requested from the State Agency, from EPA Effluent
Guidelines Division and from the applicant.
FACILITY INSPECTION
"Second Round" permits are more complex than previous permits. For
the permit writer to gain an adequate understanding of the more complex
facilities so that adequate permit conditions can be prepared, it is highly
desirable that a visit be made to the facility to personally inspect in-plant
pollution controls, wastewater treatment facilities and ancillary activities
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II-7
FIGURE 3
BACKGROUND INFORMATION REVIEW
V
CONTINUED FROM FIGURE 2
Review the Current Permit and
Associated Rationale tor Permit
Limits (If Available)
Determine What Facility Changes.
Production, Wastewater Treatment, etc
Have Occurred Since Permit Issued
Review any Inspection Reports
for Information on Other'Compliance
Problems and General Background
Review the Recent Discharge
Monitoring Reports (DMR's) to
Evaluate the Compliance History
and Obvious Treatment Deficiencies
Review Effluent Guidelines Division's
Development Documents, Volume II of
the Treatability Manual and Appropriate
Reference Textbooks to Define the
Characteristics of the Industry Type
Involved
No
Are additional Data Needed From
the Applicant and/or the State
Agency as Appropriate to Complete
the Background Information7
Yes
Are the Compiled Data
Adequate to Prepare
the Permit7
No
Is There a History
of Compliance
Problems7
Yes
Conduct a
Facility Inspection
Define What Effluent
Guidelines Have Been
Promulgated for This Industry
Request Supplemental Information
and Technical Assistance From
the Effluent Guidelines Division
as Necessary
Request Supplemental Information
from the State Agency as Necessary
Define What Water Quality
Standards are Applicable
GOTO HGURE4
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II-8
that may discharge toxic or hazardous substances. This would be especially
true if significant pollution control or treatment improvements will be
required, if internal monitoring points are needed, if frequent problems in
complying with the present permit have occurred, if there are known problems
with spills or leaks or with contaminated surface runoff, and if there is
onsite storage, treatment or disposal of hazardous wastes.
For the inspection to be most useful, it will require more than the
hour discussion of plant activities and two hour walk/drive tour of waste
treatment facilities and outfalls frequently conducted in the past. The
inspection should include a detailed review of processes to evaluate what
toxic or hazardous substances may be present in raw materials and associated
contaminants, in products and in by-products; what are the water uses and
resulting wastewater streams; and what are the in-process pollution con-
trols. This information is needed to assist in selecting toxic pollutants
to be limited and in evaluating possible in-process control improvements.
Wastewater treatment facilities, their performance and operation and
maintenance practices should be reviewed. This is useful in evaluating the
adequacy of existing treatment, in assessing the feasibility of improvements
and in evaluating performance data.
Raw material and product storage and loading areas, sludge storage and
disposal areas, hazardous waste management facilities including onsite dis-
posal areas and all process areas should be observed to determine the need
for controls on surface runoff and for specific best management practices.
Effluent monitoring points, sampling methods and analytical techiques
should be reviewed to define any needed changes and to evaluate the quality
of DMR data.
To conduct an adequate inspection at most facilities will require at
least one day. For facilities with only a few basic processes, one main
waste treatment system, limited in-process controls, few surface runoff
outfalls and limited onsite management of sludges cr hazardous wastes, an
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II-9
adequate inspection can be completed in less than two days. Complex larger
plants with several treatment systems, numerous outfalls and extensive an-
cillary activities can require a week to inspect.
Although time spent on plant inspections often results in time savings
during permit preparation, time and/or travel resources are generally not
adequate to allow inspection of all facilities that are desirable. In such
cases, the permit writer may be able to obtain much of the desired informa-
tion from the next compliance monitoring inspection. This requires advance
planning to review the permit application and background information so
that the compliance inspector can be alerted to specific information needs.
Aerial photographs are an excellent aid for conducting a plant inspec-
tion and may provide much of the needed information on the potential for
contamination of surface runoff and on ancillary activities in the absence
of an inspection. Aerial photographs may be obtained from a variety of
sources including the Surveillance and Analysis Division in some Regions,
the NEIC, EMSL-Las Vegas, and private contractors.
DEVELOP BCT LIMITS FOR CONVENTIONAL POLLUTANTS [Figure 4]
Almost all permits will contain effluent limits on one or more con-
ventional pollutants (BOD, TSS, oil and grease, pH and fecal coliform).
Unless a facility does not discharge conventional pollutants or they are
controlled by limits on other parameters, the permit must contain effluent
limits requiring the application of best conventional pollutant control
technology (BCT) by July 1, 1984.
The development of effluent guidelines for BCT involves a cost test
comparing the unit cost of conventional pollutant removal for an industrial
category with the unit cost of removal in a publicly owned treatment facil-
ity (POTW). EPA completed this test on many industry categories for which
BPT and BAT guidelines had been promulgated (44 FR 50732). For some indus-
try categories (primarily secondary industries), BCT was determined to be
equal ta either BPT or BAT. For other industries, BCT effluent guidelines
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FIGURE 4
BCT LIMITS
11-10
No
No
c
Yes
Continued From Figure 3
Are Conventional Pollutants Present
in the Effluent That are Required to
be Limited for This Industry Type7
No
Does BCT = BPT for
This Industry Type?
Does BCT = BAT for
This Industry Type7
No /
\
Are New BCT
Guidelines Available7
Go To
Figure 5
Yes
Use BPT Guidelines
Yes
Use BAT Guidelines
Yes
Use BCT Guidelines
Define the Existing
BPT Level Treatment
for the Facility
<
Select a Candidate
BCT Treatment System
*
r
Do the BCT Cost Test
1
Select a New Candidate
BCI Ireatment System
Is the Cost of Selected
BCT System Reasonable?
^^No
S '
\ r
-, „ /~ \ v
No / Is BCT More Stringent \ Yes
Than BPT7
Use BPT Guidelines
( Go to Figure 5 J
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11-11
would need to be established. Currently, very few new BCT effluent guide-
lines have been promulgated although many are under development or proposed.
The cost test used in evaluating existing effluent guidelines and also
used in BPJ procedures for developing effluent limits on a permit specific
basis in the absence of applicable guidelines has been the subject of much
controversy and a major court case. This has affected both the use of pro-
mulgated guidelines and the BPJ procedures outlined below. The permit
writer is cautioned to consult the latest Permits Division policy guidance
on this matter before establishing any BCT effluent limits.
The initial step in establishing BCT limits is to determine if any
conventional pollutants should be limited [Figure 3]. In the absence of
effluent guidelines, this may be determined from the previous permit, from
proposed guidelines, or from Development Documents.
Industry categories for which BCT = BPT or BAT are listed in the BCT
Cost Test Guidance document published by the Permits Division in September
1980. The availability of new BCT guidelines can be determined from the
Effluent Guidelines Division.
If conventional pollutants are to be limited and effluent guidelines
are not available, then BPJ procedures should be used to develop effluent
limits. The existing treatment system for the facility should be defined
and compared to the model treatment system used in the applicable Develop-
ment Document as a basis for BPT effluent guidelines. This will give an
indication if the present treatment units are equal to or better than BPT.
If the present system is essentially BPT, then possible treatment improve-
ments should be evaluated. Information on candidate improvements can be
obtained from the Development Document, the Treatability Manual and any
studies done by the applicant. The most feasible of possible improvements
should then be selected as a candidate for cost testing.
The BCT Cost Test Guidance document defines the methodology to be used.
Essentially, the unit cost of additional removal of conventional pollutants
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11-12
achieved by the candidate improvements is compared to the equivalent cost
of removal in a POTW. This requires estimating the capital and operating
costs of the improvements. Such cost data may be available in the Develop-
ment Document, the Treatability Manual or from studies by the applicant.
If the candidate treatment system improvements pass the cost test,
they are used as the basis for estabishing BCT limits. Otherwise, a new
candidate system is selected and the cost test repeated. If no improve-
ments pass the cost test, the existing treatment system becomes BCT for
that facility. This will often happen when the existing treatment system
achieves high levels of conventional pollutant removal or low effluent con-
centrations or when the waste flow treated is small. To establish BCT lim-
its based on the existing treatment system will often involve basing the
limits on long-term DMR data.
Once the BCT treatment and/or control system has been selected, the
expected performance of that system must be converted into effluent limits.
When the existing system is defined as BCT, then the effluent limits may
possibly remain the same as in the previous permit, or if DMR data shows
the system consistently achieves substantially lower concentrations/loads,
the limits may be lowered. Care should be taken, however, to not lower the
limits too close to actual plant performance in such cases or occasional
permit violations will be generated by normal variations in plant perform-
ance. The purpose of lower limits would be to insure the future operation
of the treatment system at demonstrated levels of performance.
If BCT involves treatment/control improvements, then effluent limits
must be based on expected performance of the improvements. Engineering
judgement, performance data on similar plants, the Treatability Manual and
Development Documents and engineering studies performed by the applicant
are all possible sources of data on expected performance. Often these data
will be in the form of effluent concentrations. Mass limits (required by
122.63(f)) must then be computed, usually based on daily average and daily
maximum flows reported in the DMR's. It will usually not be feasible to
develop mass limits directly related to production.
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11-13
DEFINE BEST MANAGEMENT PRACTICES [Figure 5]
Under 40 CFR 122.62(k), permits shall include best management practices
(BMPs) conditions to control or abate the discharge of pollutants whenever
BMPs are prescribed in applicable effluent guidelines, when numerical ef-
fluent limitations are infeasible (such as in some types of storm runoff
problems) or when such practices are reasonably necessary to achieve efflu-
ent limitations and standards or to carry out the purposes and intent of
the Clean Water Act (Act). In addition, regulations prescribing how BMPs
are to be applied to control discharges of toxic pollutants (as listed under
Section 307(a) of the Act) or hazardous pollutants (listed under Section 311
of the Act) have been promulgated in 40 CFR Part 125, Subpart K, Criteria
and Standards for Best Management Practices. The effective date of Subpart K
has been suspended indefinitely and it is expected that these regulations
will be revised and reproposed during 1981.
There are currently few promulgated effluent guidelines containing
BMPs. Therefore, BMP conditions will usually need to be developed by BPJ.
Although suspended, the Subpart K regulations contain good guidance on de-
veloping BMPs. Additional information is contained in the technical sup-
port document "NPDES Best Management Practices Guidance Document". The
draft version of this document distributed in early 1980 contains detailed
information on site-specific BMPs. Some recent Development Documents con-
tain information on industry type specific BMPs.
Usually BMPs will be specified only when the conditions described in
Subpart K are present. The initial step [Figure 5] in determining the ap-
plicability of BMPs then is to determine if the facility uses, produces
(as an intermediate, product or by-product), stores, handles or discharges
toxic or hazardous substances. The determination must then be made if sig-
nificant amounts of these substances may be contributed by ancillary manu-
facturing operations including material storage areas; in-plant transfer,
process and material handling areas; loading and unloading operations; plant
site runoff; and sludge and waste disposal areas. If a potential for sig-
nificant discharges of toxic or hazardous substances exists, the permit
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11-14
FIGURES
BASIC MANAGEMENT PRACTICES
Yes
C Continued from Figure 4 J
Does the Facility Use or
Produce (as Products or
By-Products) Toxic or
Hazardous Substances'
No
{Go to Figure 6 \
Point A J
Is it Known or Probable
That the Facility has Ancillary
Activities (Plant Site Runoff.
Spills or Leaks, Sludge or Waste
Disposal, or Drainage from Raw
Materials Storage) that Contribute
Signiucant Amounts ol Toxic or
Hazardous Substances to Surface
Discharges'
Require a Basic BMP Plan
No
Does the Facility Have Known
or Probable Pollution Problems
With Surface Runoff
Yes
No
Does the Facility Have a History
of Spill and Leak Problems'
Yes
No
Does the Facility Have Known
or Probable On-Site Storage or
Disposal of Hazardous Wastes'
Yes
Develop Specific BMP's
Go to Figure 6
Point 8
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11-15
should require the facility to develop a basic BMP plan for control of such
discharges. Both sample permits in Section III contains suggested standard
conditions for a facility requiring a basic BMP plan.
In addition to the BMP plan, it will often be desirable to prescribe
site-specific BMPs. This is especially true when there are known or pro-
bable surface runoff problems, a history of spills and leaks, the handling
of highly toxic substances or the onsite treatment, storage and/or disposal
of hazardous wastes. To develop site-specific BMPs will usually require
that a plant inspection be conducted. Several site-specific BMP conditions
are included in the second sample permit.
Because of the delays in implementing the RCRA permit program, the use
of BMPs in NPDES permits may be an appropriate means of prescribing ade-
quate environmental controls on the onsite storage, treatment and disposal
of hazardous wastes. The permit writer is cautioned to be sure such BMP
conditions are compatible with Interim Status Standards (Part 265) or Per-
mit Standards (Part 264).
DEVELOP BAT LIMITS FOR TOXIC POLLUTANTS [Figure 6]
A major difference between previous permits and BAT permits is the
requirement that effluent limits must be established for toxic (priority)
pollutants (as defined by Sec. 307(a)(l) of the Clean Water Act) which may
be handled or discharged by the facility. Previous permits contained few,
if any, limits on toxic pollutants. When limited, these ususally were heavy
metals, most frequently chromium and zinc because of their widespread use
as corrosion inhibitors in cooling water systems.
Not all facilities will require effluent limits on toxic pollutants;
many secondary industries will not while most primary industries will. To
determine if such limits are required, the permit writer should review the
raw materials, intermediates, and products of the facility and effluent
data. As shown in Table 1 and in Figures 1 and 6, one should then deter-
mine if toxic pollutants are used or produced as products, intermediates,
-------
FIGURE 6
BAT LIMITS FOR TOXIC SUBSTANCES
11-16
No
No
No
Continued From
Figure b,
Point A
/ Are There Priority Pollutants
N. Present m the Effluent7
Go to Figure 7 J
Use BAT Guidelines
Are Other Toxic Pollutants
Present That Need to be Limited'
Select a Candidate BAT
Treatment System
Using BPJ
Is the Selected BAT
System Economically
Achievable'
Have Several BAT
Systems Been Considered?
Select a New Candidate
BAT System
Yes
No
Yes
Yes
Continued From
Figure 5,
Point B
Determine Levels of Priority
Pollutants in the Effluent
Compare With Known BAT
Levels, Water Quality
Criteria, Treatability
Manual Data
Select Toxic Pollutants
to be Limited
Yes / Are BAT Guidelines
Is BCT Selected in Figure 4
Equivalent to BAT for Toxics
Choose the Most Practical/
Economical Alternative
With Acceptable Pollutant
Removal Levels
Select Indicator
Parameters if Appropriate
Develop BPJ—BAT Limns
No
V Available' / *"
Yes
i
r
Go to Figure 7
-------
11-17
or by-products. If so, permit regulations [122.62(e)(l)] require that all
toxic pollutants used or produced must be limited in the permit directly
or by limits on other pollutants that assure adequate treatment of the
toxic pollutants.
In addition, the permit writer should review the effluent data to de-
termine if any toxic pollutants not used or produced are present in the
effluent at levels greater than appropriate BAT levels for the pollutant
and type of facility. Such pollutants may originate as contaminants in raw
materials and products or from ancillary non-process operations. Effluent
limits must be established to either directly or indirectly limit any pol-
lutants present at elevated levels. These requirements for toxic pollutant
limits for substances used or produced or discharged at elevated levels
apply on a case-by-case basis regardless of what, if any, toxic pollutants
are limited by applicable effluent guidelines.
In the absence of appropriate effluent guidelines, the determination
of what pollutants are present at elevated levels must be made using BPJ
procedures. Effluent data for other similar plants, Development Documents
for this or similar industry types, the treatability manual and other refer-
ences on treatment of toxic wastes may be used to determine acceptable dis-
charge levels. An alternate approach would be to use the EPA published
water quality criteria for priority pollutants and the low flow volume in
the receiving water to determine if the mass discharged is excessive.
Since these criteria are not water quality standards, basing effluent lim-
its directly on this approach usually will not be feasible.
An evaluation of the existing treatment system may often assist in the
selection of pollutants to be limited. If some pollutants are used in small
amounts, they may not need to be limited directly if the treatment system
will achieve high levels of removal of both these pollutants and another
substance present in larger amounts that can be used as an indicator.
The treatment system evaluation should also determine the adequacy of
present controls. In some cases, the treatment system may be basically
-------
11-18
adequate for overall control of process wastewater but additional control
of specific toxic substances will be needed. Often this can be achieved
most economically by in-process changes or controls or by treatment units
on selected small process wastewater streams. To make such determinations,
however, will often require a combination of in-depth knowledge of the pro-
cess, a detailed site inspection and/or additional sampling data on the
small wastestream. Information on appropriate BAT controls on toxic pollut-
ants can be found in both the Treatability Manual and various Development
Documents. The selection of BCT improvements may also have provided pos-
sible candidate treatment improvements. Once candidate treatment improve-
ments have been selected, their economic achievabil ity must be evaluated.
Sometimes this will be obvious when the costs are either low or very high.
No specific guidelines for evaluatiing economic achievability are presently
available. In the absence of either a clear pass or fail, the permit writer
may wish to contact the Permit Division in Headquarters for the latest in-
formation or for assistance.
When treatment improvements have been selected, these must be trans-
lated into effluent limits. Normally, expected effluent concentrations
will have been developed during the selection process or were available for
a given treatment unit. These must then be converted to mass limits using
appropriate waste flow volumes.
DEVELOP BAT LIMITS FOR NON-CONVENTIONAL POLLUTANTS [Figure 7]
The development of BAT effluent limits for non-conventional pollutants
proceeds in essentially the same manner as for toxic pollutants. There are
no requirements, however, that specific substances must be limited. Selec-
tion of pollutants to be limited will usually involve a combination of fac-
tors such as pollutants limited in BPT guidelines, limits in the previous
permit, raw materials or products, and reported effluent characteristics.
Selection of treatment improvements and development of effluent limits
should then proceed in the same manner as for toxic pollutants.
The applicant may request exemption of certain hazardous substances
from Section 311 requirements. These substances may be either toxic or
-------
FIGURE 7
BAT LIMITS FOR NON-CONVENTIONAL POLLUTANTS
11-19
( Continued from Figure 6 J
\
Are There Non-Conventional Pollutants
in the Effluent That are Normally
Limited for This Industry Type
or at Levels Requiring Control7
Go to Continuation on
Figure 1 j
Yes
Select Pollutants
to be Limited
Yes
No
No
No
Are BAT Guidelines Available
for Non-Conventional Pollutants7
Use BAT Guidelines
Are Other Non-Conventional
Pollutants Present That Need
to be Limited'
Select a Candidate BAT
Treatment System
Using BPJ
Is the Selected BAT
System Economically
Achievable7
Have Several BAT
Systems Been Considered?
Select a New Candidate
BAT System
No
Yes v
No
Yes
Yes
Is BCT Selected in Figure 4 \ Yes
Equivalent to BAT for Non-Conventionals7
Choose the Most Practical/
Economical Alternative
With Acceptable Pollutant
Removal Levels
Select Indicator
Parameters if Appropriate
Develop BPJ—BAT Limits
( Go to Figure 1 j
-------
11-20
non-conventional pollutants. Special permit conditions and documentation
as required by 40 CFR 117 may be necessary in such cases.
EVALUATE WATER QUALITY CONSIDERATIONS [Figure 1]
In cases where the receiving water is small, the pollutant load dis-
charged is large, the receiving water receives other waste discharges, or a
combination of these factors, effluent limits may be related to water qual-
ity factors. The permit writer should determine if the previous permit was
water quality limiting or any of these condistions exist. If waste load
allocations have been made, the permit will need to have one or more limits
based on these allocations.
To determine if water quality limiting conditions exist in the absence
of waste load allocations, the permit writer should determine allowable
waste loads based on applicable water quality criteria, an appropriate low
stream flow volume (usually the 7-day low flow occuring once in 10 years),
and upstream water quality. In some cases, simple water quality modeling
may be necessary. The allowable waste loads are compared to the technology-
based effluent limits developed wn the previous steps and the minimum value
selected.
DEVELOP MONITORING REQUIREMENTS
Appropriate monitoring requirements should be specified based on such
factors as effluent and process variability, previous permit requirements,
State and/or Regional policy and/or regulations. Toxic pollutants require
particular care in selecting appropriate monitoring frequencies because of
high analytical costs. Examples of monitoring requirements and rationales
for toxics monitoring programs are presented in the two sample permits (Sec-
tion III).
-------
11-21
DEVELOP COMPLIANCE SCHEDULES
If treatment improvements, BMPs, or other changes are required, compli-
ance schedules specifying a time frame for completion should be established.
These must consider the complexity of the improvements, seasonal factors,
and statutory requirements. Schedules should include interim reporting
requirements when appropriate. No periods between steps should exceed one
year.
PREPARE A RATIONALE
The preparation of a BPJ type permit is complex. To fully substantiate
the basis for a permit, a detailed rationale must be prepared. When proper-
ly done, this will communicate clarifiying information to the permittee and
to the public and will make defense of the permit conditions much simpler
for the permit writer. Sample rationales are presented in Section III.
-------
III-l
III. SAMPLE NPDES PERMITS AND RATIONALES
Two sample NPDES permits are presented in this section as examples of
the application of the permit development steps (Section II, Table 1) to
actual permit cases. The samples are actual draft permits and associated
data with the exception that fictious names and places have been substituted.
Two different permit formats are presented. One is a format suitable
for issue by EPA. The other is an adaption to a specific State format
which represents a modification of the previous format used by that State.
Sample rationales are also presented in both cases. These rationales
give a detailed description of each facility, the specific steps followed
in the development of each permit, and the basis for all effluent limits
and permit conditions. With the exception of an evaluation of the economic
achievability of BAT effluent limits, all of the permit development steps
listed in Table 1 were used in one or both cases. Such an economic analysis
was not required in these cases.
The rationales were prepared as part of a technical assistance project
and are more detailed than may be necessary for permit purposes because
they incorporate appropriate observations from the facility inspections.
Such observations could be reported in a separate trip report as part of
the permit support documents. The permit writer is cautioned, however,
that most of the information presented in the sample rationales will be nec-
essary in most cases to defend the basis for permit limits or conditions
developed using BPJ procedures. Two slightly different formats were used
for the sample rationales reflecting the flexibility possible in these
documents.
-------
III-2
SAMPLE EPA PERMIT
The sample EPA permit has the following format which is-similar to the
old EPA permit forms.
Part I. Effluent Limitations and Monitoring Requirements
Part II. Standard Conditions
Part III. Other Requirements
Part IV. Best Management Practices Conditions
Part I is typed on the old EPA permit forms. Effluent limits include
conventional, non-conventional, and toxic (heavy metals and toxic organics)
pollutants.
Part II contains new standard conditions developed for the Region VII
project. They contain all of the permit conditions required by the May 19,
1980 Consolidated Permit Regulations. Much of the language is taken direct-
ly from the permit regulations without modification. However, the order of
presentation has been changed to group conditions in a more logical manner.
A condition concerning flow measurement (Section C, Item 2) was added be-
cause of the almost universal problem with flow measurement devices observed
during compliance inspections and the lack of specific regulations concern-
ing this.
Part III, Other Requirements, contains special conditions specific to
this facility and may be omitted from some permits.
Part IV contains standard Best Management Practices (BMP) conditions
which will usually be inserted in the permit if a facility uses, produces,
or discharges toxic or hazardous pollutants and has ancillary manufactur-
ing operations (such as material storage areas, plant site runoff, in-plant
transfers, process and material handling areas, loading and unloading oper-
ations, and sludge and waste disposal areas) which could result in signifi-
cant amounts of these pollutants reaching waters of the United States.
Frequently these conditions will be present at primary industry type facil-
ities but usually will not be present at secondary industry type facilities.
-------
III-3
These general conditions basically require the facility to prepare a
BMP plan that identifies specific sources of toxic or hazardous pollutants
and that either lists exisiting BMPs applicable to each source or describes
BMPs to be implemented for each source. These conditions were developed
based on the latest version of proposed revisions of Part 125 Subpart K
regulations in late 1980. Revision of these regulations is anticipated in
1981 that may require minor modification of these conditions.
For some permits, it may be desirable or necessary to include specific
BMP conditions to cover particular sources of toxic or hazardous wastes or
specific problem areas best mitigated by BMPs. Such conditions could be in-
serted as Section B of Part IV. Examples of specific BMP conditions are
contained in the second sample permit.
As shown in Table 2, the format of the Rationale is divided into three
main sections. The first section provides background information concerning
facility characteristics and processes, wastewater treatment facilities,
and water quality standards for the receiving stream. The amount of detail
required is dependent on the availability of the information in other refer-
ences, the complexity of the facility, and the level of existing wastewater
treatment and controls. Extensive detail may be required for the last item
in complex facilities or when the exisiting facility is either exemplary or
requires major improvements. In the sample case, substantial data were
presented because this informaion was primarily derived from the NEIC plant
inspection and the wastewater treatment facility was considered to be essen-
tially BAT.
The second section provides the key information supporting all effluent
limits developed by BPJ procedures. It should have all information required
by the permit regulations. The location of and waste streams contained in
each discharge are described. The basis for interim and final effleunt
limits are then described in detail. In this case, the limits were primar-
ily based on a recent EGD Development Document applicable to this type
facility. Interim limits were based on a model BPT treatment system with
final limits based on a model BAT treatment system. Concentration limits
-------
III-4
Table 2
OUTLINE OF RATIONALE - EPA PERMIT
I. Description of Facility
A. Background
B. Waste Treatment
I. Outfall 001
a. Miscellaneous Wastes Tank
b. Acid-Alkali Surge Tank
c. Cyanide Surge Tank
d. Interceptor Tank
e. Chrome Surge Tank
f. Solids Removal System
2. Outfall 002
C. Water Quality Standards
II. Rationale for Effluent Limits
A. Outfall 001
1. Location
2. Waste Streams
3. Basis for Effluent Limits
a. Background
b. Metals and TSS
c. Fluoride
d. Oils & Toxic Organics
e. Hazardous Substances
B. Outfall 002
1. Location
2. Waste Streams
3. Basis for Effluent Limits
a. Metals
b. Fluoride
c. Oils and Toxic Organics
d. pH
III. Monitoring Requirements
-------
III-5
from the model treatment systems were converted to the required mass limits
based on reported discharge rates.
Only limited data were available on toxic organic pollutants. The
permit requires frequent mentoring for selected toxic organics for the first
six months to develop additional data. Based on the results of this moni-
toring, the need for additional treatment, if any, to meet the final efflu-
ent limits will be determined. Periodic monitoring for other toxic organ-
ics found by EGD at other similar plants, but either not detected or de-
tected at low levels at this plant, is required to demonstrate their contin-
ued insignificance.
Exemption of various hazardous substances from Section 311 regulations
was requested by the Applicant in this case. The Rationale details the
basis for direct or indirect limits on these substances.
The third section of the Rationale lists the basis for monitoring re-
quirements.
SAMPLE STATE PERMIT
The sample permit is in a specific state format that has been modified
to reflect additional requirements of the consolidated Permit Regulations.
It differs from the EPA format primarily in that standard permit conditions
are handled by reference to State regulations (a copy is sent to the Permit-
tee with the permit) rather than explicitly. The format is as follows:
Permit Sheet
General Conditions
Appendix A - Effluent Limitations
Appendix B - Monitoring and Reporting Requirements
Appendix D - Schedule of Compliance
Appendix E - Other Requirements
Appendix F - Best Management Practices
Rationale
Interim and final limits for the main process wastewater discharge
(Appendix A) include limits on conventional, non-conventional, and toxic
-------
III-6
pollutants (metals and orgam'cs). There are four stormwater discharges.
No effluent limits are specified in the permit but monitoring for one year
is required to develop a data base from which effluent limits may be estab-
lished, if necessary.
The General Conditions section contains standard conditions applicable
to all permits. In contrast to the previous permit, most conditions incor-
porate specific regulatory language by reference to state regulations rather
than direclty in the permit. Some State standard conditions may not contain
all the necessary conditions. The omissions may be placed in the Other
Requirements section in such cases.
Appendix B specifies typical monitoring requirements for the main out-
fall and additional short-term monitoring for selected toxic orgam'cs. In
addition, extensive operational monitoring within the wastewater treatment
system is specified, a State requirement.
BMP conditions are contained in Appendix F. Section A contains general
conditions identical to the EPA sample permit. Examples of specific BMP
conditions unique to this facility are contained in Section B.
As shown in Table 3, the format of the sample State permit rationale
is similar to the EPA permit rationale but differs somewhat in lower levels
of subdivision, primarily in the grouping of discussion by pollutant type.
This order more closely tracks the permit development steps in Table 1.
A brief background section is presented to describe the facility and
waste treatment units. A separate inspection report was prepared to pro-
vide more detail in this case.
The next section describes the basis for effluent limits for the main
outfall. In addition to the information presented in the EPA rationale
format, the various supporting documents are listed because they were numerous.
-------
III-7
Table 3
OUTLINE OF RATIONALE - STATE PERMIT
DESCRIPTION OF FACILITY
RATIONALE FOR EFFLUENT LIMITS
1. Location
2. Waste Streams
3. Basis for Limitations
a. Interim Limits
b. Final Limits
4. Effluent Limits
a. Conventional Pollutants
1. BOD
2. TSS
b. Non-Conventional Pollutants
1. COD
2. Phenols
c. Toxic Substances (Priority Pollutants)
d. Hazardous Substances
e. Monitoring Requirements
STORMWATER MONITORING
1. Outfall 002
2. Outfall 003
3. Outfall 004
4. Outfall 005
PRIORITY POLLUTANT MONITORING
-------
III-8
A detailed discussion of the basis for proposed effluent limits for
conventional pollutants then follows. The existing treatment facility re-
quired some improvement to meet BCT limits. The BCT cost test was used to
determine acceptable treatment improvements. The reader is cautioned to
not use the methodology presented in this Rationale for the BCT cost test
without verifying current procedures. The BCT cost test procedure present-
ed was involved in litigation at the time of manual preparation and EPA
anticipated making revisions to the method as a result.
A detailed discussion concerning the selection and limiting of toxic
pollutants is presented next. An approach similar to the other permit is
used to develop a data base for use in determining the need for treatment
improvements to meet BAT limits. Both direct limits on toxic pollutants
and indirect limits using indicator parameters are included in the permit.
There is also the basis for modifying or droping monitoring requirements
for various toxic pollutants.
A major section outlines the basis for control of stormwater monitor-
ing. The bases for specific BMP conditions are also detailed.
-------
SAMPLE EPA PERMIT
-------
Pernit No. CA 0000001
II1-9
DEPARTMENT OF ENVIRONMENTAL CONTROL .
AUTHORIZATION TO DISCHARGE UNDER THE STATE OF CORONADO
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In coinplian.ce with the provisions of the Federal water Pollution Control Act,
as amended (33 U.S.C. '466 et. seq) , the Coronado Environmental Protection Act
(Sees. 81-1505(3) (4) (5) (6) & (7), 81-1504 (15) (25) , 81-1510(2), R.R.S. 1943),
and the Rules and Regulations promulgated pursuant thereto,
Yucatan Electric Company
is authorized to discharge from a facility located at
North 1/2, Section 6, Township 14N, 12E, Mayan County
to receiving waters named
Inca Creek and West Montezuma Creek
in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II, and III hereof.
This permit shall become effective on
This permit and the authorization to discharge shall expire at midnight,
Signed this day of
Director
-------
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PAki il
Page 1 of 12 ni-13
PART II -'
STANDARD CONDITIONS FOR MPDES PERMITS
SECTION A. GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of the Clean Water Act and
is grounds for enforcement action; for permit termination, revocation
and reissuance, or modification; or for denial of a permit renewal
application.
2. Penalties for Violations of Permit Conditions
The Clean Mater Act provides that any person who violates a permit
condition implementing sections 301, 302, 306, 307, 308, 318, or 405 of
the Clean Water Act is subject to a civil penalty not to exceed $100,000
per day of such violation. Any person who willfully or negligently
violates permit conditions implementing sections 301, 302, 306, 307, or
308 of the Clean Water Act is subject to a fine of not less than $2,500
nor more than $25,000 per day of violation, or by imprisonment for not
more than 1 year, or both.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or correct any
adverse impact on the environment resulting from noncompliance with this
permit, including such accelerated or additional monitoring as necessary
to determine the nature and impact of the noncomplying discharge.
4. Permit Actions
This permit may be modified, revoked and reissued, or terminated for
cause including, but not limited to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to
disclose fully all relevant facts; or
c. A change in any condition that requires either a temporary or
permanent reduction or elimination of the authorized discharge.
The filing of a request by the permittee for a permit modification,
revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance, does not stay any permit condition.
-------
5. Toxic Pollutants
Page 2 of 12
Permit No. 111-14
Notwithstanding paragraph A-4, above, if'\aX)to-xic effluent standard or
prohibition (including any schedule of compliance specified in such
effluent standard or prohibition) is established under Section 307(a) of
the Act for a toxic pollutant which is present in the discharge and such
standard'or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit shall be modified or revoked and
reissued to conform to the toxic effluent standard or prohibition and
the permittee so notified.
The permittee shall comply with effluent standards or prohibitions
established under section 307(a) of the Clean Water Act for toxic
pollutants within the time provided in the regulations that establish
those standards or prohibitions, even if the permit has not yet been
modified to incorporate the requirement.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" Section B, Paragraph
B-3 and "Upsets" Section B, Paragraph B-4, nothing in this permit shall
be construed to relieve the permittee from civil or criminal penalties
for noncompliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of
any legal action or relieve the permittee from any responsibilities,
liabilities, or penalties to which the permittee is or may be subject
under Section 311 of the Act.
8. State Laws
Nothing in this permit shall be construed to preclude the institution of
any legal action or relieve the permittee from any responsibilities,
liabilities, or penalties established pursuant to any applicable State
law or regulation under authority preserved by Section 510 of the Act.
9. Property Rights
The issuance of this permit does not convey any property rights of any
sort, or any exclusive privileges, nor does it authorize any injury to
private property or any invasion of,personal rights, nor any infringe-
ment of Federal, State or local laws or regulations.
10. Severabili ty_
The provisions of this permit are severable, and if any provision of
this permit, or the application of any provision of this permit to any
circumstance, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be
affected thereby. '
-------
\
Permit No.
111-15
SECTION B. OPERATION AND MAINTENANCE OF POlLlillWCONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all
facilities and systems of treatment and control (and related appur-
tenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and
maintenance includes effective performance, adequate funding, adequate
operator staffing and training, and adequate laboratory and process
controls, including appropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary facilities or
similar systems only when necessary to achieve compliance with the
conditions of the permit,
2. Duty to Halt or Reduce Activity
Upon reduction, loss, or failure of the treatment facility, the perm-
ittee shall, to the extent necessary to maintain compliance with its
permit, control production or all discharges or both until the facility
is restored or an alternative method of treatment is provided. This
requirement applies, for example, when the primary source of power of
the treatment facility fails or is reduced or lost. It shall not be a
defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain
compliance with the conditions of this permit.
3. Bypass of Treatment Facilities
a. Definitions
(1) "Bypass" means the intentional diversion of waste streams
from any portion of a treatment facility.
(2) "Severe property damage" means substantial physical
damage to property, damage to the treatment facilities
which causes them to become inoperable, or substantial
and permanent loss of natural resources which can reason-
ably be expected to occur in the absence of a bypass.
Severy property damage does not mean economic loss caused
by delays in production.
b. Bypass not exceeding limitations. The permittee may allow any
bypass to occur which does not cause effluent limitations to
be exceeded, but only if it also is for essential maintenance
to assure efficient operation. These bypasses are not subject
to the provisions of paragraphs c and d of this section.
c. Notice
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\\\\ r^
PART II
Page 4 of 12 HI-16
No.
(1) Anticipated bypass. If the p-ermittee knows in advance of
j the need for a bypass, it shall submit prior notice, if j
possible at least ten days before the date of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice
of an unanticipated bypass as required in Section D,
Paragraph D-6 (24-hour notice).
d. Prohibition of bypass.
(1) Bypass is prohibited and the Director may take enforce-
ment action against a permittee for bypass, unless:
(a) Bypass was unavoidable to prevent loss of life,
personal injury, or severe property damage;
(b) There were no feasible alternatives to the bypass,
such as the use of auxiliary treatment facilities,
retention of untreated wastes, or maintenance
during normal periods of equipment downtime. This
condition is not satisfied if the permittee could
have installed adequate backup equipment to prevent
a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(c) The permittee submitted notices as required under
paragraph c of this section.
(2) The Director may approve an anticipated bypass, after
considering its adverse effects, if the Director determines
that it will meet the three conditions listed above in
paragraph d(l) of this section.
4. Upjet Conditions
a. Definition. "Upset" means an exceptional incident in which
there is unintentional and temporary noncompl iance with tech-
nology-based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does
not include noncompliance to the extent caused by operational
error, improperly designed treatment facilities, inadequate
treatment facilities,' lack of preventive maintenance, or
careless or improper operation.
b. Effect of an upset. An upset constitutes an affirmative
defense to an action brought for noncompliance with such
technology-based permit effluent limitations if the require-
ments of paragraph c of this section are met. No determina-
tion made during administrative review of claims that noncom-
pliance was caused by upset, and before an action for noncom-
pl iance, is final administrative action subject to judicial
review.
-------
PART II
Page 5 of 12 111-17
Permit No.
c. Conditions necessary for a demonstration of upset. A per-
mittee who wishes to establish the affirmative defense of
upset shall demonstrate, through properly signed, contem-
poraneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the
specific cause(s) of the upset;
(2) The permitted facility was at the time being properly
operated; and
(3) The permittee submitted notice of the upset as required
in Section D, Paragraph D-6.
(4) The permittee complied with any remedial measures re-
quired under Section A, Paragraph A-3.
d. Burden of proof. In any enforcement proceeding the permittee
seeking to establish the occurrence of an upset has the burden
of proof.
Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the
course of treatment or control of wastewaters shall be disposed of in a
manner such as to prevent any pollutant from such materials from enter-
ing navigable waters.
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PART II
Page 6 of
Permit No.
SECTION C. MONITORING AND RECORDS
1. Representative Sampling
Samples'and measurements taken as required herein shall be representa-
tive of the volume and nature of the monitored discharge. All samples
shall be taken at the monitoring points specified in this permit and,
unless otherwise specified, before the effluent joins or is diluted by
any other wastestream, body of water, or substance. Monitoring points
shall not be changed without notification to and the approval of the
Director.
2. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to insure the accuracy and
reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to insure that the
accuracy of the measurements are consistent with the accepted capability
of that type of device. Devices selected shall be capable of measuring
flows with a maximum deviation of less than +_ 10% from true discharge rates
throughout the range of expected discharge volumes. Guidance in selection,
installation, calibration and operation of acceptable flow measurement
devices can be obtained from the following references:
1. "A Guide to Methods and Standards for the Measurement of Water
Flow", U. S>. Department of Commerce, National Bureau of Standards,
MBS Special Publication 421, May 1975, 97 pp. (Available from the
U. S. Government Printing Office, Washington, D. C. 20402. Order
by SD catalog No. Cl3.10:421).
2. "Water Measurement Manual", U. S. Department of Interior, Bureau
of Reclamation, Second Edition, Revised Reprint, 1974, 327 pp.
(Available from the U. S. Government Printing Office, Washington,
D. C. 20402. Order by Catalog Mo. I27.19/2:W29/2, Stock NorS/N
24003-0027.)
3. "Flow Measurement in Open Channels and Closed Conduits, U. S.
Department of Commerce, National Bureau of Standards, NBS Special
Publication 484, October 1977, 982 pp. (Available in paper copy or
microfiche from National Technical Information Service (NTIS),
Springfield, VA 22151. Order by NTIS No. PB-273 535/5ST.
4. "NPDES Compliance Sampling Manual", U. S. Environmental Protection
Agency, Office of Water Enforcement, Publication MCD-51,» 1977,
140 pp. (Available from the General Services Administration (8FFS),
Centralized Mailing Lists Services, Building 41, Denver Federal
Center, Denver, CO 80225.
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[jfim.orr
Page 7 of 12
Permit No.
111-19
3. Monitoring Procedures
Monitoring must be conducted according to test procedures approved under
40 CFR Part 136, unless other test procedures have been specified in
this permit.
/
4. Penalties for Tampering
The Clean VJater Act provides that any person who falsifies, tampers
with, or knowingly renders inaccurate, any monitoring device or method
required to be maintained under this permit shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by im-
prisonment for not more than 6 months per violation, or by both.
5. Reporting of Monitoring Results
Monitoring results must be reported on a Discharge Monitoring Report
(DMR) form (EPA No. 3320-1). Monitoring results obtained during the
previous months shall be summarized for each month and reported on a
DMR form postmarked no later than the 28th day of the month following
the completed reporting period. The first report is due on
Duplicate copies of DMR's signed and certified as required by Section D,
Paragraph D-ll, and all other reports required by Section-D, Reporting
Requirements, shall be submitted to the Regional Administrator and the
State at the following addresses:
6. Additional Monitoring by the Permittee
If the permittee monitors any pollutant more frequently than required by
this permit, using test procedures approved under 40 CFR 136 or as
specified in this permit, the results of this monitoring shall be in-
cluded in the calculation and reporting of the data submitted in the
DMR. Such increased frequency shall also be indicated.
7. Averaging of Measurements
Calculations for all limitations which require averaging of measurements
shall utilize an arithmetic mean unless otherwise specified by the
Director in the permit.
8. Retention of Records
The permittee shall retain records of all monitoring information,
including all calibration and maintenance records and all original strip
chart recordings for continuous monitoring instrumentation, copies of
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I'/IM li
Page 8 of 12
Permit No.
all reports required by this permit, and records of all data used to
complete the application for this permit, for a period of at least
3 years from the date of the sample, measurement, report or application.
This period may be extended by request of the Director at any time.
*\ s
9. Record Contents VAN
Records of monitoring information shall include: -~\\Vo>v
W^
a. The date, exact place, time and methods of sampling or mea-
surements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used: and
f. The results of such analyses.
10. Inspection and Entry
The permittee shall allow the Director, or an authorized representative,
upon the presentation of credentials and other documents as may be
required by law, to:
a. Enter upon the permittee's premises where a regulated facility
or activity is located or conducted, or where records must be
kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that
must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations
regulated or required under this permit, and
d.- Sample or monitor at reasonable times, for the purposes of
assuring permit compliance or as otherwise authorized by the
Clean Water Act, any substances or parameters at any location.
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PART II
Page 9 of 12 m-21
Permit No.
SECTION D. REPORTING REQUIREMENTS \ r. • '. - j -0 < \j
X-.J--.!-'^ J '
1 . Planned Changes '—'
The permittee shall give notice to the Director as soon as possible of
any planned physical alternations or additions to the permitted facility.
2. Anticipated Npncomp'1 iance
The permittee shall give advance notice to the Director of any planned
changes in the permitted facility or activity which may result in non-
compliance with permit requirements.
3. Transfers
This permit is nontransferable to any person except after notice to the
Director. The Director may require modification or revocation and reis-
suance of the permit to change the name of the permittee and incorporate
such other requirements as may be necessary under the Clean Water Act.
4. Monitoring Reports
Monitoring results shall be reported at the intervals and in the form
specified in Section C, Paragraph C-5 (Monitoring).
5. Compliance Schedules_
Reports of compliance or noncompliance with, or any progress reports on,
interim and final requirements contained in any compliance schedule of
this permit shall be submitted no later than 14 days following each sched-
ule date. Any reports of noncompliance shall include the cause of non-
compliance, any remedial actions taken, and the probability of meeting the
next scheduled requirement.
6- Twenty-Four Hour Reporting
The permittee shall report any noncompliance which may endanger health
or the environment. Any information shall be provided orally within 24
hours from the time the permittee becomes aware of the circumstances. A
written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall
contain a description of the noncompliance and its cause; the period of non-
compliance, including exact dates and times, and if the noncompliance has
not been corrected, the anticipated time it is expected to continue; and
steps taken or planned to reduce, eliminate, and prevent reoccurrence of
the noncompl iance. The Director may waive the written report on a case-by-case
basis if the oral report has been received within 24 hours.
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li^^tt
PART II
Page 10 of 1311-22
Permit No.
The follovn'ng shall be included as information which must be reported
within 24 hours:
a. Any unanticipated bypass which exceeds any effluent limitation
in the permit.
t
b. Any upset which exceeds any effluent limitation in the permit.
c. Violation of a maximum daily discharge limitation for any of
the pollutants listed by the Director in Part I of the permit
to be reported within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under
Section D, Paragraphs D-l, D-4, D-5, and D-6 at the time monitoring reports
are submitted. The reports shall contain the information listed in Paragraph
D-6.
8. Changes in Discharges of Toxic Substances
The permittee shall notify the Director as soon as it knows or has reason
to believe:
a. That any activity has occurred or will occur which would result
in the discharge of any toxic pollutant which is not limited in
the permit, if that discharge will exceed the highest of the fol-
lowing "notification levels:" \
(1) One hundred micrograms per liter (100 yg/1);
(2) Two hundred micrograms per liter (200 yg/1) for acrolein
and acrylonitrile; five hundred micrograms per liter (500
yg/1) for 2.4-dinitrophenol and for 2-methyl-4)6-dinitrophenol;
and one milligram per liter (1 mg/1) for antimony:
(3) Five (5) times the maximum concentration value reported
for that pollutant in the permit application;
(4) The level established in Part I Of the permit by the
Director.
b. That they have begun or expect to begin to use or manufacture
as an intermediate or final product or byproduct any toxic pol-
lutant which was not reported in the permit application.
9. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time,
any information which the Director may request to determine whether cause
exists for modifying, revoking and reissuing, or terminating this permit,
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PAiU II
or to determine compliance with this permit. The permittee shall also
furnish to the Director, upon request, copies of records required to be
kept by this permit.
10. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit
after the expiration date of this permit, the permittee must apply for
and obtain a new permit. The application should be submitted at least
180 days before the expiration date of this permit. The Director may
grant permission to submit an application less than 180 days in advance
but no later than the permit expiration date.
11 . Signatory Requirements
All applications, reports or information submitted to the Director shall
be signed and certified.
a. All permit applications shall be signed as follows:
(1) For a corporation: by a principal executive officer of at
least the level of vice-president;
(2) For a partnership or sole proprietorship: by a general
partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency:
by either a principal executive officer or ranking elected
official.
b. All reports required by the permit and other information re-
quested by the Director shall be signed by a person described
above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described
above.
(2) The authorization specified either an individual or a
position having responsibility for the overall operation of
the regulated .facility or activity, such as the position of
plant manager, operator of a well or a well field, super-
intendent, or position of equivalent responsibility. (A
duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) Certification. Any person signing a document under this
section shall make the following certification:
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PART II
Page 12 of 12 HI-24
Permit No.
"I certify under penalty of law that I have personally
examined and am familiar with the information submitted
in this document and all attachments and that, based on
my inquiry of those individuals immediately responsible
for obtaining the information, I believe that the infor-
mation is true, accurate, and complete. I am aware that
there are significant penalties for submitting false
information, including the possibility of fine and im-
prisonment."
12. Availability of Reports
Except for data determined to be confidential under 40 CFR Part 2, all
reports prepared in accordance with the terms of this permit shall be
available for public inspection at the offices of the State water pollu-
tion control agency and the Regional Administrator. As required by the
Act, permit applications, permits and effluent data shall not be consid-
ered confidential.
13. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false
statement, representation, or certification in any record or other document
submitted or required to be maintained under this permit, including monitor-
ing reports or reports of compliance or noncompliance shall, upon conviction,
be punished by a f.ine of not more than $10,000 per violation, or by impris-
onment for not more than 6 months per violation, or by both.
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PART III
Page 1 of 1 111-25
Permit Mo. CA0000001
PART III
OTHER REQUIREMENTS
1. Yucatan Electric shall analyze discharge 001 and 002 for phenols
and fluorides once a month for the first 6 months following permit
issuance.
2. The results of each analysis shall be reported to the Director
every quarter along with the Discharge Monitoring Reports.
3. After 6 months of monitoring Yucatan Electric shall submit a report
to the Director evaluating the data. This report shall indicate
what, if any, treatment improvements will be needed to meet final
effluent limits and shall propose a schedule leading to compliance
by July 1, 1984.
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PART IV
Page 1 of 3 111-26
Permit No.
\ U M. • .. v'-- - '
PART "IV
STANDARD BEST MANAGEMENT PRACTICES CONDITIONS
SECTION A. GENERAL CONDITIONS
1. Applicability
These conditions apply to all permittees who use, manufacture,
store, handle or discharge any pollutant listed as toxic under Section
307(a)(l) of the Clean Water Act or any pollutant listed as hazardous
under Section 311 of the Act and who have ancillary manufacturing operations
which could result in significant amounts of these pollutants reaching
waters of the United States. These operations include material storage
areas; plant site runoff; in-plant transfer, process and material handling
areas; loading and unloading operations, and sludge and waste disposal
areas.
2. BMP Plan
The permittee shall develop and implement a Best Management Practices
(BMP) plan which prevents, or minimizes the potential for, the release
of toxic substances from ancillary activities to the waters of the
United States through plant site runoff; spillage or leaks; sludge or
waste disposal; or drainage from raw material storage.
3. Implementation
The plan shall be developed within six months of the permit applica-
tion and shall be implemented as soon as practicable but not later than
one year after the effective date of the permit or 18 months after the
permit application, whichever is sooner, unless a later date is specified
by the Director.
4. General Requirements
The BMP plan shall:
a. Be documented in narrative form, and shall include any necessary
plot plans, drawings or maps.
b. Establish specific objectives for the control of toxic and
hazardous pollutants.
(1) Each facility component or system shall be examined for
its potential for causing a release of significant amounts
of toxic or hazardous pollutants to waters of the United
States due to equipment failure, improper operation, nat-
ural phenomena such as rain or snowfall, etc.
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PART IV
- - -•_•;• Page 2 of 3 m u
\\-- '• i v- \ - ' ', Permit No.
'•'
•' ,
(2) Where experience indicates a reasonable potential for
equipment failure (e.g., a tank overflow or leakage),
natural condition (e.g., precipitation), or other circum-
stances to result in significant amounts of toxic or haz-
ardous pollutants reaching surface waters, the plan should
include a prediction of the direction, rate of flow and
total quantity of toxic or hazardous pollutants which could
be discharged from the facility as a result of each condition
or circumstance.
c. Establish specific best management practices to meet the objec-
tives identified under paragraph b of this section, addressing
each component or system capable of causing a release of sig-
nificant amounts of toxic or hazardous pollutants to the waters of
the United States.
d. Include any special conditions established in Part B of this sec-
tion.
e. Be reviewed by plant engineering staff and the plant manager.
5. Specific Requirements
The plan shall be consistent with the general guidance contained in
the publication entitled "NPDES Best Management Practices Guidance Docu-
ment" and shall include the following base line BMP's as a minimum:
a. BMP Committee
b. Reporting of BMP Incidents
c. Risk Identification and Assessment
d. Employee Training
e. Inspections and Records
f. Preventive Maintenance
g. Good Housekeeping
h. Materials Compatibility
i. Security
6. SPCC Plans
The BMP plan may reflect requirements for Spill Prevention Control and
Countermeasure (SPCC) plans under section 311 of the Act and 40 CFR Part 151,
and may incorporate any part of such plans into the BMP plan by reference.
7. Hazardous Waste Management
The permittee shall assure the proper management of solid and hazard-
ous waste in accordance with regulations promulgated under the Solid Waste
Disposal Act, as amended by the Resource Conservation and Recovery Act of
1978 (RCRA) (40 U.S.C. 6901 et seq). Management practices required under
RCRA regulations shall be referenced in the BMP plan.
8. Documentation
The permittee shall maintain a description of the BMP plan at the
facility and shall make the plan available to the Director upon request.
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PART IV
Page 3 of 3111-28
— ,-•-• Permit No.
n11 ; •• •
ii !
L-s L; •- -
9. BMP Plan Modification
The permittee shall amend the BMP plan whenever there is a change
in the facility or change in the operation of the facility which materially
increases the potential for the ancillary activities to result in a dis-
charge of significant amounts of hazardous or toxic pollutants.
10. Modification for Ineffectiveness
If the BMP plan proves to be ineffective in achieving the general
objective of preventing the release of significant amounts of toxic or
hazardous pollutants to surface waters and the specific objectives and
requirements under paragraphs b and c of Section 4, the permit and/or
the BMP plan shall be subject to modification to incorporate revised BMP
requirements.
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SAMPLE RATIONALE FOR EPA PERMIT
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111-29
RATIONALE FOR PERMIT CONDITIONS
AND EFFLUENT LIMITS
YUCATAN ELECTRIC
AZTEC, CORONADO
PERMIT NO. CA0000001
I. DESCRIPTION OF FACILITY
A. Background
The Yucatan Electric Aztec Works began operations in 1957 on a 340
acre site in Aztec, Coronado. The plant currently employs around 4000
people and produces telephone and telegraph apparatus, including switch-
ing gear, and insulated non-ferrous wire and cable.
Two wastewater discharges result from the Aztec operations, one to
Inca Creek and the other to West Montezuma Creek. The West Montezuma
Creek discharge consists of relatively low contamination water such as
boiler blowdown and cooling tower blowdown. The Inca Creek discharge
consists of process waste after treatment in a physical - chemical waste
treatment plant. Both discharges are governed by a Coronado NPDES
permit (CA0000001).
The Aztec Works operates solely for the Drum System. Production is
divided between two buildings, the "Cable Building" and the "Apparatus
Building". The "Cable Building" houses tin plating and wire coating
operations. The wastes resulting from the tinning operation include
cleaning wastes, some plating rinse waters, and waste collected in floor
drains. The cleaning wastes are pumped to the acid-alkali tank at the
waste treatment plant. The rinse waters and floor drainage are pumped
to the miscellaneous waste tank before treatment.
Wire coating involves the application of polyethylene, polypro-
pylene, and/or PVC coatings to copper wire or plated wire using an
extrusion process. Certain insulating and weatherproofing sheaths
-------
111-30
are also applied to cables in this area. The water used to cool the
cables after coating is part of the cooling water system and is recircu-
lated back into the system; there is no discharge.
The "Apparatus Building" houses the apparatus operations (assembly
of switch gear, connectors, etc.), sheet metal fabrication, central
storage and maintenance, and various plating operations (gold, zinc,
chrome, copper, nickel, solder). The majority of the apparatus opera-
tions are dry, but a small amount of recirculated cooling water may be
used in plastic molding work. Metal cabinets and various other metal
pieces are fabricated in the Apparatus Building. The only discharge
from metal fabrication is an alkali rinse of the finished parts which is
routed to the acid-alkali tank at the waste treatment plant.
The plating operations in the "Apparatus Building" generate the
majority of the wastewater handled at the Aztec Works. Each of the
plating operations results in two waste streams, a cleaning rinse and a
plating rinse. Gold is deposited on connectors using a cyanide bath in
the Precious Metal Plater. An acid cleaning rinse and cyanide plating
rinse result from the Precious Metal plating. A Square Wire Plater
deposits copper and solder on wire resulting in an alkaline waste
stream. Chrome, nickel and zinc automatic platers and barrel platers
are used for plating a variety of metal parts. The waste streams from
each of these operations are sent to the appropriate section of the
waste treatment system. Waste from a chromate coating facility is
pumped to the chrome treatment system.
A drum storage area and receiving dock are located in the "Apparatus
Building". Drums of hazardous wastes, such as spent plating solutions,
are stored in an enclosed area along with empty drums and scrap metal,
awaiting shipment. Chemicals, plastics, and miscellaneous items are
received and stored in the "Apparatus Building". According to Company
personnel all unplugged floor drains in the-building drain to the waste
treatment plant.
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111-31
B. Haste Treatment
Wastewaters from the Aztec Works are segregated into six streams:
chrome wastes, cyanide wastes, acid alkali wastes, floor drain wastes,
miscellaneous wastes (including tin plating wastes), and noncontact
wastes. All but the noncontact wastes are treated in a physical chemical
treatment plant and are discharged through Outfall 001. The "noncontact
waters" are discharged through Outfall 002.
1. Outfall 001-Inca Creek Discharge
Outfall 001, to Inca Creek, handles the effluent from the 450
gpm treatment plant. The waste is segregated into five streams
each receiving a particular treatment [Figure 1] before being
combined in a flume prior to solids removal [Figure 2].
a. Miscellaneous Wastes Tank
Wastes from the Central Tin Plater and Strip Plater in
the Cable Building are collected in the miscellaneous waste
tank. From here depending on the nature of the waste, it can
be routed to the chrome or cyanide system for treatment.
b. Acid-Alkali Surge Tank
Dilute acid-alkali plating wastes and metered amounts of
spent strong acids are collected in the acid-alkali surge
tank. The pH is adjusted to 5-6 by automatic feed of lime
slurry (NaOH) or sulfuric acid (FLSO,). The waste is pumped
from this tank to a flume preceeding the solids removal
system.
c. Cyanide Surge Tank
Alkaline rinse waters, with cyanide contamination, are
collected in the cyanide surge tank. As the waste leaves the
tank NaOH is added to maintain the pH at about 10, and chlorine
-------
111-32
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-------
111-34
gas is injected to oxidize the cyanide. The waste is pumped
to a cyanide destruction tank where more chlorine can be
added, if necessary to oxidize remaining cyanide. The treated
waste combines with the acid alkali stream in the flume
preceeding solids removal.
d. Interceptor Tank
Strong alkali waste and waste collected in the floor
drains of the plating room combine in the interceptor tank.
NaOH is automatically fed to this tank to maintain a pH of 9.
The waste is sampled to determine the contaminants (chromium
or cyanide). If only one contaminant is present the waste is
sent to the appropriate system. If more than one contaminant
is present, batch treatment for specific contaminants is used
in the tank before the waste is delivered to the solids removal
flume.
e. Chrome Surge Tank
Chrome wastes from the plating room are collected in the
chrome surge tank before passing through a sulfonator, where
S02 is injected to reduce the chrome from the hexavalent to
the trivalent state. The waste is held in a chrome reduction
tank for 1 hour before combining with the other wastes in the
solids removal flume.
f. Solids Removal System
Treated acid-alkali, cyanide, chrome, and miscellaneous
wastes combine in a flume which flows into a Rapid Mix Tank
(Figure 2). Lime slurry or sulfuric acid are added to the
Rapid Mix Tank to adjust the pH to about 8.5, and ferric
sulfate .is added to aid in precipitation.
From the Rapid Mix Tank the neutralized wastes pass
through an Aeration Tank where ferrous iron is oxidized to
ferric iron for improved settling. The waste then flows
through a trough or Deaeration Tank into a High Rate Settling Unit
-------
111-35
In this unit a polyelectrolyte is added to aid settling and
sludge is removed from the bottom while clean water flows out
the top. The effluent flows through a pH adjustment tank and
out to Inca Creek (Outfall 001). Two 150,000 gallon diversion
tanks can be used in the case of an upset.
2. Outfall 002-Montezuma Creek Discharge
All "noncontact waters", consisting primarily of cooling tower
and boiler blowdowns, are discharged through Outfall 002. This
waste stream receives no treatment other than neutralization of the
boiler blowdown.
C. Hater Quality Standards
Inca Creek and West Montezuma Creek are both classified for agri-
culture use, industrial use, partial body contact sports, and growth and
propagation of fish, waterfowl, wildlife and other aquatic and semi-
aquatic life.
II. RATIONALE FOR EFFLUENT LIMITS
The Clean Water Act (CWA) specifies that industrial waste dis-
chargers are to achieve effluent limitations based on regulations
promulgated by EPA. The effluent limitations are to be established
using proven treatment technology. Initially dischargers were to meet
effluent limits requiring Best Practicable Control Technology Currently
Available (BPT) by July 1, 1977. The CWA (amended in 1977) required
that dischargers obtain effluent quality equivalent to the Best Avail-
able Technology Economically Achievable (BAT) by July 1, 1984. BAT
effluent limits apply to toxic pollutants as well as conventional
pollutants, (BOD, TSS, pH, oil and grease, and fecal coliform) and non-
conventional pollutants.
EPA has not promulgated BPT or BAT guidelines for the Metal Finish-
ing (electropolating) industry. The "Development Document for Metal
Finishing", promulgated in June 1980, presents treatment options for
-------
111-36
each subcategory within the Metal Finishing industry, but does not
establish BPT or BAT effluent limits. Specific limitations are expected
to be proposed in the summer of 1981. The Yucatan Electric, Aztec Works
are included in the common metals, cyanide, hexavalent chromium, and
oils and organics subcategories.
The Development Document presents treatment options for each
subcategory. The Effluent Guidelines staff anticipates that Treatment
Option 1, for the common metals and oils and organics subcategories,
will represent BPT, and Option 2 will represent BAT. Option 2 consists
of Option 1, precipitation and sedimentation, followed by filtration.
The Consolidated Permit Regulations (40 CFR Part 122) provide that in
the absence of effluent guidelines, permit conditions may be established
using Best Professional Judgment (BPJ) [40 CFR 122.62(a)]. Using BPJ
procedures the permit writer may use a variety of technical information
available to him. Discharge limitations proposed in this permit are
established using BPO procedures and are based on the 1980 Development
Document.
A. Outfall 001-Inca Creek
1. Location
Sampling of this outfall shall be performed at a point follow-
ing the wastewater treatment plant and prior to discharge to Inca
Creek.
2. Waste Streams
The wastes in this discharge, as reported in the application,
consist of:
a. 114,200 gpd electroplating wastes from zinc, nickel,
chromium, copper, solder, gold, tin, and anodizing
plating operations.
-------
111-37
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111-38
b. 38,500 gpd from cleaning, chromating, and phosphating for
powder finishing.
c. 72,000 gpd miscellaneous wastes from the Apparatus
Building including cooling water, leaks, drinking foun-
tains, etc.
d. 1,000,000 gpd storm water (maximum)
3. Basis for Effluent Limits
a. Background
Interim and Final effluent limitations for Outfall 001
are based on the treatment levels presented in the June 1980
Development Document for the Metal Finishing industry.
Option 1 treatment is considered to be BPT level treatment and
Option 2 is used as BAT level treatment. Limitations for
metals, TSS, fluoride, oils and toxic organics are discussed
below.
b. Metals and TSS
The effluent limitations proposed in the permit for
metals and TSS (Table I) are based on the treatment levels
presented for Option 2 in the Development Document. Cyanide
limits are based on chlorine oxidation treatment, and chromium
limits are based on chemical reduction as discussed in the
Development Document.
Concentration limits presented in the guideline document,
and an average flow of 0.23 MGD were used to establish mass
loadings for outfall 001. Effluent data for 1979-1980 indi-
cates that the Aztec Works can meet the proposed limits for
metals with present operating procedures, therefore the
interim limits are equivalent to the final limits.
-------
111-39
c. Fluoride
Yucatan Electric uses fluoroborate plating solutions in
several of the plating operations resulting in fluorides in
the discharge. The proposed permit establishes final average
and maximum fluoride limitations of 6.19 mg/1 and 13.8 mg/1,
respectively (Table I). These limitations are based on
treatability levels established under treatment Option 2 for
the Common Metals subcategory in the 1980 Development Document.
Data presented in the Yucatan Electric NPDES permit
application shows fluoride concentrations of 12.8 mg/1 in
Outfall 001. Additional testing performed in March 1981
showed a fluoride concentration of 11.5 mg/1. These con-
centrations, although below the proposed maximum of 13.8 mg/1,
suggest that the average discharge of fluoride is above the
proposed average limitation of 6.19 mg/1. The permit requires
additional monitoring to supplement the available data which
consists of only two samples. Interim limits of 19.9 mg/1-
average, and 44.4 mg/1-maximum were established based on
Option 1 treatment which represents BPT. Time is allowed to
evaluate the fluoride discharge and institute appropriate
treatment if necessary.
It may be necessary to add treatment to precipitate out
the fluoride. This treatment may be accomplished in the waste
treatment plant or on the individual fluoride process streams
before they mix in the solids removal flume.
d. Oils & Toxic Orgam'cs
Oily wastes and toxic organics include process coolants,
lubricants, and cleaning wastes. The proposed concentration
limits are based on levels established in the Oils subcategory
for Common Metals combined wastewater. Both Option 1 and
Option 2 treatment systems are considered.
-------
111-40
(1) Oil and Grease
The Option 2 treatment level was used to establish
the oil and grease limitation proposed in the permit
(Table I). Data presented in the NPDES application shows
4.0 mg/1 oil and grease in the 001 discharge, well within
the proposed average of 9.2 mg/1.
(2) Total Toxic Organics (TTO)
The Metal Finishing Development Document identifies
95 toxic organic pollutants of concern in the Common
Metals subcategory. Of these 95, the 5 listed below were
reported at detectable levels in the permit application
for the effluent from Yucatan Electric's treatment plant
(Outfall 001). However, an additional sample collected
in March 1981 showed no detectable (ND) quantity of any
parameter but phenols.
Application March
(mg/1) (mg/1)*
phenols 0.275 <0.1
1,1,1-trichloroethane 0.027 ND
1,2-trans-dichloroethylene 0.044 ND
methylene chloride 0.012 ND
trichloroethylene 0.007 ND
TTO 0.365 <0.1
EGD indicates that final effluent guidelines for the
Metal Finishing industry will establish target concen-
trations for Total Toxic Organics (TTO) around 0.01 mg/1
average concentration and 0.60 mg/1 maximum concentration.
The intent is to use these concentrations as target
levels and not to establish effluent limits.
*Detection limit for phenols is 0.1 mg/1. Detection limit for all
other parameters was 1 ug/1.
-------
111-41
Yucatan Electric's data show that the TTO in the
effluent are below the daily maximum, but exceed the
target average concentration. Phenols are the major
component of the toxic organics found, and recent efforts
by the company to locate the source of these have failed.
The permit requires monthly monitoring for phenols
for the first 6 months, and quarterly monitoring there-
after. If the data indicate that the discharge of
phenols averages less than 0.01 mg/1, no action is required.
However, if the data show phenol discharges greater than
0.01 mg/1 average, the company is required to take steps
to identify the source of the phenols and reduce the
amount being discharged.
Final effluent limits for phenols are set at 0.10
mg/1 for the average and 0.60 mg/1 for the daily maximum.
There are no interim limits.
Monitoring for Total Toxic Organics is required once
a year. This analysis shall include all parameters
listed in Part V-C of the NPDES permit application under
the GC/MS fractions for Volatile, Acid, and Base/Neutral
compounds. This monitoring will serve as an indication
that the company is maintaining control of their toxics
discharges. There are no effluent limitations for TTO.
e. Hazardous Substances
The Clean Water Act, Section 311, requires that EPA
develop a list of substances which when discharged are
hazardous to the public health or welfare. EPA promul-
gated the list of hazardous substances, 40 CFR 116, and
established reportable quantities and notification
-------
111-42
requirements for each substance, 40 CFR 117. The regu-
lations require that if a hazardous substance is dis-
charged in amounts greater than the reportable quantity
the government shall be notified. An exemption from
Section 311 requirements can be granted if the substance,
amount and origin of the discharge are documented in the
public record of the NPDES permit, and the substance is
subject to a condition in the permit.
Yucatan Electric, in the NPDES application, listed
22 Hazardous Substances for which they are requesting an
exemption from section 311 requirements. Table II lists
each substance, the amount used, the reportable quantity
under 40 CFR 117, and the origin and source of each.
Chlorine, sodium cyanide, and sulfuric acid are the only
substances used in quantities greater than the reportable
quantities.
To grant a 311 exemption of these hazardous sub-
stances it is necessary to establish a permit condition
governing their discharge. In this case certain permit
parameters are used as indicators of the presence of the
substance in the discharge (Outfall 001).
The last column of Table II lists the indicator
permit parameter for each substance. Metals or pH are
used as indicators for all substances but chlorine.
Chlorine is the only hazardous substance for which
specific monitoring is required. The residual chlorine
limitation of 0.01 mg/1 in Outfall 001 is based on Water
Quality Criteria published by EPA.
-------
111-43
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111-45
B. Outfall 002-West Montezuma Creek
1. Location
Sampling of this outfall shall be performed at an existing
manhole prior to discharge to West Montezuma Creek.
2. Waste Streams
The wastes in this discharge, as reported in the application,
consist of:
a. 154,700 gpd cooling tower recirculating system blowdown
b. 60,000 gpd boiler blowdown
c. 57,000 gpd miscellaneous wastes from the Cable Building
including cooling water, leaks, drinking fountains, etc.
d. 1,000,000 gpd stormwater (maximum)
3. Basis for Effluent Limits
The effluent limitations for Outfall 002 (Table III) are based
on information reported in the application, and the June 1980
Development Document for Metal Finishers as discussed for Outfall
001. The mass loadings are based on an average flow of 0.26 MGD.
a. Metals
The proposed permit establishes discharge limitations and
monitoring requirements for 4 toxic metals; copper, chromium,
nickel, and zinc. Monitoring of these parameters is required
to ensure that no contaminants enter the discharge through the
cooling water, spills, leaks, plant upsets, etc.
-------
111-46
b. Fluoride
Fluoroborate plating solutions are used in several
operations, and fluoride monitoring is required to detect if
any solution is carried over into the cooling water. Also, a
fluoroborate solution is used in the Central Tin Plater,
located in the Cable Building, and monitoring will detect if
any spills, or leaks from this operation enter the floor
drainage to Outfall 002.
c. Oils and Toxic Organics
(1) Oil and Grease
Oil and grease limitations are based on information
presented in the Development Document. Application data
indicates that the discharge from 002, 3.3 mg/1, is
within the proposed average limitation of 9.2 mg/1.
(2) Total Toxic Organics (TTQ)
Yucatan Electric in the permit application reported
the following 4 toxic organics present in detectable
quantities in Outfall 002. However, only phenols were
detected in the March 1981 sampling.
Application March
(mg/1) (mg/1)
phenols 0.360 <0.1
1,1,1-trichloroethane 0.006 ND
1,1-dichloroethane 0.004 ND
methylene chloride 0.012 ND
TTO 0.382 <0.1
The monitoring requirements for toxic organics at
Outfall 002 are the same as those for Outfall 001.
Monthly monitoring for phenols is required for 6
-------
111-47
months, after which the frequency is decreased to quarterly.
The monitoring data will be used to evaluate the need for
further investigation of the phenols in the discharge.
Final limits of 0.10 mg/1 and 0.60 mg/1 are to be effective
in July, 1984. Total Toxic Organic monitoring is required
on a yearly basis.
d. p_H
YucatanElectric has experienced problems in main-
taining a pH below 9 in this discharge because of high pH
of the water supplied to them by the Metropolitan Utilities
District (MUD). To account for this the permit requires
monitoring of the influent and the maximum pH limit is
adjusted to this value.
III. MONITORING REQUIREMENTS
Yucatan Electric currently is required to monitor monthly, however;
because of the variability possible in the processes it was decided that
more frequent monitoring is needed. Weekly monitoring is required for
metals, TSS, Oil and Grease and Fluorides to give a better indication of
plant upsets and variations in effluent quality.
Monitoring for specific phenols and fluorides is required once a
month for 6 months in order to establish a data base. After 6 months an
evaluation shall be made as to the need for continued monitoring and/or
additional treatment. Quarterly monitoring is required after the first
6 months for phenols and fluorides, and yearly monitoring is required
for TTO.
-------
111-48
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SAMPLE STATE PERMIT
-------
IOWA DEPARTMENT OF ENVIRONMENTAL QUALITY
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
OPERATION PERMIT
TO DISCHARGE INTO THE WATERS OF DUNE
PERMITTEE IDENTITY AND LOCATION OF FACILITY
Universe Company Universe Company
Post Office Box 819 Facility No. 23-26
Caladan, Dune Arrakan, Dune
DUNE NPDES PERMIT NUMBER RECEIVING WATERCOURSE
23-26-1-12 Usul Creek and the Uncompahqre
River
DATE OF ISSUANCE
DATE OF EXPIRATION
You are required to file for renewal of this permit by
This permit is issued pursuant to the authority of section 402(b) of the Clean
Water Act (33 U.S.C. 1342(bj), section 455B.33, Code of Dune 1977, and rule
400—19.3, Dune Administrative Code. You are authorized to operate the disposal
system and to discharge the pollutants specified in this permit in accordance
with the effluent limitations, monitoring requirements and other terms set forth
in this permit.
You may appeal any conditions of this permit by filing a written notice of appeal
and request for administrative hearing with the executive director of this depart-
ment within 30 days of your receipt of this permit. (See section 4558.33(4), Code
of Dune 1977 and rules 400—24.12(4) and (5), Dune Administrative Code.)
Any existing, unexpired Dune operation permit or Dune NPDES permit previously issued
by the Dune Department of Environmental Quality for the facility identified
above is revoked by the issuance of this Dune NPDES operation permit.
OUTFALL SERIAL NO. DESCRIPTION
001 Outfall from the final polishing pond receiving treated process
wastewaters from a completely mixed activated sludge plant and
settled stormwater runoff.
002 Stormwater discharge at the "large pellet pond" on the east
side of the plant by the rail scales.
003 Stormwater discharge at the "small pellet pond" on the east
side of the plant near the polyethylene loading area.
004 The storm water discharge pipe from the "southwest drainage
ponds" north of the large ethylene storage tank.
005 The storm water discharge pipe from the "flare drainage
pond" west of the fTare area.
-------
! .."• , ' 111-50
GENERAL CONDITIONS JJJJ jj.:''. / ;_ ' ! ,J
1. ADMINISTRATIVE RULES
Rules of this department which govern your facility operation in connection
with this permit are published in part ^00 of the Dune Administrative Code
~ in the following chapters, which are attached to this permit and made a part
of th is permi t.
Chapter 15, Definitions (as used in Chapters Mo--through 19j .
Chapter 17, Effluent and Pretreatrr^snt Standards; Other Effluent Limitations
or P rohi b i t ions .
Chapter 18, Monitoring, Analytical and Reporting Requirements.
Chapter 13, Waste Water Construction and Operation Permits.
Reference to the term "rule" is this permit means the designated provision of
Part ^00, Dune Administrative Code.
2. NOTICE OF CHANGED CONDITIONS
You are required to report.any changes 'in existing conditions or information
on which this permit is based.
(a) Facility expansions, production increases or process modifications which
may result in new or increased discharges of pollutants must be reported
to the executive director in advance. If such discharges would violate
your effluent limitations, your report must include a new application for
NPDES permit. (See rule 19-5 (5)"a''.)
(b) If any modification of, addition to, or construction of a disposal system
is to be made, you must first obtain a written permit from this.departroen
in accordance with rule 19-2.
(c) If your facility is a publicly owned treatment works or otherwise may
accept waste for treatment from commercial or industrial cons t r i butors,
see Appendix C for further notice requirements.
3. PERMIT MODIFICATION, SUSPENSION OR REVOCATION
(a) This permit may be modified, suspended or revoked for causes specified
in rule 19.3(11)•
-------
111-51
(b) This permit may be nodified due to changed conditions or i rfforrna t ion en
which this permit is based.
(c) If a toxic pollutant is present in your discharge and more stringent stand-
ards for toxic pollutants are established under section 307(a) of the Clean
__ Water Act,- this permit v/i 1 1 be modified in accordance with the new standards.
(See rule 19-6(5)"g".)
- » -
k. INSPECTION OF PREMISES, RECORDS, EQUIPMENT, METHODS AND DISCHARGES
You are required to permit authorized department personnel to inspect in ac-
cordance with rule 19.6(5)"c".
5- OPERATION AND MAINTENANCE
A!! facilities and control systems shall be operated as efficiently as possible
and maintained in good working order, in accordance with rule 19.6(5)"f", and a
sufficient number of staff, adequately trained and knowledgeable in the opera-
tion of your facility shall be retained to achieve compliance with the terms of
th is perrni t.
6. MAINTENANCE OF RECORDS
You are required to maintain records of your operation in accordance wi th rule
18.3.
7. TRANSFER OF TITLE
If title to your facility or any part of it is transferred, the new owner shall
be subject to this permit. You are required to notify the new owner of the re-
qui rarnents of this permit in writing prior to such transfer of title. The execu-
tive director of this department shall be notified in writing of such transfer
within 30 days. (See rule 19.13.)
8. SEVERAB1LITY
The provisions of this permit are severable, and if any provision or application
of any provision to any circumstances, is found to be invalid by this department
or a court. of law, the application of such provision to other circumstances, and
the remainder of this permit, shall not be affected by such finding.
9- APPLICATION OF OTHER AUTHORITY
This permit does not relieve you of the responsibility to comply with all local,
state and federal laws, ordinances, regulations or other legal requirements ap- -
plying to the operation of your facility.
181 (jan 79)
-------
111-52
'""•-v- y ''
SPECIAL CONuITIG';: • H
The attached appendices specify further conditions which govern the
operation of your facility:
x] Appendix A - Effluent Limitations
3 Appendix B - Monitoring and Reporting Requirements
Appendix C - Conditions, Limitations and Monitoring Requirements
for Contributing Commercial/Industrial Users
TJ Appendix D - Schedule of Compliance
Appendix E - Other Requirements
(~x "] Appendix F - Best Management Practices
FOR THE DEPARTMENT OF ENVIRONMENTAL QUALITY
DISTRIBUTION
1 - Permittee
1 - EPA, Region VII
1 - CWQ, Wastewater Operations
1 - Records Center
1 - R026 Washington, IA
-------
Per-!: Number
'. 111-53
;Fr:'^!:\ ~ - EffTiJen'; Lim! ;2t icn:: r'_r C.;i:'-l' 001 :o>- thi ^ri, ' L.-7-. •:" .'•;-.'
effective daze of this penr.it and lasting iii!-ojg!. June 30, 195.-;.
You are^pronibited from discharging pollutants more frequently or in excess of
the limitations specified below:
O.UiFALL
SERIAL
NUMBER
001 '
1 WASTEWATER
PARAMETER
Flow (MGD) .
BOD (5-day)
TSS
Oil and Greas
COD
Benzene
Total Cr.
.Zn
Phenols
(Standard .
oH Units)
MASS IN
(unless other
Ave raqe
POUNDS PER DAY
rj'i se spec i f i ed)
1 Maximum
2.14 | 3.67
355
490
2 180
2500
1.8
0.9
1.8
1.8
710
840
360
5000
3.6
1.8
3.6
8.9
"Minimum 6.1) and Maximum 9.C
-
CONCEMTRAT
(unless otherwi
Average
--
20
27
10
140
0.10
0.05
0.10
0.10
*•
-
ION IN mg/1
5e speci f i ed)
Maximum
--
40
47
20
280
0.20
0.10
0.20
0.50
.
DEFINITIONS
1. "Maximum" means the total discharge by mass, volume or concentration which can-
not be exceeded during a twenty-four hour period.
2. "Average" means the sum of the total daily discharges by mass, volume or concen-
tration during the reporting period divided by the total number of days during
; the reporting period when the facility was in operation, and is to be calculated
. in connection with your monitoring requirements by totaling all measured daily
- discharges by mass, volume or concentration and dividing by the number of days
during the reporting period when the measurements were made.
182-3 (Jan 73)
-------
^'6 ,• 111-54
fo-- : ' -:- r tri or becl r.ni nc J.'jlj^;), /
ou are
the limitations specified below:
harging pollutants more frequently or in excess of
i _
O.UTFALL
SERIAL
NUMBER
WASTEWA7E?,
PARAMETER
Flow (MGD)
BOD (5-day)
TSS
Oil & Grease
COD
Benzene*
Total Cr.
In
Phenols
Anthracene*
CoDDer*
Flourene*
Phenanthrene
Pyrene*
--/.-(Standard
p " Um'^-s^
. MASS IN POUNDS PER DAY
(unless otherwise specified)
Average | Maximum
2.14 ! 3.67
355
355
180
1600
0.9
0.9
. 1.8
-0.9
-0.9
0.9
0.9
- 0.9
0.9
'' ' Minimum 6,(
. --
710
710
360
3200
1.8
1.8
3.6
1.8
"1.8
1.8
1.8
1.8
1.8 .
and Maximum 9.0
CONCENTRATION IN mg/ !
(unless otherwise specified)
Average ! Maximum
20
20
10
90
0.05
0.05
0.1
0.05
0.05
0.05
0.05
0.05
* 0.05
40
40
20
180
o'.io
0.10
0.2
0.10
0.10
0.10
0.10
0.10
0.10
DEFINITIONS
1. "Maximum" means the total discharge by mass, volume or concentration which can-
not be exceeded during a twenty-four hour period.
2. "Average" means the sum of the total daily discharges by mass, volume or concen-
tration during the reporting period divided by the total number of days during
i the reporting period when the facility was in operation, and is to be calculated
in connection with your monitoring requirements by totaling all measured daily
. discharges by mass, volume or concentration and dividing by the number of days
during the reporting period when the measurements were made.
* Effluent limits for these parameters to be Devaluated after the initial 1-year
mom tori ng-program.
WQ 182-3 (Jan 79)
-------
111-55
NPDES Permit
APPENDIX B - Monitoring and Reporting Requirements
(a) Samples and measurements taken as required herein shall be
representative of the volume and nature of the monitored
discharge. All samples shall be taken at the monitoring
points specified in this permit and, unless otherwise speci-
fied, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points
shall not be changed without notification to and the approval
of the Director.
(b) "Standard Methods", as defined in rule 15.1(30), "EPA Methods",
as defined in rule 15.1(10), "ATSM", as defined in rule 15.1(3),
or other analytical and sampling methods as specified in Table
1 of Chapter 18 of the rules, or other methods approved in
writing by the Department, shall be utilized.
(c) Table III of Chapter 18 of the rules provides you with further
explanation of your monitoring requirements.
(d) You are required to monitor your wastewater as specified
below. Results of all monitoring shall be recorded on forms
provided by the Department, and submitted to the Department by
the fifteenth day following the close of the reporting period.
Your reporting period is on a monthly basis, ending on the
last day of each month.
-------
//v/III-56
'
WASTEWATER
PARAMETER
Flow
BOD (5 day)
TSS
Oil & Grease
PH
COD
Benzene
Total Cr.
Zn
Phenols
Anthracene*
Copper*
Fluorene*
Phenanthrene*
Pyrene*
FREQUENCY
Continuous
3/week
3/week
3/week
Daily
3/week
I/ week
I/week
I/week
I/week
1/mo
1/mo
1/1710
1/mo
1/mo
SAMPLE TYPE
Totalizer
24 hr. comoosite
24 hr. conoosite
Grab
Grab
24 hr. composite
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
SAMPLING REQUIREMENTS**
1.
1.
- 1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1. '
*Monitoring requirements for these parameters to be evaluated after
the initial 6 mon-ths of monitoring.
**Samples collected as specified in the sampling requirements shall be
taken at the following location:
1. - final effluent from polishing pond.
-------
111-57
(2) OPERATIC:;^
WASTEWATER
PARAMETER
Flow
BODS
COD
TSS
Mixed Liquour
Suspended Solids
Mixed Liquour
Volatile Suspendec
Solids
Phenol
PH
PH
Temperature
Dissolved Oxygen
% Solids
Hexavalent Cr.
Total Cr.
Zinc
Total
Nitrogen
FREQUENCY
Daily
2/week
3/week
2/week
4/week
2/week
5/week
5/week
2/week
5/week
4/week
I/week
5/week
2/week
5/week
I/week
SAMPLE TYPE
Total
24 hr. composite
24 hr. composite
24 hr. composite
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Z :-'•' •_ .M ; :. .-: • i"i.'.T^ •';/ -
2, 5, 6
2, 10
2, 3, 10
2, 3/10
4, 5
4
3, 1C
2, 3
4, 9
4, 9
4, 9
9
2, 7, 8
7, 8
7, 8
4
*Samples taken in compliance with the monitoring requirements specified
above shall be taken at the following location(s):
2. Influent to the equalization tank
3. Influent to the aeration basin
4. Aeration basin contents ^
5. Return activated sludge
6. VJaste activated sludge-
7. Cooling tower blowdown before the chrome treatment system
8. Cooling tower blowdown after the chrome treatment system
9. Digester contents
10. Final clarifier effluent
-------
- SCHEDULE OF COMPLIANCE
ir,e permittee shall achieve compliance with the effluent limitations, monitoring
requirements and other stipulations in accordance with the follov/ing implementa-
tion schedule:
When used below, "required facilities" means those facilities provided by the
permittee which will achieve compliance with limitations based upon "Best Con-
•.enr-jonal Pollutant Control Technology "(BCT) for conventional pollutants or "Best
Available Technology Economically Achievable" (BAT) for toxic substances as indi-
cated.
(a) by July 1, 1982, the permittee shall submit to the Dune Department of Environ-
mental Quality (DEQ) a preliminary engineering report for the construction of
the required BCT facilities.
(b) by April 1, 1982, the permittee shall submit to the Dune DEQ a report on the
priority pollutant monitoring and need for required BAT facilities as speci-
fied in Appendix E, Other Requirements of this permit.
(c) by August 1, 1982, the permittee shall submit to the Dune DEQ a preliminary
engineering report for the construction of the required BAT facilities.*
(d) by April 1, 1983, the permittee shall submit to the Dune DEQ final plans and
specifications for the construction of the required BCT and BAT* facilities.
(e) by July 1, 1984, the permittee shall complete construction of the required
BCT and BAT* facilities, and by said date, shall submit to the Dune DEQ
certification by a registered professional engineer that the construction
thereof has been completed in accordance with the application, plans, speci-
fications and permit therefor.
(f) the permittee shall submit to the Dune DEQ ninety (90) day progress reports
stating the progress being made toward completion of the required facili-
ties. The first such report shall be submitted on or before August 10, 1983.
*ihe need for required BAT facilities and associated subsequent implementation
schedule steps will be determined by the Director following submission of the
priority pollutant monitoring report about August 1, 1982.
187 (Jan 79)
-------
NPDES PERMIT <•! ''
APPENDIX E - OTHER REQUIREMENTS i-J L! _._,-,. J [j
SECTION A. STORHWATER MONITORING
Universe shall monitor stormwater discharges from the following
locations [Figure 1]:
1. OUTFALL 002
The overflow at the weir of the "large pellet pond11 on the
east side of the plant opposite the rail scales.
2. OUTFALL 003
The overflow at the weir of the "small pellet pond" on the
east side of the plant near the loading area.
3. OUTFALL 004
The outlet pipe of the "southwest drainage ponds" located just
north of the large ethylene storage tank.
4. OUTFALL 005
The outlet pipe of the "flare drainage pond" located west of
the flare area.
During the period beginning on the effective date of this permit
and for one year following the effective date Outfalls 002, 003, 004,
and 005 shall be monitored as specified below:
EFFLUENT MEASUREMENT SAMPLE
CHARACTERISTICS FREQUENCY TYPE
Flow total when discharging estimate
Oil & Grease I/day when discharging grab
COD I/day when discharging grab
BOD I/day when discharging grab
pH I/Day when discharging grab
After one year, based on the results of this monitoring the Director
may allow monitoring to be discontinued or may require additional moni-
toring and/or treatment of the discharge from Outfalls 002, 003, 004
and/or 005.
-------
111-60
SECTION B. PRIORITY POLLUTANT MONITORING - ' '"'
1. Universe shall perform a complete priority pollutant
on the discharge from Outfall 001 within 3 months of
effective date of this permit and once every 2 years
after. The analysis shall include the toxic metals,
and total phenols, and the volatile, base/neutral and
extractable fractions of the organic toxic pollutants
tained in the gas chromatography/mass spectrometry an
A listing of the priority pollutants included in this
ment is contained in Part V of the Consolidated Permi
Program Application Form 2C.
analysis
the
there-
cyanide,
acid
con-
alysis.
require-
ts
2. The results of each set of priority pollutant analysis shall
be reported to the Director within 15 days of their availa-
bility to the permittee.
3. An evaluation of the initial complete priority pollutant
analysis, the weekly monitoring data for benzene and the
monthly monitoring data for anthracene, copper, fluorene,
phenanthrene and pyrene shall be made by the permittee at the
end of 6 months of monitoring. The permittee shall submit a
report to the Director summarizing this evaluation and indi-
cating what, if any, treatment improvements will be needed to
meet final effluent limits for priority pollutants. The
Director may then continue the monitoring requirements or
modify the monitoring requirements and/or permit limits at his
discretion.
SECTION C. GENERAL MONITORING AND REPORTING
1. Appropriate flow measurement devices and methods consistent
with accepted scientific practices shall be selected and used
to insure the accuracy and reliability of measurements of the
volume of monitored discharges. The devices shall be in-
stalled, calibrated and maintained to insure that the accuracy
of the measurements are consistent with the accepted capability
of that type of device. Devices selected shall be capable of
measuring flows with a maximum deviation of less than ± 10%
from true discharge rates throughout the range of expected
discharge volumes.
2. By-passes shall be reported in accordance with rule 18.14.
-------
ln-51
DUNE PERMIT
APPENDIX F - BEST MANAG
vatMENT
PRACTICES
SECTION A. GENERAL CONDITIONS
1. Applicability
These conditions apply to all permittees who use, manufacture, store,
handle or discharge any pollutant listed as toxic under Section 307(a)(l)
of the Clean Water Act or any pollutant listed as hazardous under Section
311 of the Act and who have ancillary manufacturing operations which
could result in significant amounts of these pollutants reaching waters
of the United States. These operations include material storage areas;
plant site runoff; in-plant transfer, process and material handling
areas; loading and unloading operations, and sludge and waste disposal
areas.
2. BMP Plan
You shall develop and implement a Best Management Practices (BMP) plan
which prevents, or minimizes the potential for, the release of toxic
substances from ancillary activities to the waters of the United States
through plant site runoff; spillage or leaks; sludge or waste disposal;
or drainage from raw material storage.
3. Implementation
The plan shall be developed within six months of the effective date of
the permit and shall be implemented as soon as practicable but not later
than one year after the effective date of the permit unless a later date
is specified by the Director.
4. General Requirements
The BMP plan shall:
a. Be documented in narrative form, and shall include any nec-
essary plot plans, drawings or maps.
b. Establish specific objectives for the control of toxic and
hazardous pollutants.
(1) Each facility component or system shall be examined for
its potential for causing a release of significant
amounts of toxic or hazardous pollutants to waters of the
United States due to equipment failure, improper operation,
natural phenomena such as rain or snowfall, etc.
-------
//> \-JII-62
r, o t c TI t "i i i TOP '
jre (c.c. . a tai.K ovirflo.-; or leakage), •'
natural condition (e.g., precipitation), or other circum-
stances to result in significant amounts of toxic or
hazardous pollutants reaching surface waters, the plan
should include a prediction of the direction, rate of
flow and total quantity of toxic or hazardous pollutants
which could be discharged from the facility as a result
of each condition or circumstance.
c. Establish specific best management practices to meet the
objectives identified under paragraph b of this section,
addressing each component or system capable of causing a
release of significant amounts of toxic or hazardous pol-
lutants to the waters of the United States.
d. Include any special conditions established in Part B of this
section.
e. Be reviev;ed by plant engineering staff and the plant manager.
5. Specific Requirements
The plan shall be consistent with the general guidance contained in the
publication entitled "NPDES Best Management Practices Guidance Document"
and shall include the following base line BMP's as a minimum:
a. BMP Committee
b. Reporting of BMP Incidents
c. Risk Identification and Assessment
d. Employee Training
e. Inspections and Records
f. Preventive Maintenance
g. Good Housekeeping
h. Materials Compatibility
i. Security
6. SPCC Plans
The BMP plan may reflect requirements for Spill Prevention Control and
Countermeasure (SPCC) plans under section 311 of the Act and 40 CFR Part
151, and may incorporate any part of such plans into the BMP plan by
reference.
7. Hazardous Waste Management
You shall assure the proper management of solid and hazardous waste in
accordance with regulations promulgated under the Solid Waste Disposal
Act, as amended by the Resource Conservation and Recovery Act of 1976
(RCRA) (40 U.S.C. 6901 et. seq). Management practices required under
RCRA regulations shall be referenced in the BMP plan.
-------
111-63
The permittee shall in aim. a in a description of the Bri? plan at the
facility and shall make the plan available to the Director upon request.
9. BMP Plan Modification
You shall amend the BMP plan whenever there is a change in the
facility or change in the operation of the facility which materially
increases the potential for the ancillary activities to result in a
discharge of significant amounts of hazardous or toxic pollutants.
10. Modification for Ineffectiveness
If the BMP plan proves to be ineffective in achieving the general
objective of preventing the release of significant amounts of toxic or
hazardous pollutants to surface waters and the specific objectives and
requirements under paragraphs b and c of Section 4, the permit and/or
the BMP plan shall be subject to modification to incorporate revised BMP
requirements.
SECTION B. SPECIFIC CONDITIONS
1. All process waste, and surface runoff .from process areas subject to
spills or leaks of raw materials or products containing toxic or
hazardous materials, shall be contained and directed to the waste
treatment plant or polishing pond.
2. Storage of wastewater treatment sludges, polishing pond dredgings
and chrome treatment sludges shall be managed to minimize the
potential for release of toxic or hazardous substances to navigable
waters. Storage areas shall be graded to prevent run-on of surface
runoff from adjacent areas and to prevent accumulation or ponding
of precipitation in the storage areas. Management practices shall
be designed to minimize infiltration of precipitation into sludge
storage piles and to minimize leachate. Surface runoff and leachate
from storage areas shall be conveyed to the final polishing pond
through the existing storm drainage system. These management
conditions are based upon the classification of stored sludges and
dredgings as non-hazardous materials under applicable regulations
for hazardous wastes (40 CFR Parts 260-265). Should any changes in
the constituents of the materials being stored or in the definition
of hazardous wastes result in the stored wastes or leachate from
the storage piles meeting the definition of a hazardous waste, the
Director shall be notified and the permittee shall make the neces-
sary changes in management practices to comply with applicable
state and Federal regulations for storage of hazardous wastes.
3. The existing "land farm" area for land disposal of wastewater
treatment sludges located north of the sludge storage area shall be
managed to minimize the potential for release of toxic or
-------
L^LRJ/PJiJ
111-64
hazardous substances to navigable waters. Surface runoff from
adjacent areas shall be diverted around the disposal area. Surface
runoff from the disposal area shall be conveyed to the storm drain-
age system tributary to the final polishing pond. Surface runoff
from the disposal area shall not be allowed to discharge through
Outfall 002.
4. All drums containing hazardous substances now stored west of the
cooling towers shall either be removed from the plant site within
120 days or shall be managed in a storage area meeting the interim
status standards for storage of hazardous wastes in containers (40
CFR 262.34 and 265.170-177) until a R.C.R.A. permit is issued to
this facility. All other containers that have held hazardous
wastes shall either be triple rinsed or otherwise managed so that
they meet requirements for exclusion as a hazardous waste.
-------
SAMPLE RATIONALE FOR STATE PERMIT
-------
111-65
RATIONALE FOR PERMIT CONDITIONS AND EFFLUENT LIMITS
Universe Company
Caladan, Dune
Permit No. CD0000191
Dune DEQ Operation Permit No. 5-23-26-1-12
DESCRIPTION OF FACILITY
Universe Company operates an industrial organic chemicals and plastics
materials plant on an 800 acre site in Sections 19 and 20, Township 81N,
Range 6E, Caladan County, Dune, southwest of the City of Caladan and west
of Arrahane. The plant produces ethylene, propylene, high density poly-
ethylene plastic, low density polyethylene plastic and ethylene-vinyl ace-
tate copolymer plastic from an ethane-propane feedstock. These manufactur-
ing operations are included in Standard Industrial Classification (SIC)
codes 2821 and 2869.
Figure 1 shows the layout of the Universe Facility, including the lo-
cation of outfalls. Process wastewaters from the ethylene and polyethylene
plants, cooling tower blowdown and stormwater runoff from paved process
areas receive treatment including equalization, neutralization, floccula-
tion, primary clarification, aeration (activated sludge system) and final
clarification prior to discharge to a final polishing pond [Figure 2].
Surface runoff from about one-fourth of the plant site receives settling in
an earthen storm pond before discharge to the final polishing pond. Efflu-
ent from the pond discharges through Outfall 001, a 4-mile pipeline dis-
charging to the Uncompahgre River in Section 5, township SON, Range 6E.
This discharge averaged 1.7 mgd in 1980 but is expected to increase to 2.1
mgd upon completion of a plant expansion in early 1981.
Stormwater runoff from the remainder of the plant site is discharged
through 4 outfalls to small intermittent tributaries of Usul Creek, a trib-
utary of the Uncompahgre River. Outfalls 002 and 003 on the east side of
-------
111-66
OUTFALL
005
OUTFALL
OOJ
PL/'NI
ADMINISTRATION
AREA
ETHYLENE
PROCESS
AREA
ir
FLARE DRAINAGE
POND
DRUM
STORAGE
UTILITIES
AREA
O
FLARE
WASTEWATER
TREATMENT
PLANT
SOUTHWEST
DRAINAGE
PONDS
O
ETHYLENE
STORAGE
DAC STORAGE
O
STORAGE TANK
FARM
POLISHING
POND
STORM
POND
TRUCK & RAIL
LOADING
t OUTFALL 001
ill
2! >-
LU :n
o >—
LAND
DISPOSAL
AREA
SLUDGE
STORAGE
PILES
RAIL
SCALE
OUTFALL
003
SMALL
FLLET
POND
OUTFALL
002
LARGE
PELLET
POND
FIGURE 1
-------
JEN1
111-67
S-lo
'MARY
TLING
5 INS
STORM HATER
POND
POLISHING POND
TO Sl'/A?L
SLOUGH
SLUDGE DEPOSITED
ON PLANT GROUNDS
U ACTIVATED
SLUDGE
BASIN
FIN/
•CLARIFIER
FIGURE 2
WASTE TREATMENT PLANT
-------
111-68
the plant drain the polyethylene areas and are equipped with pellet traps.
Outfalls 004 and 005 on the west side of the plant drain the ethylene,
utility and storage tank areas and pass through settling ponds. These out-
falls flow only after heavy precipitation. No flow data are available.
Dune Water Quality Standards assign water uses to be protected in the
receiving waters. For Usul Creek downstream of Highway 67, these uses are
designated as wildlife, fish, aquatic and semi-aquatic life and secondary
contact recreation. For the Uncompahgre River, uses to be protected in-
clude primary contact recreation in addition to the uses listed above for
Usul Creek.
RATIONALE FOR EFFLUENT LIMITS - Outfall 001
1. Location
Sampling of this outfall shall be performed at the existing monitoring
point on the effluent from the final polishing pond to the outfall pipe-
line.
2. Waste Streams
The wastes in this discharge consist of:
a. Effluent from the main wastewater treatment plant which in-
cludes:
1) Process wastewaters from the ethylene plant that have re-
ceived pretreatment in a steam stripper and coalescer;
2) Process wastewaters from a high density polyethylene
plant (Philips process), a low density polyethylene plant
(Dupont process and USI process) and an ethylene-vinyl ace-
tate copolymer plant;
-------
111-69
3) Cooling tower blowdown which has received pretreatment for
for reduction of hexavalent chromium and for removal of
chromium and zinc;
4) And, stormwater runoff from paved process areas in the
ethylene and polyethylene plants.
b. Stormwater runoff from about one-fourth of the non-process por-
tion of the plant site including sludge storage and landfarm
areas, truck and rail car loading areas and some storage tank
areas. This runoff receives settling in an earthen basin before
discharge to the final polishing pond.
3. Basis for Limitations
a. Interim Limits
The interim limits are based on best practicable technology (BPT)
for all contributing processes and reflect an allowance for the
current 40% increase in production. There are no present EPA pro-
mulgated effluent guidelines for ethylene or polyethylene plants.
Effluent guidelines were promulgated for ethylene and polyethylene
plants in 1974 and revoked in 1976 as a result of a court case. As
a result, it was necessary to derive effluent limits reflecting BPT
level treatment using Best Professional Judgment (BPJ) procedures and
the following information.
1) The present Dune DEQ Operation Permit.
2) The revoked ethylene BPT guidelines.
3) The revoked polyethylene BPT guidelines.
-------
111-70
4) Development Document for Effluent Limitations Guidelines
and New Source Performance Standards for the Major Organic
Products Segment of the Organic Chemicals Manufacturing
Point Sources Category, EPA, April 1974.
5) Development Document for Effluent Limitations Guidelines
and New Source Performance Standards for the Synthetic
Resins Segment of the Plastics and Synthetic Materials Man-
ufacturing Point Source Category, EPA, March 1974.
6) Personal communications with EPA Effluent Guidelines Divi-
sion (EGD) staff concerning the results of recent EGD stu-
dies and tentative approaches to new guidelines for these
industrial categories.
7) Universe self-monitoring data showing the performance of
the existing treatment system and pollution controls for
the 21-month period, January 1979 to September 1980.
Review of the self-monitoring data indicates that the interim effluent
limits developed below can be met by the existing treatment system.
b. Final Limits
Because there are no EPA promulgated guidelines applicable to this
plant, the final limits are based on best conventional pollution
control technology (BCT) for conventional pollutants and best avail-
able technology (BAT) for toxic and non-conventional pollutants de-
rived using BPJ procedures and the following information:
1) The revoked BAT guidelines for ethylene and polyethylene
plants.
2) Information items 3.a.4-7 above.
3) The Treatability Manual, EPA, July 1980, (EPA-600/8-80-
042e).
-------
111-71
4. Effluent Limits
a. Conventional Pollutants
The conventional pollutants of concern in this discharge are
BOD, TSS, Oil and Grease, and pH. Consistent with most ef-
fluent guidelines and with applicable Dune water quality
standards, a pH range of 6.0 to 9.0 was established for this
permit.
In the present permit, Universe was required to meet efflu-
ent limits for conventional pollutants based on BPT level
treatment. Review of the development documents [references
3(a) 4 and 5] for ethylene and polyethylene indicated that
the model treatment systems on which BPT guidelines were
based included flow equalization, neutralization, aeration
(activated sludge), and final clarification for ethylene and
the same processes plus chemical addition and a final pol-
ishing process for polyethylene. The present Universe
treatment system [Figure 2] includes equalization, neutrali-
zation, chemical addition, coagulation, flocculation, pri-
mary clarification, aeration (activated sludge), final clar-
ification, and a final polishing pond. The present Universe
treatment system thus represents a higher level of treatment
than the 1974 model BPT system.
A review of the Discharge Monitoring Reports (DMRs) for the
21-month period January 1979 to September 1980 indicates
that treatment plant performance is good and that average
effluent loads are within current permit limits. Occasional
TSS discharges in excess of daily maximum effluent limits
have been observed. Several factors appear to contribute to
these high TSS loads. The treatment units are relatively
small compared to total wastewater flow making the treatment
system somewhat vulnerable to upsets from slug loads or hy-
draulic surges. The equalization tank has only about 2 hours
-------
111-72
flow detention in comparison to 24 hours for the model BPT
treatment system. Some solids handling problems in the
sludge system have occurred which would affect TSS loads in
the final effluent. Stormwater is discharged to the final
polishing pond with limited settling which would increase
TSS concentrations in the final effluent.
A majority of the recent plant expansion began operating in
June 1980. Although waste loads to the treatment system in-
creased, final effluent loads remained near pre-expansion
levels during the following three months indicating the
treatment system has capacity to handle the expanded loads.
The effluent loads reported were in compliance with permit
limits which were based on pre-expansion production rates.
To determine a rationale for interim and final limits for
conventional pollutants, a comparison was made between the
present permit limits, the reported plant effluent waste
loads, the revoked BPT and BAT guidelines, and new tentative
BCT target guidelines [Table 1]. The comparisons were made
for both the old and new (40% increase) production levels.
In Table 1, the BOD and COD concentrations for the new pro-
duction levels were computed by dividing computed waste
loads by 2.14 mgd, the expected average daily flow at full
production. For the new BCT limits, waste loads were com-
puted from the target daily average concentrations and the
2.14 mgd flow. No new BCT daily maximum concentrations were
available from EGD at this time.
1) BOD
A comparison of BOD limits in the current permit with
the revoked BPT guidelines shows that the permit limits
are about 50% higher than the guidelines. In contrast,
the final plant effluent for the 21-month period averaged
about half of the permit limits. Assuming that a 40%
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-------
111-74
increase in the final effluent BOD load would occur due
to the 40% production increase (initial treatment plant
response indicates the increase will be less), the ac-
tual effluent would still be less than BPT guidelines
and would probably be less than the revoked BAT guide-
lines. Comparison of the new BCT target concentration
vs. the revoked BAT shows that it is higher (27 vs. 20
mg/£). Use of the new BCT limit would allow a larger
BOD load than the present permit but less than the pre-
sent permit limit adjusted for the production increase.
Because none of the guidelines used for this comparison
are promulgated regulations and the new BCT target val-
ues may be revised, the limits in this permit were es-
tablished using best professional judgment (BPJ). A
daily average BOD limit of 20 mg/£ was selected for
both the interim and final limits. The corresponding
load in Table 1 was based on the 2.14 mgd expected flow.
This limit should allow for some minor decrease in the
treatment plant efficiency due to increased hydraulic
and waste loading but require good plant operation and
maintenance in order to consistently meet the limit.
No increased allowance was made for stormwater runoff
as no increase should occur as a result of the plant
expansion.
A variability factor of 2.0 was used to derive the daily
maximum limit. This ratio is consistent with the aver-
age of the revoked BPT and BAT guidelines for ethylene
and polyethylene. Ratios in these guidelines ranged
from 1.56 to 2.2. The observed ratio for the actual
plant effluent was 2.6 for the 21-month period. How-
ever, improvements for reduction of TSS discussed below
should reduce daily maximum loads.
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111-75
The interim limits for BOD were set the same as final
limits as the plant should be able to achieve these
limits immediately. Consideration was given to redu-
cing the final daily maximum limit to 31 mg/£ consis-
tent with the revoked BAT guidelines. However, this
reduction was not adopted for several reasons. The
new BCT target concentration suggests that 31 mg/£ would
be unreasonable to achieve. The historic plant perfor-
mance also supports this. Setting the lower limit
would probably result in occasional violations of daily
maximum limits without achieving any significant reduc-
tions in pollutant loads.
2) TSS
A different set of circumstances exists for TSS as com-
pared to BOD at this plant. As shown in Table 1, the
current permit limits for TSS are substantially more
stringent than the revoked BPT guidelines. Daily av-
erage TSS loads approximate the permit limits and
daily maximum loads occasionally exceed the limits.
High effluent TSS levels occur periodically. One cause
of this is that the final pond receives stormwater runoff
with high TSS and the detention time does not allow for
adequate settling.
The revoked BAT guidelines would have required a daily
average TSS concentration of 23 mg/£. The new BCT tar-
get daily average TSS concentration is 5 mg/£, substan-
tially more stringent than previous guidelines and be-
yond the capability of the present Universe waste
treatment facility.
As previously discussed the Universe treatment facili-
ties exceed the BPT model treatment system in its capa-
bility. However, it has less capability than the model
-------
111-76
systems for the revoked BCT and new BCT. For the re-
voked BAT, the model system added dual media filtration
(DMF) and/or a dissolved air flotation (DAF) unit to the
ethylene BPT model treatment system. For polyethylene,
the BAT additions were DMF and granulated activated car-
bon. For the new BCT limits, the model treatment would
include DMF and/or DAF units in addition to the present
Universe treatment system. The addition of these final
polishing units was expected to reduce TSS concentra-
tions to an average of 5 mg/2.
In the absence of promulgated BCT guidelines for an ap-
plicable industry category, BCT for conventional pollu-
tants must be determined on a plant specific basis
using a BCT cost test procedure. This procedure is de-
signed to evaluate the reasonableness of the cost of
removing additional conventional pollutants at this
facility relative to their present waste discharge and
relative to the cost of an equivalent waste load reduc-
tion in a publicly owned treatment works (POTW). This
procedure is defined in the EPA BCT Cost Test Guidance
Manual.
It is apparent from a review of Universe records that
improvements in the treatment system are needed to re-
duce the large fluctuations in TSS concentrations in
the final effluent. The revoked and new tentative
guidelines also indicate a need to reduce average TSS
levels. Varying degrees of TSS reductions could be
achieved by a variety of treatment system improvements
or additions. Several options were evaluated using the
BCT cost test as a basis for selecting final effluent
limits.
-------
Jo achieve a reduction of TSS to a daily average of
5 mg/je. would require the addition of DMF and/or DAF
units for polishing the final effluent. In addition,
added flow equalization at the treatment plant influent
would probably be required. A DMF unit adequate for the
expected average flow of 2.14 mgd would have an esti-
mated capital cost of $1.8 million and an annual cost of
$0.66 million in 1979 dollars based on EPA Treatability
Manual data. To reduce TSS from the interim permit
limits of 490 Ib/day to 89 Ib/day (5 mg/£) would result
in the removal of about 146,000 pounds of TSS annually.
The estimated removal cost using only the DMF unit
would be about $4.52/lb, about 3.0 times the equivalent
removal cost in a POTW. The unit removal cost for a DAF
unit was estimated to be about 30% higher than a DMF
unit. Thus, neither unit passes the cost test and the
cost of reducing TSS to 5 mg/£ does not appear to be
reasonable at this facility.
In this cost test, no removal credits were included for
BOD or Oil and Grease. Both pollutants are already at
low levels. If a 50% reduction in both BOD and Oil and
Grease were achieved by the added treatment, the DMF or
DAF units would still not pass the cost test.
To determine what lower level of TSS reduction would be
acceptable, an evaluation was made of the potential ef-
fects of TSS on the receiving water and on the discharge
of other pollutants such as COD and toxic substances.
The receiving stream is the Uncompahgre River with a
large flow and with TSS levels well above 5 mg/Ji. TSS
concentrations in the range of 20 mg/£ would not be
expected to significantly affect the River.
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111-78
There does not appear to be a direct correlation between
COD and TSS in the final effluent. This suggests that
most of the oxygen demanding substances remaining are in
a soluble form and not particulate. Allowing a TSS con-
centration of 20 mg/£ rather than 5 mg/£ should not sig-
nificantly affect the COD load discharged.
Data on organic toxic pollutants and heavy metals indi-
cate only very low levels are discharged. The solids
discharged would thus be expected to contain insignifi-
cant loads of toxic substances.
Several other alternative treatment system improvements
were considered. Review of the DMR data indicated that
daily TSS levels in the effluent from the wastewater
treatment plant final clarifier vary widely from day to
day as do the plant influent waste loads. The installa-
tion of additional flow equalization capacity and/or a
third final clarifier would reduce the fluctuations in
effluent TSS levels through dampening of flow and raw
waste load fluctuations and by the added TSS removal
in the final clarifiers. Plant operating history, as
reflected in the DMR data, suggests that an average
TSS level of 20 mg/£ in the polishing pond effluent
could be achieved by these improvements. A final ef-
fluent limit based on 20 mg/£ would reduce the daily
average discharge of TSS from 490 to 355 Ib/day, an
annual reduction of about 49,000 Ib.
Based on Treatability Manual cost data, additional
flow equalization capacity in the range of 1 to 2 mil-
lion gallons would have estimated annual costs in the
range of $0.3 to $0.4 million. These costs result in
unit removal costs of about $6.12 to $8.16/lb of TSS
which fails the BCT cost test. The estimated annual
cost of a third primary clarifier would be at least
-------
111-79
$0.20 million. This converts to a unit removal cost
of at least $4.08/lb of TSS which also fails the BCT
cost test. The installation of added flow equalization
or a third final clarifier are thus not justifiable.
Comparison of TSS levels in the final clarifier effluent
and the final polishing pond effluent showed that when
final clarifier effluent levels were low, small in-
creases (2-6 mg/£) in TSS levels occurred through the
final pond. This suggests that these increases may
have been at least partially due to the direct inflow
of stormwater to the final pond from the storm pond,
i.e. inadequate detention time in the storm pond.
In contrast, when TSS levels in the final clarifier
effluent were high (2 to 6 times average levels), sub-
stantial reductions (> 50%) occurred through the final
pond. These observations suggest several less expensive
treatment system improvements to reduce final effluent
TSS levels and, more importantly, peak load fluctuations.
The stormwater pond is small and was in need of mainte-
nance dredging at the time of the NEIC visit. This un-
lined earthen basin could be easily doubled in size from
0.5 to 1.0 million gallons and maintenance dredging per-
formed more frequently to reduce TSS levels in storm-
water entering the final pond. Such improvements are
estimated to cost less than $10,000 annually.
The final polishing pond is also dredged infrequently.
Although solids accumulation rates are low, increased
dredging frequency should reduce the potential for re-
suspension of solids during peak hydraulic flows or
wave action. The annual costs for increased dredging
frequency are estimated as less than $10,000.
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111*80
To achieve a reduction in daily average TSS effluent
levels to 20 mg/£ would require some reduction in
peak hydraulic flow fluctuations and additional final
polishing capacity, in addition to improvements in the
existing stormwater and final ponds. Careful manage-
ment and scheduling of intermittent activities which
produce large volumes of wastewater and/or wasteloads
could also help minimize peak hydraulic and waste loads.
The present final polishing pond has a nominal capacity
of about 5 million gallons which provides about 3 days
detention at average 1980 flows. The expected flow in-
crease with the current plant expansion would decrease
detention time to about 2 days with a corresponding de-
crease in TSS removal. The addition of a second pol-
ishing pond in series to increase total detention time
to about 4 days was selected as an adequate alternative
to achieve a final effluent average TSS concentration
of 20 mg/£. The annual cost of a 4 million gallon clay-
lined earthen basin is estimated as less than $50,000.
The total estimated annual costs for the additional pol-
ishing basin, improvements in the stormwater basin and
increased dredging frequency in the final pond are
$70,000. Estimated unit removal costs would be $1.43/lb
of TSS, 0.96 times the equivalent removal costs in a
POTW. The, BCT cost test conditions are thus met by
this treatment option.
The final daily average TSS load limit [Table 1] is
based on the estimated performance of this improved
treatment system (20 mg/£) and an expected flow rate
of 2.14 mgd. The daily maximum TSS limit was based on
a variability factor of 2.0. This is consistent with
observed treatment system performance and revoked
guidelines.
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111-81
The interim TSS limits were established using the
present permit limits increased by 40% to allow for
the production expansion and the demonstrated diffi-
culty of the treatment system in achieving present
permit limits. The interim limits are less than half
the allowable loads under the revoked BPT guidelines.
Oil and Grease limits were established as 10 mg/£ daily
average consistent with the new BCT target guidelines
and 20 mg/£ daily maximum based on the current permit.
Review of the DMR data indicates that these limits can
be consistently met.
b. Non-Conventional Pollutants
Two non-conventional pollutants are limited in the current
Universe permit, chemical oxygen demand (COD) and phenols.
Both parameters will be retained in the new permit because
they are useful indicator parameters for evaluating the ef-
ficiency of an industrial waste treatment system.
1) COD
A comparison was made between current permit limits,
COD levels in the plant effluent, and the revoked BAT
guidelines [Table 1]. There were no BPT guidelines for
COD proposed for the ethylene category in 1974 so no
comparison can be made with BPT for the combined plant.
No new COD guidelines were available from EGD. Past ef-
fluent loads average about half of the current permit
limits which are in turn about 50% lower than the re-
voked BAT daily average limit. Some increase in COD
loads has occurred as a result of the production in-
crease but the waste load increases should be less
than 40% based on results to date.
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111-82
Interim COD load limits were established as equal to
the current permit limits. Concentration limits were
adjusted downward consistent with the increased allow-
able flow. These limits are more stringent than the
revoked BAT guidelines. However, Universe should have
no difficulty meeting the limits with existing treat-
ment facilities.
Universe installed several pretreatment units in the
ethylene area in 1980 with full operation to be obtained
in early 1981. These are a filter, a coalescer, and a
steam stripper on the contact dilution steam blowdown
from pyrolosis furnaces. This waste stream is the
largest load of COD and Oil and Grease in the plant.
The pretreatment units are part of a steam recycle
system that will reduce this wastewater stream by
about 150 gpm and will reduce the Oil and Grease and
COD loads by recovery and removal of residual oils.
Full operation of the pretreatment system coupled with
the treatment improvements proposed for reduction of
TSS should at least partially offset any increases in
COD loads due to production increase.
Review of the 1974 Development Documents for ethylene
and polyethylene effluent guidelines indicated that the
ethylene BAT limits were based on a final effluent COD
concentration of 50 mg/£ and the polyethylene BAT limits
on 130 mg/£. The average of these (90 mg/£) is compar-
able to average plant performance (88 mg/£). The 90
mg/£ guidelines average was selected as the final daily
average limit as it is more stringent than the current
BPT permit limits, it is more stringent than the re-
voked BAT guidelines, but it should be readily achiev-
able by the increased treatment proposed. A variabil-
ity factor of 2.0 was used to develop the daily maximum
limit consistent with the current permit and observed
plant performance.
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111-83
2) Phenols
Phenols are presently limited to an average of 0.4 mg/£
but recent operating data indicates an average discharge
of less than 0.1 mg/£. Interim limits for this parameter
are based on current operating data and are set at
0.1 mg/£ average, and a maximum of 0.5 mg/£.
Final limits of 0.05 mg/£ average, and 0.1 mg/S, maximum
are based on the levels established in the tentative
new BAT guidelines.
c. Toxic Substances (Priority Pollutants)
EGD in sampling wastewaters from various industrial facili-
ties of the same category as Universe detected significant
discharges of the following 13 priority pollutants: aceta-
naphthalene, anthracene, benzene*, benzo(a)anthracene*,
chromium*, copper*, di-butyl phthalate*, dimethyl phthalate*,
fluorene, napththalene, phenanthrene, phenols, pyrene and
toluene*. Tentative target effluent concentrations of
0.05 mg/S, were established by EGD for the seven pollutants
marked with an asterisk(*). EGD determined that the model
BPT level treatment system for an ethylene/polyethylene
plant could achieve acceptable effluent concentrations of
six of the 13 priority pollutants. Increased treatment
(BAT level) was determined to be necessary to achieve target
or acceptable levels for anthracene, benzene, chromium, cop-
per, fluorene, phenanthrene and pyrene. The BAT treatment
improvements considered were; pretreatment of selected waste
streams, followed by combined treatment in the BPT model
system. For the ethylene plant, pretreatment systems eval-
uated included coagulation/flocculation, steam stripping,
and/or ion exchange. For the polyethylene plant, pretreat-
ment units were coagulation/flocculation, oil separation,
DMF, ion exchange, and/ or DAF.
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111-84
Universe's current permit establishes effluent limits and
requires daily monitoring for two priority pollutants:
chromium (total and hexavalent), and zinc. In addition,
weekly monitoring is required for two priority pollutants
(toluene and naphthalene) and a related compound, styrene.
There are thus substantial amounts of data on these five
pollutants. The only other toxic substance data available
were complete priority pollutant analyses of three 24-hour
composite samples of final pond effluent taken in June 1979
by EPA Region VII. Bioscreen tests including a fish test, a
water flea test, an alga test and the Ames test were con-
ducted on the Universe effluent by EPA Region VII in August
1980. The results were negative indicating no effluent tox-
icity. The bioscreen was conducted after most of the cur-
rent plant expansion had been completed. The EPA priority
pollutant analyses detected 7 priority pollutants [Table 2]
in the effluent, all at levels less than 0.015 mg/£ except
for zinc that ranged from 0.035 to 0.042 mg/£. Naphthalene,
styrene and toluene were below detection limits.
During the October 1980 EPA inspection, Universe identified
21 toxic or hazardous substances that are used as raw mater-
ials or produced as products or by-products in this facility.
Five of these are priority pollutants. An additional six
priority pollutants were detected in the effluent by the EPA
sampling. The 11 priority pollutants and 28 toxic or hazard-
ous substances are listed in Table 2. As required by the
Consolidated Permit Regulations, consideration must be given
to establishing effluent limits and monitoring requirements
for the 11 priority pollutants.
Because available priority pollutant data were not considered
adequate to fully assess the ability of the present Universe
treatment system to achieve final priority pollutant effluent
limits established below, a phased approach to limiting prio-
rity pollutants was adopted. Interim limits were established
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111-85
Table 2
TOXIC AND HAZARDOUS SUBSTANCES
ammonia
benzene1'4
butadiene
butylenes
cyclohexane
chromium1'2 '4
DAC - debutanized aromatic concentrate containing benzene,1
toluene1 and xylene.
ethylene
hexane
hexene
isobutane
naphthalene1'2'3'4
pentachorophenol1>2
p-chloro-m-cresol2
phenols2'4
propylene
residual oils
"soltrol" (a refined kerosene, mineral spirits mixture)
styrene2'3
1,1,2,2-tetrachloroethane1
1,1,2,2-tetrachloroethene1'2
toluene1'2'3'4
trans-l-2-dichloroethylene1'2
trichloroethylene1
vinyl acetate
xylene
zinc1'2
1 Priority Pollutant
2 Detected in effluent by EPA, Dune DEQ or Universe
3 Toluene, styrene, and naphthalene were below detectable limits in
the effluent in the EPA priority pollutant samples.
4 Priority pollutants detected at significant levels at other similar
plants by EGD sampling.
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III- 86
on selected pollutants as described below. Regular moni-
toring is required for these pollutants. Monthly monitor-
ing for 6 months is required for other selected priority
pollutants. In addition, a complete priority pollutant
analysis will be required within 3 months of the effective
date of the permit. Based on the results of the first 6
months of priority pollutant analyses, a determination will
then be made whether or not to increase or decrease monitor-
ing requirements, revise effluent limits, and/or provide
increased wastewater treatment.
Chromium and zinc are used as corrosion inhibitors in the
cooling system. These toxic pollutants are present in the
cooling tower blowdown in concentrations as high as 10 mg/&.
Electrolytic treatment for reduction of hexavalent chromium
and pH adjustment and settling for removal of both chromium
and zinc are provided as pretreatment for this blowdown
stream prior to discharge to the main treatment plant. This
combined treatment is considered equivalent to BAT for these
metals. The present permit limits total chromium to 0.13 mg/£
and hexavalent chromium to 0.2 mg/£ (daily average). Efflu-
ent concentrations average about 10% of these limits (zero
for hexavalent chromium). Zinc is presently limited to 0.6
mg/2 and also averages 10% of this limit. Interim and final
limits for total chromium were established at 0.05 mg/£
based on the tentative target BAT concentration and demon-
strated plant performance. The corresponding zinc limits
were set at 0.1 mg/£ based on demonstrated plant perfor-
mance. Internal monitoring of the chrome treatment system
for total and hexavalent chromium and zinc required in the
current permit to assess the system operating efficiency was
continued. Monitoring of the final effluent for hexavalent
chromium was dropped because past data indicate essentially
zero discharge, the total chromium limit is now very low and
monitoring will be continued at the chrome treatment system
where detection of any treatment problems is easier.
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111-87
The current permit contains monitoring requirements for
the priority pollutants, naphthalene and toluene, and the
related compound styrene. These compounds have been moni-
tored as the result of several fish tainting cases that
occurred prior to the installation of the present BPT level
treatment system. Weekly monitoring for the past several
years has detected these compounds only part of the time
and then usually at trace levels, well below the 0.05 mg/£
target BAT concentration for toluene. Because these past
data were available and these substances will be controlled
indirectly by other limits, no limits were established for
naphthalene, styrene, and toluene and the monitoring re-
quirement was dropped.
Benzene is a major constitutent of the by-product DAC and
was detected in significant concentrations in EGD samples
collected at similar facilities. However, it was below
detection limits (0.001 mg/£) in the three EPA samples of
Universe effluent, the only benzene data available. An in-
terim limit of 0.1 mg/S, was established, twice the final
limit of 0.05 mg/H which was based on the tentative BAT
target concentration. Based on the limited data available,
the interim limit should be easily achievable with present
treatment. The 6-month monitoring period will allow an
evaluation of the need for additional treatment to meet the
final limit. If necessary, this could be accomplished by
pretreatment of the small 20 gpm concentrated waste stream
from the steam stripper in the ethylene area. Benzene should
serve as an indicator for toluene and other organics present
in the DAC mixture.
The remaining five priority pollutants in Table 2 were
either not detected in the EGD samples or were found to be
removed to acceptable levels by the BPT model treatment.
Neither were they present in the three EPA samples col-
lected at Universe. For these reasons, no effluent limits
or monitoring requirements were established for the five.
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111-88
There were five priority pollutants present in the EGD sam-
ples which were not adequately removed by the BPT level
model treatment. These five (anthracene, copper, fluorene,
phenanthrene, and pyrene) were not detected in the three
EPA Universe samples. No interim limits were established
for these substances. However, because of the potential
for their presence, final permit limits have been estab-
lished based on target BAT concentrations and monthly
monitoring is required for 6 months beginning with permit
issuance. Six months of monitoring should be adequate to
determine if additional monitoring and/or final permit
limits are necessary or if additional treatment will be
needed.
d. Hazardous Substances
There are 15 hazardous substances used as raw materials
or produced as products or by-products by Universe that are
not priority pollutants [Table 2]. Discharges of these sub-
stances in excess of reportable quantitities established by
regulations promulgated under Section 311 of the Clean Water
Act must be reported as spills and are subject to penalties
and enforcement actions unless such discharges are regulated
by NPDES permit limitations. All of the 15 hazardous sub-
stances are normally discharged in less than reportable quan-
tities and no permit limits have been established.
Ammonia is added as a nutrient at the wastewater treatment
plant. Universe reported an average effluent concentration
of 4.2 mg/£ in their 1977 permit application. At the ex-
pected flow of 2.14 mgd, this would be an average load of
75 Ib/day. No limit is considered necessary because feed
rates are controlled to minimize use of this substance.
Most of the hazardous substances are associated with ethy-
lene production and are recycled, used in polyethelene
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111-89
production, or sold as by-products. Any unusual releases of
these substances would be detected by Oil and Grease moni-
toring or other conventional pollutant parameters. The most
volatile substances would be removed by the wastewater
treatment plant. Residual oils and Soltrol (a kerosene
mixture) are recovered for recycle or sale. Discharge of
these substances would be measured by the Oil and Grease test.
Debutanized aromatic concentrate (DAC) is a major by-product
containing primarily benzene, toluene and xylene. Permit
limits and monitoring requirements have been established for
benzene that would detect any increased discharges of DAC.
Vinyl acetate is a raw material used in the production of
vinyl acetate copolymer plastic.
e. Monitoring Requirements
Monitoring requirements for Outfall 001 were established
based on the current permit, on Dune DEQ Rules, Chapter 18,
Rule 18.11 and Table III, and on an evaluation of DMR data.
Monitoring requirements for flow, BOD, TSS, COD and pH are
based on the current permit and require the same frequency
as Rule 18.11, Table III (Category III C industry) or an in-
creased frequency (3 vs 2/week) to assist in evaluation of
fluctuating waste loads. Oil and Grease monitoring was set at
3/week consistent with monitoring for other conventional pol-
lutants. Review of the DMR data indicates daily monitoring
of Oil and Grease is not necessary to assure adequate controls.
Monitoring for phenols and the toxic substances benzene,
chromium, and zinc was set at 1/wk based on the Table III
requirements for a Category IV D industry. The current per-
mit requires daily monitoring for chromium, zinc and phe-
nols. Review of the DMR data indicates this frequency of
monitoring is not needed on the final effluent as monitor-
ing of internal points in the waste treatment system as dis-
cussed below achieves adequate control of these parameters.
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111-90
Monthly monitoring of anthracene, copper, fluorene, phenan-
threne and pyrene for 6 months is required. As discussed
in the previous section on toxic substances, the purpose of
this monitoring is to determine the need for continued moni-
toring and/or effluent limits for these substances.
The current permit requires a variety of monitoring at in-
ternal points in the waste treatment system to provide data
for evaluation of the operation of the treatment system.
These monitoring requirements are continued in this permit
to provide continued evaluation of system operation. Three
minor modifications were made in the current permit require-
ments to achieve consistency with Rule 18.11, Table III re-
quirements. The BOD monitoring frequency was changed from
I/week to 2/week. For BOD and TSS, an additional sampling
point was established at the influent to the equalization
tank.
STORMWATER MONITORING
Four stormwater discharge points were identified during an inspection
of the Universe, Caladan facility conducted by NEIC, EPA Region VII, and
DDEQ in October 1980. None of the 4 discharge points are mentioned in the
current Dune Operating Permit. There are no data available on the quantity
or quality of water being discharged from these points. In order to evalu-
ate any environmental impact, Universe will be required to monitor the dis-
charges for one year. If after one year the data indicate that the water
from these points is uncontaminated, the monitoring may be discontinued.
However, if the data indicate that there is some contamination, the Director
may require continued monitoring and/or treatment. Each of the 4 locations
is identified below and Figure 1 shows the approximate location of each.
Outfall 002
The "large pellet pond", a small earth basin with an underflow baffle
and concrete overflow weir designated Outfall 002, is located near the rail
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111-91
scales on the eastern border of the plant. This pond receives drainage
from unpaved portions and roadways in the polyethylene area of the plant
and discharges to a small intermittent stream which runs east of the plant.
The pond acts as a trap to catch any pellets which are in the runoff. The
pellets are removed and reclaimed periodically. Flow from this pond can be
significant after a heavy rain. Some of the area which drains to this pond
is adjacent to the polyethylene processing area which increases the poten-
tial for contamination of the runoff. Paved and diked areas in the proces-
sing area drain to the wastewater treatment system. If monitoring indi-
cates contamination, it may be necessary to require that the initial flush
after a rain be captured and treated prior to discharge. This could be
done by routing the runoff to the storm pond upstream of the polishing pond
through existing gates and drainage ditches.
Outfall 003
The "small pellet pond", a very small earth basin similar to Outfall
002 and designated Outfall 003, is located on the east side of the plant
near the polyethylene loading area. This pond receives runoff from the
northern side of the polyethylene area as well as the loading area and
drains through a ditch to the small stream on the eastern border of the
plant. The pond acts as a pellet trap and the captured pellets are period-
ically removed and reclaimed. This pond receives less flow than the large
pellet pond and the drainage area has a lower potential for contamination
of runoff. No means of providing additional treatment for this discharge
is currently available.
Outfall 004
The "southeast drainage ponds", two shallow unlined earth basins, in
series with a surface area when full of about 1.0 acres, are located just
north of the large ethylene storage tank on the western border of the plant.
The lower pond discharges through an inverted drain pipe (Outfall 004) into
a drainage channel along the western border of the plant and ultimately
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111-92
Into a small Intermittent stream. These ponds drain parts of the south-
western area of the plant including the wastewater treatment plant, and
some of the tank farm area. There is some potential for contamination of
runoff at the wastewater treatment plant and by spills or leaks in storage
areas.
Outfall 005
The "flare drainage pond", an unlined shallow earth basin with an area
of about 0.5 acres, is located west of the flare on the western border of
the plant. The pond discharges through an inverted drain pipe (Outfall
005) into a cornfield on the west side of the plant. Discharge from this
pond is reportedly very infrequent and only after heavy rainfall. This
pond receives runoff from portions of the west side of the plant including
the utilities area and the flare area. Some potential for contamination of
runoff exists.
PRIORITY POLLUTANT MONITORING
Universe is required to perform a complete priority pollutant analy-
sis* on the effluent from the polishing pond, Outfall 001, within 3 months.
This initial testing is necessary to confirm if the low levels or absence
of toxic pollutants in the discharge defined by the limited available data
(3 samples) are representative of normal operations with the plant expan-
sion in place. After the first test, a complete analysis* is required
every 2 years.
Monitoring for specific toxic pollutants, as discussed earlier, is
required once a month for the first 6 months. If the results of the
6 months of monitoring indicate the presence of significant levels of tox-
ics, the permit may be modified to include monitoring of the appropriate
additional toxic substances and/or additional treatment.
* This analysis shall include the toxic metals, cyanide and total phenols,
and the volatile, base/neutral and acid extractable fractions of the gas
chromotograph/mass spectrometry analyses for organic toxic pollutants.
The pesticide fraction is excluded.
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111-93
RATIONALE FOR BEST MANAGEMENT PRACTICES - SPECIFIC CONDITIONS
All process wastewaters and most surface runoff from within process
areas are discharged to sewers which are routed to the wastewater
treatment plant. Some surface runoff is routed directly to the
polishing pond. All contaminated runoff is believed to be routed to
Outfall 001 so that it receives treatment and is frequently monitored
before discharge. This condition formally requires continuation of
this containment, treatment and monitoring to minimize discharges of
toxic or hazardous substances in surface runoff. In addition, as des-
cribed in the rationale for storm water monitoring, storm runoff is
monitored at four other outfalls to detect any contaminated runoff not
routed to Outfall 001 so revisions in storm water controls can be made
if necessary.
Universe currently stores dewatered sludges from the wastewater treat-
ment plant, "Chem-fixed" sludges from a 1974 dredging of the final
polishing pond and lime sludges dredged from the chrome treatment sys-
tem settling pond in piles in an open area southeast of the wastewater
treatment plant. Drainage from the storage area is routed with storm
runoff to the settling basin and the final polishing pond. Universe
reports that these stored materials do not meet the definition of haz-
ardous wastes as confirmed by applicable tests. However, they do con-
tain toxic and hazardous materials. This condition requires manage-
ment to minimize transport of these pollutants to the final pond by
surface runoff and leachate.
It is possible that changed conditions (changes in the characteristics
of materials being stored or the leachate, changes in test procedures,
or changes in definitions of hazardous wastes) could result in the
stored material or the leachate being classified as a hazardous mate-
rial. In such a case, the Director must be notified so that appro-
priate changes in management and storage practices can be required
under applicable RCRA regulations.
Universe has begun the operation of a small "land farm" for land dis-
posal of the wastewater treatment plant sludges. Because the sludge
is not a hazardous waste, land disposal requirements do not apply.
However, toxic or hazardous substances could be potentially present in
surface runoff from the disposal area. This runoff now goes to Out-
fall 002 which has no treatment. This specific condition prescribes
management practices to minimize surface runoff and to divert the run-
off to Outfall 001 for treatment and frequent monitoring. The runoff
diversion can easily be accomplished by a simple short earthen diver-
sion ditch.
There are several hundred 55-gallon drums stored west of the cooling
towers. Most of the drums are empty but some contain hazardous wastes
and most have contained such wastes. This condition requires that the
drums containing hazardous wastes either be removed from the plant
site or managed in a storage area that would prevent contamination of
surface runoff by spills or leaks. Any empty drums must be rinsed or
otherwise decontaminated if they are stored in the present area.
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IV-1
IV. NPDES GUIDANCE DOCUMENTS
CONSOLIDATED PERMIT REGULATIONS
The consolidated permit regulations place specific requirements on the
permit writer in the preparation of a permit. These regulations should be
familiar to every permit writer and should be referred to whenever a ques-
tion on permit contents or procedures arises.
The bulk of the regulations were promulgated on May 19, 1980, and are
contained in 40 CFR Parts 122-124. Also important is Part 125, most of
which was promulgated earlier. There have been a number of small additions
or revisions to the May 1980 regulations and more are anticipated. The
permit writer is cautioned to maintain a current awareness of such changes
and always use the latest revision.
Regulations applicable to EPA and State NPDES permits are primarily
contained in Part 122, Subparts A and D; Part 124, Subparts A and D; and
Part 125, Subparts A and K. Other sections of the regulations also apply
to NPDES permits but most are administrative procedures beyond the scope of
this manual. Appendix A contains a listing of the consolidated Permit Reg-
lations.
There are several specific regulations that the permit writer should
become very familiar with. These include:
122.7 Conditions Applicable to all Permits
122.8 Establishing Permit Conditions
122.10 Schedules of Compliance
122.60 Additional Conditions Applicable to NPDES Permits
122.61 Additional Conditions Applicable to Specified Categories
of NPDES Permits
122.62 Establishing NPDES Permit Conditions
122.63 Calculating NPDES Permit Conditions
124.7 Statement of Basis
124.8 Fact Sheet
124.52 Permits Required on a Case-by-Case Basis
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IV-2
124.56 Fact Sheets
125.3 Technology-Based Treatment Requirements in Permits
125 SubpartK Best Management Practices
EFFLUENT GUIDELINES
Promulgated effluent guidelines are, of course, key regulations of use
to the permit writer. Because new guidelines have not been promulgated for
many key industry types, the promulgated guidelines may have only limited
application. Various parts of promulgated guidelines have been revoked or
suspended. The permit writer must avoid using such guidelines as if they
were in effect. They do, however, provide useful references for BPJ
procedures.
Because the status of guideline regulations changes with time^ the
permit writer must maintain an awareness of this status and specific applic-
ability for the industry types usually worked with. If a new industry type
is encountered, the writer may wish to contact the EGD Regional Desk (Mr.
Sid Jackson, 212/426-2586) to determine the current status. A listing of
promulgated regulations is contained in Appendix B.
There are various contractors' reports, draft Development Documents,
Development Documents, and other references generated by the Effluent Guide-
lines Division that contain a wealth of information on processes, wastewater
treatment and control practices, and effluent characteristics that are of
use in developing permit conditions using BPJ procedures. Most EPA librar-
ies have copies of most of these documents. Many of these are also avail-
able from the National Technical Information Service. EGD can provide in-
formation on available references for a particular industry type.
GUIDANCE MANUALS
The Permits Division has prepared a series of guidance documents of
use to the permit writer. Others are in preparation. Application of most
of these was discussed in Section II. Available manuals include:
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IV-3
BCT Cost Test Guidance, Sept. 1980
NPDES Best Management Practices Guidance Document, Dec. 1979
Policy Book, March 1981
Toxicity Reduction Manual (Draft), July 1980
Treatability Manual, July 1980
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PART II
RCRA PERMIT PROCEDURES
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V-l
V. RCRA PERMIT PROCEDURES
Because the RCRA permit program is new, permit procedures are still
under development. There are many similarities or equalities in NPDES and
RCRA permit regulations so there are many similarities in permit processing
procedures. Many of the administrative procedures are the same and are
well established. The RCRA Permit Procedures Manaul (Draft), May 1981,
contains much detail on the administrative procedures. Chapter 4 of that
manual contains a limited treatment on how to develop ermit conditions. A
sample permit is presented in Part II of the manual but there are few
instructions on how to apply the sample permit to specific facilities.
Several Permit Guidance Manuals have been developed by the Office of
Solid Waste to assist the permit writer in preparing permits for specific
types of hazardous waste management units such as tanks, containers, and
waste piles. These manuals contain very helpful technical information but
again do not contain procedural information on how to convert application
data and technical references into specific permit conditions.
To meet the critical need for technical procedural guidance in develop-
ing permit conditions, NEIC prepared the material contained in this section
and the sample permit in Section VI. Part of this material was then pre-
sented at the permit training course given in all 10 Regions and Headquarters.
The procedural guidance parallels the NPDES procedures in the first
part of this manual. Permit development steps are presented in narrative,
tabular, and graphical form. Because of their bulk, the figures depicting
permit procedures in graphical form are presented at the end of this sec-
tion rather than throughout the text.
Basic procedures for development of RCRA permit conditions and for the
initial processing of the permit application are very similar to NPDES pro-
cedures. The RCRA basic procedures are summarized in Table 4 and shown
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V-2
graphically in Figure 1 at the end of this section. The NPDES procedures
were previously presented in similar fashion in Section II.
Significant revisions of RCRA regulations are expected to occur during
the next year. The basic procedures outlined in Table 4 and shown in Fig-
ure 1 should not change significantly as a result. However, the more spe-
cific procedures discussed below and shown in Figures 2-9 could change mark-
edly. The permit writer should use the detailed procedures carefully if
such regulation changes occur.
PERMIT APPLICATION REVIEW - PART A
The initial step in the permit process is the review of Part A of the
application for completeness. It may be necessary to request supplemental
information from the applicant to complete the application. Notification
of the applicant when the application is complete is also required. Addi-
tional information on the application process is contained in Chapter 2 of
RCRA Permit Procedures Manual.
DETERMINE IF A PERMIT IS NEEDED
Because of various changes in the permit program or in conditions at
the hazardous waste management facility applying for a permit, the facility
may not need a permit. For instance, if a facility only generates and
stores hazardous wastes, it may no longer require a permit if all wastes
are now stored less than 90 days. The facility may handle only wastes
which have been delisted and are no longer hazardous wastes. Numerous fa-
cilities are now subject to a permit-by-rule and will not require a regular
permit.
REQUEST PART B OF THE PERMIT APPLICATION
The second phase of the application process is the submission of Part B
by the applicant. Unless voluntarily submitted, Part B must be requested
by the permitting authority and the applicant, must be given six months to
submit requested data.
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V-3
Table 4
OUTLINE OF RCRA PERMIT DEVELOPMENT STEPS
1. Review Permit Application - Part A
7. Determine If the Permit Should Be Denied
Review the Part A for completeness
Request supplemental information as needed
- Notify the Applicant that Part A is complete
^ - Inadequate facilities or practices
- Major environmental problems
- Violations of Interim Status Standards
2. Determine if a Permit is Needed
8. Generator Review
- Generators and Transporters do not need a permit
- Activity covered by a Permit-by-Rule
- Excluded or delisted wastes
3. Request Part B of the Permit Application
- Define applicable Part B requirements
- Define site-specific information needs
- Request Part B
Small generator exclusion clerk
- Excluded or delisted waste check
Define Generator requirements
Notify Applicant if no permit is required
9. Transporter Review
- Generator check
- Define Transporter requirements
4. Compile Background Information
10. Define Storage Requirements
- Compile RCRA file information
- Compile other file information (NPDES, UIC, PSD)
- Compile state data
- Compile reference material
5. Review Part B of the Permit Application
Review the Part B for completeness
- Review background information for missing data
- Request supplemental information as needed
- Alternate - Conduct a facility inspection
Notify the Applicant that Part B is complete
6. Facility Inspection
- When there is a history of environmental problems
- When there is a history of non-compliance with
interim status standards
- When available information is inadequate to prepare
a permit
- When large amounts of acutely hazardous or toxic
wastes are handled
- When major land disposal or surface impoundment
facilities are present
- When a previous inspection indicates the need for
a follow-up inspection
- Wastes stored longer than 90 days
- Specific permit conditions for container, tanks,
surface impoundments, and waste piles
11. Define Treatment Requirements
- Specific permit conditions for containers,
tanks, surface impoundments, waste piles,
and incinerators
Permits-by-Rule
12. Define Disposal Requirements
New facilities only
13. Define General ,Permit Conditions
Standard conditions for all facilities
14. Prepare a Complete Modular Permit
Prepare site-specific attachments
- Compile all modules
15. Prepare a Statement of Basis or Permit Rationale
16. Prepare a Fact Sheet
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V-4
There is no Part B application form. The data required vary by type of
facility and are very detailed. Required data for each type of faciltiy
are defined in 40 CFR 122.25. Prior to requesting the Part B, the permit
writer should determine the specific data required for the facility. These
requirements should be reviewed for adequacy as additional data may be need-
ed for some complex facilities or unusual cases. It is easier to request
supplemental data at this stage rather than after an incomplete application
has been received.
Conversely, some required data may not be needed for simpler facili-
ties. Waiver of certain data requirements may be possible upon request by
the applicant.
Headquarters has provided guidance to the Regions for prioritizing
facilities for permit processing. Part B requests should be submitted to
applicants in priority order unless there are compelling circumstances to
do otherwise.
COMPILE BACKGROUND INFORMATION
The permit writer has a variety of data and reference materials avail-
able to him that will assist in reviewing the Part B when received and in
preparing permit conditions. The information is also useful in determining
supplemental data needs prior to requesting Part B. These include RCRA
file information such as interim status or uncontrolled site inspection
reports, annual reports, information in other program files including NPDES,
UIC, and sometimes PSD, and technical guidance or reference manuals. In
the case of EPA permits, State files may contain additional data, especially
if the State has its own hazardous waste permit program.
REVIEW PART B OF THE APPLICATION
When Part B is received, it must be reviewed for technical and adminis-
trative completeness within 30 days for new facilities and 60 days for ex~
isitng facilities. The applicant is then notified that Part B is complete
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V-5
or supplemental Information is requested. A facility inspection may be
necessary in some cases to verify data or compile supplemental information.
The adequacy of Part B data is a key to efficient preparation of a
comprehensive permit. Thorough review of the Part B at this stage is thus
very important. A lengthy checklist to assist the permit writer in this
review is presented in Appendix A-5 of the RCRA Permit Procedures Manual
The Part B data should be compared to the background information and
discrepancies noted. In some cases, the background data may adequately
supply missing Part B information and a supplemental request would not be
needed.
INSPECT THE FACILITY
There are several factors that would indicate the need to inspect the
facility prior to permit development. These are listed in Table 4 and shown
in Figure 1. If a facility has been inspected, there may still be a need
for a follow-up inspection if the previous inspection did not include obser-
vation or documentation of critical activities or data.
As in the case of the NPDES program, resources are not adequate to
allow permitting inspection of all facilities. It may be feasible to ob-
tain the necessary information as part of an NPDES compliance inspection or
a State inspection if information needs are communicated to these inspec-
tors. Aerial photographs can also yield very useful information on many
facilities.
DETERMINE IF THE PERMIT SHOULD BE DENIED
For a minority of facilities, the background and application data and/
or inspection observations may indicate that the facility is a poor opera-
tion which cannot be satisfactorily improved and/or a major environmental
hazard. Denial of the permit which causes the facility to terminate opera-
tion may be the desired course of action in such cases.
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V-6
GENERATOR REVIEW [Figure 2]
A majority of hazardous waste management facilities are generators of
hazardous waste. Generators which do not conduct any other hazardous waste
management activities are subject to Part 262 regulations but are not re-
quired to obtain a permit. A generator may also not be required to get a
permit even if other activities are conducted if these activities meet cer-
tain requirements. These include storage of wastes for less than 90 days,
generation of waste volumes less than specified amounts, onsite disposal of
small volumes of waste in State licensed solid waste disposal facilities,
and various other exclusions. Exclusion or delisting of a hazardous waste
by recent revision of Part 261 regulations may also result in a facility no
longer requiring a permit.
The application data should be carefully reviewed against Figure 2 and
the latest lists of hazardous wastes established in Part 261 regulations to
determine if the facility may be excluded from permit requirements. Fig-
ure 2 contains references to specific regulations at each decision box to
assist the permit writer in correctly evaluating potential exclusions.
TRANSPORTER REVIEW [Figure 3]
Transporters of hazardous wastes are subject to Part 263 regulations
but do not require a permit unless they also treat, store, or dispose of
hazardous wastes. As shown in Figure 3, they may also be a generator sub-
ject to Part 262 regulations if they mix hazardous wastes in the same con-
tainer. Such a facility should then be subjected to the Generator review
[Figure 2].
DETERMINE APPLICABLE STORAGE, TREATMENT AND DISPOSAL STANDARDS [Figure 4]
Once the above procedural steps have been accomplished, the permit
writer is ready to precede with development of permit conditions specific
to the facility. This requires determining which Part 264 permit standards
apply. This can be accomplished in a general sense by reviewing Figure 4
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V-7
and then reviewing Figures 5 through 9 as appropriate to determine specific
standards.
Permit standards in effect at the time of manual preparation covered
new and exisitng facilities using containers, tanks, surface impoundments,
and/or waste piles for storage or treatment of hazardous wastes, new and
exisiting incinerators treating hazardous wastes and new landfills. This
manual does not cover landfill standards because they are not easily adapted
to this method of presentation. Figure 4 defines the standards presented
in this manual.
Figures 5 through 9 are designed to be used with the sections of the
Sample Modular Permit in Section VI that contains standard conditions for
specific types of treatment or storage facilities. By following applicable
paths of the flow chart, the permit writer receives instructions which guide
him through the development of permit conditions. It is suggested that the
permit writer skip ahead to Section VI and read the procedures for using
modular permits before reading the material below for the first time. In
this manner, a better understanding of the application of these flow charts
can be obtained.
CONTAINER STORAGE STANDARDS [Figure 5]
Figure 5 outlines procedures for developing permit conditions for con-
tainer storage facilities. It should be used with the Standard Conditions
for Container Facilities segment of the modular permit in Section VI. An
example of the use of Figure 5 follows.
Beginning at the top Start block, the permit writer follows the arrows
downward, branching at each diamond-shaped decision block as specific condi-
tions dictate. If wastes are not stored more than 90 days, no storage re-
quirements are involved and a return to the treatment segment of Figure 4
is indicated. If wastes are stored for a longer period, a determination is
made if this storage is in containers. If so, the permit writer is in-
structed to review the Part B information on the containment system. This
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V-8
information in compared to the design requirements contained in 40 CFR
264.175(a). These design requirements are described in Condition C-5 of the
Standard Conditions for containers in the Modular Permit in Section VI.
This reference is indicated by the C-5 in larger type to the right of the
design decision box.
If the design is inadequate, the permit writer is faced with a decis-
ion on whether to require the facility to be improved or deny the permit.
This decision would usually be based on the feasibility of upgrading the
containment system. If improvements are feasible, two approaches are pos-
sible. The effective date of the permit might be delayed and the facility
continued in interim status until improvements are made or a compliance
schedule could be established in the permit to require the improvements to
be completed by a specified date.
The permit writer now determines if run-on of surface runoff from ad-
jacent areas into the containment system is prevented as required by
264.175(b) and condition C-6 of the Modular Permit. If not, the capacity
of the containment system must be evaluated. If excess cpacity is suffic-
ient, the run-on prohibition may be waived. This is accomplished by a spe-
cific condition in the Other Requirements section of the Modular Permit.
(See condition 1 for an example.)
In the same manner, the permit writer proceeds through the remainder
of Figure 5, reviewing appropriate application data and documents and pre-
paring tabular material and specific permit conditions that are site-
specific as directed by the flow chart and the standard permit conditions.
TANK STORAGE OR TREATMENT STANDARDS [Figure 6]
Figure 6 provides guidance to the permit writer in the development of
permit conditions for tank storage or treatment facilities. It is used in
the same manner as Figure 5 for containers and is used with the Modular
Permit.
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V-9
SURFACE IMPOUNDMENT STORAGE OR TREATMENT STANDARDS [Figure 7]
Permit conditions for surface impoundments used for storage or treat-
ment of hazardous wastes may be developed using Figure 7 and the Modular
Permit. These procedures cannot be used to develop permit conditions for
surface impoundments used for disposal as Permit Standards for such facil-
ities have not been promulgated.
WASTE PILE STORAGE OR TREATMENT STANDARDS [Figure 8]
Permit conditions for waste piles may be developed using Figure 8.
The same restrictions as for surface impoundments apply.
INCINERATOR STANDARDS [Figure 9]
Figure 9 can be used to assist the permit writer in developing permit
conditions for incinerators, determining when a waiver from most permit
conditions can be granted when only ignitable wastes are burned and develop-
ing trial burn permit conditions.
At the time of manual preparation the sample permit conditions for
incinerators were undergoing revision. The sample conditions presented in
Section VI are not in the same modular format as for other types of facili-
ties. Consequently, Figure 9 does not contain specific references to sam-
ple permit conditions.
Figure 9 is based on both promulgated and proposed incinerator regula-
tions. References to hazardous combustion by-products, more or less strin-
gent performance standards, and performance standards for metals and halo-
gens refer to proposed regulations. The permit writer is cautioned to de-
termine the current status and form of regulations on these aspects of the
incinerator standards before applying Figure 9.
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V-10
DEFINE GENERAL PERMIT CONDITIONS
The Consolidated Permit Regulations require the various permit condi-
tions concerning inspections, contingency plans, training, security, etc.
be included in permits for all types of facilities. Examples of appropri-
ate general permit conditions are not presented in Section VI but can be
obtained from Part II of the RCRA Permit Procedures Manual.
PREPARE A COMPLETE MODULAR PERMIT
As descussed in Section VI, a complete modular permit contains several
pages of site specific information in addition to the General Conditions,
Standard Conditions for specific types of facilities, and Other Require-
ments. These permit components should be prepared at this time. The var-
ious modules can now be compiled into a complete permit.
PREPARE A STATEMENT OF BASIS OR PERMIT RATIONALE
The permit writer's job is not complete until he has documented the
basis for all conditions in the permit. This should be complete and ade-
quately detailed so that no questions remain as to the justification and/or
authority for each condition. This both assists in the defense of the per-
mit if necessary and provides major assistance to subsequent permit writers
when the permit is reissued years later.
PREPARE A FACT SHEET
The last step required by the Consolidated Permit Regulations prior to
placing the draft permit on public notice is to prepare a Fact Sheet.
-------
FIGURE 1
BASIC RCRA PERMIT PROCEDURES
-------
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-------
FIGURE 2
GENERATOR REVIEW
-------
FIGURE 2
FLOW CHART OF GENERATOR REVIEW STEPS
V-12
Yes
Does the facility generate
Hazardous Wastes? 260.10(a)(26),
262.10(c), 263.10(c)(2)
No
The facility is a Generator
and is subject to Part 262
>
Yes
Yes
Yes
The facility is not a
Generator and is not
subject to Part 262
(GO to Figure 3J
Does the facility import HW
from outside the U.S.? 262.10(c)
No
to Figure
The facility is not a Generator
and is not subject to Part 262
Does the facility generate
a HW that has been excluded
from regulation by 261.4 or
has been delisted (261 Dl or
excluded by petition (261.22)?
No
c
Go to the Next
-SIs this the only HW generated?\-
No
f
Are any other HW management
activities (.transportation,
treatment, storage, disposal)
conducted at this facility?
No
The facility is no longer
classified as a Generator
and no permit is required
Notify the Applicant
-------
V-13
FIGURE 2 (Cont.)
f Continued from
V previous page
Are all the HW generated in a product
or raw material storage tank, transport
vehicle or vessel, a manufacturing process
unit, or an associated non-waste treatment
manufacturing unit? 261.4(c)
Mo
yes / Is the generating unit a
N. surface impoundment? 261.4(c)
Yes
Are HW accumulated in the
generating unit for more than
90 days after operations have
stopped? 261.4(c)
The facility is a
Generator and is
subject to 40 CFR
Part 262
Yes
The HW are excluded from
regulation under 40 CFR
Parts 122-124 and 262-265
until they exit the generating
unit 261.4(c)
f
Does the facility generate
more than 1,000 kg of HW in
any month? 261,5(a)
/Go to the
V Next Page
-------
Yes
Yes
The facility is a Generator
subject to Part 262
( Go to Figure 3j
Notify Applicant
FIGURE 2 (Cont.)
: Continued from \
previous page J
Are more than the volumes of
acute HW (261.33) specified
in 261.5(e) generated in any
month?
Yes
Are the HW stored for more
than 90 days after the
261.5(f) exclusion limits
are exceeded? 262.34(a)
Yes
The facility is a small
Generator and does not
require a permit. It is
subject to 262.11 and
262.34(a)
V-14
No
Yes
Go to
next page
Are more than 1,000 kg
of HW or more than the
volumes of acute HW specified
in 261.5(e) accumulated at
any time? 261.5(f)
Mo
Are all wastes shipped
off-site? 261.5 (g)(3)
262.34(a).(l)
No
Are all wastes treated or
disposed of on-site? 261.5(d)
No
All off-site shipments subject
to small generator requirements
262.11, 262.34(a)
-------
V-15
FIGURE 2 (Cont.)
Continued from \
previous page )
Yes
Does all on-site treatment or
disposal of wastes occur in facili-
ties permitted, licensed or
registered by the State to manage
municipal or industrial solid
waste? 261.5 (g)(3)
The facility is a
small generator and
does not require a
permit. It is sub-
ject to 262.11
requirements
Notify Applicant
A treatment or
disposal permit
is required
Yes
Yes
Yes
Notify the Applicant
Go to
Next Page
Are all wastes that are treated
or disposed of on-site that are
not handled in the State regulated
facility treated in an elementary
neutralization unit or wastewater
treatment unit subject to a permit-
by-rule? 261.5(g)(3) and 122.26(d)
Are any sludges generated by the
wastewater treatment facility
classified as HW?
Are any of these sludges treated,
stored or disposed of in surface
Impoundments, sludge drying beds,
landfills and/or land treatment
facilities? 122,26(d)(2)Jii)
Has the Regional Administrator
terminated the eligibility of this
facility for a permit-by-rule?
122,26(d)(2)
The facility is a small Generator
and does not require a permit. It
is subject to the requirements of
262.11 and 266
No
No
-------
FIGURE 2 (Cont.)
s ~~
Continued from
previous page
V-16
Are all wastes not treated or disposed
of on-site in a state-regulated facility
or an elementary neutralization unit or
a wastewater treatment unit covered by a
permit-by-rule treated or disposed of in
a facility which beneficially uses, reuses,
recycles or reclaims the HW? 261.5(g)(3)(v
The facility is a
small generator and does
not"require a permit.
It is subject to the
requirements of 262.11
Notify Applicant
The facility is a small
generator with on-site
treatment or disposal in
a RCRA permitted facility.
It is subject to the require-
ments of 262.10(b), 262.11,
262.12, 262.40(c) & (d) and
262.43
A treatment or disposal
permit is required
261.5(g)
to Figure 3 j
-------
FIGURE 3
TRANSPORTER REVIEW
-------
V-17
FIGURE 3
FLOW CHART OF TRANSPORTER REVIEW STEPS
Is the facility a Transporter as
defined in 260.10(a)(72)?
The facility is subject
to Part 263
T Go to Figure 4 )
~
Does the facility mix different
types of HW in the same container?
263.10(c)(2)?
The facility is a Generator
and is subject to Part 262
-------
FIGURE 4
APPLICABLE STORAGE AND TREATMENT STANDARDS
-------
V-18
FIGURE 4
FLOW CHART OF APPLICABLE STORAGE AND TREATMENT STANDARDS
Yes
Yes
Yes
Review Figure 6
Tanks
Yes
Are HV! stored for
more than 90 days?
No
to Hext Paq'e)
Review Figure 7
Surface Impoundments
Yes
Review Figure 8
Waste Piles
,
Review Figure 5
Containers
\ Containers? 262 Subpart \ /
f
Are HW stored in
Tanks? 262 Subpart J
Are HW stored in
Surface Impoundments?
262 Subpart K
No
Are HW stored in
Waste Piles?
262 Subpart L
No
Go to Next
PageVf-
-------
V-19
FIGURE 4 (Contd)
S v
Continued from
Previous Page
Yes
Are HW treated at
this facility?
to Next
Page)
Review Figure 6
Tanks
Yes
Yes
Review Figure 8
Waste Piles
Yes
Review Figure 9
Incinerators
JL
Yes /Are HW treated in \No
\. Tanks? 262 Subpart J /
Are HW treated in
Are HW treated in
Waste Piles?
262 Subpart L
Are HW treated in
an Incinerator?
262 Subpart 0
No
'
'
Review Figure 7
Surface Impoundments
262 Subpart K /
i
f
No
Go to Next
-------
Yes
Interim Status
Standards Apply
to those units
Yes
Interim Status
Standards Apply
to Disposal Units
FIGURE 4 (Contd)
s* s
Continued from
Previous Page
Are HW treated in N
any other type of unit?
No
Are HW disposed of
at this facility?
No
Review Figure 10 for
Applicable General Conditions
V-20
Prepare Complete Modular Permit
Prepare Permit Basis
Prepare Fact Sheet
\
-------
FIGURE 5
CONTAINER STORAGE
-------
FIGURE
FLOW CHART OF CONTAINER STORAGE PERMIT DEVELOPMENT STEPS
V-21
No permit conditions
for container manage-
ment are required
264.170
YES
/ Are hazardous wastes stored for more \
\ than 90 days? 262.34(b) >
/ Are hazardous wastes stored in con- \ NO
\containers? 264.170
J
j Go to Treatment Flow^v
"I Charts (Figure _4_) )
f Go to Tanks Flow
"V Chart (Figure «_)
YES / Are the containers empty as defined \
\ in 261.7? /
NO
Go to Tank-; Flow Chart
£_)
Review the Part B information
on the containment system
(C-5(a-c))
Does the containment system meet the
design requirements for drainage and
containment of leaks and spills?
175(a)
NO
\ contai
\264.17
Negotiate improvements
to the containment system
to be completed prior to
the effective date of
the permit
YES
Is it feasible to upgrade the contain-
ment system to meet the design require-
ments
NO
Deny the Permit—*
YES
Is run-on to the containment system \NO
(C-6)
\prevented? 264.175(b)
f
YES
i
Does the containment system have suffi-
cient excess capacity to handle run-on?
NO
Waive run-on prohibition
(Other
Requirements)
-*"\Go to next oage
-------
FIGURE
(CON'T.)
( Continued from previous page \
V-22
Review the Operating and
Contingency Plans
(C-l, 2, 3, 4, 7)
YES
Are provisions for transferring wastes
from leaky containers, managing contain
ers and removing collected liquids from
the containment system compatible with
264.171, 264.173 and 164.175(c)?
NO
Review the Inspec-
tion Schedule
(C-8,
NPDES,
Other
Requirements)
Request appropriate revisions of
the Operating and/or Contingency
Plans
YES
Are provisions for inspecting contain- \v
ers and the containment system adequate? \
264.174 /
Request revision of the
Inspection Schedule
Are provisions in the Contingency Plan \
adequate for remedying Containment system V
deficiencies 264.156 /
(C-9)
(C-10)
Review Closure Plan (C-ll)
YES £ Are any ignitable or reactive wastes
handled?
(C-12 to 14)
NO
Specify special requirements
for such wastes 264.176
_YES / Are any incompatible or reactive \ NO
\ wastes handled? /
(C-15 to 18)
Specify special requirements)
for such wastes 264.177 I
Go to Tanks Flow
Chart (Figure 6
-------
FIGURE 6
TANKS STORAGE
-------
V-23
FIGURE J>
FLOW CHARTS OF TANKS STORAGE PERMIT DEVELOPMENT STEPS
START
YES
Does the facility treat or store Hazard
ous wastes in tanks? 264.190
Go to Surface Impoundments
Flow Charts [Figure ' ]
YES
Are any of the tanks covered underground tanks
tanks that cannot be entered for inspection?
,264.190(b)
The underground tanks currently can-
not be included in this permit and
remain in interim status 264.190(b)
YES
Are these the only tanks?
NO
Go to Surface Impoundments
Flow Charts [Figure ~J ]
Review the tank design information plans, speci-
specifications and other appropriate background
information including interim status inspection
reports 264.191
Compute minimum shell thicknesses for each tank
based on material of construction, tank dimen-
sions, wastes to be stored, liners and corro-
sion rates
(T-l)
(Table T)
Derate the tank and
specify lower liquid
depth.
Are any required minimum thicknesses greater
than existing shell thicknesses?
NO
Specify special inspec-
tion closure require-
ments
(T-l)
YE
Is the expected life of any tank less than
he permit expiration date?
NO
Go to next page'"
(Other Requirements,
Inspection and
Closure Plans)
-------
V-24
YES
( Continued from previous page )
Review data on overfilling controls and (for closed)
tanks) pressure controls 264.190 and 192(b) I
(T-l, 2)
JL
YES
Are existing controls adequate?
Negotiate with the applicant
for modification of controls
prior to effective date of
permit
Are any tanks uncovered?
264.192(b)(2)
Specify minimum freeboard
or maximum liquid depth
(Table T)
(T-l)
Prepare a table listing tank de-
scriptions, wastes to be handled
in each tank, minimum shell
thickness, overfilling and
pressure controls, minimum
freeboard and maximum liquid
depth
Are the materials compatible?
Review the compatability of the wastes
handled with the material of construc-
tion of each tank 264.192(a)
(T-4)
Is a compatible inner liner or coat-s
ing or alternate means of protection
provided? 264.192(a)
Limit wastes handled in the tank
to those compatible with the tanki
materials
Review the Inspec
|
tion Schedule p*
Does the schedule specify inspection
requirements consistent with
264.194(a)(l-5)
(T-3, 4
Table T)
Request the applicant to make
the appropriate revisions in
the Inspection Schedule
(T-5, 6)
Does the schedule define periodic com-
prehensive inspections consistent with
264.194(b)? .
(T-7)
NO
'Go to next pagei
-------
V-25
G
Continued from previous page
Review the Contingency Plan
(T-8, 9)
Does the Plan specify adequate procedures
for remedial work to correct deficiencies
discovered during inspections and to re-
spond to spills and leaks? 264.15(c) and
264.194(c)
Request appropriate revisions'
in the Contingency Plan !
YES
Are any ignitable or reactive wastes
handled? 264.198
NO
(T-ll, 12)
Specify special requirements
for such wastes 264.198(a)
YES /Are any such wastes stored in closed\
tanks? /
NO
(T-13)
(Table T)
YES
Do tank spacings comply with NFPA \ NO
buffer zone requirements? 264.198(b) /
Prohibit storage of ignitable or \
reactive wastes in any tank not j
meeting these requirements
YES
/Are any incompatible wastes or wastes
"\ and materials handled? 264.199 /
(T-14 to 16)
_J Specify special requirements for
| such wastes 264.199(a) and (b)
VE5 / Review the Closure Plan \ NO
\ Is the Closure Plan adequate?/
_____
Request appropriate revisions
in the Closure Plan
Specify closure requirements
for tanks 264.197
Go to Surface Impoiindments Flow
Charts (Figure _/_)
-------
FIGURE 7
SURFACE IMPOUNDMENTS
-------
V-26
Figure 7_
FLOW CHART OF SURFACE IMPOUNDMENT PERMIT DEVELOPMENT STEPS
Start
/There are currently no\ Yes
/ standards for a surface\'
I impoundment used for I
\disposal jf
Yes
Is the Surface Impoundment used
for disposal? 264.220
No
Is the Surface Impoundment de-
signed for complete containment?
64.221(c)
No
(S-l)
Yes
Is the only discharge a discharge
to surface waters authorized as
part of an NPDES permit? 264.221(c
There are currently no \
->; standards for a surface )
\ impoundment discharging I
\^p land or groundwaters '
Specify permit conditions
(Other Requirements) relative
to compliance of discharges
with NPDES permit requirements
(Other Requirements)
Review the detailed design information
and Operating Plan for the impoundment
and containment system submitted with
Part B
Yes
Are the design and operation adequate
to prevent overtopping? 264.222(a)
No
(S-4)
Negotiate for necessary im-
provements to be made prior
to permit issuance
Yes
Can improvements be made to
prevent overtopping? .
No
(S-5)
Is a freeboard larger or smaller
than 2 feet needed or allowable
264.221(a)
No
Deny the permit
C
Specify freeboard
Yes
(S-2)
Are waste inflow controls
adequate? 264.221(b)
No
Go to the Next
Page)
-------
V-27
Figure
(Continued)
FLOW CHART OF SURFACE IMPOUNDMENT PERMIT DEVELOPMENT STEPS
Continued from Previous Page
Yes
No
Does the impoundment have
.earthen dikes?
Yes
Yes
Is the design of the dikes
structurally adequate?
264.221(d)
(.S-6, 8)
Negotiate for the necessary
improvements to be made prior
to permit issuance
Yes
Can the dikes be made
structurally adequate?.
No
Deny the Permit :-•*-
( Stop
(S-6, 7, 8)
Are operation and maintenance
procedures adequate to protect
the dike integrity? 264.222(d)
and 223(a)
Request revisions in the
Operating Plan
Is run-on diverted away from
the impoundment? 264.222(e)
No
Require diversion of
run-on
Is the design of the leachate
system adequate? 264.221(e)
No
(S-9)
(S-10)
Negotiate for the necessary im-
provements to be made prior to
permit issuance
'Can the system be \ No
adequately improved?.
Yes
Does the Operating Plan require
timely removal of collected
leachate? 264.222(c)
Request revision of the
Operating Plan
Yes
Is the collected leachate re-
turned to the impoundment?
No
(S-ll)
~V£
Go to the Next
Specify leachate disposal
requirements
(S-10)
(Other
Requirements)
-------
Figure /- (Continued)
FLOW CHART OF SURFACE IMPOUNDMENT PERMIT DEVELOPMENT STEPS
V-28
(Continued from Previous Page ,
*
Yes
Is the design and construction of the
^the liner system adequate? 264.223(5}
No
(S-l)
Negotiate for the necessary
improvements to be made prior
to permit issuance
Yes
the liner system be
improved to acceptable
f \
Is the liner system constructed above
the water table? 264.223(b)(2)
(Other Requirements)
Specify requirements for
control of groundwater
Deny the Permit (-*
Stop
Yes
Is the water table con-
trolled to a level below
the liner system?
Yes
Is the life of the containment
\Dermit period? 264.223(c) .^
\
Spec
** UdSt!
cont
,
ify a closure date
d on life of the (Clc
ainment system
./^ Are the wastes to be tre
^es ^s^ stored in the surface im
^\ ment compatible with the
\^264.223(d)
liable b)
Prepare a table listing allowable
L— •- "if wastes or Lypes uf wastes fur1 edi.li
surface impoundment 122.19(a)
ated or ^*v.
pound- ^s^ ^°
lining? ^/^
Delete any incompatible
wastes from the list of i
wastes allowed j
(Closure Plan)
(S-3)
Review the Inspection Plan
Does the Plan specify adequate
inspection procedures and fre-
quencies? 264.226 and 227(a)
Si - - — - - - . . L - _-——
(S-12, 13, 14)
No
Request revisions of the
the Inspection Plan
Go to the Next
PageX—-
-------
V-29
Figure / (Continued)
FLOW CHART OF SURFACE IMPOUNDMENT PERMIT DEVELOPMENT STEPS
Continued from Previous
Page")
Review the Contingency
>
Plan]
Yes
Does the Plan specify adequate pro-
visions for removing an impoundment
from service in case of a containment
system failure, for repair of the con-
tainment system and for restoring an
impoundment to service? 264.227(b-e)
(S-15, 16)
Review the Closure Plan
Request revisions of
the Contingency Plan
Are closure procedures
adequate? 264.227(f)
264.228
No
(S-17, 18)
T
Request revisions of i
the Closure Plan
Yes
(S-19)
Are any ignitable or
reactive wastes handled?
No
Specify special requirements
for such wastes 264.229
Yes
Are any incompatible
wastes handled
Specify special requirements
for such wastes 264.230
(S-20)
Extract appropriate design specifi-
cations and information on the con-
tainment and leachate systems and
attach to the permit as permit
conditions
Go to the Waste Piles
Flow Chart (Figure 8 )
-------
FIGURE 8
WASTE PILES
-------
V-30
Figure 8
FLOW CHART OF WASTE PILES PERMIT DEVELOPMENT STEPS
There are currently\
no standards for V
• waste piles used for/'
\disposal J
Yes
Start
Is the waste pile
for disposal? 264.250
No
(P-1)
Yes
Yes
Is the waste pile designed for
complete containment? 264.25(bL
No
Is the only discharge a discharge
to surface waters authorized as
part of an NPDES permit? 264.252(c)
here are currently >.
no standards for a \
waste pile discharging]
to land or groundwaterx
Specify permit conditions (Other Re-
quirements) relative to compliance
of discharge with NPDES permit re-
quirements
(Other
Requirements)
Review the detailed design informa-
tion and the Operating Plan for the
waste pile and containment system
submitted with Part B
(P-2)
Yes
Are the design and the operating^
procedures adequate to control wincp
ispersal of wastes? 264.25(a)
Specify control
practices 264.252(a)
IT
Yes
No
Require diversion
"" — ^waste pi le.'
264.252(b) /^
ot
run-on
1
(P-3)
Are procedures for collection and
control of leachate and run-off
from the pile adequate? 264.252(c)
Specify collection and
control procedures in
the Other Requirements
(P-3)
Go to the Next
(Other
Requirements)
-------
V-31
Figure _8 (Cont.)
FLOW CHART OF WASTE PILES PERMIT DEVELOPMENT STEPS
Continued from Previous Page;
Yes
Does the waste pile base have an
underlying leachate detection sys
tern? 264.253(a)(3)
(P-5)
_L
Is the design of the leachate detec-
tion system adequate? 264.253(a)(3)
No
Negotiate for the necessary im-
provements to be made prior to
permit issuance
Yes
Can the system be "X No
adequately improved?/
Do operating procedures require
timely removal of collected
leachate?
No
(P-5)
Request revision of
the Operating Plan
c
Yes
Is the design of the waste
pile base adequate? 264.253(a)
Negotiate for the necessary
improvements to be made prior
to permit issuance
Yes
Can the base be ad
equately improved
Yes
(Other
Requirements)
Is the liner system constructed above
the water table? 264-253(a)(3)
Specify requirements for
control of the ground-
water
Is the water table
controlled to a level
below the liner? /
Do operating procedures ad-
equately protect the contain-
ment system from plant growth?
264.253(c)
(P-7)
"vGo to Next Page—•>-
Request revisions of
Operating Plan
-------
V-32
Figure
FLOW CHART OF WASTE PILES PERMIT DEVELOPMENT STEPS
( Continued from Previous Page1;
v— .__/
Yes
Is the life of the containment system
at least as long as the permit period?
264.253(d)
No
Yes
(Table WP)
Specify a closure date based
on life of the containment-
system
Are the wastes to be treated or stored
in the waste pile compatible with the
lining? 264.253(b)(l)
No
Prepare a table listing allow-
able wastes or types of wastes
for each waste pile 122.29(a)
(Closure
Plan)
(P-6)
Delete any incompatible
wastes from the list of
wastes allowed
Review the Inspection Plan
(P-8, 9)
Yes
I
ioes the Plan specify adequate in-
spection procedures and frequencies?
264.254 and 255(a)
Request revisions of
the Inspection Plan
Review the Contingency Plan
Yes
Does the Plan specify adequate provisions
for removing a waste pile from service in
case of a containment system failure, for
repair of the containment system and for
restoring a waste pile to service?
264.255(b-e)
Review the Closure Plan
Request revisions of
the Contingency Plan
(P-10, 11)
Are closure procedures adequate? \ No
264.255(f) 264.258
(P-12, 13)
Request revisions of
the Closure Plan
Go to the Next
PageJ-"
-------
Figure 3 (Cent.)
FLOW CHART OF WASTE PILES PERMIT DEVELOPMENT STEPS
V-33
Continued from Previous Page
Yes
Are any ignitable or reactive
wastes handled?
No
Specify special requirements [
for such wastes 264.256
Yes
Are any incompatible wastes
handled? -
No
Specify special requirements
for such wastes 264.257
Extract appropriate design specifica-
tions and information on the contain-
ment and leachate systems and attach
to the permit as permit conditions
t
Go to the Incinerator Flow Chart j
(FigureJ-' ) J
(P-14)
(P-15 to 18)
-------
FIGURE 9
INCINERATORS
-------
V-34
FIGURE 9
FLOW CHART OF INCINERATOR PERMIT DEVELOPMENT STEPS
Yes
Yes
No
The incinerator is exempt from
most 264 Subpart 0 conditions.
Specify limited incinerator permit
conditions based on 262.341 & 351.
( Go to Figure 10J
Is the Part B information
adequate to fully describe
wastes to be incinerated and
incinerator operations and to
meet the requirements of
122.25(b)(5)(i), (ii) or (iii)?
Has the applicant requested an
exemption from incinerator
standards under 264.340(b)
for ignitable wastes?
Are all the wastes incinerated
classified as hazardous only
because they are ignitable?
264.340(b)(l)
Are any of the waste constituents
listed in Part 261, Appendix VIII?
264.340(b)(2)
Go to Next
PageJ
Mo
The incinerator is subject
to 264 Subpart 0 conditions
Go to Next
Page)
-------
Yes
No
Yes
Yes
Yes
Go to the
Next Page
FIGURE 9 (Cont)
Continued from
Previous Paqe
V-35
JL
Has the applicant submitted
the results of a trial burn?
122.25(b)(5)(ii)
Has the applicant submitted
an application for a trial
Yes
Is the trial burn
122.27(b) /
".
t
urn \ NV
mplete? /
Request Supplemental
Information 122.27(b)(2)
Specify trial burn
procedures including
POHC's 122.27(b)(3)
\
/
.application complete? /
Information 122.27(b)
Issue trial
burn permit
122.27(b)(4)
Trial burn completed
and results reported
122.27(b)(5)(k)(iii)
Has the applicant submitted
information in lieu of
a trial burn? 122.25(b)(5)(iii)
.27(b)(5)(k)(iii)
Request
Supplemental
Information
Is the information adequate
to develop permit conditions?
No
Alternate
-------
V-36
Yes
Yes
FIGURE 9 (Cont)
~ •%
Continued from
Previous Page
Specify one or more POHC's
and hazardous combustion
by-products from Part 261,
Appendix VIII for each waste
feed to be burned 264.342(b)(l)
J
Do the trial burn or other
data show that the incinerator
achieves 99.99* destruction
and removal efficiency for
each POHC? 264.343(a)
Do.the trial burn or other
data show that the incinerator
reduces hazardous combustion
by-products to less than 0.01%
of waste feed POHC's?
264.34 3 (_d)
Do the trial burn or other data
show that the incinerator emits
less than allowable levels of
particulate matter?
264.343(c)
JL_
Does the incinerator burn
wastes containing more than
0.5% chlorine? 264.343(b)
JL
Do the trial burn or other data
show that the incinerator
removes more than 99%
of HC1 from the exhaust gas?
(264.343(b)
No
Go to
Point B
Next Page
No
No
-------
V-37
FIGURE 9 (Cont)
(Goto ^
Point D
Next Page ,*•
Yes
/ Go to
( Point E
\^ Next Page
Yes
Are less stringent
performance standards
potentially acceptable
for this case?
264.343(e)(2)
Are application data adequate
to develop revised operating
procedures so that the incinerator
will meet the specified performance
standards? 262.343 & 345
Is the incinerator design
technically capable of meeting
acceptable performance
standards? 262.343
Specify requirements
for a new trial burn
122.27 (b)(4)
Go Back to
Point A
Previous Page
•J5^
Issue a trial
Iburn permit
122.27(b)(4)
i
Trial burn completed and
results reported
122.27(b}(5)(k)(im
-------
FIGURE 9 (Cont)
V-38
No
Are performance standards
for metals, hydrogen
solids and/or elemental
halogens potentially needed
for this case? 264.343(f)
Are more stringent performance
standards potentially needed
.for this case? 264.343(e)(l)
Request supplemental
emissions, air dispersion,
human and environmental
exposure and exposure
consequence data
264.343(g)
Go to Point F,
Page 2?
Yes
Yes
Specify the standard
performance standards
262.343(a)to (d)
Review the incinerator design
& control system characteristics
122.25(b)(5), 122.27(b)
Does the incinerator
have an adequate
means of controlling
fugitive emissions
from the combustion
zone? 262.345(d)_
Require adequate
control system
262.345(d)
Yes
Is it technically
feasible to install
adequate controls
on this incinerator?
Is an adequate
automatic waste feed
cutoff system provided?
262.345(e)
No
Require an
automatic system
Go to Point G, \
Page SO /'
-------
V-39
FIGURE 9 (Cont)
Yes
Review supplemental data
264.343(e)
Are performance standards for metals,
halogen halides and/or elemental halogens
needed for protection of human health
and the environment? 264.343(f)
Specify appropriate
performance standards
Are more stringent performance
standards necessary to protect
human health and the environment?
264.343(e}(l)
No
Specify appropriate
performance standards
Will less stringent performance standards
achieve emission rates that provide adequate
protection of human health and the
environment? 264.343 (e) (.2)
.Specify appropriate performance standards
less stringent than 264.343(a) to (d)
for one or more characteristics
Go to Point G,
Page 30
Go back to
Point B
Page £ 7
-------
V-40
FIGURE 9 (Cont)
Review the operating
requirements submitted
in the Part B application
122.25(b)(5)
Are the operating
requirements adequate?
264.345
No
Incorporate them in the
permit conditions
264.345(a)
Specify waste analysis (264.341(b)),
monitoring and inspection (264.347)
and closure (264.351) conditions
Go back to
Figure 4
Specify additional
or revised operating
requirements 264.345(b)(6)
-------
VI-1
VI. RCRA SAMPLE PERMIT
This section presents a sample permit that includes permit forms and
general conditions applicable to all types of hazardous waste management
facilities; sets of standard permit conditions applicable, respectively, to
container, tank, surface impoundment, waste pile, and incinerator hazardous
waste management units; and examples of site-specific permit conditions for
these five kinds of units. The sample permit is based on 40 CFR Part 265
permit standards that became effective in July 1981. All site-specific
examples are hypothetical because no actual permits were yet available.
The sample permit is in a modular format [Table 5] that is designed to
minimize permit preparation time. Various pre-printed standard components
or modules can be selected from available modules and assembled as appro-
priate to the specific types of units at the facility. Site-specific in-
formation and permit conditions can be quickly entered in the tabular for-
mat. In addition to time savings, the use of this sample permit insures
that all important permit conditions are included and achieves a degree of
uniformity in permits for similar types of facilities.
Im the paragraphs that follow, the purpose of each component of the
modular permit is discussed along with instructions on how to use or pre-
pare each component. The flow charts [Figures 4-9] in Section V are de-
signed to be used with this sample permit and give additional instruction
on how to use permit application data, technical references, permit stand-
ards, and the sample permit to develop permit conditions. The permit writer
is also referred to the set of Permit Guidance manuals for various types of
facilities prepared by the Office of Solid Waste.
PERMIT COVER SHEETS
The initial cover sheet contains basic information on the facility
including permit number, EPA identification number, owner and location.
-------
VI-2
Table 5
SAMPLE MODULAR RCRA PERMIT COMPONENTS
PERMIT COVER SHEETS
Basic Facility Information
List of Attachments
HAZARDOUS WASTE TSD UNITS LIST
Lists All Treatment, Storage and Disposal
Units and Their Design Capacity
WASTES LIST
Lists All Hazardous Waste Handled at the Facility
GENERAL CONDITIONS
Standard Conditions Generic to All TSD Facilities
Including Waste Analysis, Inspections, Contingency
Plans, Training, Financial Conditions, Closure
Plans, Reporting Requirements, Etc.
STANDARD CONDITIONS FOR:
CONTAINERS
TANKS
SURFACE IMPOUNDMENTS
WASTE PILES
INCINERATORS
- Standard Conditions are Attached for Each Type
of Unit Present at this Facility
SPECIAL ATTACHMENTS
Specific Attachments Required by the Standard
Conditions for Each Type of TSD Unit
OTHER REQUIREMENTS
Additional Special Conditions for This Facility
Developed by the Permit Writer
STANDARD ATTACHMENTS
CONTINGENCY PLAN
INSPECTION PLAN
OPERATING PLAN
REQUIRED DESIGN INFORMATION
-------
VI-3
Check-off blocks are provided to indicate what types of hazardous waste
managememt activities are conducted at the facility. A second set of blocks
is provided for check-off of the specific regulations applicable to the
facility. The pemittee is required to comply with all regulations applic-
able to the facility in addition to those regulations specifically included
in permit conditions. This cover sheet is intended to be a standard form
that would be filled out on a site-specific basis.
The second cover sheet is the List of Attachments that has two pur-
poses. It lists all permit components that are a part of this permit (shown
by a check in the box). It also serves as a handy check list during permit
preparation to insure that all applicable permit components are included in
the permit under preparation.
HAZARDOUS WASTES TSD UNITS LIST
A list of all hazardous waste management units at a facility and their
design capacities must be attached to each permit [40 CFR 122.29]. An ex-
ample list in a tabular format is presented that is easily adaptable to a
pre-printed form. Some form of a key linking each unit to a map would be a
desirable feature although not required by regulations.
WASTES LIST
All hazardous wastes or types of wastes managed at a facility must be
listed in the permit [40 CFR 122.29]. An example of such a list is shown
in a tabular format. The waste number is not required but is a desirable
feature to aid in determining waste characteristics or sources.
Where several different major types of wastes are handled such as ig-
nitables, with each other are present, subdivision of the list by waste
type of incompatible group would be desirable.
GENERAL CONDITIONS
The Consolidated Permit Regulations [40 CFR Part 122] and the RCRA
-------
VI-4
Permit Standards [40 CFR Part 264] specify various permit conditions ap-
plicable to all types of hazardous waste management facilities. No sample
general conditions are presented in the sample permit because of their bulk
and pending revisions. Example conditions are contained in Part II of the
RCAR Permit Procedures Manual.
STANDARD CONDITIONS
Containers
These standard conditions are designed to be applicable to all container-
storage facilities and contain all appropriate conditions required by the
Permit Standards [40 CFR Part 264, Subpart I]. Site-specific information
and specific permit conditions are contained in other components or attach-
ments to the permit.
Where appropriate, the standard conditions refer to these components
and attachments. For a container facility these references include at-
tached design specifications (condition C-5), Other Requirements (condi-
tion C-6), the Inspection Plan, the Closure Plan, the Wastes List, Table I,
and the General Conditions.
These standard conditions are designed to be used with Figure 5, the
flow chart for containers in Section V. An example of the relationship
between Figure 5 and the standard conditions is presented in Section V.
Additional help in permit preparation may be obtained by consulting the
Permit Guidance Manual for Containers.
Tanks
These standard conditions are applicable to new and exisiting tank
units used for storage or treatment of hazardous wastes. They are parallel
in format to the standard conditions for containers, are developed in the
same manner, and are also used in the same way. Figure 6 and the accompanying
-------
VI-5
text in Section V provide guidance in the use of these standard conditions.
Additional information is available in the Permit Guidance Manual for Tanks.
SURFACE IMPOUNDMENTS
Standard conditions applicable to new and existing surface impoundments
used for storage or treatment of hazardous wastes are presented. No condi-
tions applicable to surface impoundments used for disposal are presented as
final standards for existing facilities are not available.
The standard conditions are also similar in format and application to
the container conditions. Figure 7 in Section V provides instruction in
their use.
WASTE PILES
Standard conditions for waste piles are very similar to those for sur-
face impoundments. Conditions are presented for storage or treatment facil-
ities but not for disposal facilities.
Figure 8 in Section V provides guidance in the use of these standard
conditions. Additional information is contained in the Permit Guidance
Manual for Waste Piles.
INCINERATORS
Standard conditions applicable to incinerators have not yet been pre*
pared in the modular format. Such adaptation is difficult because of the
relatively larger amount of conditions that are site-specific. Sample per-
mit conditions used in the permit training courses are presented for illus-
trative purposes.
Figure 9 in Section V provides guidance in the preparation of permit
conditions. It is not keyed to this sample permit. Additional guidance is
available in the Permit Guidance Manual for Incinerators and the Engineer-
ing Handbook for Incinerators.
-------
VI-6
SPECIAL ATTACHMENTS
There are several special attachments referenced in the standard con-
ditions for containers, tanks, surface impoundments, and waste piles.
These include Table T for Tanks, Table SI for Surface Impoundments, Table WP
for Waste Piles, and Table I for Incompatible Wastes. These attachments
provide a simple means of organizing and attaching site-specific data re-
quired by permit regulations and conditions. A sample special attachement
is Table T in the Standard Conditions for Tanks.
OTHER REQUIREMENTS
Many permits will require several site-specific permit conditions.
These can be conveniently grouped in the Other Requirements. Several sets
of standard conditions reference the Other Requirements when specific con-
ditions are needed. An example of Other Requirements is presented in the
sample permit.
STANDARD ATTACHMENTS
There are several documents submitted as part of the permit application
that will usually be attached to and become part of the permit. These in-
clude the Contingency, Inspection, and Operating Plans and contain design
information such as the containment system design for container storage
facilities. When reviewed by the permit writer and attached to the permit,
these attachments become enforceable permit conditions.
Revision of these documents during development of permit conditions
will often be required. If revision is necessary after the permit becomes
effective, permit modification may be needed in some cases.
-------
SAMPLE MODULAR RCRA PERMIT
This packet contains draft sample permit conditions applicable
to various types of hazarous waste management facilities
inluding container storage, incinerators, and tanks, surface
impoundments and waste piles used for treatment or storage.
No disposal facility conditions are included. See the draft
RCRA Permit Procedures Manual for guidance in use of this
sample permit.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE MANAGEMENT PERMIT
VI-7
Permit No.
Application No.
EPA Identification No.
Name of Permittee
(Owner/Operator)
Facility Location
Effective Date
Expiration Date
In compliance with the provisions of the Resource Conserva-
tion and Recovery Act as amended (hereinafter referred to as "the
Act"), you are authorized to conduct hazardous waste management
activities including:
Storage
Treatment
Di sposal
pro-
at the listed facility location in accordance with the applicable
provisions of 40 CFR Parts 261 to 267 checked below and with
visions and conditions attached to this permit.
Subpart A
Subparts A-E
Subpart G
Subpart H
Subpart
Subpart
Subpart
Subpart
Subpart
—
—
Part
Part
Part
Part
Part
Part
Part
Part
Part
Part
Part
Part
Part
261 ,
262
263
264,
264,
264,
264,
264,
264,
264,
264,
266
267
I
J
K
L
0
For the Environmental Protection Agency
(Title)
Date:
-------
VI-3
Permit No.:
LIST OF ATTACHMENTS
Hazardous Waste TSD Units List
Wastes List
|~~] General Conditions
l~l Standard Conditions for Containers
]~~] Standard Conditions for Tanks
Standard Conditions for Surface Impoundments
Standard Conditions for Waste Piles
[~~| Standard Conditions for Incinerators
Table T for Tanks
Table SI for Surface Impoundments
Table WP for Waste Piles
Other Requirements
LJ Contingency Plan
Inspection Plan
Operating Plan
llJ Design Specifications
-------
VI-9
Permit No.:
HAZARDOUS WASTE TSD UNITS LIST
The following hazardous waste management units described in your permit
application are covered by this permit.
Key* Unit Description Design Capacity
A Organic Waste Incinerator 100 gph
B Chlorinated Waste Incinerator 160 gph
C Incinerator Feed Tank 5,000 gal
D Chlorinated Waste Feed Tank 5,000 gal
E Acid Waste Storage Tank 10,000 gal
F Acid Waste Storage Tank 10,000 gal
G Drum Storage Pad 10,000 gal
H Container Storage Building 25,000 gal
I Wastewater Storage Impoundment 150,000 gal
J Wastewater Neutralization Tank 0.2 mgd
K Wastewater Sludge Pile 1,000 cu. yd.
attached Facility Plot Plan.
-------
VI-10
Permit No.
WASTES LIST
The following hazardous wastes described in your permit application
may be managed at this facility.
Haste No. Waste Type Waste Description
D002 Dilute Acid Spent Sulfuric Acid
D002 Waste Caustic Spent Lime Waste
D007 Sludge Wastewater Treatment Sludge
from Benzyl Chloride
Production
KOI5 Chlorinated Still Bottoms from
Organics Benzyl Chloride Production
FOOT Spent Solvent Degreasing Solvents
D002 Wastewater Acidic Process Wastewaters
K051 Ignitable API Separator Sludge
-------
vi-n
Permit No.
GENERAL CONDITIONS
See Part II, Pages 51-69 of the RCRA Permit Procedures Manual for
apporpriate conditions to be inserted here.
-------
VI-12
CONDITIONS THAT APPLY TO THE USE AND MANAGEMENT OF CONTAINERS FOR THE STOR-
AGE OF HAZARDOUS WASTES AS REGULATED IN 40 CFR PART 264, SUBPART I.
MANAGEMENT OF CONTAINERS
C-l. Hazardous wastes shall be stored in containers that are maintained in
good condition with no evidence of leaks, severe rusting or corrosion,
or apparent structural defects. If a container is not in good condi-
tion or begins to leak, all hazardous wastes shall be transferred from
this container to a container that is in good condition or manage the
waste in some other way that complies with the requirements of 40 CFR
Part 264. [264.171]
C-2. Containers shall be made of or lined with materials which will not
react with, and are otherwise compatible with, the hazardous waste to
be stored, so that the ability of the container to contain the waste
is not impaired. [264.172]
C.3. A container holding hazardous waste shall always be closed during
storage except when it is necessary to add or remove waste. [264.173(a)]
C.4. A container holding hazardous waste shall not be opened, handled, or
stored in a manner which may rupture the container or cause it to leak.
[264.173(b)]
C.5. All containers shall only be stored in areas that have a containment
system that is capable of collecting and holding spills, leaks, and
precipitation. The containment system shall conform to the following
description and the attached design specifications:
a. The base underlying the containers shall be maintained free
of cracks or gaps and shall be sufficiently impervious to
contain leaks, spills, and accumulated rainfall until the
collected material is detected and removed;
b. The system shall be designed for efficient drainage so that
standing liquid does not remain on the base longer than one
hour after a leakage or precipitation event unless the con-
tainers are elevated or in some other manner are protected
from contact with accumulated liquids; and
c. The system shall include sufficient capacity to contain 10%
of the total volume of all containers stored in the area or
the volume of the largest container, whichever is greater.
[264.175(a>]
C-6. Run-on into the containment system shall be prevented unless specifi-
cally authorized in the Other Requirements section of this permit.
[264.175(b)]
C-7. Any hazardous waste that spills or leaks as well as any accumulated
precipitation shall be removed from the sump or collection area in as
-------
VI-13
timely a manner as is necessary to prevent overflow of the collection
system. [264.175(c)]
C-8. Any material removed from the collection system (if it meets the de-
finition of a hazardous waste in 40 CFR Part 261) shall be returned to
a hazardous waste container, transferred to other hazardous waste man-
agement facilities included in this permit, managed in some other way
that complies with applicable requirements of 40 CFR Parts 262-266 or
complies with the Other Requirements of this permit.
INSPECTIONS
C-9. The permittee shall inspect at least weekly the areas where containers
are stored, looking for leaking containers and for deterioration of
containers and the containment system. Inspections must be performed
in accordance with the attached Inspection Plan. [264.174]
CORRECTION OF DEFICIENCIES
C-10. Any deterioration or malfunction of equipment or structures of the
containment system (including leaks, cracks, pervious areas and inop-
erative sump pumps) revealed by the inspection shall be remedied by
the permittee on a schedule which ensures that the problem does not
lead to an environmental or human health hazard. Where a hazard is
imminent or has already occurred, remedial action must be taken imme-
diately. [264.15(c)]
CLOSURE
C-ll. All hazardous waste and hazardous waste residues shall be removed
from the containment system at closure of the facility. Any remaining
containers, liners, bases, and soil that contain or are are contami-
nated with hazardous waste or hazardous waste residue shall be decon-
taminated or removed. Closure must be performed in accordance with
the attached Closure Plan. [264.178]
SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
C-12. Ignitable wastes listed in the attached Wastes Table may be stored
at the location(s) shown in the attached sketch.
C-13. All containers holding ignitable or reactive waste shall be at least
15 meters (50 feet) from the facility's property line. [264.176]
C-14. If any ignitable or reactive wastes are stored in containers, the
requirements of General Condition of this permit shall be com-
plied with. [264.17]
SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
C-15. Incompatible wastes listed in attached Table 1 may be stored at the
facility.
-------
VI-14
C-16. Incompatible wastes or incompatible wastes and materials shall not be
stored in the same container unless the requirements of General Condi-
tion of this permit are complied with. [264.177(a)]
C-17. Hazardous waste shall not be placed in an unwashed container that
previously held an incompatible waste or material. [264.177(b)]
C-18. Any storage container holding hazardous waste that is incompatible
with any waste or other materials stored nearby in other containers,
waste piles, surface impoundments or open tanks, shall be separated
from the other materials or protected from them by means of a dike,
berm, wall, or other device. [264.177(c)]
-------
VI-15
CONDITIONS THAT APPLY TO THE USE AND MANAGEMENT OF TANKS FOR TREATMENT OR
STORAGE OF HAZARDOUS WASTE AS REGULATED IN 40 CFR PART 264, SUBPART J.*
GENERAL OPERATING REQUIREMENTS
T-l. All hazardous waste storage or treatment tanks shall be designed,
equipped, operated and maintained such that sufficient shell strength
and, for closed tanks, pressure controls are provided to assure that
they do not rupture or collapse. The minimum shell thicknesses speci-
fied for each tank in Table T shall be maintained at all times. At
any time liquid levels shall not exceed any maximum depths specified
in Table T nor reduce the freeboard in any uncovered tanks below the
values specified. [264.191 and 264.192]
T-2. Overfilling of tanks shall be prevented by the use of the control
mechanism specified in Table T for each tank. These control mechanisms
shall be maintained in good1operating condition at all times. [264.192(b)]
T-3. Only those hazardous wastes or types of wastes specified in Table T
for each tank shall be treated or stored in that tank. [122.29(a)j
T-4. In addition to Condition T-3, wastes or other materials (e.g., treat-
ment reagents) which are incompatible with the material of construction
of a tank shall not be placed in that tank unless the tank is protected
from accelerated corrosion, erosion or abrasion by a fully intact inner
lining or coating of compatible materials or alternate means of pro-
tection. [264.192(a)]
INSPECTIONS
T-5. At least once per operating day the permittee shall inspect the fol-
lowing:
a. The overfilling control equipment to ensure that it is in good
working order. [264.194(a)O)]
b. The data gathered from monitoring equipment, where present, to
ensure that each tank is being operated according to its design.
[264.194(a)(2)]
c. The waste level in each uncovered tank to ensure compliance with
maximum depth and/or minimum freeboard requirements. [264.194(a)(3)]
T-6. At least weekly the permittee shall inspect the following:
a. The construction materials of the above ground portions of each
tank to detect corrosion or erosion and leaking of fixtures and
seams. [264.194(a)(4)]
b. The area immediately surrounding each tank to detect obvious
signs of leakage (e.g., wet spots or dead vegetation). [264.194
These conditions do not apply to covered underground tanks that cannot
be entered for inspection. [264.190(b)]
-------
VI-16
T-7. In addition to the regular inspections specified in conditions T-5
and T-6, the permittee shall conduct periodic comprehensive inspec-
tions of each tank to detect cracks, leaks, corrosion or erosion that
may lead to crack or leaks, or wall thinning to less than the thick-
ness specified in Table T. Schedules and procedures for such inspec-
tions are detailed in the attached Inspection Schedule. [264.194(b)]
CORRECTION OF DEFICIENCIES
T-8. Any deterioration or malfunction of equipment or structures
(including leaks, cracks and wall thinning in violation of condition
T-l) revealed by the inspection shall be remedied by the permittee on
a schedule which ensures that the problem does not lead to an environ-
mental or human health hazard. Where a hazard is imminent or has
already occurred, remedial action must be taken immediately.
[264.15(c)]
T-9. Any leaks or spills of waste from tanks or ancillary equipment shall
be expeditiously cleaned up and the cause of the leak or spill
remedied (including removal of waste from the tank if necessary)
following the procedures and timing prescribed in the attached
Contingency Plan. [264.194(c)]
CLOSURE
T-10. At closure, all hazardous waste and hazardous waste residues shall
be removed from tanks, discharge control equipment, and discharge
confinement structures. Closure must be performed in accordance with the
attached Closure Plan. [264.197]
SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
T-ll. Ignitable wastes listed in the attached Wastes Table may be stored at
the location(s) shown in the attached sketch.
T-12. Ignitable or reactive wastes must not be placed in any tank unless
the following conditions are met:
a. The waste is treated, rendered or mixed before or immediately
after placement in the tank so that (1) the resulting waste,
mixture, or dissolution of material no longer meets the defini-
tion of ignitable or reactive waste under 40 CFR 261.21 or
261.23, and (2) General Condition of this permit is
complied with; or
b. The waste is stored or treated in such a way that it is protected
from any material or conditions which may cause the waste to
ignite or react; or
c. The tank is used solely for emergencies. [264.298(a>]
-------
VI-17
T-13. Ignitable or reactive wastes must not be stored in covered tanks
unless the National Fire Protection Associations (NFPA's) buffer
zone requirements for tanks, contained in Tables 2-1 through 2-6
of the "Flammable and Combustible Code - 1977", are complied
with. [264.198(b)]
SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
T-14. Incompatible wastes listed in attached Table I may be stored at the
facility.
T-15. Incompatible wastes, or incompatible wastes and materials, must not
be placed in the same tank unless General Condition of this
permit is complied with. [264.199(a)]
T-16. Hazardous waste must not be placed in an unwashed tank which pre-
viously held an incompatible waste or material unless General
Condition of this permit is complied with. [264.199(b)j
-------
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-------
VI-19
CONDITIONS THAT APPLY TO THE USE AND MANAGEMENT OF SURFACE IMPOUNDMENTS
FOR THE TREATMENT OR*STORAGE OF HAZARDOUS WASTES AS REGULATED IN 40 CFR
PART 264, SUBPART K.
GENERAL OPERATING REQUIREMENTS
S-l. All surface impoundments containing hazardous wastes shall be designed,
operated and maintained to prevent discharge into the land and ground-
water during the life of the impoundment by the use of a containment
system meeting the requirements of 40 CFR 264.223 and described in an
attachment to this permit. Discharge to surface waters shall also be
prevented unless specifically authorized in the Other Requirements of
this permit. [264.221(c)].
S-2. The impoundment shall be designed and operated so that any flow of
waste into the impoundment can be immediately shut off in the event
of overtopping or liner failure. [264.221(b)].
S-3. Only those hazardous wastes or types of wastes specified in Table S
for each surface impoundment shall be treated or stored in that im-
poundment. [122.29(a)].
S-4. The surface impoundment shall be operated to prevent any overtopping
due to wind and wave action, overfilling, precipitation, or any combi-
nation thereof. [264.222(a)].
S-5. The surface impoundment shall be operated to maintain at least 60 cen-
timeters (2 feet) of freeboard unless a different amount of freeboard
is specified in the Other Requirements of this permit. [264.222(b)].
S-6. All earthen dikes shall be designed and maintained with sufficient
structural integrity to prevent massive failure without dependence
on any liner system included in the surface impoundment design.
[264.221(d)].
S-7. All earthen dikes shall be kept free of:
a. Perennial woody plants with root systems which could displace
the earthen materials upon which the structural integrity of
the dike is dependent; and
b. Burrowing mammals which could remove earthen materials upon
which the structural integrity of the dike is dependent or
create leaks through burrows in the dike.
S-8. A protective cover, such as grass, shale or rock, shall be provided
and maintained on all earthen dikes to minimize wind and water erosion
and to preserve the structural integrity of the dike. [264.223(a)].
These conditions do not apply to surface impoundments used for disposal
of-hazardous wastes or that discharge to land or groundwater.
-------
VI-20
S-9. All run-on shall be diverted away from surface impoundments.
[264.222(e)].
5-10. A leachate detection, collection and removal system shall be provided
as part of the containment system for each surface impoundment as de-
scribed in an attachment to this permit. Each leachate system shall be
designed, operated and maintained so that liquid will flow freely from
the collection system to prevent the creation of pressure head within
the collection system in excess of that necessary to cause the liquid
to flow freely. All collected leachate shall be removed as it accumu-
lates or with sufficient frequency to prevent backwater within the col-
lection system. [264.221(e) and 222(c)].
S-ll. Any material removed from the leachate collection system (if it
meets the definition of a hazardous waste in 40 CFR Part 261) shall
be returned to the surface impoundment, transferred to other hazardous
waste management units included in this permit, managed in some other
way that complies with applicable requirements of 40 CFR Parts 262-266
or complies with the Other Requirements of this permit.
INSPECTIONS
S-12. The permittee shall inspect a surface impoundment which contains
free liquids at least once each operating day to ensure compliance
with provisions S-5, S-6 and S-10 and to detect any leaks or other
failures of the impoundment. [264.226(b)(l)].
S-13. The permittee shall inspect each surface impoundment, including
dikes, berms and vegetation surrounding the dike, at least once a week
and after storms to detect any evidence of or potential for leaks from
the impoundment, erosion of dikes, and to ensure compliance with pro-
vision S-7. [264.226(b)(2)].
S-14. Whenever there is any indication of a possible failure of the contain-
ment system, the permittee shall inspect that system in accordance with
the provisions of the containment system evaluation and repair plan de-
scribed in the attached Contingency Plan. [264.227(a)].
CONTAINMENT SYSTEM REPAIRS
S-15. Whenever there is a positive indication of a failure of the contain-
ment system (e.g., an unplanned sudden drop in liquid level in the im-
poundment, waste detected in the leachate detection system, active leak-
age through the dike, or a breach, such as a hole, tear, crack or sep-
aration, in the liner system), the impoundment shall be removed from
service. To remove the impoundment from service the permittee must:
a. Immediately shut off the flow of or stop the addition of
wastes into the impoundment;
b. Immediately contain any leakage which has occurred or is occurring;
c. Immediately cause the leak to be stopped;
-------
VI-21
d. If the leak cannot be stopped by any other means, empty the im-
poundment; and
e. Take any additional actions prescribed in the attached Contingen-
cy Plan. [264.227(b, c and d)].
S-16. No surface impoundment that has been removed from service in accord-
ance with provision S-15 may be restored to service unless:
a. The containment system has been repaired in accordance with the
attached Contingency Plan; and
b. The containment system has been certified by a qualified engineer
as meeting the approved design specifications attached to this
permit. [264.227(d)(2) and (e)].
CLOSURE
S-17. At closure, all hazardous waste and hazardous waste residues shall
be removed from the impoundment. Any component of the containment
system or any appurtenant structures or equipment (e.g., discharge
platforms and pipes, and baffles, skimmers, aerators or other equip-
ment) containing or contaminated with hazardous waste or hazardous
waste residues shall be decontaminated or removed. Closure shall be
performed in accordance with the attached Closure Plan.[264.228],
S-18. A surface impoundment that has been removed from service in accord-
ance with provision S-15 and that is not being repaired shall be closed
in accordance with provision S-17. [264.227 (f)]
SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
S-19. Ignitable or reactive waste shall not be placed in a surface impound-
ment unless:
a. The waste is treated, rendered, or mixed before or immediately
after placement in the impoundment so that:
1. The resulting waste, mixture, or dissolution of material no
longer meets the definition of ignitable or reactive wastes under
40 CFR Part 261.21 and 261.23; and
2. The permittee complies with the requirements of General Con-
dition of this permit; or
b. The waste is managed in such a way that it is protected from any
material or conditions which may cause it to ignite or react; or
c. The surface impoundment is used solely for emergencies. [264.229].
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VI-22
SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
S-20. Incompatible wastes or incompatible wastes and materials shall not
be placed in the same surface impoundment unless the requirements of
General Condition of this permit are complied with. [264.230].
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VI-23
CONDITIONS THAT APPLY TO THE USE AND MANAGEMENT OF WASTE PILES FOR THE
TREATMENT QR STORAGE OF HAZARDOUS WASTES AS REGULATED BY 40 CFR PART 264,
SUBPART L.
GENERAL OPERATING REQUIREMENTS
P-l. All waste piles containing hazardous wastes shall be designed, operated,
and maintained to prevent discharge into the land, surface water, or
groundwater during the life of the pile by use of a containment system
which complies with the requirements of 40 CFR Part 264.253 as described
in an attachment to this permit. [264.251(b)].
P-2. All waste piles shall be designed, operated, and maintained to control
dispersal of the waste by wind, where necessary, or by water erosion.
Any specific control practices listed in the Other Requirements of this
permit shall also be followed. £264.251(a) and 252(a)].
P-3. Run-on shall be diverted away from all waste piles. [264.252(b)].
P-4. All leachate and run-off from waste piles must be collected and con-
trolled. If the collected leachate or run-off meets the definition of
a hazardous waste in 40 CFR Part 261, it shall be transferred to other
hazardous waste management units included in this permit, managed in
some other way that complies with applicable requirements of 40 CFR
Part 262-266 or complies with the Other Requirements of this permit.
[264.252(c)].
P-5. If the containment system for the waste pile includes a leachate de-
tection, collection and removal system beneath the base, the leachate
system shall be designed and operated to detect, contain, collect, and
remove any discharge from the base. All collected leachate shall be
removed as it accumulates or with sufficient frequency to prevent back-
water within the collection system. [264.253(a)(3)].
P-6. Only those hazardous wastes or types of wastes specified in Table WP
for each waste pile shall be treated or stored in that pile.
[122.29(a)].
P-7. The containment system shall be protected from plant growth which could
puncture any component of the system. [264.253(c)].
INSPECTIONS
P-8. Periodic inspections shall be conducted of the waste pile, exposed
portions of the base and/or liner, facilities for collection and man-
agement of leachate and runoff, and the leachate detection and collec-
tion system (if any) in accordance with the attached Inspection Sched-
ule. [264.15].
These conditions do not apply to waste piles that are used for disposal
of hazardous wastes or that discharge to land or groundwater.
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VI-24
P-9. Whenever there is any indication of a possible failure of the contain-
ment system, that system shall be inspected in accordance with the
provisions of the containment system evaluation and repair plan de-
scribed in the attached Contingency Plan. [264.255(a)j.
CONTAINMENT SYSTEM REPAIRS
P-1CL Whenever there is a positive indication of a failure of the contain-
ment system (e.g., waste detected in any leachate detection system
or a breach, such as a hole, tear, crack, or separation, in the base),
the waste pile shall be removed from service. To remove the pile from
service, the permittee must:
a. Immediately stop adding wastes to the pile;
b. Immediately contain any leakage which has or is occuring;
c. Immediately cause the leak to be stopped;
d. If the leak cannot be stopped by any other means, remove
the waste from the base; and
e. Take any additional actions prescribed in the attached
Contingency Plan. [264.255 (b, c, and d)].
P-ll. No waste pile that has been removed from service in accordance with
provision P-10 may be restored to service unless:
a. The containment system has been repaired in accordance with the
attached Contingency Plan; and
b. The containment system has been certified by a qualified engineer
as meeting the approved design specifications attached to this per-
mit. [264.255(d)(2) and (e)].
CLOSURE
P-12. At closure, all hazardous waste and hazardous waste residues shall be
removed from the pile. Any component of the containment system contam-
inated with hazardous waste or hazardous waste residues shall be decon-
taminated or removed. Closure shall be performed in accordance with the
attached Closure Plan.[264.258].
P-13. A waste pile that has been removed from service in accordance with
provision P-10 and that is not being repaired shall be closed in accord-
ance with provision P-12. [264.255(f)]
SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
P-14. Ignitable or reactive waste shall not be placed in a pile unless:
a. Addition of the waste to an existing pile:
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VI-25
1. Results in the waste or mixture no longer meeting the defi-
nition of ignitable or reactive waste under 40 CFR 261.21 or
261.23, and
2. The permittee complies with the requirements of General Con-
dition of this permit; or
b. The waste is managed in such a way that it is protected from any
material or conditions which may cause it to ignite or react.
[264.256(a)].
SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES
P-15. Incompatible wastes listed in the attached Table I may be stored at
this facility.
P-16. Incompatible wastes or incompatible wastes and materials shall not be
placed in the same pile unless the requirements of General Condition
of this permit are complied with. [264.257(a)].
P-17. A pile of hazardous waste that is incompatible with any waste or other
material stored nearby in other containers, piles, open tanks, or sur-
face impoundments must be separated from the other materials, or pro-
tected from them by means of a dike, berm, wall, or other device.
[264.257(b)].
P-18. Hazardous waste must not be piled on the same base where incompatible
wastes or materials were previously piled, unless the base has been de-
contaminated sufficiently to ensure compliance with General Condition
of this permit. [264.257(c)].
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VI-26
SAMPLE PERMIT
Conditions that apply to the use and mangement of Incinerators
for the Treatment of Hazardous Wastes as Regulated by 40 CFR Part
264, Subpart 0.
The conditions presented in this section are examples
only. We are presently refining the suggested language
for incineration permits and are providing this preliminary
draft to indicate our general approach. The sample conditions
provide information on the level of detail the complexity
and the scope of related conditions which might be developed
by the permit writer in an actual permit. All numerical
information is for illustrative purposes only.
Conditions 1 and 2 are designed to provide examples of waste
feed and POHC feed monitoring.
1. The permittee is allowed to burn, only the wastes
listed in Attachment 1 with the POHC designation and
quantities listed below. (Attachment 1 would be the
list of hazardous waste identified in waste analysis.)
2. The wastes fed to the incinerator shall be limited
by the following conditions:
a) Wastes A, B, C shall be burned in accordance with
the operating conditions resulting from the trial
burns called condition "RED", as a minimum.
Condition RED is designated as .
b) Wastes D through Q shall be burned in accordance
with the operating conditions resulting from the
trial burns called conditions "BLUE", as a
minimum wastes D through Q may be burned under
RED condition. Condition BLUE is designated as
c) Maximum feed rates for each POHC are follows:
1) POHC X x Ib/hr;
POHC X y Ib/hr;
POHC X z Ib/hr;
2) Waste feed limits are as follows:
max. Ib/hr.
waste A 800
B 700
C 4000
wastes D thru Q 6000
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VI-27
Conditions 3,4, 5 and 6 are examples of constraints on
the mode of incinerator operation.
3. During start-up and shut-down of an incinerator,
hazardous waste [except ignitable waste exempted in
accordance with §264.340] must not be fed into the
incinerator unless the incinerator is operating within
the conditions for temperature, air feed rate, etc.
specified in the permit.
4. No solid materials containing the stipulated POHC's
may be incinerated in the liquid injection incinerator.
Ony liquid wastes A, B & C containing the POHC's
having a fluidity equal to or greater than that of
American Society of Testing Materials (ASTM) No. 5
fuels oil, with a maximum viscosity of 750 Saybolt
Seconds Universal (SSU), at 38 Degrees C shall be
incinerated. The bottom sediment and water
(BS & W) shall not exceed ten (10) percent by
volume.
5. No burning of liquid wastes A, B & C shall take place
unless the incinerator is operating in the range of
1100 Degrees C to 1200 degrees C in the burning zone.
The liquid waste shall be injected directly into the
flame. Burning shall not be permitted during periods
of startup, shutdown, major upset, or fuel inter-
ruption. (See alarm and shutoff requirements).
6. The kiln shall be operated at all times in an
oxidizing atmosphere. (Oxygen in the kiln exhaust
gases shall be maintained at a level of not less
than 0.5 percent by volume.)
The following group of conditions are related to air stream
monitoring and control.
7. The Carbon-Monoxide level (as measured by Illinois EPA
ATP-2 method) shall not exceed 50 ppm.
8. The Air Pollution Control Scrubber system will operate under
conditions stipulated in the trial burns for Conditions
RED and BLUE at all times:
i The pH of the scrubber solution shall not be less
than 10.5 measured at the scrubber feed pump.
•ii A minimum flow rate of 50 gpm shall be maintained
at the feed inlet to the first stage system.
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VI-28
iii The pressure drop across the scrubber system shall
be maintained between 20 and 50 inches of water.
9. The particulate emissions shall not exceed 180 milligrams
per dry standard cubic meter (.08 grains per dry standard
cubic foot) when corrected for 12% C0_.
10. Fugitive emissions will be controlled by maintaining
combustion zone pressure lower than atmospheric pressure
at all times when burning wastes listed in this permit.
Conditions 11, 12, and 13 are examples of instrumentation
and control provisions. Condition number 13 in this set of
examples is a reminder that feed rate monitoring may
include sensing systems in the plants storage facility.
11. Instrumentation and controls shall be provided to
accomodate the following:
a. Continuous indicating anc recording of:
1) Waste feed rate;
2) Fuel flow rate;
3) Combustion gas temperatures and gas exhaust
temperature;
4) Draft (static) pressure in the firing hood
(intermittent recording);
5) Exhaust fan speed;
6) Volumetric concentration of carbon monoxide (CO),
in the stack emission.
12. Controls must be provided for alarm and automatic
shut-down of waste feed in the event the following
conditions occur:
o Auxiliary Fuel flow interruption;
o Waste feed control;
o Loss of draft in the firing hood for two (2) seconds
or longer;
o Combustion gas temperature (as measured by the gas
exhaust temperature) drops below 1100 Degrees C ;
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VI-29
o Power failure;
o Flame failure (when the UV detector detects a flame
out);
o Failure of any of the above monitoring, recording,
and controlling operations;
o A drop in prime move amperage to less than 80 amps;
o Scrubber: failure of pump, when pressure falls outside
range of 20 to 50 inches of water.
13. -Level and temperature indicators must be provided on the
waste storage tank with high temperature warning systems.
14. Monitoring and Inspections - The permittee shall
conduct, at a minimum, the following monitoring
while incinerating hazardous wastes:
(a) Combustion temperature, waste feed rate,
and air feed rate must be monitored and
recorded on a continuous basis.
(b) CO must be monitored and recorded on a
continuous basis at point lettered X on
the facility drawing.
(c) Upon request by the Regional Administrator,
but not more than twice annually, sampling
and analysis of the waste and exhaust emissions
must be conducted to verify that the operating
requirements established in the permit achieve
the performance standards of §264.343 (40
CFR, Part 264, Subpart 0).
(d) The incinerator and associated equipment
(pumps, valves, conveyors, pipes, etc.) must
be completely inspected at least daily for
leaks, spills, and fugitive emissions.
All emergency waste feed cut-off controls
and system alarms must be checked daily to
verify proper operation.
(e) This monitoring and inspection data must
be recorded and the records must be placed in
the operating log required by §264.73.
(The permit writer may stipulate reporting conditions
which are tailored to the special requirements of the permittee
and EPA's interest in assessing compliance.)
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VI-30
15. A revised permit may be required:
by any change in burner configuration or number of
burners;
any change in the feed delivery system which would
increase feed delivery capability;
any reduction in stack height;
any change in Air Pollution Control system configura-
tion which would result in modified pressure drop;
any change of measurement point of temperature, air
flow or other system operating parameter stipulated
in the permit;
- any prime mover (fan) changes which would result
in significant changes in air delivery capacity -
on the order of +_ 1G£;
any change in system configuration which would
result in a reduction in effective residence time.
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Trial Burn Permit
1. The permittee shall comply with the requirements of 40
CFR §122.27(b).
2. The permittee shall conduct the trial burn in accordance
with the trial burn plan attached to this permit.
3. The permittee shall submit to the Director a certification
that the trial burn had been carried out in accordance
with the approved trial burn plan and the results of all
the determir.c.tio.\s required in §122 . 26 (b) '. 5 )(:'.). Tc the
extent possible, this submission shall be made within 30 days
of the completion of the trial burn or sooner if the Director
so requests.
4. All data collected during any trial burn must be submitted
to the Director following the completion of the trial burn.
The results of .'he ttial burn n.ust be included w.lhh Fart B
of the permit application, if a permit application is submitted,
5. All submissions required by this paragraph shall be certified
on behalf of the applicant by the signature of a person
authorized to sign a permit application or a report under
§122.6.
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VI-32
Permit No.
OTHER REQUIREMENTS
1. Run-on of precipitation runoff from the truck loading area into the
containment system for Drum Storage Area G is permitted.
2. All collected runoff from Drum Storage Area G shall be discharged
to Wastewater Storage Impoundment I.
3. There shall be no discharge of wastes from Wastewater Storage
Impoundment I except to Wastewater Neutralization Tank J.
4. Any leachate collected from the leachate system for Wastewater
Storage Impoundment I shall be discharged to Wastewater Neutralization
Tank J.
4. Any leachate collected from the leachate system for Wastewater
Storage Impoundment I shall be discharged to Wastewater Neutralization
Tank J.
5. The water table under Wastewater Storage Impoundment I shall be
artificially depressed to a minimum of 5 feet below the bottom
liner at all times by pumping of Wells 5 and 6.
6. There shall be no discharge of waste liquids from Wastewater Sludge
Pile K except to Wastewater Neutralization Tank J. All collected
leachate and surface runoff shall be discharged to Tank J.
7. Wind dispersal of wastewater sludge shall be minimized by keeping
a tarp cover on the west face of the pile except when adding material
to the pile.
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APPENDICES
A CONSOLIDATED PERMIT REGULATIONS
B 40 CFR REGULATIONS
EFFLUENT STANDARDS AND LIMITATIONS
C RCRA REGULATIONS
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APPENDIX A
CONSOLIDATED PERMIT REGULATIONS
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A-l
ENVIRONMENTAL PROTECTION AGENCY
CONSOLIDATED PERMIT PROGRAM REGULATIONS
PART 122—EPA ADMINISTERED
PERMIT PROGRAMS: THE NATIONAL
POLLUTANT DISCHARGE
ELIMINATION SYSTEM; THE
HAZARDOUS WASTE PERMJT
PROGRAM; AND THE UNDERGROUND
INJECTION CONTROL PROGRAM
Subpart A—Definitions and General
Program Requirements
Sec.
122.1 What are the consolidated permit
regulations?
122.2 Purpose and scope of Part 122.
122.3 Definitions.
122.4 Application for a permit.
122.5 Continuation of expiring permits.
122.6 Signatories lo permit applications and
reports.
122.7 Conditions applicable to all permits.
122.8 Establishing permit conditions.
122.9 Dura tion of permits.
122.10 Schedules of compliance.
122.11 Requirements for recording and
reporting of monitoring results.
122,12 Considerations under Federal law.
122.13 Effect of a permit.
122.14 Transfer of permits.
122.15 Modification or revocation and
reissuance of permits.
122.16 Termination of permits.
122.17 Minor modifications of permits.
122,18 Noncompliance and program
reporting by the Director.
122.19 Confidentiality of information.
Subpart B—Additional Requirements for.
Hazardous Waste Programs Under the
Resource Conservation and Recovery Act
122.21 Purpose and scope of Subpart B.
122.22 Application for a permit.
122.23 Interim status. •
122.24 Contents of Part A of the RCRA
' permit application.
122.25 Contents of Part B of the RCRA
permit application.
122.26 Permits by rule.
122.27 Emergency permits.
122.23 Additional conditions applicable to
ell RCRA permits.
122.29 Establishing RCRA permit
conditions.
122.30 Interim permits for UIC wells.
Subpan c—Additional Requirements for
Underground Injection Control Programs
Under the Safe Drinking Water Act
See.
122.31 Purpose and scope of Subpart C.
122.32 Classification of injection wells.
122.33 Prohibition of unauthorized injection.
122.34 Prohibition of movement of fluid into
underground sources of drinking water.
12235 Identification of underground sources
of drinking water and exempted aquifers.
122.36 Elimination of certain Class IV wells.
122.37 Authorization of underground
injection by rule.
122.38 Application for a permit
authorization by permit
122.39 Area permits.
122.40 Emergency permits.
122.41 Additional conditions applicable to
all UIC permits.
122.42 Establishing UIC permit conditions.
122.43 Waiver of requirements by Director.
122.44 Corrective action.
122.45 Requirements for wells injecting
hazardous waste.
Subpart D—Additional Requirements for
National Pollutant Discharge Elimination
System Programs Under the Clean Water
Act
122.51 Purpose and scope of Subpart D.
122.52 Prohibitions.
122.53 Application for a permit...
122.54 Concentrated animal feeding
operations.
122.55 Concentrated aquatic animal
production facilities.
122.56 Aquacullure projects.
122.57 Separate storm sewers.
122.58 Silvicultural activities.
122.59 Geiv?r •!;-"•"-
122.60 Additional condi-jne applicable to
all NPDES permits.
122.61 Additional conditions applicable to
specified categories of NPDES permits.'
122.62 Establishing NPDES permit
conditions.
122.63 Calculating NPDES permit
conditions.
122.64 Duration of certain NPDES permits.
122.65 Disposal of pollutants into wells, into
publicly owned treatment works or by
land application.
122.66 New sources and new dischargers."
Appendix A to Part 122—NPDES Primary
Industry Categories.
Appendix B to Part 122—NPDES Criteria for
Determining a Concentrated Animal
Feeding Operation (§ 122.54).
Appendix C to Part 122—NPDES Criteria for
Determining a Concentrated Aquatic
• Animal Production Facility (§ 122.55).
Appendix D to Part 122—NPDES Permit
Application Testing Requirements
(§ 122.53).
Authority: Resource Conservation and
Recovery Act. 42 U.S.C. § 6901 et seq.; Safe
Drinking Water Act. 42 U.S.C. § 300f et seq.;
and Clean Water Act, 33 U.S.C. § 1251 el seq.
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A-2
PART 123—STATE PROGRAM
REQUIREMENTS
Subpart A—General Program Requirements
Sec.
123.1 Purpose and scope.
123.2 Definitions.
123.3 Elements of a program submission.
123.4 Program description.
123.5 Attorney General's statement.
123.8 Memorandum of Agreement with
Regional Administrator.
123.7 Requirements for permitting.
123.8 Requirements for compliance
evaluation programs.
123.9 Requirements for enforcement
authority.
123.10 Sharing of information.
123.11 Coordination with other programs.
123.12 Approval process.
123.13 Procedures for revision of State
programs.
123.14 Criteria for withdrawal of State
programs.
123.15 Procedures for withdrawal of State
programs.
Subpart B—Additional Requirements for
State Hazardous Waste Programs
123.31 Purpose and scope.
123.32 Consistency.
123.33 Requirements for identification and
listing of hazardous wastes.
123.34 Requirements for generators of
hazardous wastes.
123.35 Requirements for transporters of
hazardous wastes.
123.36 Requirements for hazardous waste
management facilities.
123.37 Requirements with respect to permits
and permit applications.
123.38 EPA review of State permits.
123.39 Approval process.
Subpart C—Additional Requirements for
State UIC Programs
123.51 Purpose and scope.
123.52 Requirement to obtain a permit.
123.53 Progress reports.
123.54 Approval process.
123.55 Procedures for withdrawal of State
UIC programs.
Subpart D—Additional Requirements for
State Programs Under the National
Pollutant Discharge Elimination System
123.71 Purpose and scope.
123.72 Control of disposal of pollutants into
wells.
123.73 Receipt and use of Federal
information.
123.74 Transmission of information to EPA.
123.75 EPA review of and objections to
State permits.
123.76 Piohibition.
123.77 Approval process.
Subpart E—Additional Requirements for
State Programs Under Section 404 of the
Clean Water Act
123.91 Purpose and scope.
123 92 Activities not requiring permits.
123.93 Prohibitions.
123.94 Permit application.
123.95 General permits.
123.96 Emergency permits.
123.97 Additional conditions applicable to
all 404 permits.
123.98 Establishing 404 permit conditions.
123.99 Memorandum of Agreement with the
Secretary.
123.100 Transmission of information to EPA
and other Federal agencies.
123.101 EPA review of and objections to
State permits.
123.102 Coordination requirements.
123.103 Enforcement authority.
123.104 Approval process.
Subpart F—Requirements for Interim
Authorization of State Hazardous Wasts
Programs
123.121 Purpose and scope.
123.122 Schedule.
123.123 Elements of a program submission
123.124 Program description.
123.125 Attorney General's statement.
123.126 Memorandum of agreement.
123.127 Authorization plan.
123.123 Program requirements for interi—
authorization for Phase 1.
123.129 Additional program requirements
for interim authorization for Phase II.
123.130 Interstate movement of hazardous
waste.
123.131 Progress reports.
123.132 Sharing of information.
123.133 Coordination with other programs.
123.134 EPA review of State permits.
123.135 Approval process.
123.136 Withdrawal of State programs.
123.137 Reversion of State programs.
Authority: Resource Conservation and
Recovery Act. 42 U.S.C. 6901 et scg.; Safe
Drinking Water Act, 42 U.S.C. 300(f) et sag.;
Clean Water Act, 33 U.S.C. 1251 et seq.
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A-3
PART 124—PROCEDURES FOR
DECISIONMAXING
Subpart A—General Program Requirements
Sec.
124.1 Purpose and scope.
124.2 Definitions.
124.3 Application for a permit.
124.4 Consolidation of permit processing.
124.5 Modification, revocation and
reissuance, or termination of permits.
124.6 Draft permit.
124.7 Statement of basis.
124.8 Fact sheet
124.9 Administrative record for draft
permits when EPA is the permitting
authority.
124.10 Public notice of permit actions and
public comment period.
124.11 Public comments and request? for
public hearings.
124.12 Public hearings.
124.13 Obligation to raise issues and
provide information during the public
comment period.
124.14 Reopening of the public comment
period.
124.15 Issuance and effective date of permit.
I?.4rl6 Stays of contested permit conditions.
124.17 Response to comments.
124.18 Administrative record for final
permit when EPA is the permitting
authority.
124.19 Appeal of RCRA.UIC and PSD
permits.
124.20
124.21
Computation of time.
Effective date of Part 124.
Subpart B — Specific Procedures Applicable
to RCRA Permits [reserved]
Subpart C— Specific Procedures Applicable
to PSD Permits
124.41 Definitions applicable to PSD
permits.
124.^2 Addition?! procedures for PSD
afiuCn.-ig Class I areas.
Subpart 0 — Specific Procedures Applicable
to NPDES Permits
124.51 Purpose and scope.
124.52 Permits required on a case-by-case
basis.
124.53 State certification.
124.54 Special provisions for State
certification and concurrence on
applications for section 301(h) variances.
124.55 Effect of State certification.
124.56 Fact sheets.
124.57 Public notice.
124.58 Special procedures for EPA-issued
general permits for point sources other
than separate storm sewers.
124.59 Conditions requested by the Corps of
Engineers and other government
agencies.
124.60 Issuance and effective date and stays
of NPDES permits.
124.61 Final environmental impact
statement.
124.62 Decision on variances.
124 63 Procedures for variances when EPA
is the permitting authority
124.64 Appeals of variances.
124 65 Special procedures for discharge into
marine waters under section 301(h).
124.66 Special procedures for decisions on
thermal variances under section 316(a).
Subpart E—Evidentiary Hearing for EPA-
Issued NPDES Permits and EPA-Terminated
RCRA Permits
124.7: Applicability.
124.72 Definitions.
124.73 Filing and submission of documents.
124.74 Requests for evidentiary hearing.
124.75 Decision on request for a hearing.
124.76 Obligation to submit evidence and
raise issues before a final permit is
issued.
124.77 Notice of hearing.
124.78 Exports communications.
124.79 Additional parties and issues.
124.80 Filing and service.
124.81 Assignment of Administrative Law
Judge.
124.82 Consolidation and severance.
124 83 Prehearing conferences.
124.84 Summary determination.
124.85 Hearing procedure.
124.86 Motions.
124.87 Record of hearings.
124.88 Proposed findings of fact and
conclusions: brief.
124.89 Decisions.
124.90 Interlocutory appeal.
124.91 Appeal to the Administrator.
Subpart F—Non-Adversary Panel
Procedures
124.111 Applicability.
124.112 Relation to other Subparls.
124.113 Public notice of draft permits and
public comment period.
124.114 Request for hearing.
124.115 Effect of denial of or absence of
request for hearing.
124.116 Notice of hearing.
124.117 Request to participate in hearing.
124.118 Submission of written comments on
draft permit.
124.119 Presiding Officer.
124.120 Panel hearing.
124.121 Opportunity for cross-examination.
124.122 Record for final permit.
124.123 Filing of brief, proposed findings of
fact and conclusions of law and
proposed modified permit.
124.124 Recommended decision.
124.125 Appeal from or review of
recommended decision.
124.126 Final decision.
124.127 Final decision if there is no review.
124.128 Delegation of authority; time
limitations.
Appendix A to Part 124—Guide to
Decisionmaking under Part 124.
Authority: Resource Conservation and
Recovery Act, 42 U.S.C. § 6901 et seq: Safe
Drinking Water Act. 42 U.S.C. § 300(f) et seq:
Clean Water Act. 33 U.S.C. § 1251 et seq: and
Clean Air Act, 42 U S.C. § 1857 et seg.
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A-4
PART 125—CRITERIA AND
STANDARDS FOR THE NATIONAL
POLLUTANT DISCHARGE
ELIMINATION SYSTEM
Subpart A—Criteria and Standards for
Imposing Technology-Based Treatment
Requirements Under Section 301(b) of the
Act
Sec.
125.1 Purpose and scope.
125.2 Definitions.
125.3 Technology-based treatment
requirements in permits.
Subpart B—Criteria for Issuance of Permits
to Aquaculture Projects
125 10 Purpose and scope.
125.11 Criteria.
Subpart C—Criteria for Extending
Compliance Dates for Facilities Installing
Innovative Technology Under Section
301(k) of the Act [Reserved]
Subpart D—Criteria and Standards for
Determining Fundamentally Different
Factors Under Sections 30i(b)|i)(A),
301(b)(2) (A) and (E), and 307(b) of the Act
125.30 Purpose and scope.
125.31 Criteria.
J25.32 Method of application.
Subpart E—Criteria for Granting Economic
Variances From Best Available Technology
Economically Achievable Under Section
301(c) of tha Act [Reserved]
Subpart F—Criteria for Granting Water
Quality Related Variances Under Section
301(g) of the Act [Reserved]
Subpart G—Criteria for Modifying the
Secondary Treatment Requirement Under
Section 301(h) of the Act [Reserved]
Subpart H—Criteria for Determining
Alternative Effluent Limitations Under
Section 316(a) of the Act.
125.70 Purpose and scope.
125.71 Dtfmitions.
125.72 Early screening of applica:ions for
section 3l6(a) variances.
125.73 Criteria and standards for the
determination of alternative effluent
limitations under section 316(a).
Subpart I—Criteria Applicable To Cooling
Water Intake Structures Under Section
316(b) of the Act [Reserved]
Subpart J—Criteria for Extending
Compliance Dates Under Sectiin 301(i) of
the Act
125.90 Purpose and scope.
125.91 Definition.
125.92 Requests for permit modification and
issuance under section 301(i)(l) of the
Act.
125.93 Criteria for permit modification and
issuance under section 301(i){lj of the
Act.
125.94 Permit terms and conditions under
section 301(i)(l) of the Act.
125.95 Requests for permit modification or
issuance under section 301{i)(2J of the
Act.
125 96 Criteria for permit modification or
issuance under section 301(i)(2) of the
Act.
125.97 Permit terms and conditions under
section 301(i)(2] of the Act.
Subpart K—Criteria and Standards for Best
Management Practices Under Section
304(e) of the Act
125.100 Purpose and scope.
125.101 Definition.
125.102 Applicability of best management
practices.
125.103 Permit terms and conditions.
125 104 Best management practices
programs.
Subpart L—Criteria and Standards for
Imposing Conditions for the Disposal of
Sewage Sludge Under Section 405 of the
Act [Reserved]
Subpart M—Ocean Dumping Criteria Under
Section 403 of the Act (Reserved]
Authority: Clean Water Act. as amended
by the Clean Water Act of 1977. 33 U.S.C.
1251 et seq.
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APPENDIX B
40 CFR REGULATIONS
EFFLUENT STANDARDS AND LIMITATIONS
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B-l
Toxic Pollutants Effluent Standards Part 129
Pretreatment Regulations for Existing and New Sources of Pollution . Part 403
Effluent Limitations Guidelines for Dairy Products Processing
Industry Point Source Category Part 405
Grain Mills Point Source Category Part 406
Canned and Preserved Fruits and Vegetables Processing Point Source
Category " Part 407
Canned and Preserved Seafood Processing Point Source Category .... Part 408
Sugar Processing Point Source Category Part 409
Textile Industry Point Source Category Part 410
Cement Manufacturing Point Source Category Part 411
Feedlots Point Source Category Part 412
Electroplating Point Source Category Part 413
Organic Chemicals Manufacturing Point Source Category Part 414
Inorganic Chemicals Manufacturing Point Source Category Part 415
Plastics and Synthetics Point Source Category Part 416
Soap and Detergent Manufacturing Point Source Category Part 417
Fertilizer Manufacturing Point Source Category Part 418
Petroleum Refining Point Source Category Part 419
Iron and Steel Manufacturing Point Source Category Part 420
Nonferrous Metals Manufacturing Point Source Category Part 421
Phosphate Manufacturing Point Source Category Part 422
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B-2
Steam Electric Power Generating Point Source Category Part 423
Ferroalloy Manufacturing Point Source Category Part 424
Leather Tanning and Finishing Industry Point Source Category .... Part 425
Glass Manufacturing Point Source Category Part 426
Timber Products Processing Point Source Category . . Part 429
Pulp, Paper, and Paperboard Point Source Category Part 430
Builders Paper and Roofing Felt Segment of the Builders Paper and
Board Mills Point Source Category Part 431
Meat Products Point Source Category Part 432
Coal Mining Point Source Category Part 434
Offshore Segment of the Oil and Gas Extraction Point Source Category Part 435
Mineral Mining and Processing Point Source Category Part 436
Pharmaceutical Manufacturing Point Source Category Part 439
Ore Mining and Processing Point Source Category Part 440
Paving and Roofing Materials (Tars and Asphalt) Point Source
Category Part 443
Paint Formulating Point Source Category Part 446
Ink Formulating Point Source Category Part 447
Gum and Wood Chemicals Manufacturing Point Source Category Part 454
Pesticides Chemicals Manufacturing Point Source Category Part 455
Explosives Manufacturing Point Source Category Part 457
Carbon Black Manufacturing Point Source Category Part 458
Photographic Point Source Category Part 459
Hospitals Point Source Category Part 460
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APPENDIX C
RCRA REGULATIONS
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RCRA REGULATIONS - HW Management System C~]
Part 260 - General Provisions
Subpart A - General
B - Definitions
" C - Rulemaki.ng petitions.
Part 261 - Identification and Listing of HW
Subpart A - General
" B - Criteria for Identifying the Characteristics of
HW and for Listing HW
" C - Characteristics of Hazardous Wastes
D - Lists of HW
Appendices
Part 262 - Standards Applicable to Generators of HW
Subpart A - General
B - The Manifest
" C - Pretransport Requirements
11 D - Recordkeeping and Reporting
" E - Special Conditions
Part 263 - Standards Applicable to Transporters of HW
Subpart A - General
" B - Compliance With the Manifest System & Recordkeeping
C - HW Discharges
Part 264 - Standards for Owners & Operators of HW
Treatment, Storage & Disposal Facilities
Subpart A - General F
" B - General Facility Standards F
" C - Preparedness & Prevention F
" D - Contingency Plan & Emergency Procedures F
" E - Manifest System, Recordkeeping & Reporting F
" F - Ground Water & Air Emission Monitoring P
" G - Closure & Post-Closure IF
" H - Financial Requirements P
" I - Use & Management of Containers IF
J - Tanks IF
" K - Surface Impoundments IF
L - Waste Piles IF
11 M - Land Treatment P
N - Landfills P
" 0 - IncineraHfrfs-T1* ?'•••'"'>••*** *«.^•m$n',*<"; •* ,i IF
P - (Reserved) /, -, ».-. ^,,^\ / ,'..7r:,
Q - (Reservad)o^M .<-,;„.-.>-,> .:>»: ... y U
" R - Underground Injection; J.'HIVJ »i ?•#. • ;}*.•; P
" S - Seepage Facilities ' '"* * ' "' " P
" T - Minimum Acceptable Treatment of HW P
Prior to Disposal
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C-2
Part 265 - Interim Status Standards for Owners & Operators of
HW Treatment, Storage & Disposal Facilities
Subparts A through 0 - Same as Part 264
Subpart P - Thermal Treatment
" Q - Chemical, Physical & Biological Treatment
" R - Underground Injection
Part 266 - Standards for the Management of Specific HW and
Specific Types of HW Management Facilities
Subpart A - General
" B - Elementary Neutralization Units &
Wastewater Treatment Units
Part 267 - Interim Standards for Owners & Operators of
New HW Land Disposal Facilities
Subpart A - General
" B - Environmental Performance Standard
C - Landfills
" D - Surface Impoundments
" E - Land Treatment
" F - Ground Water Monitoring
" G - Underground Injection
U.S. Environmental Protection Agency
Region 5, library {pt-UJ>
77 West Jackson Boulevard, 12th Floor
Chicago, II. 60604-3590
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