&EPA
United States
Environmental Protection
Agency
Office of
Water Enforcement
and Permits
October 1983
Procedures Manual
for Reviewing a POTW
Pretreatment Program
Submission
01A0004413
Stream/Ocean
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
GOT 5 1983 OFFICE OF
WATER
MEMORANDUM
SUBJECT: Pretreatment Program Guidance
TO: Users of the Procedures Manual for Reviewing a
iPOTW Pretreatment Program Submission
, .tA-CX>Cx««- \rJ /-]"*.
FROM: Kebecca W. Hanmer
Acting Assistant Administrator for Water (WH-556)
This manual presents the procedures for EPA Regions and
approved States to review local POTW pretreatment program submis-
sions. It facilitates the determination whether the submittal
contains the data and information required by the General Pretreat-
ment Regulations (.40 CFR Part 403), and whether the program is
approvable. It provides the reviewers with a suggested separate
checklist for reviewing each program element.
EPA Regional offices and States with approved programs must
continue their efforts to review and approve local POTW pretreat-
ment programs in their respective geographical areas. The approval
of local POTW pretreatment programs is the cornerstone of the
Agency's national pretreatment program.
While this approval is critical to the success of the national
pretreatment program, Approval Authorities must ensure that all
substantive parts of the local pretreatment program are present
when the program is approved. Prematurely approving incomplete
programs may cause major problems in the future. In instances
where a segment of the program is not fully developed when the
program is approved, then the Approval Authority and the POTW
should publicly document (preferably in writing) that a segment
of the program is not fully established and that it will be
developed after approval in accordance with an agreed upon time
table.
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Approval Authorities can use this manual to review and
approve any local POTW pretreatment program. However, when using
the manual and its checklists, these Authorities must understand
that the manual is for guidance and its use must be tailored to
the complexity and size of the program under review. A program
developed by a small POTW with relatively few industrial users
should not be reviewed in the same manner as a program developed
by a large POTW with many industrial users. The level of detail
and sophistication in the former program will naturally be less
than in the latter program. Approval Authorities must bear this
fact in mind when using this manual.
I believe that Approval Authority personnel will find this
manual to be a useful tool in reviewing local POTW pretreatment
program submissions on a consistent basis. As this guidance may
be revised periodically to reflect program experience or changes
in program regulations, please feel free to write to the Office
of Water Enforcement and Permits (EN-336) if you have suggestions
on how the guidance may be improved or areas which should be
addressed. Thank you.
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PROCEDURES MANUAL
FOR
REVIEWING A POTW
PRETREATMENT PROGRAM SUBMISSION
Rebecca Hanmer
Acting Assistant Administrator, Office of Water
Bruce R. Barrett, Jr.
Director, Office of Water Enforcement and Permits
Martha G. Prothro
Director, Permits Division
Dr. James D. Gallup
National Pretreatment Coordinator
October 1983
Office of Water Enforcement and Permits
Office of Water
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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ACKNOWLEDGEMENTS
This document was prepared with guidance from EPA
Headquarters, Office of Water Enforcement and Permits
and EPA Regional Offices. The State of Maryland Water
Resources Administration and New York State Department
of Environmental Conservation participated as peer
reviewers and provided valuable comments which have been
incorporated into this document. This Procedures Manual
was prepared by JRB Associates under EPA Contract No.
68-01-6514.
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TABLE OF CONTENTS
Page
1. INTRODUCTION 1-1
1.1 PURPOSE OF THIS MANUAL 1-1
1.2 HOW TO USE THIS MANUAL 1-2
1.3 COMMENTING ON PROGRAM SUBMISSIONS 1-3
2. LEGAL AUTHORITY 2-1
2.1 SUBMISSION COMPLETENESS 2-2
2.1.1 Relevant Regulations 2-2
2.1.2 Evaluation of Completeness 2-2
2.2 EVALUATION OF ATTORNEY'S STATEMENT 2-3
2.2.1 Relevant Regulations 2-3
2.2.2 Evaluation of Statement 2-4
2.3 LEGAL ADEQUACY 2-5
2.3.1 Relevant Regulations 2-5
2.3.2 Evaluation of Adequacy 2-5
2.4 MULTIJURISDICTIONAL SUBMISSIONS 2-13
2.5 LEGAL AUTHORITY CHECKLIST 2-14
3. TECHNICAL INFORMATION 3-1
3.1 INDUSTRIAL WASTE SURVEY 3-1
3.1.1 Adequacy of the Survey Master List 3-2
3.1.2 Thoroughness of Survey Questionnaire 3-3
3.1.3 Response to Survey 3-5
3.1.4 Completeness of Summary Information 3-5
3.2 LOCAL EFFLUENT LIMITS 3-6
3.2.1 Identification of Past POTW Operating Problems .... 3-7
3.2.2 Sampling and Analysis to Determine Fate and Effect . . 3-8
3.2.3 Development of Local Effluent Limits 3-10
TECHNICAL INFORMATION CHECKLIST 3-12
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TABLE OF CONTENTS (cont)
Page
4. PROGRAM IMPLEMENTATION PROCEDURES 4-1
4.1 UPDATE THE INDUSTRIAL WASTE SURVEY 4-1
4.2 NOTIFY INDUSTRIAL USERS OF APPLICABLE STANDARDS
AND REQUIREMENTS 4-2
4.3 UNDERTAKE COMPLIANCE MONITORING PROCEDURES 4-3
4.3.1 Receive and Analyze Self-Monitoring Reports
and Other Notices 4-4
4.3.2 Conduct Compliance Sampling and Analysis 4-5
4.3.3 Investigate Noncompliance 4-7
4.4 PUBLIC PARTICIPATION 4-9
PROGRAM IMPLEMENTATION PROCEDURES CHECKLIST 4-12
5. ORGANIZATION, STAFFING, EQUIPMENT, AND FUNDING 5-1
5.1 RELEVANT REGULATIONS 5-1
5.2 EVALUATION OF ORGANIZATION AND STAFFING 5-2
5.2.1 Clear and Appropriate Lines of Authority 5-3
5.2.2 Identification of Staff Responsibilities 5-4
5.2.3 Staff Qualifications 5-5
5.2.4 Staffing Levels 5-5
5.2.5 Coordination with Other Departments 5-6
5.3 EVALUATION OF EQUIPMENT 5-6
5.4 EVALUATION OF FUNDING 5-11
5.4.1 Implementation Costs 5-12
5.4.2 Financing Sources and Cost Recovery Systems 5-15
RESOURCES CHECKLIST 5-18
APPENDIX A BIBLIOGRAPHY OF PRETREATMENT REFERENCES A-l
APPENDIX B DEVELOPMENT OF DISCHARGE LIMITATIONS TO CONTROL
INCOMPATIBLE POLLUTANTS B-l
APPENDIX C PRIORITY POLLUTANTS AND CATEGORICAL INDUSTRY INFORMATION . C-l
ii.
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LIST OF TABLES AND WORKSHEETS
WORKSHEET 1
WORKSHEET 2
WORKSHEET 3
WORKSHEET 4
TABLE 5-1
TABLE 5-2
TABLE 5-3
TABLE 5-4
TABLE 5-5
TABLE 5-6
TABLE 5-7
Page
LEGAL AUTHORITY CHECKLIST 2-15
TECHNICAL INFORMATION CHECKLIST 3-12
PROGRAM IMPLEMENTATION PROCEDURES CHECKLIST 4-12
RESOURCES CHECKLIST 5-18
POTW PRETREATMENT PROGRAM PERSONNEL
REQUIREMENT RANGES 5-7
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES 5-8
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PROGRAM ACTIVITY 5-9
TYPICAL EQUIPMENT FOR A TWO-MAN FIELD SAMPLING CREW. . 5-13
TYPICAL COMMERCIAL LABORATORY COSTS 5-14
FACTORS AFFECTING POTW LEVELS OF EFFORT FOR
PRETREATMENT PROGRAM OPERATING TASKS 5-16
HYPOTHETICAL POTW PRETREATMENT PROGRAM
OPERATIONAL COSTS 5-17
iii
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1. INTRODUCTION
1.1 PURPOSE OF THIS MANUAL
This document has been prepared to assist States and EPA Regional Offices
in reviewing local pretreatment program submissions. It is intended to pro-
vide a framework for the review of local programs as well as general criteria
for evaluating these programs. The document can also serve as a starting
point for States to develop individualized checklists for review of local pro-
grams under their jurisdiction, if such checklists have not yet been devel-
oped.
A successful pretreatment program cannot be developed without adequate
legal authority, technical information, implementation procedures, and re-
sources. Each of these elements is essential in a successful program, and the
pretreatment program submission must demonstrate that all are present if it is
to be approved. A separate chapter in this manual is devoted to each element.
Each chapter contains:
A summary of pertinent regulatory requirements
A discussion of key items that should be included in the submission
General guidelines and criteria for assessing the adequacy of the
approaches proposed by the POTW
A checklist to aid the reviewer in evaluating completeness and
adequacy.
The focus of the review is to determine that the program not only meets
regulatory requirements, but also that it will function well once it is
implemented.
A majority of the regulatory requirements associated with a local pre-
treatment program are addressed in the legal authority chapter. Other
chapters identify activities, staff roles, and program items that are most
likely to be included in a well-planned program.
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1.2 HOW TO USE THIS MANUAL
Each of the four checklists is intended to be photocopied and used in
actual reviews. Agencies using these checklists may wish to separate the
various sections and delegate portions of the review to individuals who have
expertise in the appropriate areas. For example, a review of the technical
information chapter may be assigned to an engineer. A lawyer may be assigned
the task of reviewing the legal authority chapter, while someone with manage-
ment or administrative experience might be responsible for reviewing the pro-
gram implementation and resources sections of the submission. Each checklist
allows the reviewer to indicate whether the section as a whole adequately
satisfies Federal requirements, and to sign or initial this decision.
Not every item on a checklist must necessarily be included in the submis-
sion to satisfy Federal requirements for an approvable program. Optional
items are recommended on the checklists for a more comprehensive pretreatment
program, but these items are not required. The review must be flexible, since
the features necessary to operate a pretreatment program in a large community
may not be necessary or appropriate for a smaller one with few industrial
users. Where tables have been included in this manual to identify levels of
staff and costs associated with operating a program, they are intended to be
used as general guidance for the reviewer, not as rigid requirements for the
program submission. Program approval must ultimately be based on the best
professional judgement of the reviewer.
To make this manual most useful, the reviewer should be familiar with its
companion document, Guidance Manual for POTW Pretreatment Program Development.
The Preparation Manual is intended to assist municipalities in developing
their pretreatment programs and in preparing their program submissions. It is
important for the reviewer to understand both the objectives that the local
program is designed to achieve, and the process followed by a POTW in devel-
oping its program.
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1.3 COMMENTING ON PROGRAM SUBMISSIONS
A pretreatment program submission may be inadequate in some areas.
Inadequacies can be expected because the level of guidance and expertise
available to POTWs developing pretreatment programs varies across the country.
The reviewer should look upon weaknesses in a submission not as a problem, but
as an opportunity to give constructive guidance to the POTW authorities.
Comments should be designed to assist a particular POTW in preparing an
approvable submission, not simply make the submission package look good or
enable the POTW to comply quickly with a deadline.
The reviewer should point out specific weaknesses in the submission to
the POTW and offer suggestions to correct these weaknesses. By providing
clear and specific comments to the POTW, the reviewer can save the POTW time
in revising its submission. Written comments should be provided to the POTW
to ensure clarity, perhaps by sending a copy of the checklist with an explana-
tory cover letter that outlines the submission's inadequacies. The EPA
Regional Offices have a number of guidance documents, such as the Preparation
Manual, that contain information useful to a POTW developing its pretreatment
program. These documents (or relevant portions of them) could be attached to
the cover letter and sent to the POTW as additional assistance in program
development. Appendix A lists several guidance documents relevant to program
development.
The agency's review of a program submission should be complete before it
is transmitted to the POTW. All comments and questions should be sent to the
POTW at one time. The POTW should have a reasonable time period within which
to respond to the comments. If better documentation only is needed to com-
plete the submission, a few weeks will probably be sufficient. However, if
major areas were not addressed (such as sampling and analysis, or local pol-
lutant limits), as is often the case in first submissions, many months may be
needed to develop the required information.
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2. LEGAL AUTHORITY
The ability to develop and implement a successful pretreatment program
depends upon the existence of adequate legal authority. Since program imple-
mentation and control rest with local government, it is important that legal
authority be present at this level. The POTW must be able to respond to
challenges by industrial users, to protect its investment in the treatment
plant, to ensure the beneficial uses of its waters, and to protect the health
and welfare of its citizens.
The legal authorities needed to implement a pretreatment program are
listed in 40 CFR 403.8(f)(l). In summary, a POTW must be able to:
Deny or condition new or increased contributions of pollutants, or
changes in the nature of the pollutants discharged to the POTW
Require compliance with applicable pretreatment standards and require-
ments by industrial users
Control, through permit, contract, or other means, the contribution to
the POTW by each industrial user
Require the development of a compliance schedule by each industrial
user, and the submission of all notices and self-monitoring reports as
necessary to assure compliance
Carry out all inspection, surveillance, and monitoring procedures to
determine compliance, independent of information supplied by the
industrial user
Obtain remedies for noncompliance, including the ability to seek
injunctive relief, seek civil or criminal penalties, and/or collect
liquidated damages
Comply with the confidentiality requirements and limitations on data
restrictions specified in 40 CFR 403.14.
To document these authorities, the materials submitted by the POTW must
include a statement from the city solicitor or comparable official, and copies
of all pertinent statutes, ordinances, and related material.
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Determining the adequacy of a POTW s legal authorities requires a two-
part review. First, the submission must be reviewed to ensure that it is
complete. Second, if the submission is complete, the individual items must be
reviewed in more detail to determine that the legal authorities are adequate.
The checklist for evaluating legal authority is divided into two parts to
facilitate this review. The remaining sections of this chapter explain how to
use the checklist, and how to evaluate each of the items on the checklist.
2.1 SUBMISSION COMPLETENESS
2.1.1 Relevant Regulations
40 CFR 403.9(b) identifies the information that must be submitted to
document legal authority, including:
1. A statement from the city solicitor or a city official acting in a
comparable capacity (or the attorney for those POTWs which have in-
dependent legal counsel) that the POTW has authority to carry out the
program.
2. A copy of any statute, ordinance, regulation, contract, agreement, or
other authority that will be relied upon by the POTW to administer
the program.
3. A statement reflecting the endorsement or approval of local boards or
bodies responsible for supervising and/or funding the program.
2.1.2 Evaluation of Completeness
Part I of the Legal Authority Checklist is designed to evaluate complete-
ness. The final pretreatment program submission should be reviewed to ensure
that all of the items listed above are included. If they are not, the re-
viewer should notify the POTW that the submission is incomplete, noting the
specific deficiencies.
To determine that statements of all local boards/bodies are present, the
reviewer may first refer to the organizational portion of the submission to
identify the local boards/bodies involved in the program. It is also a good
idea to check the technical information portion of the submission because data
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from the industrial waste survey, service area description, or maps might
indicate participation by other jurisdictions. In several cases, a check of
the letterhead has also identified other boards/bodies.
Finally, if any of the legal authorities cited are discretionary on the
part of an official, the reviewer should look for a statement endorsing the
program by that official. While such an endorsement is not mandatory, it is
highly desirable. This endorsement is separate and distinct from the "funding
endorsement."
Having completed this review, the next and more difficult step is to
review the adequacy of the documentation itself. While the documentation may
be complete, even extensive, the requisite legal authority may not be present.
Conversely, legal authority may be adequate, but poorly documented due to a
lack of understanding.
2.2 EVALUATION OF ATTORNEY'S STATEMENT
2.2.1 Relevant Regulations
40 CFR 403.9(b)(l) requires a statement from the POTW attorney, city
solicitor, or another city official acting in a comparable capacity. The
individual who signs this letter should be the person who is responsible for
bringing an enforcement action in court. An acceptable statement must
identify:
1. The provision of the legal authority under section 403.8(f)(l), which
provides a basis for each procedure under section 403.8(f)(2)
2. The manner in which the POTW will implement the program requirements
set forth in section 403.8, including the means by which pretreatment
standards will be applied to individual industrial users (e.g., by
order, permit, ordinance, contract, etc.)
3. How the POTW intends to ensure compliance with pretreatment standards
and requirements and to enforce them in the event of noncompliance by
industrial users.
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It is important to keep in mind the following:
The statement must cite the provision of the POTWs legal authority
that fulfills each 403.8(f)(l) requirement, be it in the sewer use
ordinance, city code, or some other document
If the legal authority for each 403.8(f)(2) procedural requirement is
not clear, the statement should elaborate on where the requisite
authority lies
Whatever legal authorities exist in the permit, contract, etc., should
also be cited
The statement must specify the legal remedies that will be used to
ensure compliance with pretreatment standards and to enforce against
violators.
2.2.2 Evaluation of Statement
Part I of the Legal Authority Checklist is also used to evaluate the
attorney's letter. In evaluating an attorney's statement, look for evidence
that the attorney understands the scope of the POTWs pretreatment program.
Three basic questions should be answered in the evaluation:
(1) Does the statement identify the provision of legal authority for
each procedural requirement under 403.8(f)(2)?
The attorney's letter must specifically refer to the basic statutory
authority for the entire program (usually a provision in State law authorizing
the municipality to enact certain local ordinances or to enter into con-
tracts) , and cite particular ordinance (or contract or permit) provisions for
each authority listed in 403.8(f)(l). Where this has not been done or where
the cited provisions are found to be inadequate, the reviewer should note the
insufficiencies and a letter asking for clarification should be sent to the
attorney. Copies of this letter should also be sent to the POTW, EPA, and/or
the State. Any clarification received should be reviewed for completeness and
inserted into the submission package.
(2) Does the statement identify the manner in which pretreatment program
requirements of 403.8 will be implemented?
The attorney must state the control mechanism(s) to be employed in
applying pretreatment standards to industrial users. These include permits,
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contracts, ordinance provisions, and orders, among others. Most attorneys'
statements will not contain a detailed listing of 403.8 procedures, and this
is not necessary. A general description of the procedures %nd relevant con-
trol raechanism(s) is sufficientprovided the submission contains detailed
descriptions elsewhere. Often, the attorney's statement will simply refer to
the appropriate portions of the submission. This is acceptable if the submis-
sion itself is found to be adequate. If it is not, the attorney, POTW, and
other parties (e.g., EPA, State) should be notified of the problem with the
submission.
(3) Does the statement identify how the POTW intends to ensure compli-
ance?
A detailed explanation of compliance procedures does not necessarily have
to appear in the attorney's statement as long as these procedures are de-
scribed elsewhere in the submission. If the attorney's statement refers to
such a description or generally describes enforcement procedures that will be
followed, this portion of the statement should be judged adequate. However,
if enforcement is the responsibility of more than one jurisdiction, the state-
ment must explain how the POTW will ensure that the other jurisdictions carry
out their responsibilities, typically through a joint powers agreement (see
Section 2.4, Multijurisdictional Submissions, if more information is needed or
desired to make a determination). The statement should specify remedies
available in the event such an agreement is breached. A letter from the
attorney for each jurisdiction is required.
2.3 LEGAL ADEQUACY
2.3.1 Relevant Regulations
The legal authorities required for a local pretreatment program are
listed in 40 CFR 403.8(f)(l) and summarized in the introduction to this
chapter (page 2-1). Each is discussed in turn below.
2.3.2 Evaluation of Adequacy
The reviewer should look first for a reference to the State law author-
izing a municipality to enact an ordinance controlling use of the public sewer
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system and treatment plant. In some situations, several municipalities may
join in an agreement forming a new entity to operate and control a POTW and
its users. The te%ms of such an agreement must be examined to determine the
new entity's powers and to ensure that State law authorizes these powers.
Part II of the Legal Authority Checklist is used to assess the adequacy
of the authorities available for a POTWs pretreatment program. The required
legal authorities may be contained in a sewer use ordinance, joint powers
agreement, series of contracts, local regulations, or a combination of these
documents. Pretreatment programs that include many jurisdictions must contain
legal documentation from each participating jurisdiction.
The submission must show that the POTW has authority to:
(1) Deny or condition new or increased contributions
A POTW must have the power to regulate the discharge of pollutants which
may cause pass-through, interference, or sludge contamination problems, or may
exceed Federal categorical standards. Any ordinance or other written manifes-
tation that provides authority to effectively control such discharges by in-
dustrial users will satisfy this requirement. The reviewer should look for a
general prohibition of unauthorized (unpermitted) discharges and the authority
to deny or place conditions on discharges that change in character or volume
(e.g., a permit that can be modified upon notice of changed discharges). It
is recommended that a POTW require an industrial user to provide timely notice
of any substantial change in the quantity or quality of its industrial waste
discharge.
(2) Require compliance with applicable pretreatment standards
The POTW must be able to prohibit the introduction of pollutants into the
system which pass through or interfere with the operation or performance of
the treatment works. To accomplish this, the POTW must be able to enforce:
* General prohibitions against interference and pass-through
The five specific prohibitions listed under 403.5(b)
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Any local limits developed to implement the general and specific
prohibitions
National categorical pretreatment standards as they are promulgated.
The POTW must be able to require compliance with national categorical
pretreatment standards as they are promulgated. This prohibition should be
spelled out in the ordinance. The ordinance should explicitly reference
Federal pretreatment regulations and standards as an indication that these
standards have been fully incorporated and made enforceable by the ordinance.
Since not all of the national categorical standards have been promulgated, it
is unlikely that a complete list of the standards will be included in an
ordinance. Authority is adequate if the ordinance states that national
categorical standards will apply to industrial users once such standards are
promulgated, or that such standards will be imposed as a permit or contract
condition.
When operational problems arise, POTW officials must have the legal
authority to impose or revise local effluent limits to correct the problem.
Any generic authority to establish specific effluent limits is adequate.
Ordinance language indicating that local effluent limits may be made more
stringent than prevailing Federal standards in order to meet the POTW's NPDES
permit limitations or State water quality standards is recommended, but not
required.
Another operational problem that must be considered is sludge contami-
nation, which often limits disposal options. This concern stems from the
Federal pretreatment regulations which define a POTW interference to encompass
any discharge that prevents sludge use or disposal in accordance with Federal,
State, and local laws. Accordingly, either the ordinance definition of inter-
ference or effluent limits set in the ordinance should effectively prohibit
discharges which prevent proper sludge use or disposal.
Usually prohibited discharge standards are spelled out in an ordinance.
If they are not, authority may be adequate so long as the prohibitions can and
will be imposed as permit or contract conditions. General language is
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sufficient for prohibited discharge standards. Numerical limits are not
mandatory, for example, in defining explosive discharges. Since similar
questions often arise in reviewing programs, a few special cases are discussed
here for guidance. Where an industrial user end-of-pipe heat limitation is
set at a temperature higher than 104°F (as is often the case), the POTW should
demonstrate, as part of its technical submission, that the higher end-of-pipe
heat limitation will not cause the treatment plant influent temperature to
exceed the prohibited discharge standard of 104°F. In addition, it is
preferred that the dilution prohibition and the accompanying authority to
impose mass effluent limits be explicit in the POTW ordinance, and that these
authorities be extended to noncategorical industrial users.
Sometimes ordinances allow POTWs to establish special agreements with
industrial users to accept industrial waste discharges which otherwise do not
conform to effluent limits contained in the ordinance. Such provisions must
not allow the waiver of national pretreatment standards. Local standards may
be waived, but national pretreatment standards may not, unless such a waiver
is granted by mechanisms established under the General Pretreatment Regula-
tions (such as removal credits, fundamentally different factors variances, or
net/gross calculations).
(3) Control through permit, contract to ensure compliance
The POTW must be able to control the discharge of each industrial user.
This individual control can be accomplished by a permit that allows discharges
conforming to the standards set forth or by contract where the POTW provides
its services subject to agreed upon terms and conditions (similar to permit
provisions). An order to an industrial user is another acceptable technique.
Each of these approaches establishes a legal framework that controls the
volume and constitutents discharged, and establishes penalties for noncompli-
ance.
For larger systems, the establishment of a discharge permit system to
administer and enforce pretreatment standards and requirements is strongly
recommended. It should be noted that the regulations imply the use of a
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discharge permit, not a connection permit. A connection permit merely allows
individuals to hook up to the sewer system, and is similar to a building
license or construction permit. A discharge or sewer use permit regulates
continuing use of the sewer system and imposes conditions on discharges to the
system. Once adopted, a permitting mechanism should contain the following
components:
Permit application - used to collect pertinent data; often appended to
final industrial discharge permit
Limited duration - preferably no more than five years; allows periodic
review of discharge conditions
Non-transferability - any transfer of a discharge permit must, at a
minimum, be subject to POTW approval
Modification - allows incorporation of categorical standards and any
specific effluent limits necessary to correct operational problems at
the POTW; useful in dealing with noncompliance
Conditions - conditions for discharge should be clearly stated in the
discharge permit
Revocation - excellent enforcement tool; permit system can be used
effectively to enforce against detrimental activities besides illegal
waste discharges (e.g., falsification of self-monitoring reports,
tampering with monitoring equipment and methods, refusal to allow
timely access to industrial premises, etc.).
A discharge permit system should allow adequate flexibility in altering
discharge conditions to correct any operational problems at the POTW or to
reflect changes in environmental regulations. An industrial discharge permit
should never grant excessive legal right to pollute, as may occur, for exam-
ple, if permits are issued for indefinite duration or made freely transferable
without the need for POTW approval.
(4)(a) Require development of compliance schedules for installation of
technology
A POTW must have the authority to establish and enforce deadlines for the
installation by an industrial user of any treatment facilities needed to meet
applicable pretreatment standards. "Compliance schedules" should either be
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specifically mentioned in the ordinance or be imposed under some broad author-
ity (e.g., permits). The authority to require installation of pretreatment
technology and impose in a permit any conditions necessary to ensure compli-
ance with the ordinance is adequate. These conditions should include time
limits that ensure progress is being made in discrete steps.
(4)(b) Require submission of notices and self-monitoring reports
The POTW must be able to require the five reports listed in 403.12 and
any reports listed separately as part of a categorical standard, including:
Baseline monitoring reports
Compliance schedule progress reports
Compliance report on categorical standards deadlines
Periodic reports on continued compliance
Notice of slug loading.
The reviewer should look in the ordinance (or contract) for either a detailed
description of the reports or a provision stating that reporting will be re-
quired at a particular official's discretion or as a permit condition. If the
ordinance actually details what the reports will contain, the reviewer must
ensure that the reports required by the ordinance meet the specifications
listed in 403.12.
A POTW must also have the authority to require industrial users to pro-
vide prompt notification upon the discharge of any slug load or accidental
discharge which may contribute to an interference at the treatment plant. In
addition, it is recommended that a POTW establish penalties for any action
taken by an industrial user which affects the integrity of monitoring proce-
dures, such as falsifying self-monitoring reports or tampering with monitoring
equipment and methods.
(5) Carry out inspection, surveillance, and monitoring procedures
A POTW must have the authority to enter industrial premises for the pur-
poses of inspecting, sampling and monitoring industrial waste discharges, and
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reviewing any records required to be kept onsite. POTW officials must be
allowed to enter the premises at any reasonable time, not just during normal
working hours. This additional flexibility may be necessary for handling
emergency situations, suspected illegal nonwork hour discharges, and cases of
suspected tampering with monitoring equipment. No language in a POTW ordi-
nance shall require the POTW to afford prior notice of inspection, sampling,
and monitoring activities. Although prior notice may be given to ensure
cooperation, it is not always a good idea because it may enable the user to
alter conditions being investigated.
The checklist identifies several items that might be included in the
right to inspect. It is not important for the ordinance to specifically list
these things so long as they are permissible interpretations of a given
authority. The reviewer should beware of any language limiting the right of
an inspector to enter any premises where effluent sources, treatment systems,
or records are located (e.g., process investigation restrictions or limita-
tions on access to records). A POTW must also have the authority to require
industrial users to install, use, and maintain monitoring equipment that en-
ables effective self-monitoring by the industrial user and compliance moni-
toring by the POTW.
(6)(a) Obtain remedies for noncompliance
Two remedies for noncompliance must be available: injunctive relief, and
civil or criminal penalties. An injunction may be necessary to prevent irrep-
arable harm to the treatment plant, to the health and safety of plant workers
and other individuals, or to the environmentthose situations where damages
at law would not be an adequate remedy. Injunctive relief might not be spe-
cifically mentioned in the sewer use ordinance. It might still be available,
however, as a matter of common law. In such a circumstance, the attorney
should explain precisely how the POTW can seek injunctive relief.
Where a POTW has police powers, it must establish the authority to
enforce civil or criminal penalties against industrial users that violate
pretreatment standards or requirements. An ordinance provision granting a
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POTW the authority to impose a penalty or fine of at least $300/violation/day
constitutes an adequate civil or criminal penalty for the purposes of this
requirement. EPA regulations specify that, where State law does not permit a
municipality to impose civil or criminal penalties, the municipality must
enter into contracts that provide for liquidated damages for a violation of
pretreatment standards and requirements. This type of contract should be
avoided if at all possible for two reasons. First, courts generally do not
enforce penalty clauses in contracts. A liquidated damages clause is likely
to be perceived as a penalty substitute and therefore held unenforceable.
Second, even if the clause is held enforceable, most POTWs would not want to
be limited in the amount recoverable for actual plant damages caused by an
illegal discharge. The establishment of an administrative/adjudicative
mechanism (e.g., show-cause hearing) to resolve conflicts between industrial
users and the POTW is also recommended.
(6)(b) Authority to immediately and effectively halt or prevent any
discharge
A POTW must be able to halt immediately any actual or threatened dis-
charge which may present an imminent or substantial endangerment to the health
and welfare of persons or the environment, or cause interference with the
treatment plant's operation. An ordinance can provide this authority by
allowing the POTW to suspend wastewater treatment service and/or discharge
permits in such situations, and by requiring the discharger to immediately
stop or eliminate the contribution upon notification of the suspension. The
ordinance should further provide that if the discharger fails to comply volun-
tarily with a suspension order, the POTW may take any steps necessary, in-
cluding severance of the sewer connection, to prevent further discharge. If
the ordinance does not provide such authority, it may still be available as a
valid exercise of police powers. The POTW attorney should explain emergency
procedures in his statement.
(7) Comply with confidentiality requirements
While a POTW may establish procedures to protect confidential data, it
must be able to release effluent data to the public. Effluent data as defined
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in 40 CFR 2.302 must be available to the public without restriction. Effluent
data include:
Information necessary to determine the identity, amount, frequency,
concentration, temperature, or other characteristics of any pollutant
discharged
A description of the manner or rate of operation of any source to the
extent necessary to determine what was discharged under an applicable
standard or limitation
A general description of the location and nature of the source to the
extent necessary to distinguish it from others.
Data or information on research, products, processes, and methods can be pro-
tected to a large extent and need only be released if necessary to disclose
that a source is in or out of compliance or to allow a determination of feasi-
bility/attainability of a standard or limitation. Information that is propri-
etary, a trade secret, or business confidential can be withheld provided it is
not "effluent data" as defined above.
2.4 MULTIJURISDICTIONAL SUBMISSIONS
POTWs often serve more than one political jurisdiction. In these
instances, the agency or entity holding the NPDES permit for the discharge of
municipal wastewater has primary responsibility to enforce pretreatment stan-
dards throughout the entire geographical area served by its conveyance and
treatment system. A sufficient ordinance/resolution or regulation and
pretreatment program must be in place for each industrial user within the
treatment plant's service area.
This requirement may or may not present a problem, depending upon how the
POTW is structured. If a special sewer district encompassing the entire
service area has been created, and the sewer district has rulemaking authority
sufficient to implement a centralized pretreatment program, there is no
problem. The typical case, however, involves municipal POTWs which service
industries lying beyond the municipal boundaries and thus beyond the reach of
municipal ordinances. A mechanism to control the discharges of these
industries should be established. In order to control the discharges of such
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industries, there must be either: (1) an agreement between the POTW and the
outlying jurisdiction where the industry is located (this agreement should
specify that the outlying jurisdiction will enforce the POTW1s requirements or
else allow the POTW itself to undertake enforcement); or (2) a contract
between each industry and the POTW which conditions the industry's receipt of
sewer service upon compliance with the POTW's requirements.
It is recommended that the POTW and each outlying jurisdiction with a
categorical or significant industrial user enter into an interjurisdictional
pretreatment agreement. This agreement should address the following:
Ordinance or regulation
Local discharge limit mechanism
Pretreatment program administration
Records transference
Inspection and sampling authority
Enforcement.
In its final pretreatment submission, the POTW should include:
The ordinance/resolution or regulation for each jurisdiction involved
The POTW1s pretreatment agreements with the contributing jurisdic-
tions.
Each ordinance should be evaluated individually for the required legal author-
ities discussed in Section 2.3. It will be necessary for the reviewer to
complete a Legal Authority Checklist for each jurisdiction served.
2.5 LEGAL AUTHORITY CHECKLIST
The Legal Authority Checklist (Worksheet 1) is divided into two parts.
Part I is designed to cover submission completeness, while Part II covers
legal adequacy. Both parts reference the applicable sections of the Federal
pretreatment regulations.
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Worksheet 1
Legal Authority Checklist
Name of POTW
Date
Yes No
Section
of POTW s
Submission
PART I.
A.
Submission Completeness Checklist (Legal Aspects)
40 CFR 403.9(b) requirements for submission:
(1) Does the submission contain a statement from
the city solicitor, POTW attorney, or other
official?
(2) Does the submission contain a copy of every
legal authority source cited in the attorney's
statement or necessary for program implemen-
tation? (e.g., ordinances, contracts, statutes,
joint agreements, permits, regulations, etc.)
(3) Does the submission contain endorsements from
all local boards/bodies responsible for super-
vising/funding the pretreatment program?
k(4) If any of the legal authorities cited are vested
in a particular official's discretion, is there
a statement of endorsement from such official?
B.
C.
40 CFR 403.9(b)(l) requirements for attorney's
statement:
(1) Does the statement identify the provision of
legal authority for each requirement under
403.8(f)(2)?
(2) Does the statement identify the manner in which
403.8 program requirements will be implemented?
(3) Does the statement identify how the POTW intends
to ensure compliance?
If the POTW service area includes more than one
agency, jurisdiction, government, or body, does the
submission include all ordinances, resolutions,
regulations, service agreements and other legal
documents relevant to the analysis of multijuris-
dictional issues? (Use separate Part II forms
for each jurisdiction.)
PART II. Legal Adequacy [403,8(f)(l)]
Does the POTW have the authority to:
A. Deny or condition new or increased contributions of
pollutants? [403.8(f)(l)(i)]
B. Require compliance with applicable pretreatment
standards? [403.8(f)(l)(ii)]
(1) General prohibitions:
ference [403.5(a)]
pass-through, inter-
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Worksheet 1
Legal Authority Checklist (Continued)
Name of POTW
Date
(2) Specific prohibitions [403. 5(b)]:
Fire/ explosive hazard?
pH/ corrosion?
Solid or viscous - obstruction/ interference?
Flow rate or concentration to cause inter-
ference?
Heat - treatment plant influent 40 °C (104°F)?
Locally developed limits? [403. 5(c) and (d)]
National categorical standards?
(3)
(4)
Yes
No
Section
of POTW's
Submission
C. Control through permit, contract, etc., to ensure
compliance? [403.8(f)(l)(iii>]
D. Require development of compliance schedules and
submission of reports? [403.8(f)(l)(iv)]
(1) Development of compliance schedules for
installation of technology?
(2) Submission of notices and self-monitoring
reports including 403.12 requirements (baseline
report, compliance schedule progress report,
report on final compliance with categorical
pretreatment standards, periodic reports on
continued compliance, notice of slug loading)?
E. Carry out inspection, surveillance, and monitoring
procedures: [403.8(f)(l)(v)]
(1) Right to enter premises at any reasonable time?
(2) Right to inspect generally for compliance?
(3) Right to sample?
(4) Right to require installation of monitoring
equipment?
(5) Right to inspect and copy records [403.12(n)]?
F. Remedies for non-compliance by industrial users?
[403.8(f)(l)(vi)J
(1) Obtain remedies for noncompliance:
Injunctive relief?
Are the civil or criminal penalties sufficient
to bring about compliance , or act as a
deterrent?
(2) Halt immediately and effectively any actual or
threatened discharge?
G. Comply with confidentiality requirements (protection
of public access to effluent data)? [403.8(f)(l)(vii)]
[403.14]
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Worksheet 1
Legal Authority Checklist (Continued)
Name of POTW
Date
Yes
No
Section
of POTW's
Submission
H. Form special agreements (waivers):
(1) Does the ordinance contain a special agreement
clause?
(2) If yes, does this special agreement clause
specifically exclude the waiver of Federal
categorical pretreatment standards?
I. Control extra-jurisdictional agencies, and industries
which contribute industrial wastewaters to the POTW?
*Indicates item is recommended, but not mandatory.
I have reviewed this submission in detail and have determined the legal authority
to be:
) Adequate
Date:
( ) Inadequate
Reviewed by:
(Name)
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3. TECHNICAL INFORMATION
Sound technical information is necessary to develop and implement a suc-
cessful pretreatment program. Although the information available to a POTW
will increase and improve in accuracy once the pretreatment program is under-
way, the submission should contain sufficient, valid technical data to demon-
strate that:
All industries discharging pollutants which may adversely impact the
collection system or treatment works have been identified
The pretreatment program (particularly procedures) is designed to
control the number and type of industrial users discharging to the
system
Local effluent limits are adequate to protect the POTW and enable
compliance with its NPDES permit.
Without this information, the ability to achieve the objectives of a pretreat-
ment program may be questioned.
This chapter focuses on evaluating the completeness and adequacy of the
technical information upon which the local program is based. Two major ele-
ments will be assessed: (1) the industrial waste survey (IWS), the method by
which a POTW gathers relevant data on its industrial users, and (2) the local
effluent limits developed to prevent industrial discharges that might inter-
fere with POTW operations or cause permit violations. A checklist is provided
to assist the reviewer in determining the completeness and adequacy of the
documentation provided in the submission.
3.1 INDUSTRIAL WASTE SURVEY
40 CFR 403.8(f)(2) requires a POTW to identify and locate all possible
industrial users that might be subject to the pretreatment program and to
identify the volume and character of pollutants discharged to the treatment
plant. The objective of these requirements is to ensure that the pretreatment
program includes those industries which can potentially cause pass-through,
interference, or sludge contamination problems* The program submission must
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demonstrate that these requirements have been met. A suggested method to
gather this required information involves the following steps:
Develop a list of potential industrial users
Eliminate industrial users that are not problems
Survey remaining industrial users to gather pertinent data
Follow up as necessary to ensure adequate response
Compile and evaluate information collected.
While variations from this generic approach are acceptable, most approvable
submissions will include these elements.
3.1.1 Adequacy of the Survey Master List
The pretreatment program submission should include a master list of all
industrial users discharging to the treatment plant. The sources used to
develop this list should be documented, such as:
Water use and billing records
Sewer connection permits
Business license records
Chamber of Commerce rosters
Local telephone directory
Utility company records
Property tax records
Other standard listings of industrial firms.
Lists based on current water use, sewer permits, and license records are
usually very complete. If these are not available, several different sources
may be needed to develop a comprehensive master list. In determining the
adequacy of the sources, the reviewer should examine critically the type and
number of sources used. A small POTW with few industrial users will often
know its users well. In such a case, the sources used to develop the master
list are not critical. However, for a large POTW, this would not necessarily
be the case, and sources should be carefully reviewed.
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Since the sources above may include insignificant industries, the POTW
will often establish criteria for eliminating industries from the list. These
criteria should be valid and should be documented in the pretreatment program
submission. For example, valid criteria for exclusion could include:
A manufacturing operation which does not generate wastewater (dry
manufacturing process)
A direct discharger
A discharger of sanitary wastewater only.
In reviewing the exclusion rationale, it is important to determine which
industries were eliminated from the list and why they were eliminated. The
reviewer should determine (based upon experience with similar operations)
whether any of the eliminated industries might potentially affect the treat-
ment plant. If this is the case, the POTW should be notified of the concern.
3.1.2 Thoroughness of Survey Questionnaire
The POTW should gather discharge information from all industries on its
master list. The submission should identify the procedure used to gather
information. This procedure might include:
Questionnaires mailed to industries
Telephone calls
Visits to industries
Information already on file at POTW.
The submission should also provide the date of the industrial waste survey.
Survey information should be as current as possible, and preferably no more
than three years old.
It is satisfactory for a small POTW with few industries to use telephone
calls or site visits to survey its industries. This is usually not feasible
for a larger system with many industrial users. Most large POTWs use ques-
tionnaires to collect survey information. It is helpful for the submission to
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include a copy of the questionnaire, although this is not required. If in-
cluded, the questionnaire should be reviewed to determine whether it requests
sufficient information to establish a basis for local limits development and
the compliance monitoring program. The questionnaire should be easy to read
and understand. It should require the signature of an official authorized to
sign for the company, as well as the name of a company representative who can
be contacted by the POTW to arrange site visits for inspection and monitoring.
Information requested from industrial users, whether by questionnaire,
phone call, or visit, should be described. At a minimum, the following infor-
mation must be requested:
Name of industry
Address of facility
SIC code(s) or expected classification
Wastewater flow (or water consumption rate if flow is not known)
Quantities and concentrations of pollutants discharged
Major products manufactured or services supplied
Description of onsite pretreatment facilities and practices.
Although not required, it is recommended that the following information also
be requested:
Locations of discharge points
Raw materials used or stored at the site
Flow diagram or sewer map for the industry
Description of current wastewater treatment practices
Number of employees
Operation and production schedules.
A POTW which already has an existing pretreatment program may possess files
containing information normally gathered by a survey. If the information is
current and includes both industrial classifications and pollutant concentra-
tion/quantities, an additional survey may not be needed.
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3.1.3 Response to Survey
The submission should describe the survey1s comprehensiveness by includ-
ing the number and percentage of industrial users responding to the survey.
It should also include a detailed description of follow-up procedures used to
obtain information from industries which either failed to respond or returned
incomplete surveys. Follow-up measures would most likely include letters of
reminder, telephone calls, and/or site visits. A response rate of less than
80 percent will most likely hinder the establishment of an effective program.
At lower rates, there would be less confidence in extrapolating survey re-
sults, since major classes of dischargers will probably be omitted or inappro-
priately represented.
3.1.4 Completeness of Summary Information
Unless the State or EPA specifically requests the inclusion of all
responses to the industrial waste survey, it is not necessary that they be
included in the submittal. It is usually more valuable to have the results of
the survey summarized. Results should be tabulated in a format that includes
the number of industries in specific SIC categories and the quantities of
specific pollutants entering the POTW system. This format will enable the
POTW to more easily identify industries which will be subject to categorical
standards and industries discharging pollutants controlled by local standards.
Appendix C provides the reviewer with information concerning the 25 cate-
gorical industries. Table C-l indicates which pollutants are commonly dis-
charged from each category of industries. Table C-2 lists those categories or
subcategories which have been excluded from regulation and Table C-3 contains
a listing of SIC codes for industries affected by the categorical standards.
The summary data should be reviewed to determine whether the POTW has
full knowledge of the nature and extent of pollutant discharges affecting the
plant. This summary should demonstrate that sufficient information is avail-
able to provide a sound foundation for all subsequent program development
activities.
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3.2 LOCAL EFFLUENT LIMITS
40 CFR 403.5(c) requires the POTW to develop and enforce local effluent
limits to ensure that:
Pollutants discharged by industrial users do not pass through or
interfere with the operation and performance of the treatment plant
Prohibited discharges (i.e., heat, explosive/fire hazards, corrosive
agents, etc.) are avoided.
Local effluent limits must not be developed and enforced without providing
individual notice and an opportunity to respond to any affected party request-
ing such notification.
In order to demonstrate the adequacy of local limits, the program submis-
sion should include the technical information on which these limits are based.
This information includes operation and maintenance data, a description of
current sludge disposal practices, and the nature and extent of sampling
activities. It is not adequate to adopt, without any rationale, literature
values or values from other POTW ordinances as local limits. Unique charac-
teristics at each POTW should preclude the uniform application of literature
values.
Furthermore, it is not acceptable to have a pretreatment submission with-
out any numerical limits. A pretreatment program is not in force in the
absence of limits, since limits supply the benchmark against which all non-
compliance enforcement activities will be measured. Without specific limits,
monitoring will have very little meaning since the POTW will have no way of
knowing whether a violation exists. If a violation does develop, there would
be no basis for enforcement. As a result, limits on industrial pollutants,
including those limits that can be currently met by industry without any
treatment or in-plant control, are a minimum requirement.
The major steps toward establishing local effluent limits include:
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Identifying industrial pollutants entering the treatment system
Identifying past POTW operating problems
Sampling and analyzing to determine fate and effect
Developing numerical limits.
The first step was discussed in Section 3.1. The remaining steps will be
discussed in the following sections. The intent is to provide the reviewer
with guidelines to ascertain the adequacy of the information presented.
3.2.1 Identification of Past POTW Operating Problems
It is important for the reviewer to determine whether the POTW has taken
adequate steps to identify operating problems known or suspected to have been
caused by industrial discharges. At a minimum, these steps would include a
review of operating records to identify the frequency of treatment plant
upsets and NPDES violations. The submittal should indicate the number and
frequency of upsets, problems, or violations during a recent period (usually
the past 18 months) and the probable cause of such incidents.
The submission should describe each known or suspected case of operating
problems caused by an industrial discharge, such as:
Reductions in removal efficiency
Degradation of the collection system facilities
Emergencies such as sewer plugging, excessive corrosion, unusual
odors, explosion hazards, explosions or fires
Violation of NPDES permit conditions
Water quality degradation and fish kills at the POTW1s effluent dis-
charge point
Sludge contamination.
These descriptions should be sufficiently detailed to determine the cause of
the problem (e.g., industrial discharge, equipment failure, or improper opera-
tion and maintenance), duration of the incident, magnitude of the damage done,
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and corrective actions taken. In the case of permit violations, the specific
parameter(s) violated should also be identified.
Although prevention of sludge contamination is a major objective of the
Federal regulations, this issue is often overlooked in preparing a local
pretreatment program. The submission should include a description of the
volume and characteristics of sludges produced at the treatment facility and
discuss current methods of disposal. The impact industrial contributors have
on current sludge disposal methods should be discussed, and any future dis-
posal methods should be evaluated. The most stringent applicable standards,
whether Federal, State, or local sludge pollutant limits (other than for
conventionals), should be provided.
If the program is for a new treatment plant, information on past perform-
ance will not be available. In this case, it is important to ensure that the
POTW used the pollutant information obtained from its industrial waste survey
to assess: (1) the treatment system's tolerance for pollutants; (2) the
effects of pollutants on proposed NPDES permit limits and/or on receiving
water quality; and (3) the effect of these pollutants on the POTWs sludge
disposal options.
3.2.2 Sampling and Analysis to Determine Fate and Effect
The nature and extent of the POTW sampling program should be documented
in the program submission. Often, POTWs sample and analyze influent and
effluent quality for parameters such as BOD, TSS, pH, fecal coliform, tempera-
ture, flow, chlorine demand or residual chlorine, and dissolved oxygen.
Sometimes, parameters such as COD, ammonia, total nitrogen, and total phospho-
rus are also measured. Based on a review of both industries discharging to
the POTW and past operational problems, additional sampling and analysis may
be needed to quantify the extent of pollutant pass-through and sludge contami-
nation, and to provide a basis for establishing local limits.
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Such a sampling program should be designed to obtain quantitative infor-
mation regarding the concentration, loads, and fluctuations of specific pollu-
tants identified from the industrial waste survey. The program may include:
Sampling of significant industries to quantify industrial pollutant
loading
Sampling of nonindustrial interceptors within the collection system to
determine the background concentration and loading from nonindustrial
sources
Scan of the POTW influent, effluent, and sludge for the 126 priority
pollutants
Sampling within the treatment plant itself to determine, via mass
balance calculation, the fate of the specific pollutants within the
treatment plant, and to determine the areas within the system which
are most heavily affected by the pollutants in question
Sampling and analysis of POTW sludge for priority pollutants when the
POTW uses land spreading or ocean dumping for sludge disposal
Sampling and analysis of POTW sludge leachate when the POTW uses a
sanitary landfill
Sampling and analysis of ash resulting from incineration of POTW
sludge.
In evaluating a pretreatment sampling program, the reviewer needs to
determine if:
The appropriate pollutants were sampled
The appropriate sampling locations were chosen
The appropriate type of sampling was performed (composite or grab)
Sufficient samples were taken to acquire the necessary information to
establish limits
The data are adequate to support the limit-setting process
The sampling and analysis procedures were adequate.
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3.2.3 Development of Local Effluent Limits
Local effluent limits must be established in the following cases:
If an industry is discharging pollutants which are harmful to the
treatment system
If categorical standards have not yet been promulgated for that
industry
If categorical standards are not sufficient to protect the treatment
plant
If significant industries are not covered by categorical standards.
The program submission should explain the basis for deciding what local limits
are required. The reviewer should determine if the need for local limits has
been correctly assessed based upon information in the IWS, past operational
problems, and any sampling results presented.
The program submission should document the procedures used, or proposed
to be used, to establish specific local limits. The procedures should have a
strong scientific basis, and all industrial pollutants of concern should be
covered. The reviewer should evaluate appropriateness, adequacy, and consis-
tency with applicable national and State pretreatment standards. In no case
can local limits be less stringent than existing national and State pretreat-
ment standards for a given industry.
The reviewer should also ascertain whether local limits are applied
equitably among the industries discharging the regulated pollutants. Ideally,
the limits should be technically and economically achievable. The criteria
for "economic" and "technical" feasibility, if used, must be stated and be
consistent with applicable Federal, State, and local laws. As a general rule,
limits on specific pollutants should not be lower than the detection limits of
currently available standard laboratory analytical techniques. Finally, the
reviewer should check to see that the procedures used to develop limits, the
data supporting the limits, and the rationale for the limits have been made
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available to industrial users and other interested parties. These parties
must also have been given the opportunity to review and comment on the limits,
A general methodology for establishing local limits is presented in
Appendix B. If the reviewer is unfamiliar with the establishment of such
limitations, this Appendix may be useful in evaluating the methods and limits
contained in the POTW's submission.
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Worksheet 2 Name of POTW
Technical Information Checklist Date
Section
of POTW's
Yes No Submission
PART I. Industrial Waste Survey [403.8(f)(2)(i) and (ii)]
A. Were the sources used sufficient to assure that all
major industrial users were identified and located?
B. Were the criteria used to eliminate industries
from the inventory appropriate?
C. Survey Questionnaire
(1) Did the POTW obtain the following information
(either through the survey or other means):
Name?
Address?
SIC code(s) or expected classification?
Wastewater flow rate or water consumption
rate?
Loads and/or concentrations of pollutants
in discharge?
Major products manufactured or services
supplied?
* Residuals generated by lU's disposal methods?
* Locations of discharge points?
Description of existing pretreatment
facilities and practices?
(2) Is the information current within the last
3 years?
*(3) Does the questionnaire require the signature
of an authorized company representative?
D. Follow-Up Procedures
(1) Did the POTW follow up the questionnaire (with
additional written requests, telephone calls
or site visits) to obtain a complete and
accurate response?
E. Summary Information
(1) Were the users classified by industrial category
and/or SIC code?
(2) Has the POTW correctly characterized the waste
discharged from each industrial user or
industrial type?
(3) Does the information obtained demonstrate
sufficient characterization of the lU's waste
discharges to the POTW?
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Worksheet 2
Technical Information Checklist (Continued)
Name of POTW
Date
Yes No
PART II. Methodology for Establishing Discharge Limitations [403.5(c)]
A. POTW Operating Problems and Plant History
(1) Did the POTW adequately document instances of:
Inhibition/upset?
Pass-through?
Sludge contamination?
B. Developmental Sampling Program
(1) Has the POTW recently sampled and analyzed:
Treatment plant influent?
Treatment plant unit operations?
Plant effluent? ^^ ~^_
Sludge? ' ""
Industrial effluents?
(2) Did this analysis include pollutants of
concern identified in the survey?
(3) Were appropriate sampling locations chosen?
In the treatment system?
In the collection system?
At the industries?
(4) Was the appropriate type of sampling performed
for each pollutant type (composite or grab)?
*(5) Was the sampling frequency sufficient to
give an accurate characterization?
Section
of POTW's
Submission
C. Need for Locally Developed Discharge Limitations
(1) Did the POTW assess whether or not pollutants are
present in the influent in amounts that inhibit
treatment processes used by the POTW?
(2) Did the POTW assess whether or not toxic pollu-
tants are present in the POTW effluent in
amounts known to exceed water quality criteria?
(3) Are sludge disposal methods acceptable in view
of pollutant load?
D. Methodology for Setting Local Discharge Limits
(refer to Appendix B)
(1) Is the methodology appropriate?
(2) Were relevant numbers used for:
Inhibition/upset concentrations?
Background concentrations?
Removal efficiencies?
Water quality criteria/standards?
Land application criteria?
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Worksheet 2 Name of POTW
Technical Information Checklist (Continued) Date
Section
of POTW's
YejB No Submission
Non-secured landfill disposal (including ash
disposal)?
E. Appropriateness of Locally Developed
Discharge Limitations
(1) Are local limitations at least as stringent as
national pretreatment standards for the
appropriate categories?
(2) Do local limitations enable the POTW to meet
NPDES permit limits?
(3) Will State water quality standards be met once
local discharge limits are complied with?
(4) Will State sludge disposal guidelines/
regulations be complied with?
F. Multijurisdictional Submissions
Were data from lUs and treatment plants in all
jurisdictions considered in developing this
technical information?
*Indicates item is recommended, but not mandatory.
I have reviewed this submission in detail and have determined the technical
information to be:
( ) Adequate ( ) Inadequate
Date: Reviewed by:
(Name)
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4. PROGRAM IMPLEMENTATION PROCEDURES
Thorough and complete program implementation procedures are necessary
components of a pretreatment program. The minimum procedures which must be
documented in the pretreatment program submission are detailed in 40 CFR
403.8(f)(2). A POTW must be able to:
Identify and locate all industrial users possibly subject to the pre-
treatment program
Identify the character and volume of pollutants discharged to the
treatment works by these users
Notify industrial users of applicable standards and requirements
Receive and analyze self-monitoring reports and other notices from
industrial users
Randomly sample and analyze industrial effluents
Investigate instances of noncompliance
Comply with public participation requirements.
The procedures adopted by a POTW should be well thought out and easy to under-
stand. They should be clear enough to be followed by all users, the public,
and POTW staff members. Finally, the procedures should be flexible enough to
allow reaction to day-to-day operating situations. In evaluating these proce-
dures, the reviewer needs to determine whether they are complete and respon-
sive to the Federal requirements outlined above, and whether they can be
effectively implemented.
The first two requirements have already been covered in Section 3.1,
Industrial Waste Survey. Accordingly, this chapter will focus only on updat-
ing the IWS and on the remaining five procedures. As in earlier chapters, a
checklist is provided at the chapter's end.
4.1 UPDATE THE INDUSTRIAL WASTE SURVEY
To adequately implement the pretreatment program, information on indus-
trial users should be updated on a regular basis. Up-to-date information is
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essential not only for determining the nature and quantity of the waste
entering the system, but also for scheduling pretreatment activities and
allocating resources to meet changing program needs. The submission should
include procedures for identifying and gathering information on new industries
moving into the POTW service area and for updating its existing user informa-
tion base. There are various mechanisms through which new industrial users
can be identified, including:
A requirement that new industries fill out applications for sewer use
when they apply for business licenses
Communication with other city departments (water, utilities, health,
and building departments) concerning new industries in the POTW ser-
vice area
Continual review of business license records and/or other standard
listings of industrial firms, such as Chamber of Commerce rosters or
the telephone directory.
In addition, the IWS should be updated on a continual basis. Several
updating procedures are available, such as:
A permit system which requires notification of changes in industrial
processes, wastewater discharges, or industry ownership
Ongoing POTW inspection and monitoring activities
Periodic expiration of permits and subsequent reapplication by permit
holders
Periodic mailing of an IWS questionnaire to the industry accompanied
by a request to update the information.
4.2 NOTIFY INDUSTRIAL USERS OF APPLICABLE STANDARDS AND REQUIREMENTS
The POTW is responsible for being up-to-date on all Federal pretreatment
standards and applicable requirements under the Clean Water Act and Resource
Conservation and Recovery Act. Such standards and requirements include:
Federal categorical standards
State standards
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Local limits
Other pertinent requirements (e.g., user charges).
A number of techniques are acceptable for obtaining current information
on the status of national categorical standards. A POTW may assign a staff
member to review the Federal Register or it may rely upon an attorney to per-
form this function. In some instances, the POTW may obtain the information
from the State pretreatraent coordinator, if the State provides such a service.
Periodic requests or phone calls to State or EPA officials may also be suffi-
cient.
The POTW is also responsible for notifying any industrial user that may
be affected by existing or newly promulgated standards and requirements.
Ongoing procedures to do this should be identified in the program submission.
Suitable procedures include:
General mailing list
Individual letters to industries
Permit/contract conditions
Permit/contract modifications
Published notices in newspapers, circulars, etc.
If notification by mail is proposed, it is usually a good idea to require a
signed acknowledgement of receipt to ensure that the notice has actually been
received by the industry. Newspaper notices may be adequate if the notices
appear in the same section of the paper on a fixed schedule (e.g., once a
week), and if industrial users are informed of the location and time of
publication. Permit and contract amendments are probably the best method of
notification since acknowledgement is ensured when a company official signs
the permit/contract.
4.3 UNDERTAKE COMPLIANCE MONITORING PROCEDURES
Self-monitoring, compliance sampling, and noncompliance investigations
are closely related. The first two activities determine an industrial user's
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compliance with pretreatment standards, limits, and other requirements. The
third activity constitutes the POTW's response to potential instances of
noncompliance. All three involve sampling and analysis of industrial efflu-
ents and data analyses. Under self-monitoring, the sampling and analysis are
performed by the industrial user's staff or representative. Under compliance
sampling and investigations, the work is carried out by the POTW's staff or
authorized representative. Investigatory sampling and analysis must be per-
formed with sufficient care to produce evidence that is admissible in court,
and thus, it is normally more rigorous than compliance sampling and analysis.
4.3.1 Receive and Analyze Self-Monitoring Reports and Other Notices
The program submission must describe the POTW's procedures for receiving,
analyzing, and storing self-monitoring reports, compliance schedule reports,
and other reports/notices submitted by industrial users. A systematic
approach to managing the data collected from these sources should be evident.
The system may be manual or computerized depending upon the POTW's size and
number of industrial users. The system should ensure that reports are
received on time, reviewed by a technical specialist, and ultimately filed in
a retrievable manner. The system should facilitate a comparison between
discharge values reported by industrial self-monitoring or POTW compliance
monitoring, and discharge limits specified in the industry's permit or con-
tract or in the municipal ordinance.
Basic features of a workable system include:
A master list or log of expected reports during a specified time frame
(monthly is sufficient)
A procedure to enter date of receipt of each report (usually on the
master list or log)
A procedure to screen and compare reported values and compliance
information with discharge standards and compliance schedules
A procedure (if the screening is done by a non-technical person) to
refer problem submissions to a technical specialist for more thorough
evaluation
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A filing system to ensure that the data are retrievable and maintained
for an appropriate period of time (three years or longer)
The ability to cross reference to permit, contract, and POTW monitor-
ing files, if applicable.
It is also important to ensure that the expected volume of reports can be
handled by the proposed procedures. In addition, the submission should iden-
tify by title the individual responsible for evaluating self-monitoring and
compliance schedule reports.
4.3.2 Conduct Compliance Sampling and Analysis
The submission must document and describe the POTW1s procedures for sam-
pling and analyzing industrial effluents. Three basic types of compliance
sampling and analysis are commonly used:
Scheduled monitoring (sampling and analysis on a fixed schedule)
Random monitoring (sampling and analysisscheduled or unscheduled
that is unannounced or performed with short notice)
Demand monitoring (sampling and analysis triggered by an event such as
a public complaint or an observed POTW operating problem).
The reviewer should note that monitoring for billing purposes (e.g., surcharge
for BOD or SS) is not compliance monitoring. Compliance monitoring involves a
comparison of actual discharge amounts to permitted discharge amounts.
Although sometimes the two types of monitoring may be combined and conducted
at the same time, monitoring for billing purposes alone is not sufficient to
assess compliance.
The regulations specifically call for program procedures to randomly
sample and analyze industrial discharges to the treatment works. Random
sampling is intended to ensure that collected samples are representative of
actual operations. It is particularly useful when industries can easily and
quickly alter their processes or operations to obtain more favorable results.
The requirement for random sampling does not mean that the events cannot be
scheduled. A POTW may schedule its random monitoring activities on a
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quarterly, semi-annual, or even annual basis, provided it does not inform the
industrial user of the specific time or day the sampling will take place far
enough in advance to enable the user to alter its discharge. A limited amount
of advance notice, such as providing indefinite information about the day or
time of arrival, or telephoning the company representative just before arriv-
al, is acceptable, and is often necessary to ensure access to the sampling
point.
Besides identifying the types of monitoring that the POTW will conduct,
the submission should also include:
The minimum sampling frequency at each major industrial user (at least
annually is necessary)
A list of industries, both categorical and noncategorical, that will
be included in the random sampling program (major or significant users
should be noted)
The activities or events that will trigger the demand sampling program
(e.g., upsets, inhibitions, public complaints).
The reviewer should determine whether the sampling frequency assures reason-
able coverage each year of all categorical and significant users.
The frequency and type of sampling (grab, composite, or flow proportion-
al) will vary depending on the type of industry, pollutants of concern, and
resources available (e.g., manpower and equipment). Each submission should
identify the sampling approach, frequency, and technique as well as the pollu-
tants to be monitored for each group of industrial users. The program's ade-
quacy can be determined by comparing it with the results of the industrial
waste survey. The reviewer should check that each industrial user that is or
will be subject to national categorical standards will have its effluent moni-
tored by the POTW at appropriate intervals. In addition, when an industrial
user is known to discharge a priority pollutant in its wastewater, the POTW
should sample and analyze for that pollutant. A list of priority pollutants
usually present in the wastewaters of various industrial groups is included in
Appendix C. POTWs will probably also monitor flow rates and measure
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conventional pollutant parameters such as BOD, COD, TSS, pH, and others.
Whether the samples obtained are grab samples, a grab sample series, or com-
posite samples should also be identified.
As part of this section's review, the reviewer should evaluate the appro-
priateness of sampling procedures. Sampling procedures should conform with
those described in the EPA NPDES Compliance Sampling Inspection Manual.
Chain-of-custody procedures should be identified in the submission.
The analysis of samples, as well as the sampling itself, may be performed
in-house or under contract by a commercial laboratory. The submission should
describe the analytical methods to be employed and the quality assurance pro-
gram that will be followed. When samples from categorical industries are
analyzed, the methods used must conform to those prescribed in the applicable
categorical standard. Test procedures for other pollutants should conform to
one of the standard analytical methods cited in Table I of 40 CFR 136, "Guide-
lines Establishing Test Procedures for the Analysis of Pollutants." Other
methods may be used only where they have been approved by the EPA Regional
Administrator. Laboratory quality assurance procedures should conform to
specifications contained in EPA's Handbook for Analytical Quality Control in
Water and Wastewater. Table C.4 in Appendix C lists the detection levels and
approved EPA methodologies for analysis of the priority pollutants. If com-
mercial laboratory services are to be used, the POTW should provide the name
of the laboratory or a description of its criteria for selecting a laboratory.
Official certification of the laboratory is normally a good thing for the POTW
to require because the certification ensures that correct procedures and
equipment are used and that the appropriately trained staff are employed.
4.3.3 Investigate Noncompliance
The pretreatment program submission must describe how the POTW will
investigate instances of noncompliance. These methods should be capable of
handling three types of situations:
4-7
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An emergency situation when the POTW must move immediately to halt an
industrial discharge that "reasonably appears to present imminent
endangerment to health or welfare of persons."
A nonemergency situation when the POTW desires to halt or prevent a
discharge which "presents or may present an endangerment to the envi-
ronment or threatens to interfere with the POTWs operation."
A situation when an industrial user fails to comply with other pre-
treatment requirements, such as timely submission of reports, achieve-
ment of compliance schedule milestone(s), maintenance of sampling and
pretreatment facilities, and maintenance of records.
The information gathered should be admissible as evidence in enforcement pro-
ceedings or judicial actions. Thus, sampling and analysis, and other data
collection activities should be conducted with a greater degree of care than
would otherwise be required.
Noncompliance investigation procedures may be detailed in the legal or
procedural section of the program submission. If these procedures are dis-
cussed in the legal section (e.g., in the sewer use ordinance), the procedural
section of the submission should cite the appropriate legal document. The
procedures that will be used to investigate instances of noncompliance should
include the following:
Establish criteria for classifying situations as emergencies
Notify industrial users of noncompliance incidents
Provide for industry response to notification
Take actions to correct identified problems
Verify that violation has been corrected
Resort to legal recourse to obtain industrial compliance and/or allow
industry to challenge POTW violation determination
Perform quick response sampling, analysis, and inspection in the event
of emergency conditions such as fire, explosion, corrosive action,
acute upset, or imminent danger to health and safety
Gather data so that it is admissible in court proceedings or other
enforcement actions.
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Informal notice of industrial user noncompliance usually involves
letters, telegrams, telephone calls, meetings, and visits. It is always a
good idea for the industrial user to acknowledge receipt of the notice.
Formal notification methods include cease and desist orders, injunctions,
citations, and subpoenas. Industrial users can respond through letters,
telephone calls, meetings, and show-cause hearings.
To abate and control the problem discharge, the user may take corrective
procedures, such as process change, installation of new treatment technology,
improved operating practices, repair of faulty equipment, and termination of
discharge. The time frame for correcting the violation which the POTW estab-
lishes should be flexible enough to cover both emergency and less severe
situations. Under emergency conditions, the POTW may need to terminate the
discharge until other corrective measures are in place. The POTW should have
this authority and provisions for using it. A nonemergency violation may be
handled by modifying the permit, contract, or other provision. The POTW can
verify corrective actions through certification by the industrial user that
the violations has been corrected, increased self-monitoring requirements, and
follow-up monitoring inspection by the POTW. While certification is accept-
able for less serious violations, the POTW should verify corrective actions
first-hand in serious cases.
Because it is impossible to predict which actions will require legal
proceedings, and because the integrity of data must be proved if the case
ultimately goes to trial, it should be assumed that any data collected during
an investigation will end up in court. Thus, chain-of-custody and quality
assurance provisions become important aspects of a POTW's noncompliance inves-
tigation. The program submission should indicate that the POTW will follow
proper chainof-custody procedures.
4.4 PUBLIC PARTICIPATION
The pretreatment program submission must describe the procedures used by
the POTW to ensure public participation in the program. Specific requirements
include:
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Informing the public on the compliance status of industrial users
Individual notice and comment on proposed local effluent limits
Public access to nonconfidential data and records.
Although usually not required by Federal regulation, it is a good idea
for the POTW to hold public meetings as it develops the local program. In
situations where grant assistance is being provided, full-scale public partic-
ipation (citizen advisory committees, public meetings, or public hearings) may
be required. If meetings were held, the results of these meetings and the
resolution of any issues should be documented in the submission in the form of
summaries, verbatim transcripts, or by attaching meeting notes. A description
of the attendees (i.e., number, groups represented) should be included.
The POTW must publish, at least annually, a list of significant indus-
trial violations in the largest local daily newspaper. A significant viola-
tion is one that:
Results in the exercise of emergency authority
Remains uncorrected 45 days after notice of noncompliance is given to
the industrial user
Involves failure to accurately report.
The name of the newspaper should be specified and the frequency of publication
stated. Information other than the name of the discharger may be included in
the notice, although this is not required.
The requirement for individual notice of local limits was mentioned
earlier in Section 4.2. Since groups and individuals other than industrial
users may request notice, it is important that the submission described proce-
dures for accomplishing this notice.
It is recommended that public access to nonconfidential information
contained in the documents and records developed in the course of the program
be provided. In this case, the submission should identify the steps taken by
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the POTW to provide such public access. The location or office where inter-
ested people can go to read or copy documents, permits (if a permit system is
used), and monitoring records should be specified. The local library, city/
town hall, public works office, or POTW are acceptable locations. The hours
of operation should include convenient times for the public at large. These
provisions should also allow the POTW to restrict access to confidential
information about industrial users.
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Worksheet 3
Program Implementation Procedures Checklist
Name of POTW
Date
Yes
PART I. Updating the Industrial Waste Survey [403.8(f)(2)(i)
and (ii)]
A. Are procedures identified for updating (periodically)
the waste survey information for existing users?
B. Do procedures require new industries to supply
discharge information or otherwise ensure that it
will be collected?
PART II. Notification of Appropriate Federal, State, and/or Local
Standards or Limitations [403 .8(f)(2)(iii)]
A. Are there procedures for keeping abreast of existing
and newly promulgated standards and requirements?
B. Is there a mechanism to identify and notify
industrial users of standards, limitations, or
other requirements?
PART III. Receipt and Analysis of Self-Monitoring Reports and
Other Notices [403.8(f)(2)(iv)]
A. Are there procedures for determining what self-
monitoring and other reports are due?
B. Are values reported by industries compared to
discharge standards or compliance schedules?
C. Are problems referred to appropriate authorities
for technical evaluation and follow-up?
PART IV. POTW Compliance Sampling and Analysis [403.8(f)(2)(v)]
A. Does the description of the monitoring program
include procedures for periodic random sampling
of significant industrial dischargers?
B. Are sampling and monitoring parameters identified
for each firm or group of industries?
C. Is the POTW sampling for the significant pollutants
identified by the Industrial Waste Survey or by the
priority pollutant/industry matrix? (Appendix C)
D. Do the sampling and monitoring procedures conform to
EPA requirements? (40 CFR 136."Standard Methods")
E. Is the frequency adequate to determine compliance
independent of information supplied by lUs
(at least annually)?
No
Section
of POTW1s
Submission
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Worksheet 3
Program Implementation Procedures Checklist (Continued)
Name of POTW
Date
Yes
No
Section
of POTW's
Submission
PART V. Noncompliance Investigations and Enforcement
[403.8(f)(2)(vl)l
A. Are follow-up activities described that include
provisions to:
(1) Cover emergency situations?
(2) Notify industrial users of violations?
(3) Allow for response by industrial users?
(4) Abate and control problem discharges?
(5) Verify that corrective actions have worked?
(6) Obtain compliance through legal means if
necessary?
(7) Assess penalties for noncompliance?
B. Are procedures for quick response sampling and
analysis included (demand sampling)?
C. Are chain-of-custody and quality control provisions
specified?
PART VI. Public Participation
A. Do procedures include at least annual notice of
violations published in local newspapers?
[403.8(f)(2)(vii)]
B. Is notice and opportunity to respond provided, both
to the industrial users and the general public, on
the process of developing local industrial
effluent limitations? [403.5(c)(3))
*C. Are program records available to the public?
PART VII. Multijurisdictional Submissions
A. Are there procedures to coordinate monitoring,
enforcement, and implementation activities
between the jurisdictions involved?
B. Has the NPDES permit holder assumed lead
responsibility in program implementation?
*Indicates item is recommended, but not mandatory.
I have reviewed this submission in detail and have determined the implementation
procedures to be:
( ) Adequate
Date:
( ) Inadequate
Reviewed by:
(Name)
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5. ORGANIZATION, STAFFING, EQUIPMENT, AND FUNDING
The ability to develop and implement a successful pretreatment program
depends upon a number of factors. The importance of legal authority, sound
technical information, and proper procedures has already been discussed. This
chapter focuses on needed resources and an organization to apply them effi-
ciently and effectively. An acceptable submission will demonstrate that the
POTW has:
A workable organization to integrate elements of the program
A staff of appropriate size and training to carry out program
requirements
The necessary equipment to fulfill monitoring and other program needs
Adequate funds to support the proposed program.
The above elements are closely interrelated, and all should be present in a
successful program.
While the level, type, and kind of resources will vary from program to
program, it is possible to establish guidelines for use in evaluating the sub-
mission's adequacy. This is the approach taken in this chapter. Rather than
attempting to cover all possible solutions to the resources problem, each ele-
ment is discussed generically. Key factors are identified, "rules of thumb"
are provided for evaluating staffing and funding levels, and a framework for
review is established. A checklist is provided to assist the reviewer.
5.1 RELEVANT REGULATIONS
40 CFR 403.8(f)(3) requires that the POTW have "sufficient" resources and
qualified personnel to implement the authorities and procedures called for in
the program. Although the regulations do not specify what is "sufficient,"
they do require that the POTW submit certain items:
A brief description (including organization charts) of the POTW orga-
nization which will administer the program
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A description of funding levels and full- and part-time manpower
available to implement the program.
If more than one agency is responsible for administering the program, each
agency must be identified. The responsibilities of each participating agency
must also be delineated and procedures for coordination described in the sub-
mission.
In some instances, a submission may indicate that certain equipment,
staff, and/or funds are not yet available to carry out the program. Such a
program can be approved conditionally pending the acquisition of complete
funding, manpower, and/or equipment, provided that:
The inadequately supported aspect(s) of the program does not need to
be implemented immediately
Adequate legal authority and procedures exist for the complete pro-
gram, including the aspect(s) not being implemented immediately
The necessary resources will be available when such aspect(s) is
implemented.
This provision for conditional approval [40 CFR 403.9(c)] is designed to avoid
the unnecessary costs that can result from acquiring and maintaining resources
(particularly staff and equipment) before they are needed.
5.2 EVALUATION OF ORGANIZATION AND STAFFING
Organization and staffing requirements will vary according to the com-
plexity and comprehensiveness of the local program. Whether the staff is
large or small, it must be organized in a way that facilitates the successful
completion of program responsibilities. The adequacy of the program's organi-
zation and staffing is based not only on whether essential functions are
covered, but also on whether the number and type of staff are appropriate to
implement program requirements. The following elements should be evident in
the submission:
Clear and appropriate lines of authority
Identification of staff responsibilities
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Qualifications of staff
Staffing levels related to required work effort
Coordination with other departments
Contract management (if required).
5.2.1 Clear and Appropriate Lines of Authority
A description of the POTW organization is needed, including the func-
tional departments which will carry out the program. This description may
include the titles and numbers of employees within each functional department,
and the employees (or department) within the POTW that will coordinate with
each service district in interjurisdictional programs. It is recommended that
the functional departments identify services such as administration, engineer-
ing, sampling/inspection, laboratory analysis, legal work, accounting, and
billing.
A POTW must submit either an organization chart for the entire wastewater
treatment program or a chart specifically structured for the pretreatment
program. If the entire POTW organization is shown, notations on the chart or
an accompanying text should indicate where pretreatment responsibility rests.
In particular, responsibility for procedural functions such as notifying
industrial users of applicable standards, receiving and reviewing self-
monitoring reports, conducting sampling and analysis of industrial effluents,
and initiating enforcement actions should be clearly identified. If the
pretreatment organization is provided, its relationship to the overall POTW
organization is provided, its relationship to the overall POTW organization
should be described.
A variety of different organizational systems and structures are approv-
able. The key is to determine whether the proposed structure is workable.
In evaluating the program's organization, the reviewer may ask the following
questions:
Are authorities and responsibilities clearly designated?
Do supervisors have direct responsibility for the appropriate number
of employees (usually no more than six or eight staff members)?
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Is the program effectively integrated with the rest of the POTW's
activities?
5.2.2 Identification of Staff Responsibilities
Text accompanying the organization chart should identify the responsi-
bilities and duties of each staff member or department involved in the pro-
gram , including:
Technical assistance. A staff member or department should have the
responsibility of evaluating data that industrial users supply on
their IWS forms, self-monitoring reports, and compliance schedule
reports. This person or department also should have responsibility
for reviewing results of POTW monitoring and sample analyses and for
industrial inspections.
Industrial monitoring. The submission should designate a staff member
or department with responsibility for staffing and supervising field
monitoring personnel. It should also specify the number and qualifi-
cations of personnel who will be assigned to the field monitoring
crew(s) .
Laboratory analysis. As indicated earlier, a POTW may either perform
its own sample analyses or contract with a commercial laboratory for
analytical services. If the work is done in-house, laboratory support
staff must be identified.
Legal assistance. The person(s) providing legal assistance to the
municipality will interpret regulations and other legal documents that
affect pretreatment program operations and prepare contracts or other
agreements. This person also will initiate formal legal actions
against violators, including injunctive relief when necessary.
Administration. The program administrator and administrative staff
should have responsibility for data management, communication with
lUs, program finances and accounting, personnel, and the public
participation program.
A small POTW may have the same person performing the duties associated
with one or more of these five general work areas, while a large POTW may have
several people assigned to each functional group. In addition, a large POTW
may wish to separate functions that are grouped together under administration.
Responsibility for some of the work areas may be assigned to contractors or
other local agencies, but all areas of work and corresponding staff should be
identified in the submission.
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5.2.3 Staff Qualifications
The submission should include the qualifications for all key staff posi-
tions. The qualifications of existing and proposed staff should be reviewed
to ensure that they are appropriate for the position. While there are no
rigid guidelines that apply, there are several factors that can be used to
evaluate the adequacy of staff qualifications. The education and experience
should match the functions to be performed. Sampling and analysis functions,
for example, would normally be performed by a chemist experienced in effluent
monitoring (preferably industrial). Tradeoffs between education and experi-
ence are acceptable, and certification in an appropriate discipline (e.g.,
professional engineer) is desirable, but not required. Key disciplines that
one would expect to see are engineering (environmental, civil, sanitary,
chemical), chemistry (organic, inorganic, physical, analytical), public
administration, business administration, and law.
5.2.4 Staffing Levels
The level of staff needed to implement a program depends on the size of
the treatment plant and the number of industrial users regulated under the
pretreatment program. Small POTWs with few industrial users may be able to
implement a pretreatment program satisfactorily using only one or two person-
years of effort. Large POTWs with many industrial users may need a pretreat-
ment program staff with as many as 30 to 50 people, depending on the number of
samples and measurements to be obtained, the frequency of monitoring, and the
number and complexity of analyses to be performed. POTW staff requirements
will also vary significantly if work is performed by outside personnel (e.g.,
contract support). These outside resources should be included when assessing
the adequacy of staffing levels.
A quantitative estimate of the level-of-effort, including outside
support, should be provided in the submission for each staff position or
function. Such estimates may be in the form of labor hours per year, person-
years, or percent involvement of a person in pretreatment program activities.
The amount of work required to perform necessary sampling and analysis,
technical reviews, and administrative tasks should be compared to the proposed
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staffing levels. Generalized estimates of personnel requirements as a func-
tion of POTW size and number of industrial users are shown in Table 5-1. More
refined and detailed personnel estimates for a POTW having a flow of 5 mgd and
10 industrial users are shown in Tables 5-2 and 5-3. These figures can be
used to gauge the adequacy of staffing levels for individual functions,
although they should not be treated as rigid requirements.
5.2.5 Coordination with Other Departments
Interaction between groups within the pretreatment program and other POTW
departments in order to facilitate the program's smooth operation should be
clear in the submission. A flow chart for routine program operations may be
included. For example, the chart would show who receives and reviews self-
monitoring reports, what happens when the reports are acceptable, and what
happens when they indicate violations.
5.3 EVALUATION OF EQUIPMENT
The major items of equipment necessary to implement a successful pre-
treatment program may include sampling gear, analytical instruments, vehicles,
office furniture and accessories, and data processing devices. The type and
amount of equipment needed will vary as a function of program size, complex-
ity, and structure (i.e., contract or other outside services). The pretreat-
ment program submission should list the major equipment to be used in the
program, including any commercial services or outside capabilities. This list
should be reviewed for completeness and adequacy. At a minimum, the POTW
should show that it has the capability to sample and analyze industrial waste-
waters for all pollutants of concern identified in the technical information
section of the submission (e.g., metals, priority pollutants, or special
pesticides).
Some of the specific capabilities that the program submission should
demonstrate include grab and flow composite sampling, gas and liquid chroma-
tography, atomic absorption, and mass spectroscopy. The equipment needed may
be available in-house or from external sources. It is a good idea for all
analytical work to be performed by a certified laboratory to ensure the
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TABLE 5-1
POTW PRETREATMENT PROGRAM
PERSONNEL REQUIREMENT RANGES
Ranges presented in this table are estimates based on anticipated
averages for typical programs. Individual program personnel requirements may
vary significantly from the ranges shown here.
POTW
Flow Range
(MGD)
5
5-25
25-50
50
100
Relative Number of
Indirect Dischargers
small
large
small
large
small
large
small
large
large
Range of Personnel
Requirements for
Pretreatment Program
1-3
2-5
2-4
4-8
4-6
8-10
6-8
10-15
15-50*
*Special cases, such as large metropolitan systems, require more in-depth
review.
Source: Local Pretreatment Program Requirements and Guidance.
Environmental Technology Consultants, Inc.: September 1979.
5-7
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TABLE 5-2
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES
POTW AVERAGE DESIGN FLOW: 5 MGD
NUMBER OF INDUSTRIAL USERS IN PROGRAM: 10
PERSONNEL
1. Supervisor - For delegating the responsibilities
and running the program
2. Engineer - To review reports and assist the
Supervisor
3. Field Crew - To take samples and do all field
investigations
4. Laboratory - For analyzing samples
Technician
5. Lawyer - For all legal action and proceedings
NUMBER
REQUIRED
1
part-time
part-time
TOTAL FULL-TIME PERSONNEL REQUIRED
5.0
5-8
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TABLE 5-3
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PROGRAM ACTIVITY
Estimates presented in this table are based on anticipated averages for typi-
cal programs. Individual program personnel requirements may vary significant-
ly from the estimates shown here.
POTW AVERAGE DESIGN FLOW: 5 MGD
NUMBER OF INDUSTRIAL USERS IN PROGRAM: 10
Frequency of Workdays
Activity per Number of per Total
Program Activity POTW or IU Activities Activity Workdays
Program Development
1. Develop Pretreatment once 1 15-25 25
Program
2. Conduct Industrial once 1 15-25 25
Waste Survey
3. Determine POTW once2 1 10-20 20
Removal Allowance
4. Review IU Pretreatment once 10 0.5-2 20
Facility Proposal
TOTAL WORKDAYS = 90
90 4 220 WORKDAYS/PERSON/YEAR = .41 Person-years
Program Operation
1. Review IU Compliance 3/year 30 0.5-1 30
Schedule Reports
2. Review IU Final Compli- once 10 0.5-2 20
ance Schedule Report
3. Review IU Self- 2/year 20 0.1-0.5 10
Monitoring Report
4. Sample IU I/year 10 2-4 40
(spot-check)
5. Investigate IU 5 1-5 25
Non-compliance
5-9
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TABLE 5-3 (Continued)
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PROGRAM ACTIVITY
Frequency of
Activity per
Program Activity POTW or IU
6.
7.
8.
9.
10.
11.
Administrative
Enforcement Action
Legal Enforcement
Actions
Comply with Public 1 /year
Notice Requirements
Sample POTW Influent, I/year
Effluent, and Sludge
Prepare Self-Monitoring 2/year
Report for Approval
Authority
Laboratory Analysis I/year
of Required Sampling
Workdays
Number of per Total
Activities Activity Workdays
3 3-10 30
1 15-20 20
1 1-3 3
1 5-10 10
2 5-10 20
13 1-2 26
TOTAL WORKDAYS =234
234 4 220 WORKDAYS/PERSON/YEAR = 1.06 Person-years
IWS is periodically updated during program implementation procedures.
2
Annual monitoring and reporting by the POTW is required during program
implementation to maintain any removal credit allowance.
Source: Local pretreatment Program Requirements and Guidance. Environmental
Technology Consultants, Inc.: September 1979.
5-10
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quality of results. Other equipment that may or may not be necessary depend-
ing upon the size and complexity of the program includes vehicles for sampling
and inspection, computer terminals, software and hardware for data reduction
and analysis as well as for program administration, and office accessories,
such as word processing, duplication, and production devices.
5.4 EVALUATION OF FUNDING
An itemized estimate of pretreatment program costs must be included. The
submission must contain either projected costs for the first year of program
operation or the actual costs for the most recent operating year if the pre-
treatment program was fully implemented in that year. These costs should be
itemized in the following areas:
Labor (salaries, benefits)
Annualized capital costs
Operation and maintenance costs (travel, supplies, etc.)
Overhead (rent, phones, etc.)
Debt service
Other applicable costs.
The submission should also provide an account of the revenue sources to
be used to cover the annual costs of the pretreatment program. This account
may be descriptive, or may be an itemization of each revenue source and
amount. In addition, a system for continuous revenue generation (e.g., user
charges) should be discussed. It is helpful if the POTW submits its most
recent annual financial statement showing actual expenditures and revenues so
that the reviewer can assess the POTW's financial base. However, submitting
the financial statement is not a Federal requirement.
In reviewing the funding section of the submittal, it will be necessary
to evaluate whether cost estimates are appropriate, and to determine whether
costs will be adequately met by the proposed sources of revenue. Where short-
falls exist, the program may still be approvable if the inadequately funded
5-11
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program element need not be implemented immediately and future funding will be
available when needed.
5.4.1 Implementation Costs
A POTW program submission should provide an estimate of the annual cost
of implementing its pretreatment program. The two types of costs involved are
capital costs and operating costs. The capital cost of purchasing equipment
represents a single cash outlay, while labor, O&M, and the other items repre-
sent operating expenses that must be recovered yearly. Equipment may be
purchased directly out of the POTWs budget if sufficient reserve cash is
available; its may also be financed or leased and then repaid annually as an
ongoing cost in the operating budget.
Capital Costs
A major financial decision for a POTW implementing a program involves the
procurement of sampling and analysis equipment. A POTW has the choice of
purchasing equipment, leasing equipment, contracting services, or any combina-
tion of these. Depending on the level of monitoring required for the program,
a POTW should determine which of these options is the most cost-effective. It
may be most feasible for small or medium-sized plants to buy equipment for
sampling and conventional pollutant analyses, while using a commercial
laboratory for metals and organics analyses. Larger POTWs, conducting more
toxics analyses, may choose to buy equipment for full in-house capability.
Since sampling/analysis equipment can be expensive to purchase and maintain,
the POTW should determine what the impact of these costs would be on sewer and
monitoring charges to industries and whether purchase is warranted. Typical
costs for sampling and analysis equipment for nonconventional pollutants are
shown in Table 5-4. Typical analytical costs of a commercial laboratory are
shown in Table 5-5.
Operating Costs
Annual operating costs will generally be based on the level of effort
estimated to conduct various tasks within the program. While the majority of
operating costs may be attributed to labor, other significant costs may result
5-12
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TABLE 5-4
TYPICAL EQUIPMENT FOR A TWO-MAN FIELD SAMPLING CREW
EQUIPMENT PURCHASE PRICE
Van with two-way radio $12,000
Gas Detector 450
2 self-contained breathing units 1,500
4 portable samplers with bottles 8,200
1 portable pH meter 800
2 flow meters 3,000
Flumes and weirs 1,600
Velocity meter 600
Safety equipment 400
Miscellaneous tools and equipment 200
TOTAL $28,750
ADDITIONAL LABORATORY EQUIPMENT FOR SAMPLE ANALYSIS
ESTIMATED
EQUIPMENT PURCHASE PRICE
- Atomic absorption $ 25,000
spectrometer (basic)
- Supplies for AA 3,000
- Gas chromatograph 120,000
mass spectrometer (GC/MS)
- Accessories and glassware 15,000
for GC/MS (including a yearly
service contract)
- Reagents and other chemicals 15,000
TOTAL $178,000
Source: Odeal, Erwin J. "Economics of Local Pretreatment Program Adminis-
tration." Proceedings; National Pretreatment Symposium. Duluth,
Minnesota: August 22-24, 1979. Cost information updated, 1983.
5-13
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TABLE 5-5
TYPICAL COMMERCIAL LABORATORY COSTS1
Parameter Price per Analysis
Conventional Analysis
Acidity/alkalinity $ 9
BODS 20
COD 20
Chloride 15
Nitrogen (total) 20
Oil & grease 20
Suspended solids 8
Toxics Analysis
Metals (typical) $10 - 18/metal
Organics by GC 60/compound
NPDES Analysis (scans)^
Base neutrals $350
Acid extracts 200
Pesticide/PCBs 225
13 metals 300
Total 126 Compounds 800-1200
Based on 1983 estimated costs from commercial laboratories
2
Includes $300 for asbestos
5-14
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from equipment O&M, overhead, and debt repayment. For simplicity, some POTWs
estimate labor hours for each program task and then convert these to total
cost by multiplying by a gross factor that represents overhead and other
costs. Table 5-6 lists program tasks and various factors affecting the level
of effort for each. By combining labor costs with other direct and indirect
costs, the total annual budget for the program can be calculated. See Table
5-7 for estimated operational costs of a POTW pretreatment program.
5.4.2 Financing Sources and Cost Recovery Systems
The means for recovering program costs should be presented in the
submission. Major capital expenditures, such as equipment purchase, may be
financed by municipal bonds or with surplus capital improvement revenues, if
available. As mentioned earlier, leasing and contract services are viable
options that avoid large cash outlays.
Continuous revenue sources from fees, charges, or interest are necessary
to recover annual operating costs, which include debt service payments if
loans are outstanding. Ideally, revenues should be generated from the indus-
tries serviced by the program in proportion to their relative use. However,
any means of generating continuous revenues adequate to recover costs is
acceptable.
A cost allocation scheme should be used to recover pretreatment costs
from various groups or classes of users according to some basis, such as moni-
toring. There are many types of charges or fees that may be used to generate
revenues from users. The most appropriate types for a pretreatment program
include a service or monitoring charge, an industry surcharge, and a pollutant
strength surcharge. The POTW should choose a justifiable and equitable
allocation basis when applying pretreatment charges to industrial users.
5-15
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TABLE 5-6
FACTORS AFFECTING POTW LEVELS OF EFFORT FOR
PRETREATMENT PROGRAM OPERATING TASKS
Activities
Factors
Sampling and Inspection
-Total number of lUs
-Frequency of sampling
Laboratory Analysis
-Number of samples
-Type of analysis
-Pollutants analyzed (i.e., toxics,
conventionals, metals, etc.)
Technical Assistance
(including permitting
process and report
review)
-Treatment plant capabilities
-POTW influent and effluent characteristics
-Total number of lUs
-Number of lUs with pretreatment
Legal Assistance
-Number and seriousness of violations
-Availability of in-house counsel
-Burden of proof created by ordinance
Financial/
Administrative
-Total number of IDs
-Frequency of monitoring
-Size of service area
5-16
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TABLE 5-7
HYPOTHETICAL POTW PRETREATMENT PROGRAM OPERATIONAL COSTS1
Size of POTW
Cost Component Small Medium Large
(1) Sampling & Industrial Review $13,500 $ 26,000 $ 47,000
Labor 11,000
Non-Labor 2,500
(2) Laboratory Analysis $28,000 $ 51,000 $105,000
Labor 20,000 84,000
Non-Labor 28,000 31,000 21,000
(3) Technical Assistance $ 27,000 $ 54,000
Labor
Non-Labor
(4) Legal Assistance $ 7,320 $ 13,300 $ 36.000
Labor
Non-Labor
(5) Program Administration
TOTAL
$25,000
$76,820
$ 28,000
$142,300
$ 31,000
$273,000
Assumptions
(1) Size is defined in terms of "significant" industrial users. Small is
assumed to include 40, medium 130, and large 300 industrial users.
(2) Major metropolitan areas are excluded from this analysis. They are
considered special cases and should be evaluated on an individual basis.
(3) A 33% overhead rate is assumed for municipal employees.
(4) Sampling & Industrial Review. Small POTW: 1 person half-time, medium
POTW: 2 persons half-time, large POTW: 2 persons full-time.
(5) Laboratory Analysis. Small POTWs contract out all lab analysis. Medium
size POTWs possess AA capabilities. Large POTWs possess both AA and
GC-MS capabilities.
(6) Technical Assistance. For small POTWs, this service is performed by the
program manager who is accounted for in program administration. Assume
senior and junior engineers part-time for medium-sized POTWs and full-
time for large POTWs.
(7) Legal Assistance. Small POTWs obtain part-time assistance from municipal
lawyer. Medium-sized POTWs use one-third time of in-house legal counsel.
Large POTWs have one person full-time.
(8) Program Administration. Includes program management and coordination as
well as clerical support.
Source: Odeal, Erwin J. "Assessing Administrative and Financial Needs of a
Local POTW Pretreatment Program." Proceedings; National Pre-
treatment Symposium. Duluth, Minnesota: August 22-24, 1979.
5-17
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Worksheet 4
Resources Checklist
Name of POTW
Date
Yes
No
Section
of POTW s
Submission
PART I. Organization and Staffing [403.8(f)(3) and 403.9(b)(3)]
A. Is the description of the POTW organization clear
and appropriate?
B. Are mechanisms identified for delegating pretreatment
tasks to other local government agencies?
C. Are personnel or positions identified that are
responsible for:
(1) Technical review?
(2) Monitoring? "
(3) Laboratory analysis?
(4) Legal assistance and enforcement?
(5) Administration? "
D. Have appropriate staffing levels been determined
based on the program description?
PART II. Equipment
A. Does the POTW have adequate sampling equipment or
other provisions to conduct necessary sampling?
B. Does the POTW have adequate analytical capabilities
to perform analyses for:
(1) Nutrients and other nonconventionals?
(2) Metals? '
(3) Toxic organics?
C. If not, are other arrangements made to do so
(e.g., contract with private laboratory,
other agency)?
PART III. Funding Estimates and Sources
A. Does the POTW present an itemized estimate of pre-
treatment implementation costs?
B. Is there an account of revenue sources that will
cover the annual costs of the pretreatment program?
5-18
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Worksheet 4 Name of POTW
Resources Checklist (Continued) Date
Section
of POTW's
Yes No Submission
PART IV. Multijurisdictional Submissions
A. Does each jurisdiction participate in funding the
pretreatment program?
B. Are the relationships between the staff (personnel)
of the participating jurisdictions adequately
described and documented?
I have reviewed this submission in detail and have determined the
resources to be:
( ) Adequate ( ) Inadequate
Date: Reviewed by:
5-19
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APPENDICES
-------
APPENDIX A
BIBLIOGRAPHY OF PRETREATMENT REFERENCES
-------
APPENDIX A
BIBLIOGRAPHY OF PRETREATMENT REFERENCES
Association of Metropolitan Sewerage Agencies, Pretreatment Resource Reader.
Washington, DC: Association of Metropolitan Sewerage Agencies, 1982. (NTIS
Order No. PB82-181629) .
Dyer, J., Feiler, H., and Bernick, A., Handbook of Industrial Waste
Pretreatment (Water Management Series). New York: Garland Publishing,
Inc., 1981.
U.S. Environmental Protection Agency, Fate of Priority Pollutants in Publicly
Owned Treatment Works, Volumes I and II (EPA Publication No. 440/1-82-303).
Washington, DC: U.S. Environmental Protection Agency, September 1982.
(NTIS Order No. PB83-122788).
U.S. Environmental Protection Agency, Guidance Manual for POTW Pretreatment
Program Development. Washington, DC: U.S. Environmental Protection Agency,
October 1983.
U.S. Environmental Protection Agency, Handbook For Sampling and Sample
Preservation of Water and Wastewater. (EPA Publication No. 600/4-82-029).
Washington, DC: U.S. Environmental Protection Agency, September 1982.
(NTIS Order No. PB83-124503).
U.S. Environmental Protection Agency, Industrial Residuals Manual, Volumes I,
II, and III. Washington, DC: U.S. Environmental Protection Agency,
November 1981. (Available from EPA Office of Water Enforcement and
Permits).
U.S. Environmental Protection Agency, Methods for Chemical Analysis of Water
and Wastes. (EPA Publication No. 600/4-79-020).Washington, DC:U.S.
Environmental Protection Agency, March 1979. (NTIS Order No. PB-297686).
U.S. Environmental Protection Agency, Treatability Manual, Volumes I, II, III,
IV, and V. (EPA Publication No. 600/8-80-042c). Washington, DC: U.S.
Environmental Protection Agency, July 1980. (NTIS Order Nos. PB80-223050,
PB80-223068, PB80-223076, PB80-223084, and PB80-223092).
Water Pollution Control Federation, Industrial Wastewater Control Program for
Municipal Agencies. Washington, DC: WPCF, 1982. (WPCF Order No. MOP
OM-4).
Water Pollution Control Federation, Joint Treatment of Industrial and
Municipal Wastewaters. Washington, DC:WPCF, 1976.(WPCF Order No.
M0021).
Water Pollution Control Federation, Pretreatment of Industrial Wastes.
Washington, DC: WPCF, 1981. (WPCF Order No. 'MOP FD-3).
A-l
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Sources listed with an NTIS Order Number are available from:
National Technical Information Service
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
Sources listed with a WPCF Order Number are available from:
Water Pollution Control Federation
2626 Pennsylvania Avenue, N.W.
Washington, DC 20037
A-2
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APPENDIX B
DEVELOPMENT OF DISCHARGE LIMITATIONS
TO CONTROL INCOMPATIBLE POLLUTANTS
-------
APPENDIX B
DEVELOPMENT OF DISCHARGE LIMITATIONS
TO CONTROL INCOMPATIBLE POLLUTANTS
1.0 INTRODUCTION
A critical part of a municipality's task in developing a local pretreat-
raent program is the development of defensible numerical effluent limitations
for the discharge of incompatible pollutants. These limitations are often
incorporated directly into a municipal ordinance or are applied through indi-
vidual permits issued to nondomestic users of the sewerage system. Such lim-
its are needed to enforce the prohibited discharge standards of the General
Pretreatment Regulations and to implement the three fundamental objectives of
the National Pretreatment Program:
To prevent the introduction of pollutants into the POTW which could
interfere with its operation
To prevent the pass-through of untreated pollutants which could vio-
late a POTW's NPDES permit limitations and applicable water quality
standards
To prevent the contamination of a POTW s sludge which would limit
selected sludge uses or disposal practices.
Locally developed limits are also necessary in cases where categorical stan-
dards have not yet been promulgated for an industry, the industry is not
covered by categorical standards, or categorical standards are not adequate to
protect the municipal treatment plant, receiving stream, or sludge.
This Appendix is intended to assist POTWs in calculating limits to imple-
ment these three objectives. The first section of the Appendix outlines the
general methodology for determining allowable pollutant loadings, choosing the
appropriate level of protection, and allocating these loadings to dischargers.
Sections 2, 3, and 4 present equations and guideline data that can be used to
calculate the limiting pollutant concentrations at the influent of the munici-
pal treatment plant which will protect the wastewater treatment processes, the
receiving water, and sludge disposal options. Section 5 discusses
B-l
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considerations for allocation of pollutant loadings to individual industrial
users. Section 6 demonstrates the calculation of a discharge limit for one
pollutant, copper, using a hypothetical example.
The methodology described here for determining allowable influent concen-
trations and setting industrial effluent limits is widely known and accepted.
The basis for some of the material that appears in this Appendix is a document
originally prepared by the State of Indiana and the EPA Region V Office. The
original document has been reorganized and expanded to facilitate a better
understanding of the material.
1.1 GENERAL METHODOLOGY
An incompatible pollutant's effect on a POTW must be evaluated simul-
taneously from three perspectives impact on the treatment plant, impact on
the receiving water, and impact on sludge described above. The limit for that
pollutant can then be set to ensure that all pretreatraent program objectives
are met. It should be pointed out that the limiting factor which meets the
most restrictive of the three objectives may vary from pollutant to pollutant.
For example, at a particular POTW, constraints on the land application of
sludge may limit the allowable influent concentration of cadmium, while the
effects on the receiving water may limit the influent concentration of copper.
The hypothetical example provided at the end of this document will demonstrate
the effect of these limiting factors on the influent pollutant limit for
copper.
As a general procedure, influent concentration limits should be calcu-
lated for a particular pollutant based on each of the three factors (i.e.,
treatment processes, water quality, and sludge). The most stringent of the
three will determine the influent limit to be used for that pollutant. The
POTW will then have to translate that influent limit into discharge limits for
its industrial users that discharge the pollutant into its sewage system.
Although this document provides some specific data on only cyanide and
nine metallic pollutants, a POTW may receive other industrial pollutants with
B-2
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toxic characteristics. Industrial waste surveys and/or POTW sampling, if done
properly, should identify the existence of such pollutants. Calculation of
limits for such pollutants would follow the same general methodology discussed
in this Appendix, although inhibition and removal data would have to be devel-
oped from other sources. It should be noted that this methodology does not
account for any cumulative, synergistic, or antagonistic effects that may
occur when several toxic pollutants are present simultaneously. Figure 1
shows an overview of the steps used in developing pollutant discharge limita-
tions. Table 1 presents the two basic formulae used to determine local dis-
charge limitations. The back calculation formula is used to calculate allow-
able POTW influent concentrations based on threshold concentrations from
various in-plant criteria. The mass conversion formula allows for the deter-
mination of a mass loading (in Ibs/day) if the flow and concentration of the
wastewater are known.
B-3
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FIGURE 1
BASIC STEPS IN DEVELOPING
POLLUTANT DISCHARGE LIMITATIONS
Influent to POTW
NPDES
Activated Anaerobic Limitations or Sludge
Sludge Digestion Water Quality Standards Disposal
Determine
Inhibitory
Concentration
Value
Calculate
Influent
Concentration
that is not
Inhibitory
to this Process
Determine
Inhibitory
Concentration
Value
Calculate
Influent
Concentration
that is not
Inhibitory
to this Process
1. Calculate
Influent
Concentration
which will
allow POTW to
comply with
its NPDES
permit and/or
protect water
quality
Determine
Sludge Disposal
Method
Calculate
Influent
Concentration that
will allow Disposal
Option
T
Select Most
Stringent Value
t
Calculate Load
Available for Industrial
Dischargers
t
Allocate Load to
Industries By
Permit or Order
B-4
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TABLE 1
BACK CALCULATION FORMULA
Where: Lp * Allowable POTW influent concentration (in mg/1)
Li = Threshold concentration for the appropriate unit operation or
appropriate permit limitation (in mg/1)
Ep = Reduction in upstream unit processes (expressed as a decimal)
MASS CONVERSION FORMULA
L = Q x C x 8.34
Where: L - Mass loading (in Ibs/day)
Q = Wastewater flow (in MGD)
C = Concentration (in mg/1)
8.34 = Conversion factor
B-5
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2.0 PREVENTION OF INHIBITION OF TREATMENT PROCESSES
One of the primary objectives of the National Pretreatraent Program is to
prevent the discharge to a POTW of incompatible pollutants that would inter-
fere with or inhibit the POTWs operation. In the case of cyanides, "heavy"
metals, and other toxic pollutants, treatment plant upsets could result if the
pollutant's toxicity is great enough to inhibit the microbial activity of the
biological treatment system and cause a decrease in the pollution removal
efficiency of the municipal treatment facility. Pollutant discharge limits
should be set to maintain the concentration of each toxic pollutant below the
inhibition threshold of the treatment unit.
2.1 ACTIVATED SLUDGE PROCESS
To calculate a discharge limit that will prevent inhibition of an acti-
vated sludge process, it is necessary to determine if an inhibition or upset
condition exists. This determination can be made by examining POTW operating
records for disruptions or changes (e.g., settling characteristics of second-
ary sludge, bacterial species populations in the mixed liquor of the aeration
basin, etc.). If, after examining various operating parameters, no inhibition
or upset conditions can be found, but a POTW protection criteria is desired,
current levels of pollutants of concern should be used as threshold concentra-
tions to determine maximum allowable influent loadings based on prevention of
activated sludge inhibition. If, however, inhibition or upset conditions are
found, the POTW must first determine the concentration of each pollutant of
concern entering the activated sludge process. Care should be taken to
include all recycle and return lines which may be sources of these pollutants,
e.g., return activated sludge (RAS).
After this concentration has been determined, it should be compared with
various inhibitory concentration values that can be found in the technical
literature. Table 2 lists threshold concentrations for inhibitory effects of
several metallic pollutants and cyanide on activated sludge processes, nitri-
fication processes, and anaerobic sludge digestion. These inhibitory values
are taken from technical literature and the experience of States and munici-
palities.
B-6
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TABLE 2
THRESHOLD CONCENTRATIONS* OF TOXIC POLLUTANTS
THAT COULD INHIBIT BIOLOGICAL TREATMENT PROCESSES
Toxic
Pollutant
Arsenic
Cadmium
Chromium (total)
Chromium (hex)
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Threshold of
Inhibitory Effect
on Activated Sludge
0.05 mg/1
1.0 mg/1
10.0 mg/1
1.0 mg/1
1.0 mg/1
0.1 mg/1
0.1 mg/1
0.1 mg/1
1.0 mg/1
1.0 mg/1
Threshold of
Inhibitory Effect
on Nitrification
0.1 mg/1
0.5 mg/1
0.5 mg/1
0.5 mg/1
0.1 mg/1
Threshold of
Inhibitory Effect
on Anaerobic
Sludge Digestion
1.5 mg/1
0.02 mg/1
100.0 mg/1
50.0 mg/1
10.0 mg/1
4.0 mg/1
10.0 mg/1
20.0 mg/1
*Concentrations are specified at influent of the unit process in dissolved
form.
References: (1), (3), and (5)
B-7
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Some qualifications to the data in Table 2 should be noted. The concen-
trations reported in Table 2 are for the dissolved form of each metal and
should be used only for comparison purposes and preliminary calculations if
the actual proportion of dissolved to total metal is unknown. In addition,
concentrations reported in this table reflect the minimum concentration which
showed an inhibitory effect for all bench-scale and full-scale studies regard-
less of test conditions. The result is that many of the values are contra-
dictory, with the same concentration having no inhibitory effects, some
inhibitory effects, or total upset effects. Thus, in using the data in Table
2, it should be noted that these inhibitory concentrations are not absolute
and all other possibilities should be examined prior to adopting a value from
this table as a threshold concentration.
Using an established threshold concentration, a maximum allowable influ-
ent concentration to the POTW (Lp) is calculated for each pollutant of concern
using the back calculation formula from Table 1, as follows:
Li
Where: Lp = Maximum allowable influent concentration to the POTW (in
mg/1)
Li = Established threshold concentration for the pollutant of
concern (in mg/1)
Ep = Reduction of the pollutant of concern through the primary
treatment processes (expressed as a decimal)
Table 3 presents typical removal rates through primary and secondary
treatment processes for several metals, but should only be used for comparison
purposes and preliminary calculations. Plant-specific data are more valid and
should always be used by the POTW for final calculations.
If , after maximum allowable influent concentrations have been calculated
for all possible in- plant criteria, the activated sludge is selected as a
controlling in-plant criteria (i.e., having the lowest maximum allowable
influent concentration) , the maximum allowable influent concentration for
B-8
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TABLE 3
TYPICAL POTW REMOVAL RATES
FOR INCOMPATIBLE POLLUTANTS
Toxic
Pollutant
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Percent Removal
Through Primary Treatment
Median Value1
7
16
18
20
22
6
26
Percent Removal Through
Primary and Secondary Units
Median Value
50
71
82
56
57
51
32
76
Reference: (1)
2
Reference: (2)
B-9
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sludge is converted to a mass loading (L) prior to the allocation procedure
(see Section 5.0), using the mass conversion formula from Table 1 as follows:
L = Q x C x 8.34
Where: L = Maximum allowable mass loading to the POTW (in Ibs/day)
Q = Design flow (in MGD) of the POTW
C = Maximum allowable influent concentration (in mg/1)
8.34 = Conversion factor
2.2 ANAEROBIC DIGESTION
To calculate a discharge limit that will prevent inhibition of anaerobic
sludge digestion, the same basic procedure utilized for the activated sludge
process is followed. First, it must be determined if an inhibition or upset
condition exists by examining POTW operation records for disruption or changes
in such operating parameters as digester supernatant volume and methane gas
production. If no inhibition or upset conditions are found, a POTW can adopt
current concentration levels of pollutants of concern entering the digester as
threshold concentrations, if a POTW protection criteria is desired. If an
inhibition condition does exist, the POTW must determine the concentration of
the pollutant of concern entering the digester, and only then compare the
actual value to the data contained in Table 2, being sure to take into account
all limitations of these literature data.
After establishing a threshold concentration, the POTW must determine the
maximum allowable mass loading to the digester, using the mass conversion
formula, as follows:
L = Q x C x 8.34
Where: L = Maximum mass loading to the digestor (in Ibs/day)
Q = Sludge flow to the digester (in MGD)
C = Established threshold concentration for the anaerobic
digestion process (in mg/1)
8.34 = Conversion factor
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After a maximum allowable loading to the digester is determined, the max-
imum allowable influent concentration to the POTW (C) is calculated, using
another form of the mass conversion formula, as follows:
C =
Q x 8.34
Where: C = Maximum allowable influent concentration (in mg/1)
L = Maximum allowable mass loading to digester (in Ibs/day)
Q = Design wastewater flow of the POTW (in MGD)
8.34 = Conversion factor
However, the amount of a pollutant of concern in the sludge is limited by
the amount of pollutant removed from the wastewater. In the case of metals,
all metals removed from the wastewater are generally deposited in the sludge.
Therefore, the maximum allowable influent concentration for metals must be
adjusted for the amount of metals which remain in the final effluent as
follows:
C*
Ep
Where: C* = Adjusted maximum allowable influent concentration (in mg/1)
C = Unadjusted maximum allowable influent concentration (in
mg/D
Ep = Reduction of pollutant of concern through the entire POTW
(expressed as a decimal)
The final result is that the POTW maximum allowable influent concentra-
tion is allowed to increase by a factor of (1-Ep) to account for the pollutant
of concern (metal) in the final effluent. For other types of pollutants,
other removal mechanisms such as air stripping of volatile pollutants (which
would reduce the amount of pollutant in the sludge) must be similarly con-
sidered. Assuming that anaerobic digestion is selected as the controlling
in-plant criteria, the adjusted maximum allowable influent concentration to
the POTW is converted to a mass loading prior to the allocation procedure.
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This is performed using the mass conversion formula found in Table 1 as
follows:
L = Q x C* X 8.34
Where: L = Maximum allowable influent mass loading (in Ibs/day)
Q = Design wastewater flow of POTW (in MGD)
C* = Adjusted maximum allowable influent concentration (in mg/1)
8.34 = Conversion factor
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3.0 PREVENTION OF POLLUTANT PASS-THROUGH
The second objective of the National Pretreatment Program is to prevent
the pass-through of incompatible pollutants, which could violate a POTW's
NPDES permit requirements and applicable water quality standards. Two proce-
dures are presented below. The first assists the POTW in developing pollutant
discharge limits to ensure that NPDES permit limitations or any applicable
State or local discharge limits are not violated. The second provides the
POTW with a methodology for developing pollutant discharge limits to protect
water quality criteria if desired, in the absence of specific national, State,
or local discharge limitations.
3.1 COMPLIANCE WITH THE POTW NPDES PERMIT
There is only a single step involved in determining the maximum allow-
able influent concentration to the POTW required for that POTW to comply with
its NPDES permit requirement for a particular pollutant of concern. Using the
back calculation formula, the maximum allowable influent concentration is
determined as follows:
Li
Where: Lp = Maximum allowable influent concentration (in mg/1)
Li = NPDES permit limitation for the pollutant of concern
(in mg/1)
Ep = Reduction of pollutant of concern through the entire
POTW (expressed as a decimal)
If the NPDES compliance in-plant criteria controls, the maximum allowable
influent concentration is converted to a mass loading prior to the allocation
procedure, as shown in previous sections.
3.2 PROTECTION OF RECEIVING STREAM'S WATER QUALITY
EPA and State publications contain information on the effects of toxic
pollutants on receiving water quality. The main problems caused by toxic
pollutants are the restriction of domestic and industrial uses of surface
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water, toxicity to aquatic organisms, and the accumulation of toxics in the
food chain. Also, there has been recent concern about trace organics that are
carcinogenic to humans. For these reasons, a POTW can, in the absence of spe-
cific toxic pollutant effluent discharge limitations, develop specific local
discharge limitations to protect the receiving stream's quality by using
established national water quality criteria. However, it should be noted that
the establishment of water quality standards for a particular receiving stream
is the responsibility of the NPDES authority and the POTW is under no obliga-
tion to develop these standards. In addition, any effluent discharge limita-
tions based on water quality criteria that are developed by a POTW would still
be subject to revision by the NPDES authority and would require corresponding
revisions to a POTW's local discharge limitations.
Exhibit A summarizes water quality criteria for 21 priority pollutants
contained in EPA's Ambient Water Quality Criteria, Series (1), as published in
the November 28, 1980, Federal Register. These new criteria have replaced
those formerly established in the 1976 edition of quality Criteria for Water
(the "Red Book"). The criteria were derived by using "guidelines," which,
theoretically, would ensure protection of aquatic health and human health.
Officially, the criteria are only recommended values; they are not enforceable
as water quality standards. However, they do provide useful documentation in
the interpretation of State water quality standards.
To calculate the maximum allowable pollutant loading to the POTW's treat-
ment plants that will protect the receiving water quality from degradation,
the POTW has to determine the in-stream water quality standard (C ) for the
pollutant of interest. This may be available from the State water quality
agency. Otherwise, data from Exhibit A-may need to be used even though they
are not specific and may be too stringent. The maximum allowable pollutant
concentration in the POTW's effluent (C ff) can then be calculated, taking
into account the dilution factor of the receiving stream, as follows:
C cc = (C )(Dilution factor)
err wq
Where: C ff = Maximum allowable pollutant concentration (in mg/1) at the
POTW effluent to protect receiving stream's water quality
C = In-stream water quality standard (in mg/1)
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Qstr + Qeff
Dilution Factor = -
Qeff
Where: Q = Critical low flow of receiving stream (in mgd)
SC1T
Q ff = POTW actual effluent flow (in mgd)
Calculation of the dilution factor involves determining the total volume
of effluent discharged by the POTW into the receiving stream, either by actual
flow measurement or by estimation, using the actual POTW influent flow and
subtracting other sources of wastewater leaving the POTW, such as sludge flow.
Once the maximum allowable pollutant effluent concentration (C ff) is deter-
mined, the maximum allowable influent concentration to the POTW based on
protection of water quality is calculated using another version of the back
calculation formula, as follows:
" 1-Ep
Where: Lp = Maximum allowable influent concentration to the POTW (in
mg/D
C ff = Maximum allowable pollutant concentration at the POTW
et effluent (in mg/1)
Ep = Reduction of pollutant of concern through the entire POTW
(expressed as a decimal)
If water quality is selected as a controlling in-plant criteria, the maximum
allowable influent concentration is converted to a mass loading prior to the
allocation procedure, as shown in previous sections.
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4.0 PROTECTION OF SLUDGE QUALITY
The last major objective of the National Pretreatment Program is the gen-
eration of sludge that is compatible with the overall sludge management pro-
gram and consistent with the selected disposal option of the POTW. Pollutant
discharge limits should be calculated so that the POTW sludge remains compat-
ible with the selected disposal option. There are three basic methods which
POTWs utilize for sludge disposal at the present time:
Incineration
Landfilling
Land application.
Each of these methods has different costs and benefits associated with its
use. For this reason, the required sludge quality and degree of pretreatment
needed will also vary.
4.1 INCINERATION
Incineration of sludges with high concentrations of priority pollutants
can volatilize organics and metals. Little information exists on the release
of these pollutants into the air during incineration. What is known about
incineration is that it is very expensive to operate and requires an air pol-
lution control permit. If incineration is the disposal option used, the POTW
should sample and analyze the resulting ash to determine if the ash quality is
compatible with its disposal method.
4.2 LANDFILL DISPOSAL
The determining factor for landfill disposal is whether the sludge is
classified as a hazardous waste. To ensure that a particular sludge is not a
hazardous waste, the EP (extraction procedure) toxicity test must be per-
formed. When landfill disposal is used by the POTW, the sludge leachate
should be sampled and analyzed when there is a possibility that the leachate
may contaminate or degrade groundwater or surface water resources.
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4.3 LAND APPLICATION
To predict the sludge quality needed for land application, plant opera-
tional data should be analyzed, and land quality and quantity should be deter-
mined. The POTW should know the general soil type and Cation Exchange
Capacity (CEC) of the land application site. Table 4 provides Federal guide-
lines on loading limitations for land application of metal-bearing sludges.
In addition, each State may have its own land application limitations. Both
Federal and State rules should be evaluated to determine necessary sludge
quality and allowable pollutant loads to the municipal treatment plant. These
limitations should be utilized by the POTW to find the maximum cumulative pol-
lutant loading (L) for a specific contaminant. Two procedures are described
below. The first procedure is designed to assist the POTW in assessing sludge
disposal impacts while the second will help in establishing local discharge
limitations which will allow the POTW to dispose of its sludge properly and
economically.
4.3.1 Procedure to Assess Sludge Disposal Impacts
In order to evaluate the impacts of possible sludge contamination, a POTW
must first analyze its final sludge product for each pollutant of concern.
Units of this analysis are generally in terms of milligrams of pollutant per
kilogram of sludge on a dry weight basis. (If data are provided on a wet
weight basis, be sure to convert to dry weight using the sludge percent
solids.) After converting from mg/kg dry to Ibs/dry ton (by multiplying by
0.002), a maximum cumulative loading (L) for the appropriate pollutant of con-
cern is chosen based on the particular characteristics of the soil (Table 4 or
applicable State or local loading limitations). Using these two values, the
maximum amount of sludge which can be applied per acre is determined, as
follows:
Where: AR = Maximum allowable amount of sludge applied per acre (in dry
tons/acre)
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TABLE 4
REQUIREMENTS FOR SLUDGE APPLICATION TO AGRICULTURAL LAND
PRIMARY REQUIRMENT - NITROGEN
1. Sludge application rates should provide total plant available nitro-
gen fertilizer requirement of the crop growth, and the requirement to
prevent nitrate pollution of groundwater.
ADDITIONAL REQUIREMENTS - TRACE METAL ELEMENTS
1. Maximum annual Cd loading:
Jan. 1, 1981 to Dec. 31, 1985 1.25 kg/ha
Beginning Jan. 1, 1986 0.50 kg/ha
2. Soil/sludge pH control
pH of sludge amended soil should be maintained at 6.5 or greater
3. Total cumulative metal loadings (kg/ha)
Cation Exchange Capacity (meq/100 gm)
Element 0-5 5-15 >15
Pb
Zn
Cu
Ni
Cd
500
250
125
50
5
1000
500
250
100
10
2000
1000
500
200
20
4. Cd/Zn ratio of sludge applied should be less than 0.015 in naturally
acidic soils.
Derived from Reference (7).
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L = Maximum cumulative loading (in Ibs/acre)
C = Pollutant concentration in sludge (in Ibs/dry ton)
Using the maximum amount of sludge which can be applied per acre and the
available acreage for sludge application, the total amount of sludge that can
be applied is calculated as follows:
TA = AR x A
Where: TA = Total amount of sludge allowable for disposal on available
acreage (in dry tons)
AR = Maximum allowable amount of sludge applied per acre (in dry
tons/acre)
A = Available acreage for sludge disposal (in acres)
This total amount of sludge allowable for disposal on available acreage
is next divided by the POTW s current sludge generation rate to determine the
lifetime of the available acreage based on the amount of pollutant in the
sludge, as follows:
T* =--
SG
Where: T* = Adjusted site lifetime (in years)
TA = Total amount of sludge allowable for disposal on available
acreage (in dry tons)
SG = POTW's current sludge generation rate (in dry tons/yr)
This adjusted site lifetime can then be compared to the original lifetime
of the available acreage. If the site lifetime is not reduced significantly,
the POTW may decide to set a threshold concentration at current pollutant
levels as a POTW protection criteria. However, if the site lifetime is re-
duced significantly, the POTW must establish a local discharge limitation
which will allow an acceptable disposal site lifetime.
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4.3.2 Procedure to Establish Local Discharge Limitations to Protect POTW
Sludge Disposal Options
The maximum cumulative pollutant loading per acre (L, previously deter-
mined using the soil characteristics of the sludge disposal site), the amount
of available site acreage (A), and the original site lifetime (T) are used to
calculate the maximum allowable pollutant mass loading in the sludge to comply
with the maximum cumulative pollutant loading per acre and still maintain the
original site lifetime, as follows:
T x 365
Where: ML = Maximum allowable pollutant mass loading (in Ibs/day)
L = Maximum cumulative pollutant loading per acre (in Ibs/acre)
A = Available acreage (in acres)
T = Original site lifetime (in years)
365 = Conversion factor (in days per year)
Next, the maximum allowable pollutant mass loading (ML ) to the influent
of the treatment plant, to ensure appropriate sludge quality for land applica-
tion, can be calculated by adjusting ML for removal through the entire plant,
as follows:
Where: ML* = Adjusted maximum allowable pollutant mass loading (in
Ibs/day)
ML = Unadjusted maximum allowable pollutant mass loading (in
Ibs/day)
Ep = Pollutant reduction through the entire POTW treatment system
The maximum allowable pollutant concentration at the influent of the
plant (C) can be found by converting the adjusted maximum allowable influent
pollutant mass loading using the mass conversion formula, as follows:
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C ML*
Q x 8.34
Where: L = Maximum allowable pollutant concentration (in mg/1)
ML* = Adjusted maximum allowable influent mass loading (in
Ibs/day)
Q = POTW design flow (in MGD)
8.34 = Conversion factor
This concentration is used as the sludge disposal in-plant criteria in
determining which in-plant criteria controls. If the sludge disposal criteria
controls, the adjusted maximum allowable influent mass loading (ML*) is used
to begin the allocation procedure.
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5.0 ALLOCATION OF THE POLLUTANT LOAD TO INDUSTRY
The final step in the process of setting effluent limitations is to
allocate the maximum pollutant loading to the treatment plant to the individ-
ual industrial dischargers. This may be accomplished in several ways, as dis-
cussed below.
5.1 ALTERNATIVE METHODS
Single concentration or mass limit; A single concentration or mass
limitation can be established, which no industrial user (IU) can
exceed, and, when domestic contribution is taken into account, will
not exceed the allowable influent loading. This method corresponds to
the example calculation shown in Section 6 of the Appendix. A single
limit for all users may be easier to regulate and enforce.
Proportionate: Allocation can be accomplished proportionately, using
various IU characteristics such as mass loading or flow rate to divide
up the allowable pollutant discharge. The preferred method of alloca-
tion is the one based on mass loadings. However, if concentration
data is not available for each IU, the mass loading ratio may not be
used, and proportionality will have to be based on another character-
istic such as IU flow. However, if the flow is based on water usage,
this method penalizes the industrial user that recycles or reuses some
portion of its wastewater. This method may be desirable when there
are only a few dischargers of a given pollutant in the entire indus-
trial community.
Technology-based: Technology-based limitations are developed by con-
sidering wastewater treatment systems for each particular industrial
user that are best suited to that IU's wastewater. Information on
state-of-the-art treatment system performance can be obtained from EPA
Development Documents supporting effluent limitations guidelines and
standards.
5.2 OTHER CONSIDERATIONS
Growth; Expansion should also be considered in the POTW service area
when allocating pollutant loading. Expansion can include domestic
contributions where future population growth can cause overloads of
compatible pollutants, as well as future industrial contribution. If
land has been zoned for industrial parks or other developments, POTWs
must allocate a certain portion of the allowable influent loading to
this planned expansion.
Design; Proposed or planned design changes in the municipal treatment
plant should be taken into account when developing and setting indus-
trial effluent limitations. For example, nitrification is a more
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sensitive process than activated sludge for some pollutants. A POTW
planning to upgrade would need to develop protection criteria for this
process if it is the limiting factor for some pollutants. Industrial
discharge limits might then have to be made more stringent to protect
the new design. Industrial users should be kept informed of such
plans and developments so that pretreatraent technologies are appro-
priate over time.
5.3 PROCEDURE FOR ALLOCATION OF POLLUTANT LOADINGS TO INDUSTRY
After determining the controlling in-plant criteria and converting the
maximum allowable influent concentration to mass (Ibs/day), the uncontrollable
fraction of the maximum allowable influent loading should be subtracted prior
to allocation. For most POTWs , the uncontrollable fraction will be the pollu-
tants contributed by domestic wastewaters, and is determined by sampling a
typical domestic sewer interceptor where no industry exists. Table 5 presents
data on typical background concentrations of various pollutants found in raw
sewage and other nonindustrial sources, but should only be used for comparison
purposes and preliminary calculations.
Once the uncontrollable fraction of a pollutant is subtracted from the
maximum allowable influent loading, the controllable or allocatable fraction
remains. After considerations such as expansion have been considered, allo-
cation of the controllable fraction is performed using one of the three
methods specified. Procedures for single concentration and proportionate
allocation method follow.
Single concentration allocation is performed by adding together the flows
of all current and future IUs contributing a specified pollutant of concern
and then applying the mass conversion formula, as follows:
Single Concentration , . . Allocatable Fraction (Ibs/day)
Limitation - ~ (Qj + Q2 +Q3. . .) X 8.34
Where: (Q + Q? + Q ) = Sum of all IUs1 flows which discharge the
specific pollutant of concern
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TABLE 5
TYPICAL BACKGROUND CONCENTRATIONS OF
TOXIC POLLUTANTS IN NONINDUSTRIAL SEWAGE
(INCLUDES DOMESTIC AND COMMERCIAL SEWAGE)*
Toxic Pollutant "Background" Concentration
Arsenic 0.003 mg/1
Cadmium 0.003 mg/1
Chromium (total) 0.05 mg/1
Copper 0.061 mg/1
Cyanide 0.041 mg/1
Lead 0.050 mg/1
Nickel 0.021 mg/1
Zinc 0.175 mg/1
* Concentrations are total pollutants except where otherwise indicated.
References: (9)
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Proportionate allocation is based on a particular characteristic of each
industrial user. For example, using each Ill's mass loading or wastewater flow
to establish the appropriate proportion, the allocation is performed as
follows:
Proportionate Allocation Method 1 (Mass) ;
Proportionate Concentration A11 U1 . , 1V ,, » 1
T. r_ _, ., _ ,,, = Allocatable Fraction (Ibs/day) X 7-: r-
Limitation For IU ffl (L )
Where: L. = Current mass loading from IU #1 for a
specific pollutant (Ibs/day)
L = Total mass loading from all industrial
users for a specific pollutant (Ibs/day)
Q = Wastewater flow of IU #1 (MGD)
8.34 = Conversion factor
This is the preferred method of proportionate allocation, if industrial user's
pollutant concentrations are known. If they are not, the next method may be
used.
Proportionate Allocation Method 2 (Flow);
Proportionate Concentration Ann . . . n'
Limitation For IU f 1 = Allocatable Fraction (Ibs/day) X
Q x 8.34
Where: Q = Wastewater flow of IU #1 (MGD)
Q = Sum of wastewater flows for all lUs which discharge
a specific pollutant of concern
8.34 = Conversion factor
The above procedures would be repeated for all industrial users discharging
that particular pollutant of concern.
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6.0 A HYPOTHETICAL POTW EXAMPLE
For reasons of brevity and simplicity, this example calculation of allow-
able influent loading to a POTW addresses only one pollutant, copper. The
methodology presented here, however, will be equally applicable for calculat-
ing limits for other pollutants discharged by electroplaters or other indus-
tries. Our hypothetical POTW utilizes an activated sludge unit for secondary
treatment and anaerobic digestion of sludge. POTW sludge is applied on nearby
farmland.
The treatment plant has a design flow of 10.0 MGD (9.9 MGD average). The
POTW is required to develop a pretreatment program because it has an electro-
plating facility manufacturing printed circuit boards contributing copper to
its system. The POTW pumps 0.2 MGD of raw sludge, thickens it from 1 percent
to 5 percent solids, and then pumps to anaerobic digesters.
For the purpose of this example calculation, we will assume that the
electroplating facility discharges only copper. The POTW has determined,
through its sampling program, that the average removal of copper through the
activated sludge portion of the treatment system is 83 percent with primary
treatment achieving an average of 25 percent removal. The POTW has an NPDES
effluent limitation for copper of 1.0 mg/1.
The POTW has documented upset and inhibition conditions at its treatment
plant caused by high copper concentrations. The threshold copper concentra-
tions at the influent to each appropriate unit operation for this example are
as follow:
Activated sludge - 1.0 rag/1
Anaerobic digestion - 10.0 mg/1
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6.1 CALCULATING MAXIMUM ALLOWABLE POLLUTANT LOAD TO THE POTW FOR COPPER
6.1.1 Preventing Inhibition of Treatment Plant Processes
To determine the influent concentration of copper that will not inhibit
treatment plant process, the POTW must calculate in-plant criteria for both
the activated sludge process and the anaerobic digestion process to find the
controlling in-plant criteria concentration.
(1) Activated Sludge
Using the back caluclation formula presented in Table 1, the in-
plant criteria for the activated sludge process can be determined,
as shown below:
Where: Activated sludge copper threshold concentration =1.0 mg/1
POTW % removal through primary treatment = 25% (or 0.25)
(2) Anaerobic Digestion
Determining the allowable influent copper concentration for proper
anaerobic digestion is slightly more complicated. The allowable
amount of copper, in Ibs/day, in the anaerobic digester is deter-
mined by first calculating the flow of sludge to the anaerobic
digester, and then applying the mass conversion formula shown in
Table 1, using the anaerobic digestion copper threshhold concentra
tion and the calculated flow rate, as follows:
C\
'
0.04 MGD (concentrated by extracting water from 1% to 5%)
Allowable Cu mass loading to digester = (0.04 MGD)(10 mg/l)(8.34)
= 3.34 Ibs/day
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Using the allowable amount of copper to the digester, an allowable
influent concentration can be calculated, using another form of the
mass conversion formula and the POTW design flow, as follows:
Allowable influent Cu concentration = wo = 0.04 mg/1
v, IU
However, only 83 percent removal of copper is achieved through the
entire treatment system and, therefore, only this portion of the
influent copper reaches the digester. Consequently, the allowable
influent concentration is adjusted using another form of the back
calculation formula as follows:
Allowable influent Cu concentration = '^g = 0.048 mg/1
U .o j
6.1.2 NPDES Permit Compliance
Using the back calculation formula presented in Table 1, the in-plant
criteria to meet the POTW NPDES permit requirement is calculated as follows:
Where: NPDES permit limitation =1.0 mg/1
Reduction of copper through the entire POTW = 83% (or 0.83)
6.1.3 Determination of Possible Sludge Disposal Impacts
In addition to the possible impacts mentioned above, sludge disposal
options may be limited for this hypothetical POTW because of the amount of
copper in its digested sludge, which it intends to apply to surrounding farm-
land. In order to evaluate this possibility, the POTW has analyzed its
digested sludge and found it to contain 525 rag/kg (dry weight) of copper.
Converting to pounds per ton:
Copper content of = 525 mg/kg (dry weight) x 0.002 = 1.05 Ibs/dry ton
digested sludge
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Using the most stringent total cumulative metal loading option from
Table 4 (125 kg/ha), and converting to Ibs/acre:
Total cumulative metal loading 111 Ibs/acre - , ,
r-. -3r-6^ = . ' ., .' = 106 dry tons/acre
Copper content of digested sludge 105 Ibs/ton
yields the maximum amount of sludge which can be applied in dry tons/acre.
The hypothetical POTW applies approximately 45 dry tons/month of de-
watered digester sludge to about 410 acres of surrounding pasture and farm-
land. Using the maximum amount of sludge which can be applied per acre and
the land available for application, the total amount of sludge which can be
applied for the lifetime of the sites can be calculated:
Total sludge allowable 106 dry tons x 410 acres . _ .,.. ,
c ,. , ,, , n = L = 43,460 dry tons
for disposal on available acre ' J
acreage
Using this total site lifetime application and the current sludge dis-
posal rate (45 dry tons/month), the lifetime of the sites available for appli-
cation is calculated:
Lifetime of available 43,460 dry tons n,,
.. , , = TTj 1 TT = 966 months or 80 years
acreage for sludge 45 dry tons/months J
disposal
Therefore, unless the original lifetime expectancy of the sludge disposal
sites is well over 80 years, this POTWs sludge disposal options will not be
affected by the current amount of copper in its sludge. In addition, any
reduction of the POTW plant influent copper concentration due to other local
limitations will further lower the amount of copper in the sludge and extend
the useable lifetime of the sludge disposal sites.
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6.1.4 Determination of Controlling In-Plant Criteria
Reviewing the in-plant criteria for each condition;
Activated sludge - 1.3 mg/1
Permit conditions - 5.88 mg/1
Anaerobic digestion - 0.048 mg/1
It can be seen that anaerobic digestion is the controlling in-plant criteria.
Therefore, it is possible that a POTW can be substantially below its permit
condition for a toxic pollutant and still experience inhibition and inter-
ference severe enough to prevent proper plant operation from that same pol-
lutant.
6.2 ALLOCATION OF LOCAL LIMITS FOR COPPER
After calculating an allowable influent concentration of 0.048 mg/1 of
copper as an in-plant criteria for proper anaerobic digestion, the POTW must
allocate the required reduction to attain this concentration among its indus-
trial users. The POTW has identified an electroplating facility as the only
major industrial user discharging copper to its system. This facility has a
flow of 0.050 MGD and currently averages 7.0 mg/1 copper in its effluent.
Using the allowable influent concentration, the allowable pollutant mass
loading is calculated:
Allowable Ibs/day = (10.0 MGD)(0.048 mg/l)(8.34) = 4.0 Ibs/day
After sampling at a number of domestic interceptors, the POTW has determined
the copper concentration in domestic wastewater to be 0.025 mg/1. Calculating
the current domestic copper mass loading:
Domestic Ibs/day = (9.85 MGD)(0.025 mg/l)(8.34) = 2.1 Ibs/day
The allowable copper which can be allocated to industry is then calcu-
lated by subtracting the domestic background loading:
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Allowable Ibs/day =4.0 Ibs/day - 2.1 Ibs/day =1.9 Ibs/day
The current electroplating mass discharge is:
Electroplating Ibs/day = (0.050 MGD)(7.0 mg/l)(8.34) = 2.92 Ibs/day
This particular electroplating facility is subject to a categorical stan-
dard of 4.8 mg/1 for copper. When compliance with this categorical standard
is achieved, the electroplating mass discharge will be:
Electroplating Ibs/day = (0.050 MGD)(4.8 mg/l)(8.34) = 2.00 Ibs/day
The POTW has two future contributions to its system planned. One is a
housing project which will house approximately 500 people. At an estimate of
150 gallons per person daily, the total wastewater flow increase is 0.075 MGD.
However, because of the high cost of copper, builders are planning to use PVC
pipe instead of copper pipe, which the POTW believes is the major source of
domestic copper contribution. Therefore, the POTW is assuming a negligible
amount of copper in this additional flow. The second future addition is a
brass plating operation, which will be a major discharger of copper. This
facility will have a design flow of 0.025 MGD and is also subject to a cate-
gorical standard for copper of 4.8 mg/1. Knowing that the existing facility
already exceeds the allocatable loading using the categorical standard, a more
stringent single concentration local limitation is established:
Allowable electroplating 1.90 Ibs/day ,
concentration ~ (0.050 + 0.025 MGD)(8.34) mg
Therefore, a single concentration local limitation of 3.0 mg/1 for both the
existing and future electroplating facilities will allow the POTW to meet its
allowable influent concentration and will not violate the controlling in-plant
criteria.
B-31
-------
REFERENCES
1. U.S. Environmental Protection Agency. Federal Guidelines - State and
Local Pretreatment Programs. Vols. I, II, and III. EPA-430/9-76-017a, b,
and c. January 1977.
2. U.S. Environmental Protection Agency. Fate of Priority Pollutants in
Publicly Owned Treatment Works. EPA-440/1-82-303. September 1982.
3. Anthony, Richard M., and Breimhurst, Lawrence H. "Determining Maximum
Influent Concentrations of Priority Pollutants for Treatment Plants."
Journal of the Water Pollution Control Federation, Vol. 53. October 1981.
4. Dyer, Jon; Feiler, Howard; and Bernick, Arnold. Handbook of Industrial
Waste Pretreatment, Water Management Series. New York: Garland
Publishing Inc. 1981.
5. Eick, Richard W. "History of Priority Pollutants at the District and
Determination of Prohibitive Discharge Limits (PDL)." 2nd Edition.
Sanitary District of Rockford, Illinois. March 1982.
6. U.S. Environmental Protection Agency. Ambient Water Quality Criteria.
EPA-440/5-80. October 1980.
7. U.S. Environmental Protection Agency. "Municipal Sludge Management-
Environmental Factors." Federal Register, 41, No. 108, pp. 22531, 22543.
June 1976.
8. JRB Associates. "How to Set Local Limits." Handout prepared for
Pretreatment Seminars, sponsored by U.S. Environmental Protection Agency
under Contract No. 68-01-5052. May 1982.
9. JRB Associates. "Assessment of the Impacts of Industrial Discharges on
Publically Owned Treatment Works." Prepared for U.S. Environmental Pro-
tection Agency under Contract No. 68-01-5052. November 1981.
B-32
-------
EXHIBIT A
This Exhibit presents a summary of national water quality criteria that
have been generated by EPA. These numbers do not have any regulatory status;
they are intended to serve as general guidelines for the preservation of the
intended uses of water. The criteria numbers on this table are organized
under two major headings: aquatic life and human health. The first heading
is further subdivided into acute and chronic criteria. These two numbers
represent pollutant concentrations which, if not exceeded, should protect
most, but not necessarily all, aquatic life and its uses. The aquatic life
criteria specify both acute (maximum) and chronic (24 hour average) concen-
trations. The combination of the two numbers is designed to provide adequate
protection of aquatic life and its uses from acute and chronic toxicity and
bioconcentration while being more flexible than a one number criterion.
The human health criteria are divided into two categories. The first
group of numbers under water and organisms was generated assuming consumption
of both drinking water and aquatic organisms (i.e., fish) by humans. The
second group of criteria was derived assuming the consumption of aquatic orga-
nisms only. The criteria for human health are based on the carcinogenic,
toxic or organoleptic (taste and odor) properties of the pollutants. The
meanings and practical uses of these criteria values vary accordingly.
For carcinogenic substances, no scientific basis exists for estimating
"safe" levels. Therefore, the criteria are expressed as ranges of values
corresponding to incremental cancer risks of 10 to 10 (one additional case
of cancer in a population ranging from ten million to 100,000, respectively).
A detailed discussion of these criteria, how they were developed and
qualifications regarding their use can be found in Reference 6.
B-33
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B-39
-------
APPENDIX C
PRIORITY POLLUTANTS
AND
CATEGORICAL INDUSTRY
INFORMATION
-------
TABLE C.I
MATRIX OF PRIORITY POLLUTANTS POTENTIALLY
DISCHARGED FROM INDUSTRIAL CATEGORIES
Table C.I lists the 25 categorical industries and the potential
priority pollutants that can occur in significant amounts in the
wastewater discharged from each group. This does not mean that every
facility within a specific group discharges that pollutant; it does
mean that there is a high probability that it will be discharged,
based on a national survey of the industries conducted by USEPA. In
addition, it does not mean that other priority pollutants will not be
found in significant quantities, but that, in general, the manufacturing
process and raw materials involved do not lead to the discharge of these
pollutants.
NOTE: The information in the table was developed from Industry
Summaries prepared by the USEPA, dated March 1979, from the published
development documents for effluent limitations from industrial point
source categories. This information is subject to change, and, as
shown in Tables C.I and C.2, some industry groups may not be regulated.
C-l
-------
TABLE C.I £
H
CO
MATRIX OF PRIORITY POLLUTANTS &
POTENTIALLY DISCHARGED FROM §
INDUSTRIAL CATEGORIES *
h- ]
<
POLLUTANT FOUND IN £J
SIGNIFICANT QUANTITY g
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PRIORITY POLLUTANTS \^
1 . acenaphthene
2. acrolein
3. aery Ion itrile
4 . benzene
5 . benzidine
6. carbon tetrachloride
7. chlorobenzene
8 . 1,2 ,4-trichlorobenzene
9 . hexachlorobenzene
10. 1 , 2-dichloroethane
11. 1,1,1-tnchloroe thane
12 . hexachloroethane
13. 1,1-dichloroe thane
3-4. 1,1,2-trichloroethane
15. 1, 1,2,2-tetrachloroethane
16 . ch lor oe thane
17. bis(2-chloroethyl) ether
18 . 2-chloroethvl vinyl ether (mixed)
19 . 2-chloronaphthalene
20. 2,4,6-trichlorophenol
21. parachlorometa cresol
22 . chloroform (trichloromethane)
23. 2-chlorophenol
24. 1,2-dichlorobenzene
25 . 1, 3-dichlorobenzene
26. 1 , 4-dichlorobenzene
27. 3 , 3-dichlorobenzidine
28 . 1, 1-dichloroethvlene
29. 1,2-trans-dichloroethylene
30. 2 , 4-dichlorophenol
31 . 1 , 2~dichloropropane
32 . 1 , 2-dichloropropylene (1, 3-dichloropropene)
33- 2,4-dimethylphenol
34 . 2 , 4 -d in itro toluene
35 . 2, 6-dlnitro toluene
36. 1 , 2-diphenylhydrazine
37 . ethylbenzene
38 , fluorathene
39 . 4-chlorophenyl phenyl ether
40. 4-bromophenyl phenyl ether
41. bis(2-chloroisopropyl) ether
42 . bis (2-chloroethoxy) methane
43. met hygiene chloride (dichlorome thane)
44. methyl chloride (chloromethane)
45 . methyl bromide (bromomethane)
46. bromof orm (tribromomethane)
47 . dichlorobromomethane
48. chlorodibromomethane
49 . hexachlorobutadiene
50. hexachlorocvclooenfAdiene
51 . isoohorone
52. naphthalene
53. nitrobenzene
54. 2-nitroDhenoL
55 . 4-nitrophenol
56. 2,4-dinitrophenol
57. 4.6-dinitro-o-cresol
58 . N-nitrosodimethylamine
59 . N-nitrosodiphetiylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62. phenol
63. bis(2-ethylhexyl) phthalate
64 . butyl benzyl phthalate
ADHESIVE
ALUMINUM FORMING
BATTERY MANUFACTURING
COAL MINING
COIL COATING
COPPER FORMING
ELECTRICAL PRODUCTS
ELECTROPLATING
FOUNDRIES
INORGANIC CHEMICALS
C-2
-------
TABLE C.I (Continued)
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
CATEGORICAL INDUSTRY
\
65. di-n-butyl ohthalate
66. di-n-octvl phthalate
67. diethyl phthalate
68. dimethyl phthalate
69. benzo(a)anthracene (1,2-benzanthracene)
70. benzo (a)pyrene (3,4-benzo~pyrene
71. 3,4-benzofluoranthene (benzo (b) fluoranthene)
72. benzo (k) f luoranthane (11 , 12-benEof luoranthene)
73. chrysene
74. acenaphthylene
75. anthracene
76. benzo(ghi)perylene (1, 12-benzoperylene)
77. fluorene
78. phenanchrene
79. dibenzo(ah)anthracene (1.2,5.6~dibenzanthracene)
80. indeno (1,2, 3-cd)pyrene (2 , 3-o-phenvlenepyrene)
81. pyrene
82. tetrachloroethylene
83. toluene
84. trichloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane (technical mixture & metabolites)
89. 4,4-DDT
90. 4,4-DDE (p.p-DDX)
91. 4,4-DDD IP.P-TDE)
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrin
96. endrin aldehyde
97. heptachlor
98. heptachlor epoxide (BHC-hexachlbrocyclohexane)
99. Alpha-BHC
100. Beta-BHC
101. Gamma-BHC(lindane)
102. Delta-BHC (PCB-polychlorinated biphenyl)
103. PCB-1242 (Arochlor 12421
104. PCB-1254 (Arochlor 1254)
105. PCB-1221 (Arochlo 1221)
106. PCB-1232 (Arochlo 1232)
107. PCB-1248 (Arochlo 1248)
108. PCB-1260 (Arochlo 1260)
109. PCB-1016 (Arochlo 1016)
110. toxaphene
111. antimony (total)
112. arsenic (total)
113. asbestos (fibrous.
L14. beryllium (total)
115. cadmium (total)
117. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)
121. nickel (total)
122. selenium (total)
123. silver (total)
.24. thallium (total)
.25. zinc (total)
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
ADHESIVE
ALUMINUM FORMING
BATTERY MANUFACTURING
COAL MINING
COIL COATING
COPPER FORMING
ELECTRICAL PRODUCTS
ELECTROPLATING
FOUNDRIES
INORGANIC CHEMICALS
C-3
-------
TABLE C.I (Continued) g
r~*
to
MATRIX OF PRIORITY POLLUTANTS g
POTENTIALLY DISCHARGED FROM H
INDUSTRIAL CATEGORIES ^
u
POLLUTANT FOUND IN g
SIGNIFICANT QUANTITY o
H
<
U
PRIORITY POLLUTANTS \_
1. acenaphthene
2. acrolein
3. acrylonitrile
4. benzene
5. benzidine
6. carbon tetrachloride
7 . chLorobenzene
8, 1, 2 ,4-trichlorobenzene
9. hexachlorobenzene
10. 1,2-dichloroethane
11. 1, 1, 1-trichloroechane
12. hexachloroethane
13. 1,1-dichloroethane
14. I,lj2-trichloroethane
15. 1,1,2,2-tetrachloroethane
16. chloroethane
17. bis(2-chloroechyl) ether
18. 2-chloroethvl vlnvl ether (mixedl
19. 2-chloronaphthalene
20. 2,4,6-trichlorophenol
21. parachlorometa cresol
22. chloroform (trichloromethanel
23. 2-chlorophenol
24. 1,2-dichlorobenzene
25. 1,3-dlchlorobenzene
26. 1,4-dlchlorobenzene
27. 3,3-dichlorobenzidine
28. 1.1-dlchloroethvlene
29. 1,2-trans-dichloroethvlene
30. 2,4-dichlorophenol
31. 1 , 2-dichloropropane
32. 1,2-dichloropropylene (1, 3-dichloropropene)
33. 2,4-dimethylphenol
34. 2,4-dinitrotoluene
35. 2,6-dinitrotoluene
36. 1,2-diphenylhydrazlne
37. ethylbenzene
38. fluorathene
39. 4-chlorophenyl phenvl ether
40. 4-bromophenyl j>henyl ether
41. bis (2-chloroisopropyl) ether
42. bis(2-chloroethoxy) methane
43. methylene chloride (dichloromethanel_
44. methyl chloride (chloromethane)
45. methyl bromide (bromomethane)
46. bromoform (tribromomethatie)
47. dichlorobromomethane
48. chlorodibromomethane
49. hexachlorobutadiene
50. hexachlorocvclooenta^iene
51. isophor^ne
52. naphthalene _
53. nitrobenzene
54. 2-nitroohenol
55. 4-nitrophenol
56. 2 ,4-dinitrophenol
57. 4,6-dinitro-o-cresol
58. N-nitrosodimethylamine
59. N-nitrosodiphenylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62 . phenol
63. bis(2-ethylhexyl) phthalace
64. butyl benzyl phthalate
tJ
W
w
H
to
^a
*z
o
cat,
\ i
THER TANNING & FINISHING |
iS
hJ
AL FINISHING |
H
W
S
-FERROUS METALS |
23
O
&
MINING & DRESSING |
Ed
Pd
O
\NIC CHEMICALS, PLASTICS 1
SYNTHETICS 1
O Q
<& 2
0 <
IICIDES 1
CO
w
PM
ROLEUM REFINING j
H
Ed
P-,
ElMACEUTICALS |
s
PH
3TICS PROCESSING |
^
PM
C-4
-------
TABLE C.I (Continued)
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
CATEGORICAL INDUSTRY
\
65. di-n-butyl Dhthalate
66. di-n-octvl Dhthalate
67. diethvl Dhthalate
68. dimethyl phthalate
69. benzo(a)anthracene (1.2-benzanthracene)
70. benzo(a)pyrene (3,4-benzo-pyrene
71. 3, 4-benzofluoranthene (benzo(b)fluoranthene)
72. benzo(k)fluoranthane (11 , 12-benzof luorantheneL
73. chrysene
74. acenaphthylene
75. anthracene
76. benzo(ghi)perylene (1,12-benzoperylene)
77. fluorene
78. phenanthrene
79. dibenzo(ah)anthracene (1.2. 5.6-dibenzanthracene)
80. indeno (1, 2, 3-cd)pyrene (2,3-o-phenylenepyrene)
81. pvrene
82, tetrachloroethylene
83, toluene
84. trichloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane (technical mixture & metabolites)
89. 4,4-DDT
90. 4.4-DDE (p.p-DDX)
91. 4,4-DDD (p.p-TDE)
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrin
96. endrin aldehyde
97. heptachlor
98. heptachlor epoxide (BHC-hexachlorocyclohexane)
99. Alpha-BHC
100. Beta-BHC
101. Gamma-BHC(lindane)
102. Delta-BHC (PCB-polvchlorinated biohenvl)
103. PCB-1242 (Arochlo 1242)
104. PCB-1254 (Arochlo 1254J
105. PCB-1221 (Arochlo 1221)
106. PCB-1232 iArochlo 1232)
107. PCB-1248 (Arochlo 1248)
108. PCB-1260 (Arochlo 1260)
109. PCB-1016 (Arochlor 1016)
110. toxaphene
111. antimony (total)
112. arsenic (total)
113. asbestos (fibrous)
114. beryllium (total)
115. cadmium (total)
116. chromium (total)
117. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)
121. nickel (total)
122. selenium (total)
123. silver (total)
124. thallium (total)
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
i-i
w
w
H
CO
<3
&
o
03
M
LEATHER TANNING & FINISHING
METAL FINISHING
NON-FERROUS METALS
ORE MINING & DRESSING
ORGANIC CHEMICALS, PLASTICS
AND SYNTHETICS
PESTICIDES
PETROLEUM REFINING
PHARMACEUTICALS
PLASTICS PROCESSING
*
C-5
-------
1
>H
TABLE C.I (Continued) H
P
MATRIX OF PRIORITY POLLUTANTS §
POTENTIALLY DISCHARGED FROM M
INDUSTRIAL CATEGORIES <
u
i i
POLLUTANT FOUND IN O
SIGNIFICANT QUANTITY w
E~<
<
CJ
PRIORITY POLLUTANTS \^
1. acenaphthene
2. acrolein
3. aery Ionic rile
4. benzene
5 . benzidine
6. carbon tetrachloride
7 . chlorobenzene
8. 1,2,4-trichlorobenzene
9 . hexachlorobenzene
10- 1,2-dichloroe thane
11. 1, 1,1- trichloroe thane
12 . hexachloroethane
13. 1 ,1-dichloroe thane
14. 1,1, 2- trichloroe thane
15 . 1,1,2, 2-tetrachloroethane
16. chloroe thane
17. bis(2-chloroethyl) ether
18. 2-chloroethvl vinyl ether (mixed)
19 . 2-chloronaphthalene
20. 2 1 4 7 6-trichlorophenol
21. parachlorometa cresol
22. chloroform (trichloromethane)
23. 2-chlorophenol
24 . 1,2-dichlorobenzene
25 . 1, 3-dichlorobenzene
26. 1,4-dichlorobenzene
27 . 3 , 3-dichlorobenzidine
28 . 1 . 1-dichloroe thvlene
29 . 1 , 2- trans-dichloroe thvlene
30. 2,4-dichlorophenol
31 . 1 7 2-dichloropropane
32 . 1 , 2-dichlorqpropylene (1 , 3-dichloropropene)
33. 2,4-dimethylphenol
34. 2, 4-dinitro toluene
35. 2, 6-d in itro toluene
36. 1 , 2-diphenylhydrazine
37 . ethylbenzene
38. fluorathene
39 . 4-chlorophenyl phenyl ether
40. 4-bromophenyl phenyl ether
41. bis(2-chloroisopro_pyl) ether
42 . bis (2-chloroethoxv) methane
43. me thvlene chloride (dichlorome thane)
44 . methyl chloride (chloromethane)
45. methyl bromide (bromomethane)
46. bromoform (tribromomethane)
47 . dichlorobromomethane
48 . chlorodibromome thane
49 . hexachlorobutadiepe
50. hexachlorocvcloopntadienfi
51 . isophorone
52 . naphthalene
53. nitrobenzene
54 . 2-nitroohenol
55 . 4-nitrophenol
56. 2,4-dinitrophenol
57. 4,6~dinitro-o-cresol
58. N-nitrosodimethylamine
59 . N-nitrosodiphenylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62. phenol
63. bis(2-ethylhexy_l) phthalate
64 . butyl benzyl phthalate
PORCELAIN ENAMELING |
PULP, PAPER, AND FIBERBOARD |
STEAM ELECTRIC 1
TEXTILE MILLS
TIMBER PRODUCTS PROCESSING |
C-6
-------
TABLE C.I (Continued)
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
/ CATEGORICAL INDUSTRY |
65. di-n-butyl phthalate
66. di-n-octvl chthalate
67. diethvl phthalate
68. dimethyl phthalate
69. benzo(a)anthracene (1 , 2-benzanthracene)
70. benzo (a)pyrene (3,4-benzo-pyrene
71. 3, 4-benzofluoranthene (benzo(b)fluoranthene)
72. benzo (k) fluoranthane (11,12-benzof luoranthene)
73. chrysene
74. acenaphthylene
75. anthracene
76. benzo(ghi)perylene (1 , 12-benzoperylene)
77. fluorene
78. phenanthrene
79. dibenzo(ah)anthracene (1.2. 5.6-dibenzanthr<
icene)
80. indeno (1,2, 3-cd)pyrene (2, 3-o-phenvlenepyrene)
81. pyrene
82. tetrachloroethylene
83. toluene
84. trichloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane (technical mixture & metabolites)
89. 4,4-DDT
90. 4,4-DDE (p.p-DDX)
91. 4,4-DDD (p,p-TDE) _^
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrin
96. endrin aldehyde
97. heptachlor
98. heptachlor epoxide (BHC-hexachlorocyclohexane)
99. Alpha-BHC
100. Beta-BHC
101. Gamma-BHC(lindane)
102. Delta-BHC (PCB-polighlorinated biphenyl)
103. PCB-1242 (Arochlor 1242)
104. PCB-1254 (Arochlor 1254J_
105. PCB-1221_(Arochlor 1221J_
106. PCB-1232 (Arochlor 1232J_
107. PCB-1248 (Arochlor 1248J_
108. PCB-1260 (Arochlor 1260)
109. PCB-1016 (Arochlor 1016)
110. toxaphene
111. antimony (total)
112. arsenic (total)
113. asbestos (fibrous)
L14. beryllium (total)
L15. cadmium (total)
116. chromium (total)
117. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)
121. nickel (total)
122. selenium (total)
123. silver (total)
124. thallium (total)
125. zinc (total)
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
PORCELAIN ENAMELING
PULP, PAPER, AND FIBERBOARD
STEAM ELECTRIC |
TEXTILE MILLS
TIMBER PRODUCTS PROCESSING
C-7
-------
TABLE C.2
STATUS REPORT OF CATEGORIES TOTALLY OR PARTIALLY
EXCLUDED FROM PRETREATMENT REGULATION
CATEGORY/SUBCATEGORY AFFECTED
Industrial Category as listed in PARAGRAPH 8 EXCLUSION PROJECT DEFERRED
the EGD / NRDC Settlement Agreement Total Partial Total Partial
Adhesive and Sealants
Aluminum Forming
Auto and Other Laundries
Battery Mfg.
Carbon Black
Coal Mining
Coil Coating
468 Copper Forming
Electrical and Electronic Products
Electroplating
457 Explosives Mfg.
Foundry
_Gum and Hood Chemicals
Ink Formulation
415 Inorganic Chemicals
Iron and Steel Mfg.
Leather Tanning and Finishing
Mechanical Products
_433 2Metal Finishing
421 Honferrous Metals Manufacturing
471 Nonferrous Metals Forming
440 Ore Mining and Dressing
414 Organic Chemicals
446 Paint Formulation
_443 Paving and Roofing Materials
455 Pesticides
419 Petroleum Refining
439 Pharmaceutical Mfg.
459 Photographic Equipment and Supplies
416 Plastics and Synthetics
463 Plastics Molding and Forming
466 Porcelain Enameling
448 Printing and Publishing
430 Pulp, Paper, and Faperboard
428 Rubber Mfg.
470 Shipbuilding
417 Soap and Detergent Mfg.
423 Steam Electric Powerplants
410 Textile
429 Timber
^he organic Chemicals and the Plastics and Synthetics Categories have been combined
for BAT ruleraaking under the Organic/Plastic Category.
^The Electroplating and the Mechanical Products Categories have been combined for BAT
ruleraaking under the Metal Finishing Category.
Source: This table is an update of the July 1981 Summary of paragraph 8 Exclusions prepared by the Office of Quality
the Effluent Guidelines Division, Office of Water Regulations and Standards, Office o£ Water, EPA.. It was at
memorandum from Jeffrey Denit, dated August 18, 1981. This information is subject to change.
C-8
-------
TABLE C.3
REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES
Industry Category
SIC Code
2891
Adhesives and Sealants
Aluminum Forming
Rolling with Emulsions
Rolling with Neat Oils
Extrusion
Drawing with Neat Oils
Forging
Drawing with Emulsions or Soaps
Coal Mining
Coal Preparation
Acid/Ferrugenous Mine Drainage
Alkaline Mine Drainage
Areas under Reclamation
Western Coal Mines
Coil Coating
Steel Basis Material Coating
Galvanized Basis Material Coating
Aluminum Basis Material Coating
Copper Forming
Hot Rolling
Cold Rolling
Extrusion
Drawing
Pickling
Alkaline Cleaning
Forging
Copper Foil Production
Electroplating (Metal Finishing)
Electroplating of Common Metals
Electroplating of Precious Metals
Electroplating of Speciality Metals
Anodizing
Coatings
Chemical Etching & Milling
Electroless Plating
Printed Circuit Board
Chemical Matching
Immersion Plating
Pickling
Bright Dipping
Alkaline Cleaning
Source: Summarized from (1) "Summary of Paragraph 8 Exclusions," EGD, OWRS,
EPA, July, 1981; (2) Standard Industrial Classification Manual,
Executive Office of the President, Office of Management and Budget,
1972.
C-9
3353, 3355
3353, 3355
3354
3353, 3355
3463
3353, 3355
1111, 1112, 1211, 1213
1111, 1112, 1211, 1213
1111, 1112, 1211, 1213
1111, 1112, 1211, 1213
1211, 1213
3479
3479
3479
3351
3351
3351
3351
3351
3351
3351
3497, 3351
3471 & 3479
(Some industries within
these subcategories may
not be subject to regu-
lations)
-------
TABLE C.3 (Continued)
REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES
Industry Category
SIC Code
Foundries
Iron and Steel
Copper
Aluminum
Zinc
Lead
Magnesium
Inorganic Chemicals
Chlorine & Na or K Hydroxide
Hydrofluoric Acid Production
Na Dichromate & Sulfate Production
Titanium Dioxide
Aluminum Fluoride Production
Chrome Pigment
Copper Sulfate Production
Hydrogen Cyanide Production
Nickel Sulfate Production
Sodium Bisulfite Production
Sodium Silicofluoride Production
Iron and Steel Manufacturing
(BAT subcategorization scheme)
Cokemaking
Sintering
Ironmaking
Steelmaking
Vacuum Degassing
Continuous Casting
Hot Forming
Scale Removal
Acid Pickling
Cold Forming
Alkaline Cleaning
Hot Coating
Leather Tanning and Finishing
Hair Pulp Unhairing with Chrome
Tanning and Finishing
Hair Save Unhairing with Chrome
Tanning or Finishing
Unhairing with Vegetable or
Alum. Tanning and Finishing
Finishing of Tanned Hides
Vegetable or Chrome Tanning of
Unhaired Hides
Unhairing with Chrome Tanning and
No Finishing
Shearing
3322, 3324, 3325
3362
3361
3369
3369
3369
2812
2819
2819
2816
2819
2816
2819
2819
2819
2819
2819
3312
3312
3312
3312
3312
3312
3312, 3315, 33171
3312, 3315, 33171
3312, 3315, 33171
3316
3312, 3315, 3316, 33171
3312, 3315, 33171
3111
3111
3111
3111
3111
3111
3111
C-10
-------
TABLE C.3 (Continued)
REGULATED INDUSTRIES SUBCATEGORIES WITH ASSOCIATED SIC CODES
Industry Category
SIC Code
Metal Finishing/Mechanical Products
Nonferrous Metals Manufacturing
Bauxite Refining
Primary Aluminum Smelting
Secondary Aluminum Smelting
Primary Copper Smelting
Primary Copper Refining
Secondary Copper
Primary Lead
Primary Zinc
Metallurgical Acid Plants
Primary Columbium Tantalum
Secondary Silver - Photographic
Secondary Silver - Nonphotographic
Primary Tungsten
Secondary Lead
Ore Mining and Dressing
Base and Precious Metals
(Cu, Pb, Zn, Ag, Au, Pt, Mo)
Ferroalloy Ores
Uranium, Radium, Vanadium Ores
Tungsten Ore
Nickel Ores
Vanadium Ore (non-radioactive)
Antimony Ore
Organic Chemicals, Plastics and
Synthetic Materials
Processes with Process Water,
Contact as Steam Diluent
Quench or Vent Gas Absorbent
Pesticides Chemicals
Organic Pesticide Mfg.
Metallo-Organic Pesticides
Pesticide Chemicals Formulating
Petroleum Refining
Topping
Cracking
Petrochemicals
Lube
Integrated
Large number of subcate-
gories including: 3411-29;
3432-66; 3482-3599; 3613-
23; 3629-39
2819
3334
3341
3331
3331
3341
3332
3333
3331, 3332, 3333
3339
3341
3341
3339
3341
1021, 1031, 1041, 1044,
1061
1061
1094
1061
1061
1094
1099
2865, 2869
2869, 28792
2869, 2879
2869, 2879
2911
2911
2911
2911
2911
C-ll
-------
TABLE C.3 (Continued)
REGULATED INDUSTRIES SUBCATEGORIES WITH ASSOCIATED SIC CODES
Industry Category
SIC Code
Pharmaceutical Manufacturing
Fermentation Products
Extractions
Chemical Synthesis Products
Mixing/Compounding - Formulation
Research
Plastics and Synthetics (Organic
Chemicals, Plastics, Synthetic
Materials)
Polyvinyl Chloride
Polyvinyl Acetate
Polystyrene
Polypropylene
Polyethylene
Cellophane
Rayon
ABS and SAN Resin - Copolymers
Polyester
Nylon 6
Cellulose Acetate
Acrylics
Ethylene - Vinyl Acetate
Polytetrafluoroethylene
Polypropylene Fiber
2833, 2831
2831, 2833
2833
2834
2831, 2833, 2834
2821
2821
2821
2821
2821
2821
2823
2821
2821
2821
2823
2821
2821
2821
2823
Alkyds & Unsaturated Polyester Resins 2821
Cellulose Nitrate 2821
Polyamide (Nylon 6/12) 2821
Polyester Resins (Thermoplastics) 2821
Silicones 2821
Porcelain Enameling
Steel
Cast Iron
Aluminum
Copper
Pulp, Paper and Paperboard
Unbleached Kraft
Sodium Based neutral Sulfite
Semi-Chemicals
Ammonia Based Neutral Sulfite
Semi-Chemical
Unbleached Kraft-Neutral Sulfite
Semi-Chemical
Paperboard from Wastepaper
Dissolving Kraft
3631, 3632, 3633, 3639,
3469, 3479, 3431
Mainly 3631, 3431
Mainly 3469, 3479, 3631
Mainly 3479, Limited use
in 3469 and 3631
2611
2611
2611
2611
2631
2611
C-12
-------
TABLEC. 3 (Continued)
REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES
Industry Category SIC Code
Pulp, Paper and Paperboard (Continued)
Market Bleached Kraft 2611
OCT Bleached Kraft 2611
Fine Bleached Kraft 2611
Papergrade Sulfite 2611, 2621
Dissolving Sulfite Pulp 2611
Groundwood - Thermo - Mechanical 2611, 2621
Groundwood - CMN Papers 2611, 2621
Groundwood - Fine Papers 2611, 2621
Soda 2611, 2621
Unbleached Kraft & Semi-Chemical 2611
Semi-Chemical 2611
Wastepaper - Molded Products 2646
Nonintegrated - Lightweight Paper 2621
Nonintegrated - Filter and Nonwoven
Pa'pers 2621
Nonintegrated - Paperboard 2631
Deink 2611, 2621
Nonintegrated Fine Paper 2621
Nonintegrated Tissue Papers 2631
Tissue from Wastepaper 2647
Papergrade Sulfite (Drum Wash) 2611, 2621
Steam Electric Power Generating
Generating Unit 4911, 4931
Small Unit 4911, 4931
Old Unit 4911, 4931
Area Runoff 4911, 4931
Textile Industry
Wool Scouring 2299
Wool Finishing 2231
Woven Fabric Finishing 2261, 2262, 2269
Knit Fabric Finishing 2251-59
Carpet Mills 2271, 2272, 2279
Stock and Yarn Dyeing & Finishing 2269
Nonwoven Manufacturing 2297
Felted Fabric Processing 2291
Timber Products
Wood Preserving - Boultonizing 2491
Wood Fuming and Fixtures (with 2511, 2512, 2517, 2521
and Without Water Wash Spray 2531, 2541
Booths or Laundry Facilities)
*Mainly Zero Dischargers
2Low Flow or Zero Discharge
C-13
-------
TABLE C.4
DETECTION LEVELS FOR PRIORITY POLLUTANTS
Detection
PRIORITY POLLUTANT3 Level (ug/L)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
acenaphthene
acrolein
acrylonitrile
benzene
benzidine
carbon tetrachloride
chlorobenzene
1 ,2 ,4-trichlorobenzene
hexachlorobenzene
1 ,2-dichloroethane
1 ,1 ,1-trichloroethane
hexachloroethane
1 ,1-dichloroethane
1 ,1 ,2-trichloroethane
1 , 1 ,2 ,2-tetrachloroethane
chloroe thane
bis (2-chloroethyl) ether
2-chloroethyl vinyl ether (mixed)
2-chloronaphthalene
2 ,4 ,6-trichlorophenol
parachlorometa cresol
chloroform ( trichloromethane)
2-chlorophenol
1 ,2-dichlorobenzene
1 ,3-dichlorobenzene
1 ,4-dichlorobenzene
3 ,3-dichlorobenzidine
1 ,1-dichloroethylene
1 ,2-trans-dichloroethylene
2 ,4-dichlorophenol
1 ,2-dichloropropane
1 ,2-dichloropropylene (trans 1 ,3-dichloropropene)
2 ,4-dimethylphenol
2 ,4-dinitrotoluene
2 ,6-dinitrotoluene
1 , 2- d i pheny 1 hyd r a z ine
ethylbenzene
fluoranthene
4-chlorophenyl phenyl ether
4-bromophenyl phenyl ether
1.8
0.6
0.5
0.2
0.08
0.12
0.25
0.05
0.05
0.03
0.03
1.6
0.07
0.02
0.03
0.52
0.3
0.13
1.9
0.64
0.36
0.05
0.31
0.15
0.32
0.24
0.13
0.13
0.1
0.39
0.04
0.34
0.32
0.02
0.01
b
0.2
0.21
3.9
2.3
EPA
Method
610
603
603
602
605
601
601
612
612
601
601
625
601
601
601
601
611
601
625
604
604
601
604
601
601
601
605
601
601
604
601
601
604
609
609
b
602
610
611
611
C-14
-------
DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued)
Detection
PRIORITY POLLUTANT3 Level (ug/L)
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
bis (2-chlorisopropyl) ether
bis (2-chloroethoxy) methane
methylene chloride (dichlororaethane)
methyl chloride (chloromethane)
methyl bromide (bromomethane)
bromoform ( tribromomethane)
dichlorobromome thane
chlorodibromome thane
hexachlorobutadiene
hexachlorocyclopentadiene
isophorone
naphthalene
nitrobenzene
nitrophenol
4-nitrophenol
2 ,4-dinitrophenol
4 ,6-dinitro-o-cresol
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-propylamine
pentachlorophenol
phenol
bis (2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
dimethyl phthalate
benzo (a) anthracene (1 ,2-benzanthracene)
benzo (a) pyrene (3 ,4-benzopyrene)
3 ,4-benzof luoranthene
benzo (k) fluoranthane (11, 12-benzof luoranthene)
chrysene
acenaphthylene
anthracene
benzo (ghi) perylene (1, 12-benzoperylene)
fluorene
phenanthrene
dibenzo (a,h) anthracene (1 ,2 ,5 ,6-dibenzanthracene)
indeno (1,2,3-cd) pyrene (2 ,3-o-phenylenepyrene)
pyrene
tetrachloroethylene
0.8
0.5
0.25
0.08
1.18
0.2
0.1
b
0.34
-
5.7
1.8
3.6
0.45
2.8
13.0
16.0
0.15
0.81
0.46
7.4
0.14
2.0
0.34
0.36
3.0
0.49
0.29
0.013
0.023
0.018
0.017
0.15
2.3
0.66
0.076
0.21
0.64
0.03
0.043
0.27
0.03
EPA
Method
611
611
601
601
601
601
601
601
612
c
609 FID
610
609 FID
604
604
604
604
607
607
607
604
604
606
606
606
606
606
606
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
601
C-15
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DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued)
PRIORITY POLLUTANT
a
Detection EPA
Level (ug/L) Method
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.
121.
122.
123.
toluene
trichloroethylene
vinyl chloride (chloroethylene)
aldrin
dieldrin
chlordane (technical mixture & metabolites)
4, 4 '-DDT
4, 4 '-DDE (p, p'-DDX)
4, 4'-DDD (p, p'-TDE)
Alpha-endosulfan
Beta-endosulf an
endosulfan sulfate
endrin
endrin aldehyde
heptachlor
heptachlor epoxide
Alpha-BHC
Beta-BHC
Gamma-BBC (lindane)
Delta-BHC
PCB-1242 (Arochlor 1242)
PCB-1254 (Arochlor 1254)
PCB-1221 (Arochlor 1221)
PCB-1232 (Arochlor 1232)
PCB-1248 (Arochlor 1248)
PCB-1260 (Arochlor 1260)
PCB-1016 (Arochlor 1016)
toxaphene
antimony (total)
arsenic (total)
asbestos (fibrous)
beryllium (total)
cadmium (total)
chromium (total)
copper (total)
cyanide (total)
lead (total)
mercury (total)
nickel (total)
selenium (total)
silver (total)
0.2
0.12
0.18
0.004
0.002
0.014
0.012
0.004
0.011
0.014
0.004
0.066
0.006
0.023
0.003
0.083
0.003
0.006
0.004
0.009
0.065
b
b
b
b
b
b
0.24
10
10
b
1
1
5
1
20
10
0.2
10
5
1
602
601
601
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
FUR6
FUR
FLAMEf
FUR
FUR
FUR
DIST8
FUR,
cv11
FUR
FUR
FUR
C-16
-------
DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued)
Detection EPA
PRIORITY POLLUTANT3 Level (ug/L) Method
124. thallium (total) 10 FUR
125. zinc (total) 1 FUR
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) 0.003
This numbering does not correspond with numbers on EPA's list of pri-
ority pollutants.
No detection limit determined.
*%
Flame ionization detection (FID).
High pressure liquid chromatography (HPLC).
6 Furnace (FUR).
f Flame (FLAME).
g Distillation (DIST).
Cold vapor (CV).
Source: "Methods for Organic Chemical Analysis of Municipal and Industrial
Wastewater," Environmental Monitoring and Support Laboratory,
Cincinnati, OH 45268. EPA-600/4-82-057. July 1982.
Table C.4 lists the analytical methods and appropriate detection
limits for the EPA priority pollutants. The information contained in
"Methods for Organic Chemical Analysis of Municipal and Industrial
Wastewater" represents an effort to provide procedures that are as
uniform and cost effective as practical for a wide cross-section of
chemical compound classes. Due to the variable chemical and physical
properties of the parameters, some compromises had to be made.
Therefore, in some of the methods, the extraction procedures, cleanup
procedures and determinative steps are not optimum for all param-
eters.
C-17
U . S . GOVERNMENT PRINTING OFFICEi 1983-421-545/3078
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