903R91050
Targeted Permit Oversight
EPA Region III
General Permits Section
Francisco Cruz
Leo Essenthler
Larry Liu
Rich Palste
Kathleen Stager
Dan Sweeney
Dale Wlsmer
PA/DC Permits Section
Elaine Harbold
Thomas Henry
Victoria (off
Robert Koroncal
Kevin Magerr
Krlstlne Matzko
Ray Mlhallovlch
Alexander Sllnsky
Augusts, 1991
TD
223.1
.T37
1991
U.S. EPA Region III
Regional Center for Environmental
Information
1650 Arch Street (3PM52)
Philadelphia, PA 19103
-------
Regional Center foi hn\in)rimt.'nt
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TARGETED PERMIT OVERSIGHT
U.S. EPA Region III .
Regional Center for Ermronme
EPA REGION III
Philadelphia, PA 19103
* INTRODUCTION
This project examined the problem of regional oversight of all major permits issued by
- delegated states in Region 3. The analysis for Pennsylvania was conducted by the
Pennsylvania team and the analysis for all other delegated states was conducted by the
General Permit team. While the analytical procedures used for all states were the same, the
conclusions on which permits to target for review were different. This difference can mostly
be attributed to differences in state programs. Specifically, Pennsylvania has a well defined,
comprehensive chemical specific program whereas Pennsylvania has a minimal biomonitoring
program as compared to other states. A thorough description of the approach, data,
analysis, and recommendations is provided for Pennsylvania. Since the procedures used for
• the others states are similar, only summary data analysis and recommendations are provided
after the complete analysis is presented for Pennsylvania.
t
BACKGROUND
The five states in Region III were delegated the NPDES permit program between 1974 and
* 1982. Thus, EPA has been reviewing draft permits issued by each state in the Region for
a minimum of 9 years as required by 40 CFR 123.24(d) which necessitates review of all draft
permits in the following categories:
•
(1) Discharges into the territorial sea;
-------
(2) Discharges which may affect the waters of a State other than the one in which the
discharge originates;
(3) Discharges proposed to be regulated by general permits (see 122.28);
(4) Discharges from publicly owned treatment works with a daily average discharge
exceeding 1 million gallons per day;
(5) Discharges of uncontaminated cooling water with a daily average discharge
exceeding 500 million gallons per day;
(6) Discharges from any major discharger or from any discharger within any of the
21 industrial categories listed in Appendix A to Part 122;
(7) Discharges from other sources with a daily average discharge exceeding 0.5 (one-
half) million gallons per day, except that EPA review of permits for discharges of
non-process wastewater may be waived regardless of flow.
This requirement is further defined in 40 CFR 123.44 requiring EPA to make general
comments upon, objections to, or recommendations with respect to state proposed permits
as noted above.
While such intensive oversight was necessary for some time after delegation, it stands
to reason that such oversight should be reduced as a state demonstrates competence in
implementing the permit issuance program.
The question for FY '91, is the same level of oversight necessary in light of recent
data?
-------
DATA
In order to determine the effectiveness of EPA Region Ill's effort in overviewing
states' NPDES permit issuance programs, a careful analysis was performed of all permit
reviews completed in FY'89 and '90. The effectiveness of EPA's oversight can be
characterized through the following measures:
(1) Total number of permit reviews;
(2) Total number of permits reviews generating comments;
(3) Total number of comments and permit reviews resulting in state action either by
modification or explanation of the original draft;
(4) Total number of comments and permit reviews resulting in state action and
environmental benefit as determined by Section consensus. Environmental benefit
is broadly defined as a decrease in pounds of pollutant discharged.
A listing of all permits reviewed in FY '89 and '90 by the PA/DC Section with and
without comments divided into Industrial, Municipal, and Federal Facilities categories is
included as Attachment No. 1. For Pennsylvania, verbal as well as written comments were
included in the analysis. Additionally, it was assumed that, in the case of permits not issued
at the time of this review, the state would incorporate EPA's comments in certain areas
which historically were always included. For example, the State of Pennsylvania always
considers all of EPA's comments on pretreatment, most likely because the program is not
delegated; therefore, it was assumed that all comments concerning pretreatment would result
in modification of the original drafts before issuance of the final permit. The results of this
data analysis are represented in Table 1 and in Figures 1 and 2.
-------
It is important to note that almost half of all permit reviews (45%) generated no
comments whatsoever. 35% generated environmentally significant comments, while only
21% of permit reviews generated significant comments that were included in the final permit
by the state.
Figure 1 is a classic Pareto relationship: 100% of our effort yielded only 20% of its
intended benefit.
The question now becomes: How can we best direct our efforts to maximize benefit
to the environment?
-------
TABLE I
State of Pennsylvania
Permit Review of Summary for FY '89 and '90
Total Permits Reviewed - 156
Total Permit Reviews Generating
No Comment - 70
Comments in FY '89 and '90
Limit Added
Explain WQ
Limit Derivation
Modify Analytical
Methods
Intern. Mon. Pt.
0
0
State
Action and
Category
Sludge
304(L)
Biomonitoring
Pretreatment
cso
Non-304(l)
Toxics Policy
Include Non-
detect language
in Pt. C of Permit
Tighten Limit
Add Limit
Fecal Coliform
Total
Comments
24
22
15
12
2
14
10
8
5
5
State
Action
24
22
1
12
1
0
10
8
5
5
Environmentally
Significant
0
4
15
12
1
14
0
8
5
0
Environmenta
Significant
0
4
1
12
1
0
0
8
5
0
0
0
0
0
-------
Comments in FY'89 and '90 (Con't)
Total State
Comments Action
State
Action and
Environmentally Environmentally
Significant Significant
Redirect Flow to Main 1
Treatment Plant
Model Rerun 1
Separate Organic 1
Limit Into Isomers
Include WQ Limits 1
for Non-detectable
Toxic Review 1
Fish Tissue Sampling 1
Specify IWC 1
Metal Finishing
Guidelines 1
Confusing Footnotes 1
1
1
1
1
0
0
1
1
1
1
1
0
0
0
1
0
0
0
1
1
0
0
0
0
0
0
0
TOTALS
132
99*
64
**
33'
* Multiple comments possible in one permit review
** Resulted from 55 separate permit reviews
*** Resulted from 32 separate permit reviews
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ANALYSIS
The most effective use of EPA's permit review time from the summaries above is in
the oversight of permits requiring pretreatment. 12 out of 33 environmentally beneficial
comments acted upon by the state were in this category. The comments requested the state
to modify the pretreatment special condition in the permits to make the pretreatment
program more enforceable by requiring local limits reevaluation, development of an
Enforcement Response Plan, and yearly monitoring. The repetition of this comment to the
State can be seen as a problem in the issuance process; the state is unaware of the latest
language approved by EPA to implement the pretreatment program.
Let us consider the next category with the most repetitive comment, sludge. 24
permit reviews resulted in the suggestion that the following special condition be included:
"Slurries, sludges, and other solids shall be handled and disposed of in compliance with 25
PA Code, Chapter 75, 40CFR 257, and Section 405 (d)(4) of the Clean Water Act and its
amendments." Although incorporated by the state, it was thought that the comment was too
general to be environmental significant; compliance with 25 PA Code, Chapter 75 is already
anticipated and there is no way to determine compliance through NPDES. However, that
the state needed to be reminded to include sludge language indicates an emerging process
problem. As federal sludge regulations are promulgated, much more specific special
conditions with definitive environmental significance will be necessary.
There were 15 comments made concerning the need for whole effluent biomonitoring
requirements to be placed in permits. All were considered environmentally significant,
although the state included only 1 such requirement in the final permit. The difficulties
-------
experienced in attempting to initiate whole effluent biomonitoring for toxics control in
Pennsylvania are well documented. FY'91 will mark concerted efforts by the region to
involve the state in this approach to toxics monitoring. Questions of funding, manpower,
laboratory availability, central office management decisions, regional office personnel
training, and additional toxicity data collection must be answered. This is both a process and
an implementation problem.
The 304(L) effort is reflected in a variety of 22 comments, most of which were
administrative in nature approving the format of the permit, or questioning the state
concerning scheduled effective dates for pollutants of concern. These comments were the
result of process modifications to implement 304(L).
Certain comments were obviously amendable to process modifications as soon as the
analysis was completed. For example the non-304(L) toxics policy and non-detection
language (to specify analytical methods for minimum detection levels) together accounted
for a total of 24 comments. These comments were all generated in one Region
(Williamsport) due to start-up problems with aspects of the non-304(L) toxics policy and all
were related to process concerns. This region, since being advised, will take our comments
into consideration in all future permits. Draft permits which have been reviewed since this
region was advised have indciated compliance with our comments.
Additionally, utilization of the permit prep package, a computer driven aid to NPDES
permit writers in the State of Pennsylvania, will help to eliminate most of the comments
made to tighten or include new limitations in permits. Many of these comments resulted
from typographical errors or incorrect interpretation of a water quality model.
The results of this data analysis after process improvements can be seen in Figure 3,
-------
which describes targeted review. From this figure it can be seen that if we focus our reviews
on the first 5 permit review areas only [sludge, 304(L), biomonitoring, pretreatment and
CSO], we will risk not making environmentally significant comments for only 6% of all
permit reviews. This is clear when Figures 1 and 3 are considered simultaneously. Out of
156 total permit reviews from Figure 1, we will, by reviewing the 5 categories above, only
risk not making approximately 10 environmentally significant comments from Figure 3
representative of implementation variability which process improvements cannot correct.
PROPOSED SOLUTION
From this analysis it is apparent that the most expeditious way to direct regional
manpower to benefit the environment regarding permit review is through targeting such
reviews. The data suggests that only permits involving new or changing initiatives should be
reviewed by regional staff. This includes all permits related to pretreatment, sludge,
combined sewer overflows, 304(L), and biomonitoring. All permits to be issued in these
categories can be readily identified before submission to the region.
It is important to note that we will be performing reviews of a predetermined portion
of the targeted permits (only CSO or pretreatment language, for example) to obtain a clear
understanding of how much time will be saved while at least 94% of the environmental
benefit achieved through total review is preserved. Even estimating generously , targeted
review will take only 20% of the present level of effort necessary for total review. This
translates to a savings of 1 FTE in the PA/DC Permits Section every year that targeted
review procedures are utilized.
The trade off is obvious: 80% of saved effort can be reinvested in other more
-------
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8
pressing environmental initiatives, such as biomonitoring, stormwater, sludge, CSO's,
pollution prevention, and even additional Total Quality Improvement projects with minimal
loss of environmental benefit from total permit review, approximately 6%. The relationship
in resource savings and environmental benefit is demonstrated in Figure 3A.
FORCE-FIELD ANALYSIS
A force-field analysis was completed and is represented in Figure 4. The major factor
to be noted is that the environment benefits primarily from the use of targeted oversight.
Cynthia Dougherty of HQ unofficially approved of a targeted approach, indicating that other
EPA regions are already employing some variation of this approach. It has already been
demonstrated that regional staff will have considerable additional time for more pressing
environmental initiatives by targeting permit reviews.
As noted above however, CFR 123.24(d) now requires review of all major draft
permits. Environmental groups could become a problem if they interpret targeted review
as opposing existing regulations. Given proper background and understanding of the
benefits of targeted review, they will see where the greater benefit lies.
PRESENT STATUS
As of this date, Headquarters, Divisional, and PADER approval have all been
obtained. The PA/DC Permits Section has implemented targeted oversight as proposed in
this paper.
It is the State's desire to continue forwarding all draft permits to EPA for review as
agreed to in the State/EPA Memorandum of Agreement based on CFR 123.24(d) The
-------
-------
'I CURE 4
FORCE-FIELD ANALYSIS
TOTAL PERMIT REVIEW
TARGETED PERMIT REVIEW
DRIVING-FORCES
RESTRAINING FORCES
Jan 91 Proposed Regs CFR 123.24d
Public, Environmental Groups
>
- Given proper background to see
more benefit to the environment
Environment
States
>
Headquarters (Unofficial)
>
Staff
>
- Allows us to concentrate on
upcoming initiatives of more
immediate benefit to the
environment, such as pollution
prevention, stormwater, sludge.
Current Regulations CFR 123.24d
Public, Environmental Groups
- If it is their opinion that EPA
must do total review, according
to the regs as written today.
-------
PA/DC Permits Section will forward a no comment letter on all non-targeted draft permits
received for review. For FY'91, the PA/DC Permits Section will only review and comment
on targeted portions of permits identified on the coded list (Attachment 2).
As problems are found in targeted permit areas in the future, we will involve the state
more closely in the process of developing correct permit language to address targeted
concerns.
Our goal through this process is the eventual elimination of the need for any permit
oversight, targeted or otherwise.
MONITOR
At the beginning of the fourth quarter of FV92, an appropriate number and types
of issued permits, depending on what the state has issued, will be selected for EPA review
using the attached checklist (Attachment 3). The results of this review will determine if any
modification is necessary to improve the process, the date for the next permit review and
if targets should be added or deleted. Our goal here is to minimize problems in state issued
permits with a minimum level of effort in reviewing permits by regional staff since it has
been determined that the greatest environmental benefit does not result from mass
inspection of state draft permits.
Our ultimate goal is the elimination of the need for any permit review in the State
of Pennsylvania through the use of process controls.
-------
10
OTHER DELEGATED STATES
Similar to the Pennsylvania evaluations, an analysis was made of major permits
reviewed in Delaware, Maryland, Virginia, and West Virginia covering the two-year period
in Fiscal Years '89 and '90. During that time frame, 239 permits were reviewed by EPA
Region III. Tables 2 through 5 and Figure 5 summarize the results of these permit reviews.
Figure 6 is a Pareto chart showing the kinds of comments generated for the four
states. An evaluation of the data shows that a large portion of the comments relate to the
toxics aspect of NPDES permit limitations. In Figure 6 the categories of 304(L),
Biomonitoring, Monitoring, Add Limit, Compliance Date, and Tighten Limit account for 91
of 111 comments generated, and are considered directly related to the toxics programs. The
Combined Sewer Overflow (CSO) Control Program also generated a significant number of
comments (14). There were two cases where effluent guidelines interpretations were
addressed and both of those dealt with the Organic Chemicals, Plastics, and Synthetic Fibers
(OCPSF) industry. Two comments addressed the pretreatment program which is now fully
delegated in Maryland, Virginia and West Virginia.
CONCLUSIONS
The targeted permit review approach for the four states other than Pennsylvania will
be limited in scope because all permits must be reviewed regarding water quality-based
concerns where the vast majority of comments were generated. The exception is the
technology-based requirements for municipal and industrial permits, i.e. secondary treatment
for municipals and effluent guidelines-based requirements for industrials. However, since
the OCPSF effluent guidelines are relatively new and complex and problems were
encountered as a result of EPA reviews, draft permits involving these guidelines must still
-------
11
be reviewed by EPA. Therefore, EPA should continue to review all major permits, but the
reviews will focus on all aspects except the non-OCPSF technology-based requirements. The
targeted reviews in the four states will achieve a 23 percent savings of EPA permit review
resources by eliminating the technology-based portions (See Figure 7).
Targeted review may be expanded in one or more of the four states during FY '92
as each of these states establishes regulations and EPA approved programs for the control
of toxic pollutants. Figure 8 shows a resource savings of 87 percent if water quality-based
reviews were not required for all permits.
FOLLOW-UP ACTIONS RECOMMENDED
1. During the remainder of FY'91, eliminate the review of technology-based aspects of
municipal and industrials permits except for the application of OCPSF regulations.
2. Once each state finalizes their toxics regulations and procedures, EPA Region III will
consider further targeting based on a track record of implementation.
3. Initially, permit reviews (utilizing Attachment 3) will be conducted of a representative
sample of major permits issued during the 12 month period of targeted reviews. The
reviews will be continued periodically at intervals deemed appropriate by EPA. The decision
on continuing permit reviews periodically will be greatly influenced by the results of the
initial review.
4. The goal of targeted oversight is to eliminate areas of concern for permit review,
while concentrating on the remaining environmentally critical areas. Process controls will
be utilized to maximize environmental benefit from any targeted review performed by
regional staff.
-------
12
5. The ultimate goal of the targeted approach and permit review monitoring is to
eliminate all permit review by regional personnel through process modifications thereby
allowing us to turn our attention to more pressing and rewarding environmental initiatives.
-------
TABLE 2
DELAWARE
TOTAL PERMITS REVIEWED-20
State Action and
Total
Category Comments
Sludge
cso
Biomonitoring
WET Limit
Pretreatment
ICS (304L)
Limit
Modification
Add Limit
Biocide
Compliance Date
Monitoring
OCPSF
0
0
0
0
0
7
3
0
0
0
6
0
State
Action
0
0
0
0
0
7
3
0
0
0
4
0
Environmentally Environmental!
Significant Significant
0
0
0
0
0
7
2
0
0
0
5
0
0
0
0
0
0
7
2
0
0
0
3
0
TOTAL
16
14
14
12
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TABLE 3
MARYLAND
TOTAL PERMITS REVIEWED-45
State Action and
Total
Category Comments
Sludge 1
CSO 0
Biomonitoring 12
WET Limit 0
Pretreatment 0
ICS (304L) 12
Limit
Modification 1
Add Limit 0
Biocide 0
Compliance Date 0
Monitoring 0
OCPSF 0
State
Action
1
0
12
0
0
12
1
0
0
0
0
0
Environmentally
Significant
1
0
12
0
0
12
1
0
0
0
0
0
Environment*
Significant
1
0
12
0
0
12
1
0
0
0
0
0
TOTALS
26
26
26
26
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TABLE 4
VIRGINIA
TOTAL PERMITS RE VIEWED-104
State Action and
Total State Environmentally Environmentally
ft Category Comments Action Significant Significant
Sludge
cso
Biomonitoring
WET Limit
Pretreatment
ICS (304L)
Limit
Modification
Add Limit
Biocide
Compliance Date
Monitoring
OCPSF
TOTALS
0
1
2
2
1
13
1
8
1
5
0
0
34
0
1
2
2
1
13
1
8
1
3
0
0
32
0
1
1
2
1
13
1
8
1
3
0
0
31
0
1
1
2
1
13
1
8
1
3
0
0
31
-------
TABLES
WEST VIRGINIA
TOTAL PERMITS REVIEWED-77
State Action and
Total State Environmentally Environmentally
Category Comments Action Significant Significant
ft
ft
ft
ft
•
Sludge
cso
Biomonitoring
WET Limit
Pretreatment
ICS (304L)
Limit
Modification
Add Limit
Biocide
Compliance Data
Monitoring
OCPSF
0
13
8
4
1
2
0
0
0
1
4
2
0 0
0 2
5 8
0 4
1 1
1 1
0 0
0 0
0 0
1 1
2 4
0 1
0
0
5
0
1
1
0
0
0
1
2
0
TOTALS 35 10 22 10
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ATTACHMENT NO. 1
FY '89 MUNICIPAL PERMIT REVIEWS GENERATING COMMENTS
PA0020290
Quakertown Borough Mun. Treatment Plant
A. ICS administrative
PA0025950
Monongahela STP
A. Sludge language
B. Sludge survey questions
PA0026468
Lower Bucks County Joint Municipal Authority
A. Include pretreatment program as requirement
PA0026476
Coaldale-Lansford-Summit Hill
A. Sludge language
B. CSO language
PA0026492
Scranton Sewer Authority
A. Biomonitoring
B. Sludge language
C. Sludge survey
D. -I-A Toxic Review
PA0026531
Downingtown Area Regional Authority
A. Develop permit limits for total trihalomethane and total halomethane
B. Put limitations in Pt. C.
PA0026581
Westmoreland-Fazette Municipal Sewage Authority
A. Sludge language
PA0026701
Morrisville Borough Municipal Authority
A. Sludge language
PA0026751
Indiana Borough
A. Sludge language
B. Sludge survey questions
-------
PA0026883
Ciry o>r Beaver Falls
A. Sludge language
PA0026921
Greater Hazleton Joint Sewer Authority
A. Sludge language
B. Sludge survey questions
C. CSO-the combined sewer overflows should be included in DER's CSO Strategy
PA0027316
City of Lebanon
A. Biomonitoring
PA0029017
Schuylkill Haven
A. Sludge language
B. Sludge survey questions
C. Pretreatment language
PA0035360
Holiday Park STP
A. Sludge language
B. Sludge survey questions
PA0043729
Allison Park STP
A. Sludge language
B. Sludge survey questions
Total 15
-------
FY '89 INDUSTRIAL PERMIT REVIEWS GENERATING COMMENTS
PA002143
Penntech Papers, Inc.
A. 0.02 ppq limit for dioxin in Part A
B. More sensitive analytical procedure in Pt. C.
C. Fish tissue sampling
D. Specify IWC in Pt. C.
PA0003239
Babcock and Wilcox Co.
A. ICS administrative
PA0004073
U. S. Steel-Irwin Works
A. ICS administrative
PA0004472
USS Div. of USX Corp.
A. ICS administrative
PA0005037
Penelec Homer City
A. ICS administrative
PA0005754
J&L Specialty Products Corp.
A. ICS administrative
PA0006467
Youngwood Electronic Metals
A. Biomonitoring
PA0007625
Hedstrom Co.
A. ICS administrative
B. Tighten total chromium limit to 2.44 mg/1, technical limit more stringent than
W.Q.
PA0008923
Corning Glass Works, State College
A. Biomonitoring
-------
PA0010782
Met Ed-Titus
A. Include water quality standard for temperature
PA0022047
Crompton & Knowles Corp.
A. ICS administrative
B. Biomonitoring
PA0094510
USS, Div. of USX Corp.
A. ICS administrative
Total 12
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FY '90 MUNICIPAL PERMIT REVIEWS GENERATING COMMENTS
PA0020273
Milton Municipal Authority
A. Suspended Solids 110 mg/1 to 100 mg/1 (typo)
B. Non-304(l) toxics policy
C. Non-detect language
PA0020460
Pennridge Authority
A. Pretreatment language
PA0020486
Bellefonte Borough
A. Non-304(l) toxics policy
PA0020621
Waynesboro Borough Authority
A. Include footnote on fecal coliform limit
PA0021661
Mars Borough
A. Confusing footnote references
PA0021687
Wellsboro Municipal Authority
A. Non-304(l) toxics policy
B. Non-detect language
PA0023043
North East Bord
A. water quality based effluent limitation needed in Pt. C.
PA0024068
Kennett Square Boro
A. Pretreatment language
B. Biomonitoring
PA0025933
City of Lock Haven
A. Biomonitoring
B. Non-304(l) toxics policy
C. Non-detect language
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PA0026000
Allentown City Authority
A. Pretreatment language
PA0026191
Huntington Boro
A. Include footnote on fecal coliform limit
PA0026239
University Area Joint Authority
A. Non-304(l) toxics policy
PA0026247
Hatfield Twp. Mun. Auth.
A. Explanation of 304(1) pollutant removal
PA0026263
York City WWTP
A. Explanation of 304(1) pollutant removal
PA0026361
Lower Lackawanna Valley Sanitary Authority
A. Pretreatment language
B. Sludge
C. Biomonitbring
PA0026387
Saint Mary's Borough Mun. Auth.
A. Explain elimination of 304(1) pollutant
PA0026492
Scranton Sewer Auth.
A. Include footnote in fecal coliform limit
PA0026549
Reading City
A. Correct schedule dates
B. Include WQ limits for non-detectable
C. Tighten silver limit by 2 ug/1 in accordance with WQ model
PA0026662
City of Philadelphia, S. E. Plant
A. Sludge language
B. Pretreatment
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PA0026671
City of Philadelphia, S.W. Plant
A. Sludge language
B. Pretreatment language
PA0026689
City of Philadelphia, N.E. Plant
A. Sludge language
B. Pretreatment language
PA0026786
Pottstown Boro Council, WWTP
A. Pretreatment language
PA0026972
Exeter Twp WWTP
A. Pretreatment language
PA0026808
Springettsbury Twp. S.A.
A. Include WQ limit for nickel
PA0027049
Williamsport San. Auth.
A. Non-304(l) toxics policy
B. Biomonitoring
C. Non-detect language
PA0027057
Williamsport San. 'Auth.
A. Non-304(l) toxics policy
B. Biomonitoring
C. Non-detect language
PA0027073
Lackawanna River Basin Sewer Auth.
A. Sludge language
B. Biomonitoring
C. Schedule correction
PA0027090
Lackawanna River Basin Sewer Authority
Throop STP
A. Biomonitoring
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PA0027405
Ephrata Borough WWTP
A. Internal Monitoring point needed
PA0027553
Pine Creek Mun. Auth.
A. Non-304(l) toxics policy
B. Non-detect language
PA0028576
Clarks Summit-South Abington Joint
A. Sludge language
B. Schedule correction
PA0028681
Kelly Twp. Mun. Auth.
A. Non-304(l) toxics policy
B. Non-detect language
C. Biomonitoring
PA00371SO
Perm Twp. STP
A. Include footnote on fecal coliform limit
PA0038482
Fox Twp.
A. Instantaneous max. for chloroform 0.002 mg/1, not 0.003 mg/1
PA0043257
New Freedom WVYTP
A. Include footnote on fecal coliform limit
r
t
PA0044661
Lewisburg Area Joint Sewer Auth.
A. Non-304(l) toxics policy
B. Non-detect language
PA0051624
Square D. Co.
A. Pretreatment language
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PA0060089
Fernwood STP
A. Add Chlorine limit
Total 38
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FY '90 INDUSTRIAL PERMIT REVIEWS GENERATING COMMENTS
PA0001201
Powerex, Inc.
A. Explanation of removal of TCE from 304(1) pollutant list
PA0001627
Duquesne Light Co.
A. Non-detect language
PA0005975
St. Mary's Carbon Co., Inc.
A. Explain eliminated 304(1) parameter
PA0006254
Arco Chemical Co.
A. Backsliding - Mercury "monitoring only" to 0.0015 mg/1
PA0006378
Cyclops Corp.
A. Explain WQ limit derivation
PA0007510
International Paper Co.
A. Non-304(l) toxics policy
PA0008443
Pennsylvania Power and Light Co.
Montour Steam Electric Station
A. Non-304(l) toxics policy
B. Non-detect language
PA0008800
Westfield Tanning Co.
A. Minor schedule change for 304(1) limits effective date
PA0008869
PH Glatfelter CCK
A. Dioxin/Furan - more sensitive analytical method
PA0008923
Corning Asahi Video Products Co.
A. Non-304(l) toxics policy
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PA0009202
Cerro Metal Products Co.
A. Suspended solids - 110 to 100 mg/1 (typo)
B. Non-304(l) toxics policy
PAGO10031
Penelec
Shawmill Steam Elec. Station
A. Reroute pollutant stream in outlying outfall to main treatment plant when
pollutants detected
PA0011134
AT&T Technologies, Inc.
A. Biomonitoring
B. Include silver in TRE
PA0011762
American Nickeloid
A. Biomonitoring
B. Explanation of silver limit
PA0012751
Zinc Corp. of America
A. New application data not used in model
PA0013129
Carpenter Tech. Corp, Reading
A. Hex. chromium limit modified from 0.03 mg/1 to 0.014 mg/1 based on model
recalculation , .
PA0033367
Gunnison Brothers Tannery
A. Phenol limit, 16 mg/1 to 16 ug/1 (typo)
PA0044342
International Jensen
A. Explain WQ limit
PA0070S05
International Minerals and Chemicals
A. Include all 304(1) pollutants in TRE
Total: 19
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FY '90 FEDERAL FACILITY PERMIT REVIEWS GENERATING COMMENTS
PAGO10502
Letterkenny Army Depot
A. Separate organic pollutant limit into isomers
PA0010987
Tobyhanna Army Depot
A. Metal finishing guidelines needed
TOTAL: 2
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FY '89 MUNICIPAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0025976
PA0026018
PA0026107
PA0026182
PA0026239
PA0026450
PA0027031
PA0027146
PA0027235
PA0027383
PA0027618
PA0028380
PA0028584
PA0028801
PA0034576
PA0051934
PA0052167
PA0110582
Upper Moreland Hatboro Sewage
West Chester Borough Taylor
Wyoming Valley San. Auth.
Lansdale Sewage Treat. Plant
University Area Jt. Authority
Bristol Township
West Chester Borough
Ambridge Borough Municipal Auth.
Easton Area Joint Sewer Authority
South West Del. City Mun. Auth.
Bethel Park STP
Tinicum Township
West Goshen Sewage Treatment Plant
Montour Run Moon Twp.
Towanda Mun. Auth.
Limerick Twp Mun. Auth.
Wind Gap Mun. Auth.
Selinsgrove Mun. Auth.
TOTAL: 18
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FY '89 INDUSTRIAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0001554
PA0001716
PA0001791
PA0002054
PA0002372
PA0002925
PA0004481
PA0005011
PA0007137
PA0007510
PA0008419
PA0008451
PA0008664
PA0011363
PA0011631
PA0012963
PAOQ13463
Sharon Steel
FMC Corp.
GTE Sylvania Warren
Penelec Seward
Quaker State Oil
West Perm. Power
U.S. Steel-Homestead
Penelec Covenaugh
Season All Ind.
International Paper
Merck & Co.
PP&L Co. (Shamokin)
UGI Hunlock
NGK Metals
Phila. Elect. Cromby
Rock Term. Co.
USX Inc. Fairless
TOTAL: -17
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FY '90 MUNICIPAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0020168
PA0020664
PA0020893
PA0021580
PA0022535
PA0023108
PA0023124
PA0023256
PA0025976
PA0026034
PA0026042
PA0026085
PA0026557
PA0026794
PA0026859
PA0026964
PA0027065
PA0027081
PA0027090
PA0027669
PA0031127
PA0037290
PA0039004
PA0043729
PA0045985
PAOQ53147
East Stroudsburg Boro STP
Middletown WWTP
Manheim STP
Catasauqua Borough Authority
Millersburg Area Auth. STP
Elizabethtown Boro STP
Albion Borough
Upper Gwynedd Twp. Auth.
Upper Moreland-Hatboro Sewage
Johnstown City
Bethlehem Auth. WWTP
Upper Merion Twp. Auth.
Sunbury City Mun. Auth.
Conshohocken Boro Auth.
Coatsville Mun. Auth. STP
Montgomery County Sewer Auth.
Lackawanna River Basin Sewer Auth.
Strahbard STP
Clinton STP
Lackawanna River Basin Sewer Auth.
McCandless Twp. San. Auth.
Northampton Mun. WWTP
Wesland Development, Inc.
Upper Gwynedd
Towamencin Mun. Auth.
Hampton Twp.
Allison Park STP
Mountaintop Area WWTP
Upper Saucon Twp. Mun. Auth.
TOTAL: 26
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FY '90 INDUSTRIAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0010782
PA0011258
PA0033600
PA0034622
PA0044920
PA0047325
PA0091383
PA0103055
PA011183Q
Met Ed Titus
Cabot Corp./Kawecki Berylco Div.
James Austin Co.
Ajax/Acom Manufacturing, Inc.
Lehighton Electronics, Inc.
PA Power and Light Co.
Susquehanna
Paul Chrome Plating, Inc.
Custom Industrial Processing
Emporium Specialties Co.
TOTAL: 9
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ATTACHMENT NO. 2
STATE OF PENNSYLVANIA
TARGETED PERMITS
FOR REVIEW
FY'91
(Some Previously Issued)
SOUTHEAST REGIONAL OFFICE
U. S. Steel
Hatfield Twp. Municipal Authority
Abington Twp.
East Norriton-Plymouth Joint Authority
White Marsh Twp. Authority
Norristown Borough
Ambler Borough (South)
Upper Merion (Trout Creek)
WILKES-BARRE
Honesdale Borough
Borough of Stroudsburg
Cabot Corp.
The New Jersey Zinc Co., Inc.
Allentown City Authority
Bethlehem City (Bethlehem Authority)
Schuylkill Haven Borough
Scranton City S. Authority
LRBSA Throop Plant
Ashland Municipal Authority
Shenandoah Municipal S. Authority
HARRISBURG
Hollidaysburg WWTP
Tyrone Boro Sewer Authority
Lewistown Boro Municipal Authority
Huntingdon Water & S. A.
PA0013463 L
PA0026247 L
PA0026867 B
PA0026816 P.S.B
PA0026298 B
PA0027421 P.S.B
PA0026603 P.S.B
PA0026131 P.S.B
PA0023469 C
PA0029289 C
PA0011258L
PA0012751 L
PA0026000 L.P.S
PA0026042 P,S
PA0029017 B
PA0026492 L.C.P.S
PA0027090 L,C,P,S
PA0023558 C
PA0070386 C
PA0043273 C,B
PA0026727 P.S.B
PA0026280 B
PA0026191 L,C
(See Page 3 for Codes)
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Lowengart and Co. - Mercerburg
NGK Metals Corp.
Carpenter Tech. Corp.
Carlisle Bor. S. S. Authority
Letterkenny Army Depot
Highspire Boro STP
Hanover, Boro of
Manheim Boro Authority
Springettsbury Twp.
York City Sewer Authority
P. H. Glatfelter Co.
Penn Twp.
Lititz Sewer Authority
Millersville Borough
New Holland Boro Authority
WILUAMSPORT
Westfield Tanning Co.
Shamokin Coal Twp. Jt. S. A.
Clearfield Municipal Authority
Moshannon Valley Jt. S. A.
PITTSBURGH
Duquesne Light - Cheswick Power Station
Penn Hills Twp. Sandy Creek
Ebensburg Boro
Duquesne STP
McKeesport Water Pol Control
Jeannette City M. A.
Charleroi Boro Authority
Pigeon Creek Sanitary Authority STP
California Boro
Westinghouse Elec. - Semicord (POWEREX)
ARCO Chem. Co. Beaver Valley
Alcosan Waste Treatment Plant
Robinson Twp. - Campbells Run STP
Washington E. Wash. STP
PA0009521 L
PA0011363 L
PA0013129 L
PA0026077 P,S
PA0010502 L
PA0024040 B
PA0026875 P.S.B
PA0020893 L
PA0026808 L.P.S,
PA0026263 L.P.S
PA0008869 L
PA0037150 L.P.S
PA0020320 B
PA0026620 B
PA0021890 B
PA0008800 L
PA0027324 C.P.S
PA0026310 C
PA0037966 C
PA0001627 L
PA0026409 B
PA0022292 B
PA0026981 C
PA0026913 C.P.S
PA0027430 C
PA0026891 C
PA0044679 B
PA0022241 C
PA0001201 L
PA0006254 L
PA0025984 P.S.B
PA0036293 P.S.B
PA0026212 P.S.B
(See Page 3 for Codes)
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MEADVILLE
Gunnison Bro. Tannery PA0033367 L
Erie Sewer Authority PA0026301 C.P.S.B
Meadville, City of PA0026271 B
Conneaut Lake Jt. Mun. Auth. PA0021598 B
Titusville, City of PA0036650 C.P.S.B
Punxsutawney M. A. PA0020346 C.P.S
Ellwood City Boro PA0026832 C
Butler Area S. A. PA0026697 P,S
Codes:
L - 304(L)
C- CSO
P - Pretreatment
S - Sludge
B - Biomonitoring
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ATTACHMENT NO. 3
Permit #:
Facility name:
Reviewer:
Permit Expiration Date:
PERMIT QUALITY REVIEW CHECKLIST
I. ADMINISTRATIVE RECORDS
1. Does the permit file contain each of the following items?
Permit application and supporting data
Draft permit
Statement of Basis or Fact Sheet
All documents cited in Fact Sheet
All comments received during public comment
Transcripts and submissions from any hearing held
Responses to significant comments
Final permit
Explanation of changes from draft to final permit
Permit amendments or modifications
Indication of new source
Major/minor federal facility
II. PUBLIC NOTICE AND COMMENT
1. Was a public notice issued of the preparation of draft permit
and providing an opportunity for comment at least 30 days
prior to final permit decision? Was notice forwarded to all
necessary parties including permittee?
2. Was a public hearing held?
Was a notice of public hearing issued at least 30 days
prior to the hearing?
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3. Was a summary response to significant comments raised during
comment period and/or hearing prepared and issued at time of
final .permit decision?
III. PERMIT MODIFICATIONS
1. Does the permit documentation indicate that the permit was
modified or revoked and reissued?
What was the reason for the modification or reissuance
(40 CFR 122.62(a) and (b))?
Was the permit modification or reissuance put through
proper public notice?
IV. BOILERPLATE/SPECIAL CONDITIONS
1. Are the following general conditions incorporated into the
permit, either directly or by reference to 40 CFR Part 122.41?
(a) Duty to comply
(b) Duty to reapply
(c) Need to halt or reduce activity
(d) Duty to mitigate
(e) Proper operation and maintenance
(f) Permit actions
(g) Property rights
(h) Duty to provide information
(i) Inspection
(j) Monitoring and records
(k) Signatory requirements
(1) Reporting requirements
(m) Bypass
(n) Upset
(o) Penalties for violations
2. Are there other conditions that are included as part of the
boilerplate instead of being specified in another part of the
permit?
3. Are any special conditions requiring best management practices
(BMPs) included in the permit? Identify.
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4. Does the permit application indicate that there are
intermittent discharges at any outfall? Are these addressed
in the permit?
A. INDUSTRIAL PERMITS
1. Does the permit include any limitations or conditions for
internal waste streams? Describe.
2. Are limitations for all pollutants discharged expressed
as both maximum daily and average monthly values.
B. MUNICIPAL PERMITS
1. Are septage haulers or other "mobile source" dischargers
addressed in the permit?
2. Are flow limits contained in the permit?
3. Is inflow/infiltration correction addressed?
4. Are sewage sludge requirements (Section 405) included?
5. Are limitations for all pollutants discharged expressed
as weekly and monthly daily averages.
6. Is whole effluent biomonitoring included in the
application for municipal facilities with flow greater
than 1.0 mgd?
V. PERMIT LIMITS
1. Have a set of permit limits been included in the permit for
every outfall?
2. Are all limits at least as stringent as in previous permit.
If limits are less stringent in new permit, does it meet new
EPA backsliding requirements?
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3. Complete the chart for each pollutant parameter with specific
limits:
Pollutant
Basis of Limit
(Water Quality-Based)
State
EPA
Narrative
(Tech-Based)
BAT
BPT
BPJ
Sec.Trt.
Other
4. Are there parameters for which limits (or monitoring) are not
required, but which might be appropriate to limit (or
monitor)?
5. Is it clear whether daily maximum and/or daily average limits
will be enforced if monitoring is once a month? Is monitoring
frequency adequate to judge compliance?
6. If batch discharged, are limitations expressed in appropriate
terms, max. daily, average monthly, concentration, loading.
7. Does the permit contain seasonal
limitations justified?
limits?
Are these
A. INDUSTRIAL PERMITS
1. Were appropriate effluent guideline limitations used as
a basis for permit effluent limitations?
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Are all pollutant limitations in the applicable
guidelines included in the permit?
2. Are applicable effluent guideline limitations based on
production?
Was production basis in the permit a reasonable
measure of average actual production? (See form 2C,
items III-B and C.) Specify the production basis.
• Have alternate permit limitations been included to
address different production levels? Specify the
number of tiers of limits.
3. Is a BPJ analysis used as a basis for permit limitations?
Which of the following sources were used in
establishing any BPJ limitations?
Promulgated guidelines (Technology Transfer)
Proposed guidelines
Development document
Treatability manual
Treatability data base
Past facility performance (DMR data)
Other
What method was used to establish BPJ/BCT for
conventional pollutants?
B. MUNICIPAL PERMITS
1. Were secondary treatment limitations adjusted (for BOD
or SS) because of industrial contributions? Was it
appropriate and correctly computed (Special consideration
40 CFR 133.103(8))?
2. List any pollutants limited by mass or concentration that
should have been listed in the other form (i.e. secondary
limits expressed as concentration).
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VI. WATER QUALITY-BASED PERMITTING
1. What is the source of facility intake water (ground water,
municipal water supply, receiving stream)?
2. What is the Instream Waste Concentration (IWC) or dilution
factor?
3. Why does this permit have water quality-based toxics control?
effluent toxicity screening
ambient stream monitoring results
inspection
DMR data
304(1) listed receiving water
other
4. What type of water quality limitation is stated in the permit
(narrative, numerical, or both)?
5. Does the permit (fact sheet) document that water quality based
limitations are at least as stringent as technology-based
limitations (industries) or secondary treatment regulations
(POTWs)?
6. Have all applicable water quality standards been clearly
identified? Have all such criteria been correctly utilized
in determining effluent limitations? (Both numerical and
narrative)
7. What is the designated water use or classification of
receiving stream? (Is stream utilized as drinking water?
Nearest intake?)
8. Have huatan health concerns been considered or specifically
used in determining limits?
9. In what terms are whole effluent toxicity (WET) limits
expressed (in toxic units, as a 96 hour LC50, etc)?
-------
10. Identify toxicity testing methods:
Type (acute /chronic, flow through/static):
Species (Ceriodaphnia, fathead minnow):
Duration (7 day, 96 hour):
11. Was EPA criteria for toxic units used (0.3 acute and 1.0
chronic toxic units)? Were both acute and chronic criteria
used?
12. Was a mixing zone concept used for this permit?
Is it a complete mixing zone? Where do the toxicity
limits apply?
• How were the mixing zones determined (dye studies,
desktop calculations, or others)?
13. Are toxicity Identification Evaluations (TIEs) and/or Toxicity
Reduction Evaluations (TREs) required? Describe briefly.
Does TRE include appropriate completion date?
Is follow-up toxicity testing required after the TRE?
14. For this permit, was wasteload allocation (WLA) modeling [more
detailed than dilution calculations] for toxicity performed?
What type of model was used to perform the WLA (Steady
state, dynamic, or other)? Describe the type of
calculation(s) used.
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What mechanisms or sources of data were used for WLA
modeling?
application form information
DMRs
308 letters
administrative orders
intensive stream survey
other (explain)
15. What stream design flow is specified? Is this a seasonal
flow?
16. Was non-point source contribution estimated? How?
17. Were the impacts of other major dischargers (multiple
discharges) taken into account in determining the WLA? How?
18. Were contributions of toxicants to overlying water from
sediments included in the assessment? How?
VII. DISCHARGE SAMPLING
1. Does the permit require monitoring for every pollutant for
which limitations are included in the permit? Are effluent
sampling frequencies specified for every pollutant?
2. Does the permit require monitoring the volume of effluent
discharged from the outfall? If not, is an explanation (in
the fact sheet) provided?
VIII.DISCHARGE REPORTING
1. Are there any pollutants for which discharge monitoring
reports are not required at lease once a year? Specify
discharge reporting frequency required in the permit.
2. Is reporting on discharge monitoring report (DMR) forms
required?
3. Have the water quality-based limits associated with this
permit been entered into the PCS database? If no, why not?
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IX. COMPLIANCE AND ENFORCEMENT
1. Does the permit include a compliance schedule for each outfall
which is not in compliance with the limitations specified in
the pejrmit? If not, is an explanation provided? Construction
grants schedules included for POTW's?
2. Have any enforcement actions been taken? If yes, briefly
describe the nature and dates of the actions. Any minor
compliance problems?
X. SPECIAL CONDITIONS
1. Pretreatment
2. Sludge
3. Combined Sewer Overflow
4. Non-304(1) toxics policy (PA)
5. Non-detection language (PA)
6. Other
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