U.S. EPA NPDES Basic Permit Writers' Course Workbook 1992

t limitations must bt applied in all new. modified and reissued Federti and State NPDES permits except to the ex:cm '..-.at variances an txpnssiy author.ied. Other aspects of tht interaction between thest limitanont and SPDES permits are discussed below. Ont subject that has received different ludicial rulings is the scaac of SPDES permit proceeamgs wr.«n effluent limitanons and star.carci da not exist Undtr current EPA re«,u:a'.ons. State* and EPA refions that :»me SPDES permits befon refuittiom are promulgated muat estaoiish erf.uent limitations on a cast-by-casc ;as:t This regulation provides a ttchnica. a.-.a :ef al bast for ntw or modified or r«.u_ed permit*. Ont itsut that warrants cm :ert;ion is tht effect of this regulation :r -« powtn of NPOES permit-».-« authontita. EPA has devt:c:ec -* hmnations and sttnaarss .- - i ' -Q

-------
F»oerai Respster

V;i. *:. No. ::4 Th^cay

N':<.er-.:er 5.

isar

R-.es

j.-.a





concentrations luted above .n 5 414.43
for '-he metal pollutants times the flow
from mettl-beinrif wutt jtrttms for
rr.etals and times tht flow from eyamdt-
beanr.g waitt Jtreami for total cyanidt.
The metai-oeennf wistt streams and
cyaniae-bear.ng wastt itntmt art
Defined at tncse wutt streams luted ;n
Asptndix A sf this part pius any
sccisionai process wastewater streams
.centtfied by :ft« central authority on i
:ase-cy-cas« oas;s as me'.ai or :yan:oe
bearing based upon a determination—
  ;t) That such  siwams contain
significant amounts of tht pollutants
.denufied above .tnd that
  •:i The comoination of such streams.
pnor to treatment with the Appendix A
waste s.tre«ms will result :n suostanuai
reduction of these pollutant!.
This deiermmation must be based upon
a review gf relevant engineering.
production, and sampling and analysis
.r.formanon.

Sueoavt I— Olr»ct Dl»ch*rg« Point
Soure** That UM €nd-ol-Wpt>
          TrMtmtmt

                              of m*
                           point
•OUTCM flwt UM end-of -p
                                        4 6-Oirwo-0-«reso*
                                          amnaiatt
   242 ;
   U6
    38
    20

   140 '
    29
   2M !
    54
    54
    59 !
    $4 1
   2M<
    163 ;
    44
    28
    25

    £4
    '•2
    230
     36
    285
    541
    :C8
     68
    '57
     ?9
    •90
     «9
     59.'
     58
     *9  •
    •24
    •23
    Zff
     26
                                                                  57
                                                                 2C3
                                                                  47
                                                                  53
                                                                  51
                                                                       'Of
                                                                                                    2AT
                                                                                  •;ra»actensBc»
                                     Maximum
                                      'or arv
                                      -"• =**
                                                                               Vinyl
22
96
37
'8
66
15

21
21
22
21
  4
  1
  1

31
  5
 •6

21
39
153

29
 '9

255
 32
 25
3C'
 «Q
 36
 20
 22
 27
 41
 '2
 71
 •9
              103
               27
               81
               '9
               22
               23
                                                                               Total C»«r»dt.
                                                                               Tot* Lead	
                                                                                   I NCk«—
                                                                                   I Zinc'	
                                           13
                              57

                              50

                             ;s*
                            2.**9
                            3.:«c
                            i 200
                             590
                            3390
                            2.5*3
       ' Ail
       •Tot* ZJne  for
     tfat uMt 9m
                                                                               so>v«tt Broeeet • 8,790
     for
     for momny
                                                                                Subpart <
                           =c«f va.-u'a
                         yoeeu  trq  i
                         >«* •-« c^* :-'c
                           g./i ana 3 :;s
                           ;av ITQ
                  r*et 0*»cnar7« Point
     Sourca* That Do Not UM Eno-ef
     84o4oo>caJ Traatmant

     } 414.100
                of dlract dUcftar^c se«nt
             met 0e net us* en*-of*oiO*
         cwa trtttmtnt.
     bt
       The provisions of 'h:s s_;:a.-. i-?
     applicable to the process •A3s:e*a:t?.'
     discharges resulting frsn :.~.e
     manufacture of the OC?SF ;rtc-c:s
     product groups defined iy i *'.4 :: :':
     any point source that sees "t -se t-
     of-pipe biological treatment a.-c ;;es
     not .nstajl end-of-pipe :io^cs::a.
     treatment to comply witr. SPT r:T..er
     limitations.
                                                                                I 414.101   Toilc pollutant <
                                                                                limitation* and standard* 'or sifvet
                                                                                        i point sources mat 30 -01
  fa) Any point source 9
subpart must achieve i.
exceeding the quant.ty
determined by multiply:.-.
wastewater flow suciec:
!:rnes the concentrations
table.
  (b) In the case of chr:r
lead, nickel, zmc. and tc
discharge quantity ;rr.ass
determined by mu!t:?;> .-
concentrations ;.s:e2 n
tab.e  for  tnese roi'.-tj-.-s
                             .ass
                             ? •-• :•
                                  s •
                                                        4-10

-------
lUgiitg / Vol Sa No. 183 / Friday. September 20. 1968 / Riles and Regulations 3*343
S-e.
421JB Effluent HnritaBons guidelines
raprasaaBnf the degree of effluent
rtductioei attainable by (he application of
rtw b«t practicable control technology
currently available.
421J09 Effluent KmitaOoaa fuidaUaae
repmontinf the degree of effluent
raducaa* attainable by iht application of
tbe bMi available technology
•caaastcaDy achievable.
421J04 Standard! of performance for MW
421 MS PretreotttMnt standards tar existing
421 JOS PrtCTMUMBt standards for now
r Tungasen and
421J07 [Raeervedl.
421JIO Applicability: deecrlptioa of th«
Mcondary runanea aad cobalt
wbeiiofory.
421 Oil 9p«MliMd iteAaMaw.
421JU EfflMni linutttton* ftidtitam
npiMHiHat tba d»r*« of •fllMat
cvdncttoo (tUiiuM* by th« ippiidUoa^f
tiM bMi prwsBeibto OMtral iKhnoloor
a*tmttr miirtte.

npiiMBHin tho dffrtt of ifffcioMi
MduetlaB •ttMMbte by tho •ppteattoa of
btM cviulabl* Mchaotogy
421J14
Mcoodvy unnium i»beatt|ory.
42U21 SpocUUxod daftrtttoM.
421J22 CflluMt Umitattou foidoUM*
npuMOttat tbt dtfm of tfBwat
roducttoa •tuiubio by rt *QH
ANT-
4214M [»a»arv»d{.
421J30 PntTMtmesl (UndArda (or new
aawt "UP
MM I i»H
a«aaM i x< no
tt I r»
42L337 ^ Mam d].

Subpwtl
1421.140
provUiotu of thai tubpeut trt
applicabta to diKhuffM muitiot from
the produetion eftmioMay tt primary
antimony tacilitiet.

1421.141 tFirtatiiJd^WboM.
For tht pwpOM of tni» rabpavi the
(enaral definitiona, abonvUtktoa, and
method* of uulyiia u< forth ia 40 CFR
401 thail apply to this tubpart

1431.141 Effluent kMtttompMeatoe*
Except at provided in 40 CFR 123JO
through 123.32. any exiatinj point aource
rabriet to thii suopart thali achieve the
following effluent limitation!
rrpmvnting the degree of «£Quent •
reduction attainable by the application
of the best practicable control
technology currently available:
(a) Sodium Antimooitt Aatodava
BPT UMfTATKJNS R» TM PNHANV AlOtMONV
SOKATCOjOMV

MM
KM
ISM
««aae
• flSB
14 US
1M70B
I'l
« M • <0 0 w

(b) Fouled aaolyte.
»at »,j * >oa • M IB**

(c) Cathode Antimony Waah Water.

BPT LJWTATIONt fO* TMC PWMAWV ANTIMONY
SuKATCOOirr
24.0B8
jaio
r»
M eanp « 7 J » 104 • * I
1421.149 INIu
aftfimem
•uy
Except as provided in 40 CFR 125.30
through 125.32. any existing point source
subject to this subpan shall achieve the
following affluent limitations
representing the degree of effluent
reduction attainable by the application
of the best available technology
economically achievable:
(a) Sodium Anttmonate Autoclave
Wastewater.

BAT LIMITATION* *Ofl TMC PMUAIIV AMTHMOMV
SUfCATfOOHV
r> no •
13*1
11440
>M7
9*37
(b) Fouled Anolyte.
-------
38346 Federal Register / Vol. 50. No. 183 / Friday. September 20. 1985 / Rules and Regulations
8AT UMITATlONa PON TWt P«M**r
SueCATtoowv
m*/* MWW
301*0 |
2,344 !
tSS7
OJSJ
(c| Cathode Antimony Waah Wafer

SAT UUITATIOH« PO* T>« PNMANV ANTIMONY
SueCATiaONY
IU70
ooo
{431.144 Standards of DOTfenmne* for

Any new source subject to this
iubp«rt shall achieve the following new
source performance standards:
(a) Sodtam Anttmonate Autoclave
Waste water.

NSPS TON THI PMMANV ANTIMONY
UVCVT—
_-fcf 30 »SO 1
I JiTjoi
j 2.344 I

— .'i I'll
t.*tt
0.107
T j » 10.0 M «

(b) Fouled Anolyte.
NSPS PON TV* PdlMAMV
SutCATlGONV
PSNS *ON THt PmMAMv AMTIMOMV
SoKATfGON*

•8J10
«J.4J»
*MT
44S.no
C>
24ST9
11370
i.«n
371.000
0
•• «nf« • T S • tt.0 • M l
§431.141 (

f 431.144
rt standard* for new
Except as provided in 40 CFR 403.7.
any new source subject to this subpart
which introduces pollutants into a
publicly owned treatment worths must
comply with 40 CFR Part 403 ai^d
achieve the following pretreatakent
standards for new sources. The mass of
wastewater pollutants in primary
antimony process wastewater
introduced into a POTW shall not
exceed the following values:
(a) Sodium Antimonata Autoclave
Wastewater.

PSNS nil TK PMMANV AKTJMOWY
•Vi
ta*au m ••mini i
21710
11448
t«sr
0.«7
(b) Fouled Anoljte.

PSNS TON TV€ PniMANY ANT1MONV
SUBCATEOONV
NSPS ran TMf PmMAffv ANTIMOMV
SuaCATCOOftr
(c) Cathode Antimony Washwater.
i W T i B io.O

(c) Cathode Antimony Wash Water.
43430 !
<1370
1431.147 [

SubpevtO—**
y BaryWum
I431.1M A
tien of Ow
The provision! of this subpart are
applicable to discharges resulting from
the production of beryllium by primary
beryllium facilities processing beryllium
ore concentrates or beryllium hydroxide
raw materials.
I421.1S1 So*
For the purpose of this subpart the
general definitions, abbreviations'and
methods of analysis set forth in 40. CFR
401 shall apply to this subpart

I431.1U EfflucMlmMsMom guideline*
i pr
by trie appttcattofi of
control tecfxxxogy
Except as provided in 40 CFR 125.30
through 125.32. any existing point source
subject to this subpart shall achieve the
following effluent limitations
representing the degree of effluent
reduction attainable by the application
of the best practicable technology
currently available:
(a) Solvent Extraction Raffmate from
Bertrandite Ore.

BPT (jMTTATIONa FON TV* PHiMANV
8CNYUJUU SUCCATEOOKY
"»/«, woundi
ootfOH at '•
1*3 000 i
9M200
Tew i
2M 400.000
n a 10 ooo
$2.090 OOQ
(1
(b) Solvent Extraction RafTma
Beryl Ore.
-------
TECHNOLOGY-BASED REQUIREMENTS
OF THE CLEAN WATER ACT
POLLUTANT
CATEGORY
Conventional
Conventional
Non-conventional
Non-conventional
Toxic
Toxic
LEVEL OF
TREATMENT
BPT
BCT
BPT
BAT
BPT
BAT
COMPLIANCE
DEADLINE
July 1, 1977
March 31, 1989
July 1, 1977
March 31, 1989
July 1, 1977
March 31, 1989
NOTES:
4-13
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THSTRUCTIOHS ""
atlons and studies applicable to the national Industrial
cwrn»nt1y available fo review and distribution as follows:
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INDUSTRIAL
POINT SOURCE
CATEGORY

n
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Transportation
Equipment
Cleaning

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TRANSPORTATIOf
EQUIPMENT
CLEANING
INDUSTRY

CO
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II

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4-37
-------
OWR/ITD Preliminary Data Sumnarigg--l9B9
EPA 440/1-89/014—Preliminary Data Summary for the Used Oil
Reclamation and Re-Refining Industry

EPA 440/i-89/060n—Preliminary Data Summary for the Hospitals Point
Source Category

EPA 440/l-89/060a—Preliminary Data Summary for the Pesticide
Chemicals Point Source Category

EPA 440/1-89/025—Preliminary Data Summary for the Pulp, Paper and
Paperboard Point Source Category

EPA 440/1-89/050—Preliminary Data Summary for the Paint
Formulating Paint Source Category

EPA 440/1-89/084—Preliminary Data Summary for the Pharmaceutical
Manufacturing Point Source Category

EPA 440/1-89/100—Preliminary Data Summary for the Hazardous Waste
Treatment Industry

EPA 440/1-89/101—Preliminary Data Summary for the Drum
Reconditioning Industry

EPA 440/1-89/102—Preliminary Data summary for the Solvent
Recycling Industry

EPA 440/1-89/103—Preliminary Data Summary for the Industrial
Laundries

EPA 440/1-89/104—Preliminary Data Summary for the Transportation
Equipment Cleaning Industry

EPA 440/1-89/105—Preliminary Data Summary for the Coastal, Onshore
and Stripper Subcategories of the Oil Gas
Extraction Point Source Category

EPA 440/1089/106—Preliminary Data Summary for the Machinery
Manufacturing and Rebuilding Industry
i»-J3
-------
XHDUSTRIAL CATEGORIES fUUECT TO K ATI ON XL EFFLUENT LIICTATJOHS AHS STAW5AMS
ZNOCSTRIAL CATEGORY
12 era PART
Aluminum Forming 417
Asbestos Manufacturing 42?
Battery Manufacturing 4il
Builder's Paper 431
Carbon'Black Manufacturing 451
Cement Manufacturing 411
Coal Mining 434
Coil Coating (Phase I and XZ) 46S
Copper Forming 4CI
Dairy Products Procassing 405
Electroplating 413*
Electrical and Electronic Components (Phases Z and ZZ) 4«9
Explosives Manufacturing 457
Feedlots 412
Ferroalloy Manufacturing 424
Fertiliser Manufacturing 411
Fruits and Vegetables Processing Manufacturing 40?
Glass Manufacturing 42fi
Grain Mills Manufacturing 406
Gum and wood Chemicals 454
Hospitals 4€0
Ink Formulating 447
Inorganic Chemicals (Phases Z and ZZ) 415
Zron and Steel Manufacturing 420
Leather Tanning and Finishing 425
Meat Processing 432
Metal Finishing 433**
Metal Molding and Casting 464
Mineral Mining 436
Nonferrous Metals Forming 4?l
Nonferrous Metals Manufacturing (Phases Z and ZZ) 421
Oil and Gas Extraction 435
Organic Chemicals and Plastics and Synthetic Fibers 414" •
Paint Formulating 44C
Paving and Roofing (Tars and Asphalt) 443
Pesticides 455
Petroleum itefining 419
Pharmaceuticals 439
Phosphate Manufacturing 422
Photographic 459
Plastics Molding and Forming 4C3"**
Porcelain enameling 4€<
Pulp and Paper 430
Rubber Processing 421
Seafood Processing Manufacturing 408
Soaps and Detergents Manufacturing 417
Steam Electric 423
Sugar Processing Manufacturing 409
Timber Products Manufacturing 429
Texxiles 410"««
•cross reference to Metal Finishing, Part 433
••Cross reference to Electroplating, Part 413.
• ••«0<-o*r:.<. Chemicals and Manufacturing* (40 CFX Part 414) had been
combined with the "Plastics and Synthetics" point source category
(40 CFX Part 411 It pretreatment standards for new sources are still ;
effect as previously identified under 40 CFX Part 414, Subpart B.
••••Category is regulated only by the general pretreatment standards four.fi
in 40 CFX Part 403.
4-39
-------
PKFEftENCU POM WATTTWATM POUJUTAHT MFOftUATON
40 CPU 401.15

40 CFK 401.16
40 OFF Part 423.
ApptndbtA
Tode PoU*** Utf of « todc poluferts
VMMr Ad Iwilon 107(i}(1)
Ltt of •
to
OrtQirvly Mi M«
from M of 65 Torfe Foiutertt; 128
{ 129 pdutvts; no*. 17. 40 and SO
or lode (priortty)
OTHER EFFLUENT OUIOEUNES CONTACTS
Arafytloif Support
(Chwrtcri T«i Uflthod*)
fWrrMng.
Ordering

Economic Anarytb tor
E*utrt Gutttfinn
Ouldcflrw Plan
(CWA 904m Ptan)
Cttwnoi tor

Foods A B»v»fio>i Miic

Low ITU Qttflcttion

Anmtyrit tor
Supfriund Sit
MTttiud.

MTatard
(AED)
Erie

DonAndcnon
(AED)
Wpooy

Don
-------
ITD PROJECT RESPONSIBILITY LIST
iminum Forming

alytical Support

tery Manufacturing

-bon Black Manufacturing

nent Manufacturing

itralized (Hazardous)
aste Treaters

il Mining
oal Remining
oal Slurry Pipelines

I Coating
icludes canmaking)

ry Products Processing

im Reconditioning

:trical & Electronic
)mponents - Phase I & n

ilosives Manufacturing

roalloy Manufacturing
Matt Jarrett

Bill Telliard
Ben Honaker

Sabita Rajvanshi

Sabita Rajvanshi

Sabita Rajvanshi

Matt Jarrett
(202) 260-3164

(202) 260-5131
(202) 260-2272

(202) 260-3164
4-41
-------
ilizer (Nitrogen
d Phosphate)

ndries (Metal Molding
d Casting)

its & Vegetables

-------
nferrous Metals Forming

nferrous Metals Manufacturing

i & Gas Extraction
)ffshore
inshore (Coastal)

ganic Chemicals, Plastics
: Synthetic Fibers

int Formulation

ragraph 4(c) Pollutants

roleum Refining

sties Molding & Forming

"celain Enameling

TW Pilot Study/Pretreatment

jltry Processing

nting & Publishing

Ip & Paper
•uilders' Paper & Board Mills
Converted Paper
*ulp, Paper & Paperboard
)ioxin
Matt Jarrett

Tom Fielding
Jan Goodwin

Sabita Rajvanshi

George Heath
Wendy Smith
Dick Williams
(202) 260-3164

(202) 260-7156
(202) 260-7142

(202) 260-7165
(202) 260-7184
(202) 260-7186
4-43
-------
bber Manufacturing

ifood Processing
anned & preserved)

am Electric Power Generation

;ar Processing
eet, Raw Cane
ane Sugar Refining

Kifund Site/POTW Guidance

.tile Manufacturing

ste Oil Reclamation

CFR 401 Revisions
Joe Vitalis

Sabita Rajvanshi

Sabita Rajvanshi

Frank Hund
(202) 260-7172

(202) 260-7182
4-44
-------
PRACTICAL EXERCISE

Calculating Daily Maximum and Monthly Average Permit Limits
Using Effluent Guidelines
ION

e the permit writer responsible for drafting the permit for Luster Glass,
a glass manufacturer in Morris, Illinois (IL0654321). After reviewing the
ation forms 1 and 2C and the effluent limitations guidelines and standards
e Glass Manufacturing point source category (40 CFR Part 426) you begin to
;p the effluent limitations for the process wastewaters, to be included in
;rmit.

iily maximum and monthly average effluent limitations for Oil and Grease/
'hosphorus, and pH for the process wastewater contribution to Outfall 001
;ter Glass. Show all calculations and assumptions.
4-45
-------
4-46
-------
Part 426
40 Cft Ch. I (7-l-W
TABLE OF STUDENTS' t VALUES AT THE 99
PERCENT CONFIDENCE LEVEL
rVUTTvW Ol HpUCSWH
7
t .
g
10 _...
11
16 _
21
26
31
61

D«gr«M
(X
frMdom
(n-1)
6
7
g
e
10
IS
20
25
30
80

Mn-1.
1-»-.W)
3.143
2.996
2896
2,821
2.764
2,602
8.528
2.405
2.457
2.390
2.326
[S3 PR 9186, Mar. 21.19881
PART 426— GLASS MANUFACTURING
POINT SOURCE CATEGORY
Imvlvttai Htorglan
Sec.
426.10 Applicability; description of the in-
•ulation fiberglass subcategory.
426.11 Special definition*.
426.12 Effluent limitations guidelines rep-
resenting the decree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.13 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.14 [Reserved]
426.15 Standards of performance for new
sources.
426.16 Pretreatinent standards for new
sources.
426.17 Effluent limitations guidelines rep-
resenting the degree* of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology (BCT).
Gl«u M«nwf«ctvriit«
426.20 Applicability; description of the
sheet glass manufacturing subcategory.
426.21 Specialized definitions.
426.22 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
Sec.
426.23 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.24 Pretreatment standards for existing
sources.
426.25 Standards of performance for ne*
sources.
426.26 Pretreatment standards for new
sources.
426.27 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control tech-
nology.
Gic«t M«nwfoctwrinf
426.30 Applicability: description of the
rolled glass manufacturing subcategory.
426.31 Specialized definitions.
426.32 ..Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.33 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best avail xble technology economically
achievable
426.34 Pretrtatment standards for existing
sources.
426.35 Standards of performance for new
sources.
426.36 Pretreatment standards for new
sources.
426.37 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control tech-
nology.
D — Plot* Gte«* Maiwfectvrlnf
426.40 Applicability; description of the
plate glass manufacturing subcategory.
426.41 Specialized definitions.
426.42 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.43 [Reserved)
426.44 Pretreatment standards for existing
sources.
426.45 Standards of performance for new
sources.
426.46 Pretreatment standards for new
sources.
4-47
-------
Environmental Protection Afjoncy
fart 426
Sec.
426.47 Effluent limitations guidelines rep-
resenting the degree* of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology (BCT).

Subpart E — Floo* Glass Manufacturing
426.50 Applicability; description of the
float glass manufacturing subcategory.
426.51 Specialized definitions.
426.52 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.53 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.54 [Reserved]
426.55 Standards of performance for new
sources.
426.56 Pretreatment standards for new
sources.
426.57 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology.

Swbpart f — Automotive Glass Tampering
426.60 Applicability; description of the
automotive glass tempering subcategory.
426.61 Specialized definitions.
426.62 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.63 [Reserved!
426.64 Pretreatment standards for existing
sources.
426.65 Standards of performance for new
sources.
426.66 Pretreatment standards for new
sources.
426.67 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology.

Svbpart G — Automotive Glass Laminating
Subcatoaory

426.70 Applicability; description of the
automotive glass laminating subcatego-
ry.
426.71 Specialized definitions.
Sec.
426.72 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.73 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.74 [Reserved!
426.75 Standards of performance for new
sources.
426.76 Pretreatment standards for new
sources.
426.77 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology.

Subpart H—Glass Container Manufacturing
Svbcatagary

426.80 Applicability; description of the
glass container manufacturing subcate-
gory.
426.81 Specialized definitions.
426.82 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.83—426.84 [Reserved]
426.85 Standards of performance for new
sources.
426.86 Pretreatment standards for new
sources.
426.87 Effluent limitations guidelines rep-
resenting the degree of eifluent reduc-
tion attainable by the application of the
best conventional pollutant control tech-
nology.

Swbpart I—Machin* "rossod and Mown Glass
Manufacturing Subcotogorv (Reserved]

Subpart J—Glass Tubing (Dannar)
Manufacturing Subcategory

426.100 Applicability; description of the
glass tubing (Danner) manufacturing
subcategory.
426.101 Specialized definitions.
426.102 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.103—426.104 [Reserved]
426.105 Standards for performance for new
sources.
426.106 Pretreatment standards for new
sources.
4-48
-------
§ 426.10
40 CFR Ch. I (7-1-89 Edition)
Sec.
426.107 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology.

Subpart K—Television Picture Tub* Envelop*
Manufacturing Svbcategery

426.110 Applicability; description of the
television picture tube envelope manu-
facturing subcategory.
426.111 Specialized definitions.
426.112 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.113 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.114 [Reserved!
426.115 Standards of performance for new
sources.
426.116 Pretreatment standards for new
sources.
426.117 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best conventional pollutant control
technology.

Subpart I—Incandescent Lamp Envelop*
Manufacturing Subcalagory

426.120 Applicability: description of the in-
candescent lamp envelope manufactur-
ing subcategory.
426.121 Specialized definitions.
426.122 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.123 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.124 [Reserved]
426.125 Standards of performance for new
sources.
426.126 Pretreatment standards for new
sources.
426.127 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
oest conventional pollutant control
technology.
Sec.
Subpart M—Hand Pressed and Blown Glass
Manufacturing Swbcateaery

426.130 Applicability; description of the
hand pressed and blown glass manufac-
turing subcategory.
426.131 Specialized definitions.
426.132 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best practicable control technology cur-
rently available.
426.133 Effluent limitations guidelines rep-
resenting the degree of effluent reduc-
tion attainable by the application of the
best available technology economically
achievable.
426.134 [Reserved}
426.135 Standards of performance for new
sources.
426.136 Pretreatment standards for new
sources.
426.137 [Reserved]
AUTHORITY: Sees. 301, 304 (b) and (c). 306
(b) and (c), 307(c). and 316(b) of the Federal
Water Pollution Control Act, as amended;
33 U.S.C. 1251. 1311. 1314. 1316 (b) and (c).
1317(b); 86 Stat. 816 et seq.. Pub. L. 92-500.
91 Stat. 1567. Pub. L. 95-217.
SOURCE: 39 FR 2565, Jan. 22. 1974. unless
otherwise noted.

Subpart A—Insulation Fiberglass
Subcatogory

§426.10 Applicability; description of the
insulation fiberglass subcategory.
The provisions of this subpart are
applicable to discharges resulting from
the production of insulation fiberglass
in which molten glass is either directly
or indirectly made, continuously fiber-
ized and chemically bonded into a
wool-like material.

§ 426.11 Specialized definitions.
For the purpose of this subpart:
(a) Except as provided below, the
general definitions, abbreviations and
methods of analysis set forth in 40
CFR Part 401 shall apply to this sub-
part.
(b) The term "cullet water" shall
mean that water which is exclusively
and directly applied to molten glass in
order to solidify the glass.

-------
Environmental Protection Agency
§ 426.62
licly owned treatment works (and
which would be a new source subject
to section 306 of the Act, if it were to
discharge pollutants to the navigable
waters), shall be the standard set
forth In 40 CFR Part 128, except that,
for the purpose of this section. 40 CFR
128.133 shall be amended to read as
follows:
In addition to the prohibitions set forth in
40 CFR 128.131. the pretreatment standard
tor incompatible pollutants introduced into
a publicly owned treatment works shall be
the standard of performance for new
sources specified in 40 CFR 426.55 provided
that, if the publicly owned treatment works
which receives the pollutants is committed.
in Its NPDES permit, to remove a specified
percentage of any Incompatible pollutant.
the pretreatment standard applicable to
users of such treatment works shall, except
In the case of standards providing for no dis-
charge of pollutants, be correspondingly re-
duced in stringency for that pollutant.

§426.57 Effluent limitations guidelines
representing the degree of effluent re-
duction attainable by the application of
the beat conventional pollutant control
technology.
Except as provided in $(125.30
through 125.32, any existing point
source subject to this subpart shall
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best conventional pollut-
ant control technology (BCT): The
limitations shall be the same as those
specified for conventional pollutants
(which are defined in §401.16) in
{426.52 of this subpart for the best
practicable control technology cur-
rently available (BPT).
[51 FR 25000. July 9. 1986]

Subpart F—Automotive Glatt
Tempering Subcategory

SOURCE 39 FR 5714. Feb. 14, 1974. unless
otherwise noted.

§426.60 Applicability; description of the
automotive glass tempering subcatego-
ty-
The provisions of this subpart are
applicable to discharges of pollutants
resulting from the processes in which
glass is cut and then passed through a
series of processes that grind and
polish the edges, bend the glass, and
then temper the glass to produce side
and back windows for automobiles.

§ 426.61 Specialized definitions.
For the purpose of this subpart:
(a) Except as provided below, the
general definitions, abbreviations and
methods of analysis set forth in 40
CFR Part 401 shall apply to this sub-
part.
(b) The term "tempering" shall
mean the process whereby glass is
heated near the melting point and
then rapidly cooled to increase its me-
chanical and thermal endurance.

6426.62 Effluent limitations guidelines
representing the degree of effluent re-
duction attainable by the application of
the best practicable control technology
currently available.
(a) In establishing the limitation set
forth in this section, EPA took into ac-
count all information it was able to
collect, develop and solicit with re-
spect to factors (such as age and size
of plant, raw materials, manufacturing
processes, products produced, treat-
ment technology available, energy re-
quirements and costs) which can
affect the Industry subcategorization
and effluent levels established. It is,
however, possible that data which
would affect these limitations have
not been available and, as a result,
these limitations should be adjusted
for certain plants in this Industry. An
individual discharger or other interest-
ed person may submit evidence to the
Regional Administrator (or to the
State, if the State has the authority to
issue NPDES permits) that factors re-
lating to the equipment or facilities in-
volved, the process applied, or other
such factors related to such discharger
are fundamentally different from the
factors considered in the establish-
ment of the guidelines. On the basis of
such evidence or other available infor-
mation, the Regional Administrator
(or the State) will make a written find-
ing that such factors are or a re. not
fundamentally different for thai, facil-
ity compared to those specified in the
Development Document. If such fun-
damentally different factors are found
to exist, the Regional Administrator
4-50
-------
§426.64

or the State shall establish for the dis-
charger effluent limitations in the
NPDES permit either more or less
stringent than the limitations estab-
lished herein, to the extent dictated
by such fundamentally different fac-
tors. Such limitations must be ap-
proved by the Administrator of the
Environmental Protection Agency.
The Administrator may approve or
disapprove such limitations, specify
other limitations, or initiate proceed-
ings to revise these regulations.
(b) The following limitations estab-
lish the quantity or quality of pollut-
ants or pollutant properties, con-
trolled by this section, which may be
discharged by a point source subject to
the provisions of this subpart after ap-
plication of the best practicable con-
trol technology currently available:
Effluenl krrautiona
Effluent charactenrtc
Average of dairy
Maximum value* tor 30
tar any 1 consecutive days
day shall not
exc*ed—
Metric unto (q/sq m ot
product)
TSS..
195
0.64
V22
.64
PH.
English units (ft/1.060 tq ft 01
product)
TSS..
Oil
pH...
0.40
0.13
0.25
.13
> Wittun me range 6.0 to 90.

§426.63 [Reserved]

§426.64 Pretreatment standards for exist-
ing sources.
The pretreatment standards under
section 307(b) of the Act for a source
within the automotive glass tempering
subcategory which is a user of a pub-
licly owned treatment works and a
major contributing industry as defined
in 40 CFR Part 128 (and which would
be an existing point source subject to
section 301 of the Act. if it were to dis-
charge pollutants to the navigable
40 Cft Ch. I (7-1-W Edition)

shall not apply. The following pre-
treatment standard establishes the
quantity or quality of pollutants or
pollutant properties controlled by this
section which may be discharged to a
publicly owned treatment works by a
point source subject to the provisions
of this subpart.
Poftutant or pollutant property
Pretrutment standard
PH....
W....
TSS..
NO limitation.
Do.
Do.
[40 FR 6444, Feb. 11, 1975]

8426.65 Standards of performance for
new sources.
The following standards of perform-
ance establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section, which may
be discharged by a new source subject
to the provisions of this subpart:
Effluent characteristic
Effluent limitations

Average o1 da*?
Maximum values lor 30
lor any 1 consecutive dtyt
day stall not
exceed—
Metric units (q/sq m of
product)
TSS..
Oil
PH....
0.24
049
02*
*9
Englisn units (lt>/1 OOO sg f. s<
TSS....
Oil
PH
O.OS
0 10
COS
•o
1 Wtttvn the range 6.0 to 9.0.

§ 426.66 Pretreatment standards for new
sources.
The pretreatment standards under
section 307(c) of the Act for a source
within the automotive glass tempering
subcategory. which is a user of a pub-
licly owned treatment works (and
which would be a new source subject
to section 306 of the Act, if it were to
discharge pollutants to the navigable
waters), shall be the standard set
forth in 40 CFR Part 128, except that,
for the purpose of this section, 40 CFR
4-46
4-51
-------
fiwironmontol
Ag«ncy
128.133 shall be amended to read as
follows:
In Addition to the prohibitions set forth In
40 CFR 128,131. the pretreatment standard
for Incompatible pollutants introduced into
a publicly owned treatment works shall be
the standard of performance for new
sources specified in 40 CFR 426.65: provided
that, if the publicly owned treatment works
which receives the pollutants is committed.
in its NFDES permit, to remove a specified
percentage of any Incompatible pollutant,
the pretreatment standard applicable to
users of such treatment works shall, except
in the case of standards providing for no dis-
charge of pollutants, be correspondingly re-
duced in stringency for that pollutant.

9426.67 Effluent limitations guidelines
representing the degree of effluent re-
duction attainable by the application of
the beat conventional pollutant control
technology.
Except as provided in Si 125.30
through 125.32. any existing point
source subject to this subpart shall
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best conventional pollut-
ant control technology (BCT): The
limitations shall be the same -as those
specified for conventional pollutants
(which are defined in $401.16) in
i 426.62 of this subpart for the best
practicable control technology cur-
rently available (BPT).
[51 FR 2SOOO. July 9. 1986]

Subpart 6 — Automotive Glass
Laminating SubcaUgory

Souiicr. 39 FR 5714. Feb. 14. 1974. unless
otherwise noted.

§426.70 Applicability; description of the
automotive g lass laminating subcatego-
ry.
The provisions of this subpart are
applicable to discharges of pollutants
resulting from the processes which
laminate a plastic sheet between two
layers of glass, and which prepare the
glass for lamination such as cutting,
bending and washing, to produce auto-
mobile windshields.

9 426.71 Specialized definition*.
For the purpose of this subpart:
§ 426.71

(a) Except as provided below, the
general definitions, abbreviations and
methods of analysis set forth in 40
CFR Part 401 shall apply to this sub-
pan.

9 426.72 Effluent limitations guidelines
representing the degree of effluent re-
duction attainable by the application of
the best practicable control technology
currently available.
In establishing the limitations set
forth in this section, EPA took into ac-
count all information it was able to
collect, develop and solicit with re-
spect to factors (such as age and size
of plant, raw materials, manufacturing
processes, products produced, treat-
ment technology available, energy re-
quirements and costs) which can
affect the industry subcategorization
and effluent levels established. It is,
however, possible that data which
would affect these limitations have
not been available and. as a result,
these limitations should be adjusted
for certain plants in this industry. An
individual discharger or other interest-
ed person may submit evidence to the
Regional Administrator (or to the
State, if the State has the authority to
issue NPDES permits) that factors re-
lating to the equipment or facilities in-
volved, the process applied, or other
such factors related to such discharger
are fundamentally different from the
factors considered in the establish-
ment of the guidelines. On the basis of
such evidence or other available infor-
mation, the Regional Administrator
(or the State) will make a written find-
ing that such factors are or are not
fundamentally different for that facil-
ity compared to those specified in the
Development Document. If such fun-
damentally different factors are found
to exist, the Regional Administrator
or the State shall establish for the dis-
charger effluent limitations in the
NPDES permit either more or less
stringent than the limitations estab-
lished herein, to the extent dictated
by such fundamentally different fac-
tors. Such limitations must be ap-
proved by the Administrator of the
Environmental Protection Agency.
The Administrator may approve or
disapprove such limitations, specify
4-52
-------
§ 426.73
40 CFI Ch. I (7-1 -i9 Edition)
other limitations, or initiate proceed-
ings to revise these regulations.

The following limitations establish the
quantity or quality of pollutants or
pollutant properties, controlled by this
section, which may be discharged by a
point source subject to the provisions
of this subpart after application of the
best practicable control technology
currently available:
Effluant dwaetaritoc
Effluant ImtaUona

Avaraga of dally
Maximum vaktta for 30
tor any 1 conaaeuttv*
-------
Environmental Protection Agency

for the purpose of this section, 40 CFR
128.133 shall be amended to read as
follows:
In addition to the prohibitions set forth In
40 CFR 128.131. the pretreatment standard
for Incompatible pollutants Introduced into
a publicly owned treatment works shall be
the standard of performance for new
sources specified in 40 CFR 426.75; provided
that, If the publicly owned treatment works
which receives the pollutants is committed.
in its NPDES permit, to remove a specified
percentage of any incompatible pollutant.
the pretreatment standard applicable to
users of such treatment works shall, except
in the case of standards providing for no dis-
charge of pollutants, be correspondingly re-
duced in stringency for that pollutant.

§426.77 Effluent limitations guidelines
representing the degree of effluent re-
duction attainable by the application of
the best conventional pollutant control
technology.
Except as provided in 5$ 125.30
through 125.32, any existing point
source subject to this subpart shall
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best conventional pollut-
ant control technology (BCT): The
limitations shall be the same as those
specified for conventional pollutants
(which are defined In 5 401.16) in
{426.72 of this subpart for the best
practicable control technology cur-
rently available (BPT).
[51 FR 25000. July 9. 1986]

Subpart H—Glass Container
Manufacturing Subcategory

SoxmcK 40 FR 2956, Jan. 16. 1975. unless
otherwise noted.

9426.80 Applicability; description of the
glass container manufacturing subcate-
fory.
The provisions of this subpart are
applicable to discharges resulting from
the process by which raw materials
are melted in a furnace and mechani-
cally processed into glass containers.

9 426.81 Specialized definitions.
For the purpose of this subpart:
(a) Except as provided below, the
general definitions, abbreviations and
methods of analysis set forth In Part
§ 426.82

401 of this chapter shall apply to this
subpart.
Cb) The term "furnace pull" shall
mean that amount of glass drawn
from the glass furnace or furnaces.
(c) The term "oil" shall mean those
components of a waste water amena-
ble to measurement by the technique
or techniques described In the most
recent addition of "Standard Meth-
ods" for the analysis of grease in pol-
luted waters, waste waters, and ef-
fluents, such as "Standard Methods,"
13th Edition, 2nd Printing, page 407.

§ 426.82 Effluent limitations guidelines
rep tesen ting the degree of effluent re-
duction attainable by the application of
the best practicable control technology
currently available.
In establishing the limitations set
forth in this section. EPA took into ac-
count all Information it was able to
collect, develop and solicit with re-
spect to factors (such as age and size
of plant, raw materials, manufacturing
processes, products produced, treat-
ment technology available, energy re-
quirements and costs) which can
affect the industry subcategorization
and effluent levels established. It is,
however, possible that data which
would affect these limitations have
not been available and, as a result,
these limitations should be adjusted
for certain plants in this industry. An
individual discharger or other interest-
ed person may submit evidence to the
Regional Administrator (or to the
State, if the State has the authority to
issue NPDES permits) that factors re-
lating to the equipment or facilities in-
volved, the process applied, or other
such factors related to such discharger
are fundamentally different from the
factors considered in the establish-
ment of the guidelines. On the basis of
such evidence or other available infor-
mation, the Regional Administrator
(or the State) will make a written find-
ing that such factors are or are not
fundamentally different for that facil-
ity compared to those specified in the
Development Document. If such fun-
damentally different factors are found
to exist, the Regional Administrator
or the State shall establish for the dis-
charger effluent limitations in the
4-54
-------
OVERVIEW OF VARIANCES TO
EFFLUENT GUIDELINES
-------
-------
LEARNING OBJECTIVES

Role of variances

Types of variances

Basic process to grant/deny
TECHNOLOGY-BASED VARIANCES

Limited relief from effluent limits and compliance deadlines

Address exceptional circumstances

Ensure relief of NPDES program for "unusual" circumstances

Only granted on rare occasions

Some may be granted by States, others require EPA approval
NOTES:
5-1
-------
VARIANCES ARE FOR EXCEPTIONAL CIRCUMSTANCES
CWA CITE

316(a)
TYPE
40 CFR CITE
APPROVAL
AUTHORITY
Economic
Water Quality
Part 125, Subpart E EPA • HQ
[Reserved]

Part 125, Subpart F EPA - Region
[Reserved]
Secondary Treatment Part 125, Subpart G EPA - HQ
Waiver - Ocean Discharge (§§125.56 -125.67)
(POTW)

Extension of Secondary Part 125, Subpart J NPDES State*
Treatment Deadline (§§125.90 -125.97)
(POTW)
Innovative
Technology
Part 125, Subpart C NPDES State*
(§§125.20 -125.27)
Fundamentally Different Part 125, Subpart D EPA - Regions
Factors (FDFs) (§§125.30 - 125.32)
Thermal Discharges
Intake - Discharge
Net Basis (Net/Gross)
Part 125, Subpart H NPDES State*
(§§125.70 -125.73)
§122.45(g)
NPDES State'
*EPA Region in absence of approved State NPDES program.
NOTES:
5-2
-------
BEST PROFESSIONAL
JUDGMENT-BASED LIMITS
-------
-------
LEARNING OBJECTIVES
Define Best Professional Judgment (BPJ)

Authority for BPJ
BPJ tools
Economic achievability protocol
DEVELOPMENT OF EFFLUENT LIMITATIONS
FOR NPDES PERMITS
Develop Water Quality-Based
Limitations
Develop Technology-Based
Limitations
Effluent Guidelines
Best Professional Judgment
Compare Limitations
Apply the Most Stringent
6-1
-------
BPJ CANDIDATES
Combined sewer overflows
Hazardous waste treaters
Equipment manufacturers
Waste oil reclaimers
Industrial laundries
Paint and ink facilities
Pharmaceuticals
Barrel reclaimers
Transportation facilities

Mining operations

Water treatment plants

Petroleum industry
NOTES:
6-2
-------
BPJ IS THE PERMIT WRITER'S OPINION

Technically based NPDES permit conditions, developed using all
reasonable available and relevant data, examined and evaluated
using a multidisciplined approach.

The multidisciplined approach includes perspectives of an
engineer, economist, statistician, chemist, biologist, and
attorney.

BPJ FACTORS - DEFINITIONS

Age of equipment and facilities: age of the plant including
manufacturing lines, sewer lines, and wastewater treatment
system

Process employed: the manufacturing process(es) used, and/or
the wastewater treatment process employed

Engineering aspects of the application of various types of control
techniques: the design, construction, cost, performance, reliability,
etc. of the wastewater treatment processes

Process changes: the feasible manufacturing process changes such
as raw material substitution or in-process design (i.e., chemical
synthesis)

Cost of achieving the effluent reduction: the capital and operating
cost of attaining a specified effluent quality

Non-water quality environmental impacts: the trade-offs associated
with achieving a specified effluent quality including energy
requirement, air pollution, hazardous waste generation, solid waste
disposal, etc.

Other factors the Administrator deems appropriate: any other
factor determined to be relevant to the facility's ability to achieve
a specified level of effluent quality
6-3
-------
BEST PROFESSIONAL JUDGMENT
DEFENSIBILITY

Defensibility depends on reasonableness

Reasonableness demonstrated by documentation

Documentation should include:

What is being imposed?
Why is it being imposed?
How it was developed?
NOTES:
6-4
-------
BPJ PERMITTING TOOLS

Abstracts of industrial NPDES permits

Treatability manual

NPDES best management practices guidance document

Technical support document for the development of water
quality-based permit limitations for toxic pollutants

Economic achtevability protocol

Report on specific facilities

Office of Research and Development
National Enforcement Investigations Center

Effluent guidelines data

Section 308 questionnaires
Screening and verification data
Development documents
Contractors reports
Proposed regulations

Other sources of information

Discharge monitoring reports
Compliance inspection reports
Industry teams/national experts
NOTES:
6-5
-------
PERMIT ABSTRACTS

Primary purpose:

To assist permit writers by providing rapid access
to information in approximately 500 industrial NPDES
permits in a standardized, cross*referenced and easy-to-read
format.

Other purposes:

To answer inquiries from, and provide information to
industry, academia, consultants and the public.
NOTES:
6-6
-------
NUMBER OF ABSTRACTED PERMITS
1001
*0t
o
0.
9
J»
Region
EFFLUENT GUIDELINES
Industry Category
6-7
-------
25
PERMITS WITH BMP PLANS
20
vt
+s
to-
I
i

I
I
\ \\ in iv v vi vn vm ix x
Region
6-8
-------
United States Office of Research and
Cnvlranwntal Protection OevelopKnt
Agency Cincinnati, OH 45268
RREL TREATABILITY DATA BASE

WHWTRD 1992 FACT SHEET
Purpose

To provide a thorough review of the effectiveness of proven treatment
technologies In the removal/destruction of chemicals in various types of media
Including, but not limited to, municipal and Industrial wastewater, drinking
water, groundwater, soil, debris, sludge, and sediment.

The database is distributed to federal, state and local governments,
foreign governments, academe, Industry, industrial trade associations,
environmental groups, law firms, and engineering firms. The database has a
current mailing 11st of approximately 2,000.

Version 4.0 of the Risk Reduction Engineering Laboratory Treatability
Data Base was released in February 1992 and contains 1166 chemical compounds
and over 9200 sets of treatability data. The chemicals contained In the
database are often those regulated under the Clean Hater Act, Safe Drinking
Water Act, Resource Conservation and Recovery Act, Toxic Substances Control
Act, Superfund Amendments and Reauthorization Act, and other environmental
laws enacted by Congress. For each chemical, the database includes:
physical/chemical properties, aqueous and solid treatablllty data, Freundllch
isotherm data, other environmental database information sources, and data
references including a reference abstract. The physical/chemical properties
included are those most routinely used, such as molecular weight, boiling
point, melting point, etc. The treatablllty data summarize the treatment
technologies used to treat the specific chemical; the type of waste/wastewater
treated; the size of the study/plant; and the treatment efficiency achieved.
In addition, each data set 1s referenced to sources of information,
operational Information on process(es) sampled and quality-coded based upon
analytical methods and reported quality assurance. ,

Computer Requirements

The database has been developed using "dBase III Plus* and compiled using
"Clipper" and will function without any specialized software. It 1s designed
to operate on an IBM or IBM compatible (MS DOS) personal computer and Is menu
driven. The database can be set to operate on a local area network system,
6-9
-------
although it 1s the user's responsibility to load and operate such a system.
The database has the following hard and software requirements:

* 8 megabyte hard disk storage;
* 640 K RAN memory;
• DOS Version 2.0 to 3.3; and
• 12 pitch printer.

The database Is currently available free of charge. To receive a copy of
the database and to be placed on a mailing 11st for all future updates, please
send a written request to:

Glenn M. Shaul
Water and Hazardous Waste Treatment Research Division
Risk Reduction Engineering Laboratory
United States Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, Ohio 45268

or FAX your request to (513) 569-7787. Please specify the type of program
diskette required for your computer (i.e., 3^" HO or 5Sj" HD).

Accurate tracking and distribution of the RREL Treatability Data Base 1s
necessary for development of future versions of this valuable product. It 1s
recommended that all parties or Individuals using the database request a copy
through Glenn Shaul at the above address rather than loading the database from
a colleague's copy. This will help track the usage of the database and ensure
all users receive future updates.

Letters commenting on the utility and effectiveness of the database and
any suggestions for Improvements are welcomed and can be sent to Glenn Shaul
at the above address.
CONTACT: Glenn M. Shaul (513/569-7408 or FTS 684-7408)
6-10
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WATER QUALITY STANDARDS
AND MODELING
-------
-------
LEARNING OBJECTIVES
Water quality standards
Beneficial uses
Water quality criteria

Antidegradation policy
WATER QUALITY STANDARDS

A water quality standard defines the water quality goals of

a water body, or portion thereof, by designating the use or uses to be

made of the water and bv setting criteria necessary to protect the uses.

(40 CFR Part 131)
NOTES:
7-1
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ESTABLISHMENT OF
WATER QUALITY STANDARDS

All "waters of the U.S." have water quality standards

Water quality standards are adopted for each waterbody in a State

Segments of waterbodies
States are responsible for establishing water quality standards

Revised every 3 years
EPA has oversight
BENEFICIAL USES
Common uses
Public water supply
Fish and wildlife propagation
Recreation
Primary
Secondary
Agricultural
Industrial
Navigation

Outstanding national resources water

National and State parks
Wildlife refuge
Ecologically unique water that need additional protection
or are of special significance (i.e., swamps, hotsprings, etc.)
NOTES:
7-2
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STATE WATER QUALITY CRITERIA
Numeric criteria
Concentrations of chemicals
Narrative criteria
"Free from..."
EPA WATER QUALITY CRITERIA

Scientifically derived ambient limits that are developed by EPA
for various pollutants of concern
1968
1973
1976
1980
1986
Green
Blue
Red
Tbxks
Gold
EPA develops 304(a) criteria goldbook
NOTES:
7-3
-------
ANTIDEGRADATION PLANS

Ensures that once a use is achieved it will be maintained

Each State is required to adopt an ant {degradation policy and
method of implementation

EPA reviews State antidegradation plans

Antidegradation plans are designed to minimize adverse
effects of economic growth and development
COMPONENTS OF THE ANTIDEGRADATION POLICY

» Level of quality necessary to protect the existing uses of a
water segment

• Protection of actual water quality where water quality exceeds
levels necessary to protect fish and wildlife propagation and
recreation on and in the water

* Special protection of waters designated as outstanding natural
resource waters

NOTES:
7-4
-------
BASIC CONCEPT
Total Maximum Daily Load (TMDL) = Dilution x Criteria

Waste Load Allocation (WLA) = Fraction of TMDL
COMPONENTS OF TMDL
eserve Capacity
(Safety Factor
Other Loads
(Nonpoint Background)
NOTES:
7-5
-------
GENERAL MASS BALANCE FORMULA
QdCd + QsCs = QrCr
Qs, Cs Upstream Qd, Cd Discharge Qr> Cr Downstream
Qd = Waste discharge flow (mgd or cfs)

Cd = Pollutant concentration in waste discharge (mg/1)

Qs = Stream flow (mgd or cfs) above discharge point

Cs = Background instream pollutant concentration (mg/1)

Qr = Stream flow after discharge (mgd or cfs) = Qd + Qs

Cr = Instream pollutant concentration (mg/l) after complete mixing

To determine pollutant concentration in the stream:
Cr_ OdCd + OsCs
Qr
NOTES:
7-6
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DILUTION FACTOR
Mass balance
QrCr
QdCd + QsCs
(Receiving Stream) (Discharge) (Upstream)
Solve for Cr:
Cr =
QdCd + QsCs
Qr
IfCs = 0,then:
Cr =
Qr
Define Dilution Factor (DF) as Qr/Qd
Therefore: Cr = Cd/DF
NOTES:
7-7
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EXAMPLE

ABC, Inc. discharges treated wastewater from a zinc plating
process. The only pollutant found in measurable amounts is zinc. What
is the downstream receiving water concentration assuming zinc in the total
form, complete mixing; and no settling or biological uptake?
ABC, Inc.
Qs = Upstream river flow = 1.2 cfs
Qd = Discharge flow = 0.31 cfs
Cs = Upstream river cone. = 0.8 mg/1
Cd = Discharge concentration = 1.75 mg/1

Cr= CdOd + CsOs
Qr
(0.31+1.2)
Cr= l.Omg/l
NOTES:
7-8
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SPECIFIC CONSIDERATIONS IN THE WATER
QUALITY MODELING PROCESS

Conservative pollutants

Mitigated by natural stream dilution
Heavy metals

Non-conservative pollutants

Mitigated by natural stream dilution and biodegradation
in the receiving stream
BOD5, ammonia, bacteria
EXAMPLE MODEL INPUTS

Wastewater flow

Upstream concentration

Effluent concentration

Mixing zones
NOTES:
7-9
-------
-------
DETERMINING THE NEED FOR AND
DERIVATION OF WATER QUALITY-
BASED LIMITS
-------
-------
LEARNING OBJECTIVE

Determining when water quality-based limits are needed

Calculating water quality-based permit limits
DEVELOPMENT OF EFFLUENT LIMITATIONS
FOR NPDES PERMITS
Develop Water Quality-Based
Limitations
Develop Technology-Based
Limitations
Effluent Guidelines
Best Professional Judgment
Compare Limitations
Apply the Most Stringent
NOTES:
8-1
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PROTECTING WATER QUALITY STANDARDS

Getting data to make a decision

Permit application
Ask (308 authority)
Previous permit

Deciding to set limits

Follow 40 CFR §122.44(d)
Options: 1) Set limit
2) Monitor and reopener
3) Monitor

Setting limits
NOTES:
8-2
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USE OF WATER QUALITY-BASED LIMITS

Water quality-based limitations are used when it has been

determined that more stringent limits than technology-based effluent

guidelines must be applied to a discharge in order to protect "designated

use" of the receiving waters. (40 CFR §122.44(d)(l))
WATER QUALITY-BASED LIMITS

Limitations must control all pollutants which will cause, have the

reasonable potential to cause, or contribute to an excursion above any

State water quality standard. (40 CFR §122.44(d)(l)(i))
NOTES:
8-3
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WATER QUALITY-BASED LIMITS

Limits must consider (40 CFR §122.44(d)(ii)):

• Effluent variability

* Existing controls on point and non point sources

• The sensitivity of species to toxicity testing

• Where appropriate, the dilution of the effluent
WATER QUALITY-BASED LIMITS
NUMERIC CRITERIA

If it is determined that a discharge causes, has the reasonable

potential to cause, or contributes to an in-stream excursion above the

allowable ambient concentration of a State numeric criteria within a

State water quality standard for:

• An individual pollutant, then the permit must contain
effluent limits for that pollutant.
(40 CFR§122.44(d)(l)(iii))

• Whole effluent toxicity, then the permit must contain effluent
limits for whole effluent toxicity.
(40 CFR §122.44(d)(l)(iv))
NOTES:
8-4
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WATER QUALITY-BASED LIMITS
NARRATIVE CRITERIA

If it is determined that a discharge causes, has the
reasonable potential to cause, or contributes to an in-stream
excursion above a narrative criterion, the permit must contain
effluent limits for whole effluent toxicity. (40 CFR §122.44(d)(l)(v))
WATER QUALITY-BASED LIMITS
NARRATIVE CRITERIA

Where a State has not established a water quality criterion
for a specific pollutant

Use numeric water quality criterion derived from proposed
State criterion or State policy or regulations, supplemented
as appropriate

Use EPA's water quality criteria published under
Section 307(a) of the C WA, supplemented as appropriate

Use an indicator parameter for the pollutant of concern
(40 CFR §122.44(d)(l)(vi))
NOTES:
8-5
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EXAMPLE

ABC, Inc. discharges treated wastewater from a zinc plating
process. The only pollutant found in measurable amounts is zinc. What
is the maximum allowable concentration in the effluent assuming zinc
in the total form, complete mixing, and no settling or biological uptake.
ABC, Inc.
Qs = Upstream river flow = 1.2 cfs
Qd = Discharge flow = 0.31 cfs
Cs = Upstream river cone. = 0.8 mg/1
Cr = Water quality standard = 1.0 mg/l

rn ^ CrfOd +Os) - CsQs
Qd
Cd=
+ 1.2) - (0.8K1.2)
0.31
Cd = 1.75 mg/1
NOTES:
8-6
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EPA TECHNICAL SUPPORT DOCUMENT FOR WATER
QUALITY-BASED TOXICS CONTROL

• Provides the most current procedural recommendations and
guidance for identifying, analyzing, and controlling adverse water
quality impacts caused by toxic discharges.

» Provides support to States and Regions for supplementing their
existing procedures.
WHAT YOU MUST DO

Protect acute and chronic water quality standards (and wasteload
allocations)

Write maximum daily and monthly average permit limits
NOTES:
8-7
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8-3
-------
PRACTICAL EXERCISE
Determining the Need for Chemical-Specific
Water Quality-Based Effluent Limitations
DIRECTIONS;
You are a permit writer and have received a permit renewal application
from a glass manufacturer, Luster Glass Inc. The previous permit was
issued using effluent limits derived from technology-based effluent
limitation guidelines and best professional judgement (BPJ). since that
time, the State has revised its water quality standards to ensure aquatic
life protection. Therefore, you must determine whether water quality-
based limits are needed.
GIVEN;

cr = (Cd)(Qd) •+ (CsMQs)
(Qd + Qs)

where Cr - the receiving water concentration,
Cd = the effluent concentration,
Qd = the effluent flow,
Cs = the receiving water background concentration, and
Qs = the appropriate receiving water flow.

Receiving Hater
Effluent Background
Concentration (Cd)* Concentration (Cs)
Pollutant (ma/It (mq/ll

Zinc 0.21 . 0.07

* - Maximum daily concentration as reported in the application Form 2C

The State water quality regulations require that water quality standards
be achieved under the following critical receiving water flow conditions:

Chronic water quality standards:
7 day, 10 year return frequency flow (7Q10)

Acute water quality standards:
One-third (1/3) of the 7Q10 flow

The 7Q10 for the Illinois River is 70.9 cubic feet per second (cfs)

Qd =7.06 cfs
(1) Calculate the following receiving water concentrations (Cr) using the
equation and data supplied above.
(a) Zinc (acute) (c) Lead (acute)

(b) Zinc (chronic) _ (d) Lead (chronic)
8-9
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(2) Compare each receiving water concentration calculated in question (1) with
the State water Quality Standard for aquatic life protection given in the
table below. Which one is larger? What does this mean? For which
pollutant(a) do you need to set a water quality-based limit?
STATE WATER QUALITY STANDARDS*
Acute
Protection
Pollutant

Zinc
Chronic
Protection
fua/1)
82 3.2

* * All State standards are applied as "not to exceed" concentrations.
(3) What effect would a stream flow (Qt) of 0 cfs have on the receiving water
concentration? What about a stream flow of 500 cfs?
(4) Are there other pollutants that are discharged that should be evaluated
for chemical-specific water.quality-based effluent limitations?
If yes, then list the pollutants and briefly explain why below:
8-10
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PRACTICAL EXERCISE

Calculating Chemical Specific Water Quality-Baaed Limits
DIRECTIONS;
Assuming there is a need for chemical specific water quality-based
limitations for lead and zinc discharges from Luster Glass, Inc.,
calculate the end-of-pipe effluent limitations using the following
procedure.
GIVEN;
The following equation is used to calculate the effluent
concentration (which is commonly referred to as the waste load
allocation (WLA)] that will ensure protection of the water quality
standard.
Cd = WLA
where
Cd
Cr
Qd
Qs
Co
Pollutant

Lead
Zinc
Cr {Qd + Qs) - (CsMQs)

WLA = waste load allocation,
the applicable water quality standard,
the effluent flow « 7.06 cfs,
the appropriate receiving water flow, and
the receiving water background concentration.
Cr = Acute State Water
Quality Standard

0.082 mg/1
0.12 mg/1
Cs * upstream
Concentration

0 »g/l
0.07 mg/1
Pollutant
Cr » Chronic State Water
Quality Standard^
Lead 0.0032 mg/1
Zinc 0.11 mg/1

Qs » 70.9 cfs {for chronic protection)
Qs - 23.6 cfs (for acute protection)
Cs » Upstream
Concentration

0 mg/1
0.07 mg/1
(1) Calculate the waste load allocations for lead using the equation and data
supplied above.

(a) Lead (acute)

(b) Lead (chronic) __
8-11
-------
(2) Calculate the waste load allocations for zinc using the equation and data
supplied above.
(a) Zinc (acute)

-------
WHOLE EFFLUENT TOXICITY (WET)

The total toxic effect of an effluent measured directly with a

toxicity test.
WET TESTS

Endpoint: Mortality
Test duration: 48 hours

Endpoint: Mortality, growth, reproduction, etc.
Test duration: 96 hours
NOTES:
8-13
-------
DEFINITION OF LC
50
Concentration of a toxicant which is lethal to 50 percent of the

exposed organism.
EXAMPLE OF ACUTE TEST DATA
100%
100
Effluent Concentration
50% 25%
80
40
% Mortality
12.5%
20
6.25%
0
100
2
o
LU
u

LC_ -30*
I
20 40 60

PERCENT MORTALITY
80
100
8-9
8-14
-------
DEFINITION OF NOEC

No Observed Effect Concentration (NOEC) - the highest
concentration of an effluent or a toxicant at which no adverse
effects are observed on the aquatic test organisms.
DEFINITION OF LOEC

Lowest Observed Effect Concentration (LOEC) - the lowest
concentration of an effluent or toxicant that results in observable
adverse effects in the aquatic test population.
RESPONSE CURVE FOR CERIODAPHNIA DUBIA
CHRONIC TEST
35 -
g> 30 J
25 -
« 20 H

I«H
•a
S 10 H
5H
NOEC
10
Percent effluent (log scale)
100
NOTES:
8-15
-------
EXAMPLES OF TOXIC UNITS (TU)
Acute: Assuming LCM = 28%

100
LC.
TU =
'SO
TU =
100
28
TU, = 3.6
Chronic: Assuming NOEC = 10%

100
NOEC
TU _
10

TUc = 10
DEFINITION OF ACUTE-CHRONIC RATIO

Acute-chronic ratio (ACR) - the ratio of the acute toxicity
of an effluent or a toxicant to its chronic toxicity. It is used as a
factor for estimating chronic toxicity on the basis of acute toxicity
data, or for estimating acute toxicity on the basis of chronic toxicity
data.
Example:
ACR =
ACR =
LC
so
TU,
NOEC TU.

LCK 28%
NOEC= TO%
ACR= 2.8
8-16
-------
PRACTICAL EXERCISE

Whole Effluent Toxicity
Water Quality-Based Effluent Limitations
DIRECTIONS;
Preliminary examination of toxicity testing data submitted by Luster
Glass, Inc. indicates that toxicity is present in the effluent discharged
to the Illinois River. Therefore, you must determine if there is a need
for developing whole effluent toxicity (WET) effluent limitations for the
Luster Glass permit. If you determine a need for WET effluent
limitations, then calculate those limits.
Cr = (Cd)(Qd) + (Cs)(Qs)
(Qd ^ Qg)

Where
Cr = receiving water concentration
Cd = effluent concentration
Qd = effluent flow
Cs = receiving water background concentration
Qs - appropriate receiving water flow

Toxicity Data (Fathead minnows) from Discharge Monitoring Reports:
LC»
f% effluent!
Average
40.2
NOEC
(% effluent)

50
3
10
30
25
1
10
1
30
10
3
30

16
Acute to Chronic
Ratio
4.5
(1) Select the effluent concentrations (Cd) for acute (LCj,,} and chronic (NOEC)
toxicity representing the most toxic concentration and convert into tox^c
units (TU).
Chronic
8-17
-------
(2) Calculate the receiving water concentration (Cr) in toxic units for both
acute and chronic toxicity given the following:
C3

Q3
QS
Qd
= 0
23.6 cfs (for acute protection)
70.9 cfs (the 7Q10 for chronic protection)
7.06 cfs
Chronic
(3) Determine the need for WET limitations by comparing each receiving water
concentration calculated in question (2) with the State water quality
standards for acute and chronic protection. Given that:

State Water Quality Standard for Acute Protection =0.3 TU.
State Water Quality Standard for Chronic Protection = 1.0 TU,

Are WET effluent limitations necessary? Explain your answer.
(4) If it was determined in question (3) above that WET limitations are
needed, then calculate the waste load allocations for acute and chronic
WET using the following equation:

Cd = WLA = Cr (Qd -•• Qs) - (Cs)(Qa)
-~
8-18
-------
(5) Convert the acute WLA (in TU.) to TU,. using the acute to chronic ratio
(ACR) provided with the toxicity data.
(6) Given that all State water quality standards are expressed as never to be
exceeded (i.e., water quality-based limits must be protective of the most
stringent waste load allocation), calculate a maximum daily limitation
(MDL) and an average monthly limitation (AMI.) for WET using the waste load
allocations calculated above. [Note: Assume a ratio of daily maximum to
monthly average of 1.6 for WET.}
8-19
-------
-------
MONITORING CONDITIONS AND
ANALYTICAL METHODS
-------
-------
LEARNING OBJECTIVES

General monitoring conditions

Permit writer's responsibility

Quality assurance/quality control
PURPOSE OF MONITORING

Determine compliance with permit conditions

Assess treatment efficiency

Establish a basis for enforcement actions
NOTES:
9-1
-------
MONITORING TYPES

Self monitoring

Permittee performs sampling and analysis; submits
results to regulatory authority on discharge monitoring
report (DMR)

Compliance monitoring

Permitting authority, or a designated representative,
performs a compliance inspection
ELEMENTS OF MONITORING
Sample location

Sample frequency

Reporting
NOTES:
9-2
-------
SAMPLE LOCATION QUESTIONS

Is the sample point on the facility property?

Is the sample point accessible?

Will the results be representative?

Are monitoring internal points needed?
FREQUENCY CONSIDERATIONS

Size of facility

Type of treatment

Location of discharge

Frequency of discharge

Compliance history

Nature of pollutants
NOTES:
9-3
-------
EXAMPLE: MONITORING FREQUENCY
PLANT CAPACITY
(MGD)

>5.0
FLOW
Weekly

Record continuously
report daily

Record continuously
report daily
OTHER PARAMETERS
Quarterly

Daily
TYPES OF SAMPLING
Grab
Composite
Time proportional

Flow proportional
Continuous
NOTES:
9-4
-------
TEST METHODS
Analytical methods

40 CFR Part 136
Alternative methods

Whole Effluent Toxicity

Specific tests
Specific procedures
Use multiple species
Specify endpoints
Get QA/QC information
NOTES:
9-5
-------
FRESHWATER FISH
Fathead minnow: adult female (left) and breeding m«1e
(right).
SALTWATER FISH
Silverside (Menldla)
9-6
-------
SALTWATER MYSID SHRIMP
Lateral and dorsal view of a typical mysid<
9-7
-------
INDICATOR PARAMETERS

Allowed in accordance with 40 CFR §122.44(d)(l)(vi)(C)

Must show that indicator will control pollutant of concern
Permit requires adequate monitoring to ensure attainment
of water quality
Include reopener
NOTES:
9-8
-------
ANALYTICAL COSTS

Priority pollutants scan
(8080, 8240,8270, cyanide, total phenols,
priority pollutant metais)
Purgeable holocarbons and aromatics
Gasoline (BTX)
Total organic carbon
BODS
Metals
(As, Cd, Pb, Se, Sb, Ti)
(Ag, Ba, Be, Ca, Cr, Cu, Fe, K, Mg, Mn, Mo,
Na, Ni, V, Zn)
Hex-chrome
Cyanide (total)
Phenols (total)
PCP
Pesticides
Herbicides
EP Toxicity (metals)
Oil and grease
Odor, color, turbidity
Total suspended solids
Volatile organics (VOA)
Chlorinated pesticides and PCBs
Polynuclear aromatic hydrocarbons (PAH)
Fecal coliform
$1000 - $1500

$150 - $300
$50 - $150
$40 - $75
$25 - $40

$10 - $20 each
$10 - $20 each

$25 - $50
$25 • $50
$40 - $75
$120 - $165
$100-$200
$110 - $250
$125 - $175
$25 - $50
$20 - $35
$10 - $20
$200 - $300
$125 - $200
$150 - $200
$10 - $25
NOTES:
9-9
-------
PERMIT ANALYTICAL COSTS (ANNUAL)
PERMIT NO. 1

BOD,
TSS
Fecal Coliform
Oil and Grease
Total
Times
Per Year
104
104
104
104

Unit
CostfS)
30
15
15
35

Annual
Cost($)
3420
1,560
1,560
3.640
9,880

PERMIT ANALYTICAL COSTS (ANNUAL)
PERMIT NO. 2
Priority Pollutants
Phenols
BOD5
TSS
BTX
Nickel
Chromium
Copper
Lead
Zinc
Cyanide
Hardness
Total
Times
Per Year
4
52
156
156
52
156
156
156
156
156
52
156
Unit
CostfS)
1,250
50
30
15
100
15
15
15
15
15
35
15
Annual
Cost(S)
5,000
2,600
4,680
2,340
5,200
2,340
2,340
2,340
2,340
2,340
1,820
2.340
35,680
9-10
-------
QUALITY ASSURANCE/QUALITY CONTROL

Standard operating procedures manual

Standard test protocols

Reference toxicant testing

Chain-of-custody

Laboratory certification

What is reported

When is information reported

Who is responsible for reporting

What format is used for reporting

How long are records kept

What kind of records

Where are the records maintained

Who keeps the records
9-11
-------
-------
MUNICIPAL NPDES PERMIT
DEVELOPMENT
-------
-------
LEARNING OBJECTIVES

Permit applications

Development of effluent limits

Special conditions

Pretreatment
Sludge
Combined Sewer Overflows (CSOs)

Key responsibilities of the municipal permit writer
SOURCES OF FACILITY INFORMATION

Application Form 1 and Form A (2A)

Supplemental information (sludge, toxicity, pretreatment, CSOs)

Construction grants - "NEEDS"

Solid waste agencies

Pretreatment program submission

Annual pretreatment performance report

Pretreatment audit/PCI
NOTES:
10-1
-------
TECHNOLOGY-BASED REQUIREMENTS FOR
MUNICIPAL DISCHARGERS SECONDARY TREATMENT
(40 CFR PART 133)
30 Dav Avg. 7 Dav Avg.
5 - Day BOD

85% BOD, and TSS
45mg/l

45mg/I
EXCEPTIONS/ALTERNATIVES TO SECONDARY
TREATMENT REQUIREMENTS
Substitution of CBOD5 for BOD5
Substitution of COD or TOC for BOD
5
[§133.102(a)(4))]
[§133.104(b)]
Adjustments to reflect:

Combined sewers
Industrial wastes
Waste stabilization ponds
Less concentrated influent for separate
sewers
Less concentrated influent for combined
sewers

Treatment Equivalent to Secondary
[§§133.103(a-e)]
[§133.105]
Waiver from secondary treatment for marine [§§125.56-125.67]
discharges
10-3
-------
EQUIVALENT TO SECONDARY

Must be trickling filter or lagoon

Biological treatment = 51+% treatment

Plant exceeds 30/30 with proper O & M

Water quality not adversely affected
E.T.S. limits:

Up to 45 mg/1 (30 day average)
Up to 65 mg/1 (7 day average)
Not less than 65% removal

Guidance distributed December 1985
PRETREATMENT PROGRAM REQUIREMENTS

What is pretreatment

Statutory authority
RoleofthePOTW
NPDES permit requirements
NOTES:
10-3
-------
NATIONAL PRETREATMENT PROGRAM

Major goal is controlling discharges in order to:

Prevent interference with POTW processes
Prevent pass through of pollutants
Protect sludge management options

Additional programmatic goals

Encourage recycling and reclamation
Ensure POTW personnel health and safety
NOTES:
10-4
-------
STATUTORY AUTHORITY - CLEAN WATER ACT

Section 307(b) - National Pretreatment Standards

Basis for technology-based National pretreatment
standards and general and specific prohibitions to prevent
pass through and interference
Provision for adjustment of technology-based standards
to account for POTW removal (through removal credits)

Section 402(b)(S) - NPDES Permit Requirements

POTWs must identify indirect dischargers
POTWs must establish local programs to ensure
compliance with pretreatment standards by indirect
dischargers
REGULATORY REQUIREMENTS - GENERAL
PRETREATMENT REGULATIONS
(40 CFR PART 403)

Prevent pass through
Prevent interference, including protection of sludge use
and disposal
Promote reuse and reclamation of effluents and sludges

National Pretreatment Standards
Requirements for POTW and State programs
Industrial and POTW reporting requirements

Effluent Limitations Guidelines (40 CFR 405-471)

Including categorical pretreatment standards
10-5
-------
NATIONAL PRETREATMENT STANDARDS

Prohibited discharge standards

National categorical pretreatment standards

Local limits
PROHIBITED DISCHARGE STANDARDS

General prohibitions

Specific prohibitions
NOTES:
10-6
-------
SPECIFIC PROHIBITED DISCHARGES [§403.5(b)]

Fire/explosive hazard

Flashpoint less than 140°F/60°C

pH lower than 5.0

Solid or viscous substances which obstruct flow to the POTW

Any pollutant (including BOD) at flow or concentration rate which
interferes with the POTW

Thermal discharges causing headworks to exceed 104°F/40°C,
unless POTW designed for such temperatures

Petroleum/mineral oils causing interference or pass through

Pollutants which create toxic gases/fumes causing worker health and
safety problems

Trucked or hauled wastes except at points designated by the POTW

Generally, treatment cannot be achieved by dilution
NOTES:
10-7
-------
NATIONAL CATEGORICAL PRETREATMENT
STANDARDS

Uniform, technology-based requirements for industries
in specific industrial categories
LOCAL LIMITS

Locally established limits, designed to implement the general
and specific prohibitions and achieve environmental objectives

Protection of water quality
Protection of sludge quality
Plant operations (e.g., inhibition)
Worker health and safety
Air emissions (future?)
NOTES:
10-8
-------
OVERVIEW OF PRETREATMENT PROGRAM PROCESS
Region/State
Identifies
POTWs
POTW Notified,
Requirement in
NPDES Permit
POTW Performs
Developmental
Work
POTW Prepares
and Submits
Program
Document
• Rejects-
Region/State
Performs
PCI/Audit
^
^
Region/State
Requires
Implementation
In NPDES Permit
^

POTW Becomes
Control
Authority
^Approves -j
Region/State
Reviews POTW
Program
Document
NOTES:
10-9
-------
PRETREATMENT PROGRAM DEVELOPMENT
Who?
POTWs > 5 MGD
POTWs < 5 MGD with past problems
What?
Legal authority
Industrial user survey
Individual control mechanisms for all SIUs
Compliance/enforcement
Resources
Data management
NPDES PERMITS DRIVE THE PRETREATMENT
PROGRAM BY REQUIRING:

Adequate legal authority

Maintain industrial user inventory

Develop/implement local limits

Issue individual control mechanisms to all SIUs

Conduct compliance monitoring activities

Take swift and effective enforcement

Perform data management and recordkeeping

Report to the approval authority (EPA or State)

Ensure public participation
10-10
-------
KEY RESPONSIBILITIES OF THE
MUNICIPAL PERMIT WRITER

Write a good permit

Identify need for, and set where appropriate, water quality-based
controls

Chemical-specific
WET

Incorporate pretreatment requirements

Incorporate sludge requirements

Incorporate CSO controls

Coordinate permit issuance with the pretreatment, sludge and
CSO coordinator/expert
NOTES:
10-11
-------
Organization of the Pretreatment Program and
Summary of Responsibilities
EPA Headquarters
Oversee Program Impiementarion at All Levels
Develop and Modify Regulations for the Presentment Program
Develop Policies to Clarify and Further Define the Program
Develop Technical Guidance for Program Implementation
Initiate Enforcement Action as Appropriate.
EPA Regions
• Fulfill Approval Authority Responsibilities for States without Program Delegation
• Oversee Slate Program Implementation
• Initiate Enforcement Actions as Appropriate.
Approval Authorities
(NPDES States with Pretreatment Program Delegation)
Notify POTWs of Their Responsibilities
Review and Approve POTW Pretreatment Programs
Review Modifications to Categorical Pretreaiment Standards
Oversee POTW Program Implementation
Provide Technical Guidance to POTWs
Regulate industries in Nonpretreatment Cities
Initiate Enforcement Action Against Noncompliant POTWs or Industries.
Control Authorities
(POTWs with an Approved Pretreatment Program)

Develop and Maintain an Approved Pretreaiment Program
Evaluate Compliance of Regulated Industrial Users
Initiate Enforcement Action Against Industries as Appropriate
Submit Reports to Approval Authority.
Develop Local Limits (or demonstrate that they arc not necessary)
Develop and Implement an Enforcement Response Plan
Industrial Users

• Comply with Applicable Pretreatment Standards: Prohibited Discharge Standards.
Categorical Standards. State Requirements, and Local Limits
• Comply with Federal and POTW Reporting Requirements.
10-12
-------
1.
2.
3.
4.
PRESENTATION PREVIEW
What is hazardous waste?
NPDES pretreatment implications
POTW RCRA permit -by-rule
Available guidance

ONLY "SOLID" WASTES CAN BE
HAZARDOUS WASTES
Solid wastes - any material which is:
Abandoned for disposal
Burned
Stored (even if to be reused later)
Treated/reconditioned
Accumulated for speculation
• Exclusions
Wastes regulated by other Federal law
NPDES effluents
Radioactive materials
Sludge (depends on disposal practice)
Domestic sewage and any other wastes which mix with
domestic sewage in sewer
NOTES:
10-13
-------
RCRA REQUIREMENTS ASSUME THAT:

NPDES (secondary treatment) and pretreatment (local limits,
categorical standards, and prohibited discharges) adequately
address wastes being discharged to sewer systems
SOLID WASTES ARE HAZARDOUS WASTES IF:

They exhibit hazardous characteristics

Ignitable (flashpoint <140°F)
Corrosive (pH <2.5 or >12.5)
Reactive (unstable in water)
Toxic (TCLP test - 40 substances)
Exclusion for household wastes and special recycled
wastes: sludge conditioner or treatment aid at POTW

The waste/or process is listed in Federal or State regulations
NOTES:
10-14
-------
FOUR TYPES OF LISTED WASTES
1. Generic industrial sources (21)

2. Specific industrial processes (88)

3. Acutely hazardous chemicals (204)

4. Toxic (known characteristic wastes) (454)
PRESSURES TO DISPOSE OF HAZARDOUS
WASTES AT POTWS

Land ban and RCRA closure requirements make self-disposal
costly/impossible

Limited number of permitted TSDFs

Domestic sewage exclusion is attractive to generators

Increasing number of CERCL A cleanups approaching POTWs
for partial treatment
NOTES:
10-15
-------
NPDES PERMIT IMPLICATIONS OF
ACCEPTING HAZARDOUS WASTES

Inhibition of biological treatment (permit violation)

Pass through (permit violation)

Sludge contamination (permit violation)

Possible worker health and safety effects

Increased self-monitoring

Report new/changed influent

NPDES permit modification
PRETREATMENT IMPLICATIONS OF
ACCEPTING HAZARDOUS WASTES

Local limits analysts needed to determine acceptability of
waste

Local limits development

Designating and monitoring a receiving point for wastes

Treating the source as SIU: permitting, monitoring, tracking
and enforcement

New multijurisdictional issues
NOTES:
10-16
-------
RCRA IMPLICATIONS OF
ACCEPTING HAZARDOUS WASTES

POTW has duty to inform potential generators of RCRA
requirements for manifesting waste and proper disposal

Treating, storing, or disposing hazardous wastes requires
RCRA permit

POTWs having releases of hazardous wastes or hazardous
constituents may have to undertake corrective action

POTWs whose sludge is a characteristic waste must
manifest and dispose at a TSD facility
REQUIREMENTS FOR POTWs WITH RCRA
PERMITS-BY-RULE

NPDES permit/compliance with permit conditions

Waste received by POTW must comply with alt pretreatment
requirements

EPA hazardous waste facility identification number

Hazardous waste manifest system and written operating
record at facility

Biannual reports to State or EPA region waste management
division
NOTES:
10-17
-------
CONTENTS OF PERM IT-BY-RULE RIDER PERMITS

• Reporting duties:

Sample wastes
Report findings

• Corrective action duties:

Interim emergency measures
Provide data and facility access
Develop C.A. plan/reopener
Implement plan within date certain
RIDER PERMIT ISSUANCE PROCESS

Duration -10 years

Use RCRA procedures

Consolidate with NPDES when possible

Consolidation requires cooperation between programs

State program issuance complexities
NOTES:
10-18
-------
AVAILABLE RCRA/CERCLA GUIDANCE

RCRA information on hazardous wastes for POTWs (9/85)

Guidance for the identification of hazardous wastes delivered
to POTWs by truck, rail or dedicated pipe (6/87)

Guidance for implementing RCRA permit-by-rule requirements
at POTWs (7/87)

Policy on the discharge of wastewater from CERCLA sites
into POTWs (4/86)
POTW AS A HAZARDOUS WASTE GENERATOR

Effluent or sludge is hazardous

Contains listed waste
Exhibits characteristics

Manifest wastes
Send to permitted TSDF
Hold long-term liability
NOTES:
10-19
-------
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MUNICIPAL SLUDGE
PERMIT CONDITIONS
-------
-------
LEARNING OBJECTIVES
Definition of sludge

Statutory requirements

Interim program

Implementation procedures

Long term program
NOTES:
11-1
-------
DEFINITION OF SEWAGE SLUDGE

Any solid, semisolid, or liquid residue removed during the
treatment of municipal wastewater or domestic sewage. Sewage sludge
includes, but is not limited to, solids removed during primary, secondary, or
advanced wastewater treatment, scum, septage, portable toilet pumpings,
type ni marine sanitation device pumpings (33 CFR Part 159) and sewage
sludge products. Sewage sludge does not include grit or screenings, or
ash generated during the incineration of sewage sludge. 40 CFR 122.2
VOLUME OF SLUDGE PRODUCED IN THE U.S.
2.7 million
dry metric tons
(1989)
NOTES:
11-2
-------
WATER QUALITY ACT OF 1987
SLUDGE USE AND DISPOSAL §405

EPA will develop technical standards for proper use and
disposal (expected July 1992)

Technical standards will be implemented primarily
through NPDES program

Interim NPDES permit conditions will be based on case-by-case
judgment of permit writer

Non-NPDES POTWs and other treatment works regulated
through separate sludge-only permit
SCOPE OF INTERIM PROGRAM

Permits for all NPDES POTWs issued after 2/4/87 will address
sludge use and disposal

As needed to protect public health and the environment EPA
may regulate

End users
Industrial facilities which treat domestic waste
Privately owned treatment works
Federal facilities

Class I sludge management facilities must receive special
attention
NOTES:
11-3
-------
ALL POTW PERMITS MUST CONTAIN:
Standard conditions (§122.41)

Minimum monitoring and reporting (§122.44)

Applicable existing sludge requirements
Landfill/land application
40 CFR Part 257

Incineration
40 CFR Parts 60 and 61
40 CFR Part 761
CONDITIONS FOR ALL PERMITTED FACILITIES

General duty to comply with existing requirements/future
Part 503 (§122.41(a)(l))

Reopener once Part 503 standards are promulgated (§122.44(c)(4))

Duty to mitigate (§122.41 (d))

Records retention (5 years) (§ 122.41 (j)(2))

' Notification requirements for significant changes to use and disposal
Reopener for changed conditions (§122.62(a)(l))

Analytical methods (§122.41(j)(4))
NOTES:
11-4
-------
CLASS I SLUDGE MANAGEMENT FACILITIES

Any POTW required under 40 CFR 403.8(a) to have an
approved pretreatment program, including POTWs covered
under 403.10(e) State program

Any other treatment works treating domestic sewage which
have been designated by EPA and approved State programs
as priorities (e.g., POTWs which incinerate sludge)
CLASS I FACILITY PERMITS MUST CONTAIN:

Standard conditions (§122.41)

Applicable existing sludge requirements (§122.44)

Other conditions necessary to protect health and the
environment developed on a case-by-case basis

Regulate additional pollutants
Prescribe management practices/siting characteristics
More than minimum monitoring
Restrict public access
Ground-water protection measures "
NOTES:
11-5
-------
SELF-MONITORING AND REPORTING
RECOMMENDATIONS

Non-Class I/no industry

Annual metals scan (Cd, Pb, Ni, Zn, Cr, Cu)

Non-Class I/industry

Priority scan at application
Annual 503 scan
Class I
Annual priority pollutant scan
503 pollutants periodically
SUPPLEMENTAL APPLICATION INFORMATION*

• Sludge profile - quality and quantity

• Other sludge permits held

• Topographical map of sludge disposal sites

• Narrative description of disposal practices

• Identify other entities handling sludge

>§122.21(d)(3)(ii) and §50U5(a)(2)
NOTES:
11-6
-------
SOURCES OF SLUDGE FACILITY INFORMATION

• National survey • results released November 1990 (55 Fed. Reg. 47210)

> Other Federal and State sludge/solid waste agencies

Pretreatment program submission and audit reports

• Compliance inspection reports

• Public health agencies

Construction grants database

> Agricultural agencies

208 basin plans

RCRA 4003 solid waste plan
EPA/STATE INTERIM AGREEMENTS

All States may participate

Establishes responsibility for interim program implementation

Permitting
Compliance monitoring
Enforcement
Information exchange

EPA responsible for interim permitting in the absence of
EPA/State agreements
NOTES:
11-7
-------
STATE PERMIT ISSUANCE PROCEDURES

State permits must notice that conditions are Federally
enforceable

Fact sheet must also note Federal enforceability

EPA reviews all Class I facility permits and affirmatively
approves sludge conditions

Region must affirmatively approve the permit (letter or
certification)
EPA ALTERNATIVES FOR ISSUANCE
IN NPDES STATES

Attach sludge-only "rider" conditions to State permits

Follows state process and procedures

Separate sludge permit

NPDES permit (402 and 405)
NPDES procedures
NOTES:
11-8
-------
LONG TERM REGULATORY PROGRAM

Part 503 - Sewage Sludge Technical Standards

Land application
Incineration
Monofills
Distribution and marketing
Surface disposal

Part 258 - Municipal Solid Waste Landfills

Management practices
Financial responsibility
Siting criteria

Promulgated: October 9,1991 (56 FR 50977)
NOTES:
11-9
-------
LONG TERM PROGRAM - PART 503

Health/environmental-based standards

Sludge quality
Management practices
Siting requirements
Implemented primarily through NPDES permits

Land application (42%)

Agricultural lands
Nonagricultural lands
Distribution and marketing (6%)

Incineration (14%)

Monofllls and surface disposal (2%)

Domestic septage

Court ordered promulgation by January 1992
NOTES:
11-10
-------
PART 503 COMPLIANCE DEADLINES

Within 1 vear of promulgation of the regulations

Within 2 years, if construction of new pollution control facilities is
required
TOOLS AVAILABLE TO ASSIST PERMIT WRITERS

NPDES/sIudge permitting and State program regulations
54 Fed. Reg. 18716 (5/2/89)

Sludge permitting strategy, OW (9/89)

• Case-by-case permitting guidance, OWEC (5/90)

• Guidance on sampling and analysis of municipal sewage sludge,
OWEC (8/89)

Proposed technical criteria 54 Fed. Reg. 5746 (2/6/89)
NOTES:
11-11
-------
-------
STORM WATER PERMITTING
-------
-------
LEARNING OBJECTIVES
Storm Water Program Overview

Industrial Requirements

Municipal Requirements
NOTES:
12-1
-------
WATER QUALITY IMPACTS
ATTRIBUTABLE TO STORM WATER

Naturally, pollution from diffuse sources such as runoff from
agriculture and urban areas are the leading causes of water quality
impairment

Diffuse pollution sources are increasingly important as controls
for industrial process dischargers and POTWs are implemented

38 States have reported urban runoff as a major cause of use
impairment

21 States report construction site runoff as a major cause of use
impairment

In some municipalities, illicit connections to separate storm sewers
have had a significant adverse impact. Removing illicit discharges
presents opportunities for dramatic improvement in the quality
of storm water discharges from urban areas.

One study showed that 14% of the buildings studied within a
drainage basin had improper connections to storm sewers;
connections approved when the structures were built.
NOTES:
12-2
-------
CLEAN WATER ACT REQUIRES PHASED APPROACH
FOR PERMITTING STORM WATER DISCHARGES

• Prior to 10/1/92, storm water permits are only required for:

Storm water regulated under an existing permit
Storm water that is associated with an industrial activity
Storm water that is discharged from municipal separate
storm sewers serving 100,000 or more persons
Administrator or State Director may designate, for permitting,
storm water discharges contributing to a violation of water
quality standards or which are significant contributors of
pollutants

All other storm water discharges are the subject of 2 EPA studies,
and subsequent regulation after 10/1/92
NOTES:
12-3
-------
STORM WATER DISCHARGE ASSOCIATED WITH
INDUSTRIAL ACTIVITY

• Discharge from any conveyance which is used for collecting
and conveying storm water

• Directly related to manufacturing, processing, or raw materials
storage areas

• Located at an industrial plant

• Other industrial facilities and operations
APPLICATION REQUIREMENTS FOR STORM WATER
DISCHARGES ASSOCIATED WITH
INDUSTRIAL ACTIVITY

• Discharges of storm water associated with industrial activity are
required to either:

Apply for an individual permit (Form 2F),

Apply for a permit through a group application, or

Seek coverage under a storm water general permit
using notice of intent
NOTES:
12-4
-------
INDUSTRIAL STORM WATER PERMIT
APPLICATION DEADLINES

Individual:
Group:
General
Permit NOI:
Construction:
October 1,1992
Parti
September 30, 1991
180 Days from
General Permit
Issuance
90 Days Prior to
Initiation of
Construction

Review Period Part 2
60 days May 18, 1992
(proposed October 1, 1992)

Estimated coverage: 100,000 facilities
STATUTORY REQUIREMENTS FOR INDUSTRIAL
STORM WATER PERMITS
Permits must require the achievement of CWA 301 [effluent
limitations (BAT/BCT)] and water quality-based limitations

Permitted industries must continue to meet all existing
requirements of CWA 402
NOTES:
12-5
-------
MUNICIPAL SEPARATE STORM SEWER SYSTEMS

Large system - serving a population of 250,000 or more

• Medium system - serving a population of 100,000 or more, but less
than 250,000
MUNICIPAL PERMIT APPLICATION DEADLINES

Medium
Municipalities
Large
Municipalities
Parti
May 18, 1992
November 18,
1991
Review Period
90 Days
90 Days
Part 2
May 17, 1993
November 16,
1992
Estimated coverage: 173 Cities and 47 Counties
NOTES:
12-6
-------
STATUTORY REQUIREMENTS FOR MUNICIPAL
SEPARATE STORM SEWER SYSTEM PERMITS

System or jurisdiction-wide permits allowed

Effectively prohibit non-storm water discharges into storm
sewers

Controls to reduce discharge of pollutants to MAXIMUM EXTENT
PRACTICABLE (MEP)
NOTES:
12-7
-------
-------
COMBINED SEWER OVERFLOW (CSO)
PERMITTING
-------
-------
LEARNING OBJECTIVES

Permitting Requirements
NOTES:
13-1
-------
cso
Definition

CSOs are flows from a combined sewer in excess of the interceptor
or regulator capacity that are discharged into a receiving water without
going to a Publicly Owned Treatment Works (POTW).

• CSOs are point sources

• CSOs are not bypasses

• CSOs are not subject to secondary treatment regulations

CSOs are subject to BCT and BAT and State water
quality standards
NOTES:
13-2
-------
0
O)
«C

if
13-3
-------
CSO URBANIZED AREAS
13-4
-------
CSO PERMIT APPLICATION FORMS

I • Form 2A - Permitted in conjunction with a POTW

Form 2C • Permitted separately from a POTW
NOTES:
13-5
-------
NOTES:
THE CSO CONTROL STRATEGY REQUIRES

States to develop CSO permitting strategies by January 15,1990

Regions to approve State CSO permitting strategies by March 31,1990
CSO PERMITS
Permit issuance
Minimum technology-based limitations
Additional CSO control measures
Monitoring
13-6
-------
MINIMUM BCT/BAT LIMITATIONS

Prohibition of dry weather overflows;

Proper operation and regular maintenance programs for the
sewer system and combined sewer overflow points;

Maximum use of the collection system for storage;

Maximization of flow to the POTW for treatment;

Review and modification of pretreatment programs to assure
CSO impacts are minimized; and

Control of solid and floatable materials in CSO discharges.
NOTES:
13-7
-------
-------
SPECIAL PERMIT CONDITIONS
-------
-------
1
LEARNING OBJECTIVES

Additional nonregulatory monitoring

Compliance schedules in permits

Best management practices
ADDITIONAL NONREGULATORY MONITORING
Used to supplement controls

Used to collect data for future limit development
NOTES:
1.4-1
-------
NOTES:
COMPLIANCE SCHEDULES
40 CFR §122.47
Allows for establishing schedules of compliance that lead to
compliance with C WA and regulations

Interim dates if schedule exceeds 1 year from permit
issuance

Reporting 14 days following each interim date
U-2
-------
BEST MANAGEMENT PRACTICES
LEGISLATIVE AUTHORITY

The Administrator.. .may publish regulations supplemental
to effluent limitations for a class or category of point
sources for toxic or hazardous pollutants under Section 307(a)
or 311 of the Act to control:

Plant site runoff
Spillage or leaks
Sludge or waste disposal
Drainage from raw material storage

.. .which are associated with or ancillary to the industrial
manufacturing or treatment process and may contribute
significant amounts of such pollutants to navigable waters.

Section 402(a)(l)

In the absence of BMPs promulgated for a category of point
sources (such as steel mills, petroleum refiners, etc.) under
authority of Section 304(e), permit writers may use the authority
of Section 402(a)(l) to place BMPs in permits on a case-by-case
basis
NOTES:
14-3
-------
USE BM Ps WHEN . . .
Numerical limits are infeasible
In lieu of chemical analysis

Where history of leaks and spills exists

Housekeeping is sloppy

Facility is complex and toxic pollutant data lacking

Other options are too expensive
BMPs IN NPDES PERMITS
BMP plan
Site-specific BMPs

Facility-specific
Pollutant-specific
NOTES:
14-4
-------
MINIMUM REQUIREMENTS OF A BMP PLAN

• General requirements

Name and location of facility
Statement of BMP policy and objectives
Review by plant manager

• Specific requirements

BMP committee
Risk identification and assessment
Reporting of BMP incidents
Materials compatibility
Good housekeeping
Preventive maintenance
Inspections and records
Security
Employee training

Most effectively used in conjunction with effluent limitations
in permits

NOTES:
14-5
-------
FLEXIBLE
Visual inspections,
Non-destructive testing, or
A dike or berm
PROCEDURAL
Conduct routine training

Maintain maintenance logs

Perform routine wall-thickness testing
QUALITATIVE

BMPs generally tell haw. or what, not how much
BUT BMPS ALSO MAY BE:
Construction
Instrumentation
Monitoring

Operation and maintenance
NOTES:
14-6
-------
BMPs SHOULD NOT:

Substitute for quantitative controls

Tell managers how to run their plants

Require costly methods when inexpensive ones will suffice
GENERIC BMPs
Preventive maintenance

Water conservation/non-use

Secondary containment

Nondestructive testing

Materials engineering

Materials handling

Visual inspections

Waste stream segregation
Source elimination

Good housekeeping

Sludge management

Security
NOTES:
14-7
-------
14-8
-------
160A/Disk #1 - 11/4/91 - 1:25 PM
NPDES
Best Management Practices
GUIDANCE DOCUMENT
U.S. Environmental Protection Agency
Office of Water Enforcement and Permits
NPDES Technical Support Branch

June 1981
-------
l60A/Disk #1 - 11/4/91 - 1:26 PM

During the period June 13, 1978, to February 26, 1979, Hydroscience, Inc., under
Contract No. 68-03-2568 to the Environmental Protection Agency (EPA), gathered
information leading to the identification of best management practices (BMPs) currently used
by industry. The result of the data gathering and analysis by Hydroscience, Inc. was a draft
report entitled "NPDES Best Management Practices Guidance Document" EPA 600/9-79-
045. In response to keen public interest in the draft report, EPA made the report available to
the public and provided a 45-day comment period. The comment period subsequently was
extended twice, resulting in a total 120-day comment period on the report. After evaluating
the comments received, EPA revised the draft report, and published the final document. This
document supersedes the Hydroscience draft report dated December, 1979.
14-10
-------
160A/Disk #1 - 10/18/91 - 1:21 PM

The purpose of this document is to assist National Pollutant Discharge Elimination
System (NPDES) permitting authorities, compliance officers, and permit applicants to
develop Best Management Practices (BMP) plans for industry. BMPs are authorized under
the 1977 Clean Water Act for the control of discharges to receiving waters of significant
amounts of any pollutant listed as hazardous under Section 311 of the Act or toxic under
Section 307 of the Act from activities which are associated with or ancillary to industrial
manufacturing or treatment processes. The general types of discharges to be controlled by
BMPs are plant site runoff, spillage and leaks, sludge and waste disposal and drainage from
material storage areas.

This document provides a basis for developing BMP plans. The proper use of the
document requires engineering experience with industrial manufacturing and treatment
processes and knowledge of current laws and regulations applicable to NPDES permits, BMP
plans, and Spill Prevention, Control, and Countermeasure (SPCC) plans.

The guidance herein is based on a review by Hydroscience, Inc. (EPA Contract No. 68-
03-2568) of current practices used by industry to control the non-routine discharge of toxic
pollutants and hazardous substances. Included in the review are published articles and
reports, technical bulletins (also termed material safety data sheets) on specific compounds,
and discussions with industry through telephone contacts, written questionnaires, and site
visits.
14-11
-------
160A/Disk #1 - 10/18/91 - 1:24 PM

SECTION I
INTRODUCTION

BACKGROUND
The Federal Water Pollution Control Act Amendments of 1972 established the objective
of restoring and maintaining the chemical, physical, and biological integrity of the Nation's
waters. This objective has remained unchanged in the 1977 amendments to the Act,
commonly referred to as the Clean Water Act of 1977, hereinafter "the Act." To achieve this
end, the Act sets forth a series of goals, including the goal of eliminating the discharge of
pollutants into navigable waters by 1985. The principal mechanism for reducing the discharge
of pollutants from point source is through implementation of the National Pollutant Discharge
Elimination System (NPDES) established by Section 402 of the Act.

At the time of first round NPDES permit issuance, conventional pollutants (BOD, pH,
TSS, etc.) were considered the parameters which most urgently needed controls. In second
round permitting, however, the Agency emphasis is shifting from the conventional pollutants
to the control of toxic pollutants and hazardous substances.

Traditionally, NPDES permits have contained chemical-specific numerical effluent
limits. Effluent guidelines are not always available to prescribe these effluent limits nor to
guarantee water quality sufficient for the protection of indigenous aquatic life. To improve
water quality, the Act provides for water pollution controls supplemental to effluent
limitations guidelines. Best Management Practices (BMPs) are one such supplemental
control. Pursuant to sections 304 and 402 .of the Act, BMPs may be incorporated as permit
conditions. In the context of the NPDES program, BMPs are actions or procedures to prevent
or minimize the potential for the release of toxic pollutants or hazardous substances in
significant amounts to surface waters. BMPs, although normally qualitative, are expected to
be most effective when used in conjunction with numerical effluent limits in NPDES permits.

STATUTORY AUTHORITY
Section 304(e) of the Act authorized the Administrator to publish regulations to control
discharges of significant amounts of toxic pollutants listed under Section 307 or hazardous
substances listed under Section 311 from activities which the Administrator determines are
associated with or ancillary to industrial manufacturing or treatment processes. The
discharges to be controlled by BMPs are plant site runoff, spillage or leaks, sludge or waste
disposal, and drainage from raw material storage.
14-12
-------
160A/Disk #1 - 10/18/91 - 1:24 PM

Section 402(a)(l) of the Act allows the Administrator to prescribe conditions in a
permit determined necessary to carry out the provisions of the Act. BMPs are one such
condition.

BMPs are intended to complement other regulatory requirements imposed by RCRA,
OSHA, the Clean Air Act, and SPCC plans for hazardous substances under the Clean Water
Act. Pursuant to Section 311 of the Act, EPA has proposed (40 CFR Pan 151) requirements
for SPCC plans to prevent discharges of hazardous substances from facilities subject to
NPDES permitting requirements. The guidelines proposed for hazardous substances SPCC
plans are very similar to those required for oil SPCC plans in the Oil Pollution Prevention
Regulations, (40 CFR Part 112). Since the Agency has received favorable comments about
the Oil Pollution Prevention Regulations, the NPDES BMP regulation has been structured to
be similar to the oil SPCC regulation.

BMP REGULATORY HISTORY
On September 1, 1978, EPA proposed regulations (43 FR 39282) addressing the use of
procedures to control discharges from activities associated with or ancillary to industrial
manufacturing or treatment processes. The proposed rule indicated how best management
practices would be imposed in NPDES permits to prevent the release of toxic and hazardous
pollutants to surface waters. The proposed regulation was incorporated as "40 CFR Pan
125, Subpart L - Criteria and Standards for Best Management Practices Authorized Under
Section 304(e) of the Act" on the August 21, 1978, proposed NPDES regulations (43 FR
37078). A 60-day comment period on proposed Subpart L was provided.

After evaluating the comments received on the proposed regulation, EPA revised
Subpart L and promulgated the regulation as Subpart K (44 FR 32954-5) on June 7, 1979.
Industries regulated by Subpart K were to develop a BMP program and submit the program
with their permit application. Subpart K stated that information on the development of BMP
programs was contained in a publication entitled "NPDES Best Management Practices
Guidance Document." Subpart K was to become effective on August 13, 1979. However,
publication of the report was delayed beyond August 13, 1979. Therefore, on August 10,
1979, EPA deferred applicability of the BMP portions of the NPDES regulations until 60 days
after publication in the Federal Register of a notice of availability of the final document (44 FR
47063). EPA announced on March 20, 1980 the availability of the draft report and provided a
45-day comment period (45 FR 17997), which subsequently was extended twice, resulting in
a 120-day comment period on the report. Based on public comments on the draft report and
14-13
-------
l60A/Disk #1 - 10/18/91 - 1:24 PM

further discussion with industry, the Agency revised the draft report and published this
guidance document.
FINAL BMP REGULATION
FINAL GUIDANCE DOCUMENT
[Reserved]
[Reserved]
14-14
-------
160A/Disk #1 - 10/18/91 - 1:25 PM
SECTION II
USE OF THE GUIDANCE DOCUMENT
This document should be used for guidance in developing BMP plans. The document is
not intended to specify site-specific or pollutant-specific BMPs. As its name suggests, the
NPDES Best Management Practices Guidance Document is to be considered guidance by
NPDES permitting authorities, compliance officers, permit applicants and permittees and
should be used in a flexible manner in the formulation of BMP plans. Consequently, the
document identifies elements of each specific requirement that should be considered in the
development of the BMP plan, but does not require that each element be included in every
facility's BMP plan.

In utilizing this document to develop a BMP plan, the applicant/permittee is encouraged
to use the most cost-effective and innovative techniques to fit the particular facility or
circumstances. The format and content of a BMP plan may vary from site to site and industry
to industry, depending upon the specific situation. In addition, an applicant/permittee may
add, delete, or modify the elements of the specific requirements presented in the document
where equivalent results can be attained.

If an applicant/permittee needs assistance to develop a BMP plan, he or she may
contact the appropriate permit issuing authority for advice. The permitting authority, as
necessary, may seek assistance from the Technical Program Development Section of the
NPDES Technical Support Branch in Washington, D.C.
14-15
-------
!60A/Disk#l - 10/18/91 - 1:51 PM

SECTION III
BMP PLANS

SCOPE
The activities which are associated with or ancillary to the industrial manufacturing or
treatment process are subject to BMPs. For brevity, all such activities are referred to as
"ancillary sources." The ancillary sources at the plant should be examined to determine if
there is a reasonable potential for equipment failure (e.g., spillage or leakage), natural
conditions (e.g., plant site runoff or drainage from raw material storage), or other
circumstances (e.g., sludge or waste disposal) which could result in the discharge of a
significant amount of toxic pollutants or hazardous substances to receiving waters. The
ancillary sources are divided for discussion in this document into five categories: material
storage areas; loading and unloading areas; plant site runoff; in-plant transfer, process, and
material handling areas; and sludge and hazardous waste disposal areas.

Material storage areas include storage areas for toxic and hazardous chemicals as raw
materials, intermediates, final products or byproducts. Included are: liquid storage vessels
that range in size from large tanks to 55-gallon drums; dry storage in bags, piles, bins, silos,
and boxes; and gas storage in tanks and vessels.

Loading and unloading operations involve the transfer of materials to and from trucks or
railcars but not in-plant transfers. These operations include pumping of liquids or gases from
truck or railcar to a storage facility or vice versa, pneumatic transfer of dry chemicals to or
from the loading or unloading vehicle, transfer by mechanical conveyor systems, and transfer
of bags, boxes, drums, or other containers from vehicles by fork-lift trucks or other materials
handling equipment.

Plant runoff is generated principally from rainfall on a plant site. Runoff from material
storage areas, in-plant transfer areas, loading and unloading areas, and sludge disposal sites
potentially could become contaminated with toxic pollutants and hazardous substances.
Heavy metals from sludge disposal sites are of special concern. Fallout, resulting from the
plant air emissions which settle on the plant site, may also contribute to contaminated runoff.
Contaminated runoff may reach a receiving body of water through overland flow, drainage
ditches, storm or noncontact cooling water sewers, or overflows from combined sewer
systems.
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In-plant transfer areas, process areas, and material handling areas encompass all in-
plant transfer operations from raw material to final product. Various operations could include:
transfer of liquids or gases by pipelines with appurtenances such as pumps, valves, and
fittings; movement of bulk materials by mechanical conveyor-belt systems; and fork-lift truck
transport of bags, drums, and bins. All transfer operations within the process area with a
potential for release of toxic pollutants and hazardous substances to other than the process
waste water system are addressed in this grouping.

Sludge and hazardous waste disposal areas are potential sources of contamination of
receiving waters. These operations include landfills, pits, ponds, lagoons, and deep-well
injection sites. Depending on the construction and operation of these sites there may be a
potential for leachate containing toxic pollutants or hazardous substances to seep into
groundwater, eventually reaching surface waters, or for liquids to overflow to surface waters
from these disposal operations. BMP requirements are not intended to duplicate the
requirements of RCRA. Actions taken for compliance with RCRA may be referenced in the
BMP plan.

MINIMUM REQUIREMENTS
BMPs may include some of the same practices used by industry for pollution control,
SPCC plans for oil and hazardous substances, safety programs, fire protection, protection
against loss of valuable raw materials or products, insurance policy requirements or public
relations. The minimum requirements of a BMP Plan are listed in Table 1 and are divided into
two categories: general requirements and specific requirements.

Table 1. Minimum Requirements of a BMP Plan

A, General Requirements
1. Name and location of facility
2. Statement of BMP policy and objectives
3. Review by plant manager
B. Specific Requirements
1. RMP Committee
2. Risk Identification and Assessment
3. Reporting of BMP Incidents
4. Materials Compatibility
5. Good Housekeeping

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<*•

6. Preventive Maintenance
7. Inspections and Records
8. Security
9. Employee Training

GENERAL REQUIREMENTS
The BMP plan should be organized and described in an orderly narrative format and
should be reviewed by the plant engineering staff and plant manager. A description of the
facility, including the plant name, the type of plant, processes used, and the products
manufactured should be included in the BMP plan. A map showing the location of the facility
and the adjacent receiving waters also should be part of the plan. Specific objectives for the
control of toxic pollutants and hazardous substances should be included in the statement of
corporate policy.

SPECIFIC REQUIREMENTS
Each of the 9 specific requirements listed in Table 1 should be addressed in the BMP
plan. The size and complexity of the BMP plan will vary with the corporate environmental
policy, size, complexity, and location of the facility, among other factors. It is anticipated that
the length and detail of the BMP plan will be commensurate with the quantity of toxic and
hazardous chemicals onsite and their opportunity for discharge. A fundamental concept of the
BMP plan is determining the potential for toxic and hazardous chemicals to reach receiving
waters and taking appropriate preventive measures.

Discussions of the specific requirements are presented on the following pages. Each
specific requirement contains important elements that should be considered in developing a
BMP plan. All elements may not be applicable to all facilities. Elements should be added,
deleted, or modified to fit the needs of a particular facility. Permittees are encouraged to use
innovative techniques to achieve equivalent results.

/. BMP Committee
The BMP Committee is that group of individuals within the plant organization which ;>
responsible for developing the BMP plan and assisting the plant management in H-.
implementation, maintenance, and updating. Thus, the Committee's functions are similar :»>
those of a plant fire prevention or safety committee.
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The scope of activities and responsibilities of the BMP Committee should include all
aspects of the facility's BMP plan, such as identification of toxic and hazardous materials
handled in the plant; identification of potential spill sources; establishment of incident
reporting procedures; development of BMP inspection and records procedures; review of
environmental incidents to determine and implement necessary changes to the BMP plan;
coordination of plant incident response, cleanup and notification of authorities; establishment
of BMP training for plant personnel; and aiding interdepartmental coordination in carrying out
the BMP plan.

Other Committee duties could include review of new construction and changes in
processes and procedures at the facility relative to spill prevention and control. The
Committee can also periodically evaluate the effectiveness of the overall BMP plan and make
recommendations to management on BMP-related matters.

Plant management has overall responsibility for the BMP plan. The plan should contain
a clear statement of the management's policies and responsibilities related to BMPs.
Authority and responsibility for immediate action in the event of a spill should be clearly
established and documented in the BMP plan, with the Committee indirectly involved in that
responsibility. The Committee should advise management on the technical aspects of
environmental incident control, but should not impede the decisionmaking process for
preventing or mitigating spills and incidents.

The size and composition of the BMP Committee should be appropriate to the size and
complexity of the plant and the specific toxic and hazardous chemicals handled at the plant.
Facility personnel knowledgeable in spill control and waste treatment such as environmental
specialists, production foreman, safety and health specialists, and treatment plant supervisor
should be included. In some small plants, the Committee might consist of the one manager or
engineer assigned responsibility for environmental control. For very small facilities, the
Committee function might even have to be fulfilled by competent engineers or managers from
the corporate staff or the nearest large plant.

A list of personnel on the BMP Committee should be included in the BMP plan. The list
should have the office and home telephone numbers of the Committee members and the
names and phone numbers of backup or alternate people.
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Elements of the "BMP Committee," listed below, should be considered in developing a
BMP plan:

• Inclusion of facility personnel knowledgeable in spill control, safety and health, and
waste treatment such as environmental specialists, production foreman, occupational
safety and health specialists, and treatment plant supervisor.
• Responsibility for:
- Providing assistance to plant management for developing a BMP plan
- Providing assistance to plant management in implementing, maintaining, and
updating the BMP plan
- Identifying toxic and hazardous substances
- Identifying potential spill sources
- Establishing BMP incident reporting procedures
- Developing BMP inspections and records procedures
- Reviewing environmental incidents
- Coordinating plant incident response, cleanup, and notification procedures
- Establishing BMP training for plant and contractor personnel
- Providing assistance for interdepartmental coordination in carrying out the BMP
plan
- Reviewing new construction and changes in processes and procedures
- Evaluating the effectiveness of the BMP plan
- Making recommendations to management in support of corporate policy on BMP-
related matters.

2. Risk Identification and Assessment
The areas of the plant subject to BMP requirements should be identified by the BMP
Committee, plant engineering group, environmental engineer, or others in the plant. Each
area should be examined for the potential risks for discharges to receiving waters of toxic
pollutants or hazardous substances from ancillary sources. Any existing physical means
(dikes, diversion ditches, etc.) of controlling such discharges also should be identified.

The areas described above should be clearly indicated on a plant plot plan or drawing. A
simplified materials flowsheet showing major process operations can be used to indicate the
direction and quantity of materials flowing from one area to another. The direction of flow of
potential spills and surface runoff could also be estimated based on site topography and
indicated on the plant site drawings. Dry chemicals which are toxic pollutants or hazardoi^
substances should be evaluated if they have the potential to reach navigable waters :;.
significant quantities via rainfall runoff, for example.
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A hazardous substance and toxic chemical (materials) inventory should be developed
as a part of the "Risk Identification and Assessment." The detail of the materials inventory
should be proportionate to the quantity of toxic pollutants and hazardous substances on site
and their potential for reaching the receiving waters. For example:

1. The plant has determined that materials stored in bulk quantities at a tank farm
have a high potential for reaching the receiving waters in the event of structural
failure or overfills. Therefore, the materials inventory for the tank farm should be
detailed, and should provide the identity, quantities, and locations of each material.
2. The plant has determined that materials stored in small quantities at the research
laboratory have a low potential for reaching the receiving waters. Therefore, the
materials inventory for the laboratory could be minimally detailed, and may not
include the identity, quantity, or location of each material but might include an
estimate of the total quantity of toxic and hazardous materials stored and would
provide the location of the laboratory. The rational for the "low risk" nature of the
laboratory would be provided in this part of the BMP plan.
3. The plant has determined that materials used in a batch operation in the
manufacturing process have a high potential for reaching the receiving water. The
plant supplies a variety of products through the batch operation process" to
accommodate fluctuations in public demand. Consequently, the materials used for
the batch process vary from week to week, oftentimes unexpectedly. Therefore, the
materials inventory for the batch operation should be detailed but remain flexible.
The inventory might include the identification of each material expected for use, and
the maximum quantity of material that the batch process can handle. The materials
inventory could be updated to include any material substitutions unanticipated at
the time of the original inventory.

The examples above illustrate the flexibility of the materials inventory. A materials
inventory should be part of the "Risk Identification and Assessment" of every BMP plan but
the detail of the inventory will vary with the size and complexity of the plant, the quantities of
toxic and hazardous chemicals on site and the potential for those materials to reach surface
waters. Determining the potential for incidents reaching receiving waters as well as the
detail needed for the materials inventory requires sound engineering judgment.

The materials inventory and other useful technical information should be made available
to the BMP Committee but may require separate filing from the BMP plan documents to
protect proprietary information or trade secrets. These data may include physical, chemical.
lexicological, and health information (e.g., technical bulletins or material safety data sheets)
on the toxic pollutants and hazardous substances handled; the quantities involved in
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operations or ancillary sources; and the prevention, containment, mitigation, and cleanup
techniques that are used or would be used in the event of a discharge.

Materials planned for future use in the plant should be evaluated for their potential to be
discharged in significant amounts to receiving waters. Where the potential is high, the same
type of technical data described above should be obtained.

Elements of "Risk Identification and Assessment," listed below, should be considered
in developing a BMP plan:

• Identification of areas of the plant subject to BMP requirements
• Examination of identified areas for potential risks of BMP incidents reaching receiving
waters
• Identification of existing site-specific or pollutant-specific containment measures
• Plant plot plans or drawings that clearly label the identified areas
• Simplified flowsheet(s) of the major process operations
• Estimation of the direction of flow of potential discharges toward navigable waters
• Evaluation of the potential for materials planned for future use to be discharged to
receiving waters in significant amounts.
• Materials inventory system tailored to the need of the particular facility
» Physical, chemical, lexicological, and health information on the toxic and hazardous
chemicals on site.

3. Reporting of BMP Incidents
A BMP incident reporting system is used to keep records of incidents such as spills,
leaks, runoff, and other improper discharges for the purpose of minimizing recurrence,
expediting mitigation or cleanup activities, and complying with legal requirements. Reporting
procedures defined by the BMP Committee should include notification of a discharge to
appropriate plant personnel to initiate immediate action; formal written reports for review and
evaluation by management of the BMP incident and revisions to the BMP plan; and
notification as required by law to governmental and environmental agencies in the event that
a spill or other reportable discharge reaches the surface waters.

The reporting system should designate the avenues of reporting and the responsible
company and government officials to whom the incidents would be reported. A list of names,
office telephone numbers, and residence telephone numbers of key employees in the order of
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responsibility should be utilized when necessary for immediate reporting of BMP incidents to
plant management for implementation of emergency response plans.

A communications system should be designated and available for notification of an
impending or actual BMP incident. Reliable communications with the person or persons
directly responsible would expedite immediate action and countermeasures to prevent
incidents or to contain and mitigate discharged chemicals. Such a communication system
could include telephone or radio contact between transfer operations, and alarm systems that
would signal the location of an incident. Provisions to maintain communications in the event
of a power failure should be addressed.

Written reports on all BMP incidents should be submitted to the plant's BMP
Committee and plant management for review. Written reports should include the date and
rime of the discharge, weather conditions, nature of the materials involved, duration, volume,
cause, environmental problems, countermeasures taken, people and agencies notified, and
recommended revisions, as appropriate, to the BMP plan, operating procedures, and/or
equipment to prevent recurrence.

Procedures and key data should be outlined for necessary reporting of BMP incidents to
federal, state, and local regulatory authorities. In some circumstances, voluntary reporting to
authorities such as municipal sewage treatment works, drinking water treatment plants, and
fish and wildlife commissions may be desirable. The plant individuals responsible for
notification should be listed. Pertinent telephone numbers should be listed for those
individuals in the plant and those in the agencies to be notified. The phone numbers should
be reviewed periodically for accuracy and might actually be used in the course of a "spill
drill."

Elements of "Reporting of BMP Incidents," listed below, should be considered in
developing a BMP plan:

• Maintenance of records of incidents through formal reports for internal review
• Notification as required by law to governmental and environmental agencies should
an incident occur
• Procedures for notifying the appropriate plant personnel and taking preventive or
mitigating actions
• Identification of responsible company and government officials
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<*•

• A list of names, office telephone extensions, and residence telephone numbers of key
personnel
• A communications system for reporting incidents in-plant (i.e., telephone, alarms,
radio, etc.).

4. Materials Compatibility
Incompatibility of materials can cause equipment failure resulting from corrosion, fire, or
explosion. Equipment failure can be prevented by ensuring tha: t materials of construction
for containers handling hazardous substances or toxic pollutants are compatible with the
containers* contents and surrounding environment.

Materials compatibility encompasses three aspects: compatibility of the chemicals
being handled with the materials of construction of the container, compatibility of different
chemicals upon mixing in a container, and compatibility of the container with its environment.
The specific requirement of materials compatibility in the BMP plan should provide
procedures to address these three aspects in the design and operation of the equipment-on
site handling toxic and hazardous materials.

The BMP documentation on materials compatibility should recognize the engineering
practices already used in the plant, and should summarize these existing practices with
regard to corrosion and other aspects of material compatibility. Specific consideration should
be given to procedures and practices delineating the mixing of chemicals and the prohibition of
mixing of incompatible chemicals which might result in fire, explosion, or unusual corrosion.
Thorough cleaning of storage vessels and equipment before being used for another chemical
should be standard practice to ensure that there is no residual of a chemical that is
incompatible with the second, or later, chemical to be used. Coatings or cathodic protection
should be considered for protecting a buried pipeline or storage tank from corrosion.

Where applicable, material testing procedures should be described. Proposed
substitutions for currently used toxic or hazardous chemicals should be studied to determine
whether the construction materials of the existing containers are compatible with the
proposed new conditions. The procedures utilized by the plant or an outside contractor to
perform the materials compatibility study should be documented. Materials compatibility
aspects of waste disposal which are covered by the RCRA hazardous waste regulations
should be referenced in the BMP plan.
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Elements of "Materials Compatibility," listed below, should be considered in
developing a BMP plan:

• Evaluation of process changes or revisions for materials compatibility
• Incorporation of existing engineering practices for materials of construction, corrosion,
and other aspects of materials compatibility
• Evaluation of procedures for mixing of chemicals and of possible incompatibility with
other chemicals present
• Cleansing of vessels and transfer lines before they are used for another chemical
• Use of proper coatings and cathodic protection on buried pipelines if required to
prevent failure due to external corrosion.

5. Good Housekeeping
Good housekeeping is essentially the maintenance of a clean, orderly work environment
and contributes to the overall facility pollution control effort. Periodic training of employees on
housekeeping techniques for those plant areas where the potential exists for BMP incidents
reduces the possibility of incidents caused by mishandling of chemicals or equipment.

Examples of good housekeeping include neat and orderly storage of bags, drums, and
piles of chemicals; prompt cleanup of spilled liquids to prevent significant runoff to navigable
waters, sweeping, vacuuming, or other cleanup of accumulations of dry chemicals as
necessary to prevent them from reaching receiving waters; and provisions for storage of
containers or drums to keep them from protruding into open walkways or pathways.

Maintaining employee interest in good housekeeping is a vital pan of the BMP plan.
Methods for maintaining good housekeeping goals could include housekeeping inspections by
supervisors and higher management; discussions of housekeeping at meetings; and publicity
through posters, suggestion boxes, bulletin boards, slogans, incentive programs, and
employee publications.

Elements of "Good Housekeeping," listed below, should be considered in developing a
BMP plan:

• Neat and orderly storage of chemicals
• Prompt removal of spillage
• Maintenance of dry and clean floors by use of brooms, vacuum cleaners, etc.
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• Proper pathways and walkways and no containers and drums that protrude onto
walkways
* Minimum accumulation of liquid and solid chemicals on the ground or floor
• Stimulation of employee interest in good housekeeping.
6. Preventive Maintenance
An effective preventive maintenance (PM) program is important to prevent BMP
incidents. A PM program involves inspection and testing of plant equipment and systems to
uncover conditions which could cause breakdowns or failures with resultant significant
discharges of chemicals to receiving waters. The program should prevent breakdowns and
failures by adjustment, repair, or replacement of items. A PM program should include a
suitable records system for scheduling tests and inspections, recording test results, and
facilitating corrective action. Most plants have existing PM programs which provide a degree
of environmental protection. It is not the intent of the BMP plan to require development of a
redundant PM program. Instead, the objective is to have qualified plant personnel (e.g., BMP
Committee, maintenance foreman, environmental engineer) evaluate the existing plant PM
program and recommend to management those changes, if any, needed to address BMP
requirements.

A good PM program should include the following: (1) identification of equipment or
systems to which the PM program should apply (2) periodic inspections or tests of identified
equipment and systems; (3) appropriate adjustment, repair, or replacement of items; and (4)
maintenance of complete PM records on the applicable equipment and systems.

The BMP plan documentation on PM may include a list of procedures, examples of
recordkeeping, a list of the principal systems to which the PM program is applicable, and
directions for obtaining the records for any particular system included or referenced in the
BMP plan. In general, it will be adequate to reference in the BMP plan the scope and location
of existing PM procedures and records applicable to the PM specific requirements.

Elements of "Preventive Maintenance," listed below, should be considered in
developing a BMP plan:

• Identification of equipment and systems to which the PM program should apply
• Periodic inspections of identified equipment and systems
* Periodic testing of such equipment and systems

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• Appropriate adjustment, repair, or replacement of parts
• Maintenance of complete PM records on the applicable equipment and systems.

7. Inspections and Records
The purpose of the inspection and records system is to detect actual or potential BMP
incidents. The BMP plan should include written inspection procedures and optimum time
intervals between inspections. Records to show the completion date and results of each
inspection should be signed by the appropriate supervisor and maintained for a period of three
years. A tracking (follow-up) procedure should be instituted to assure that adequate
response and corrective action have been taken. The recordkeeping portion of this system
can be combined with the existing spill reporting system in the plant.

While plant security and other personnel may frequently and routinely inspect the plant
for BMP incidents, these people are not necessarily capable of assessing the potential for
such incidents. Thus certain inspections should be assigned to designated qualified
individuals, such as maintenance personnel or engineering staff.

The inspection and records system should include those equipment and plant areas
identified in the "Risk Identification and Assessment" portion of the BMP plan as having the
potential for significant discharges. To determine the inspection frequency and inspection
procedures, competent environmental personnel should evaluate the causes of previous
incidents, and assess the probable risks for incident occurrence. Furthermore, the nature of
chemicals handled, materials of construction, and site-specific factors including age,
inspection techniques, and cost effectiveness, should be considered.

Qualified plant personnel should be identified to inspect designated equipment and plant
areas. Typical inspections should include examination of pipes, pumps, tanks, supports,
foundations, dikes, and drainage ditches. Records should be kept to determine if changes in
preventive maintenance or good housekeeping procedures are necessary. Each of the
ancillary sources should have "Inspection and Records" programs designed to meet the
needs of the particular facility.

Material storage areas for dry chemicals should be inspected for evidence of, or the
potential for, windblowing which might result in significant discharges. Liquid storage areu>
should be inspected for leaks in tanks, for corrosion of tanks, for deterioration of foundation.-
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or supports, and for closure of drain valves in containment facilities. Inspections could include
the examination of seams, rivets, nozzle connections, valves, and connecting pipelines.
Storage tanks should be inspected for evidence of corrosion, pitting, cracks, abnormalities,
and deformation and such evidence should then be evaluated.

For in-plant transfer and materials handling of liquids, inspections should include visual
examination for evidence of deterioration of pipelines, pumps, valves, seals, and fittings. The
general condition of items such as flange and expansion joints, pipeline supports, locking
valves, catch or drip pans, and metal surfaces, also should be assessed.

For loading and unloading operations, inspections during transfer of materials would
permit immediate response if an incident occurred. The conditions of pipelines, pumps,
valves, and finings for liquid transfer systems and pneumatic conveying systems used for
transferring dry chemicals should be inspected. Inspections (together with monitoring)
should be used to ensure that the transfer of material is complete before flexible or fixed
transfer lines are disconnected prior to vehicular departure. Before any tank car or tank truck
is filled, the lower-most drain valve and all outlets of such vehicles should be closely
examined for evidence of leakage and, if necessary, tightened, adjusted, or replaced. Before
departure, all tank cars or tank trucks should be closely examined to ensure that all transfer
lines are disconnected and that there is no evidence of leakage from any outlet.

For plant runoff, inspections should be used for examining the integrity of the
stormwater collection system and the diversion or overflow structures, and for ensuring the
drain valves and pumps for diked areas are properly closed. The plant sewer and storm
sewer system should be periodically surveyed to ensure that toxic and hazardous pollutants
are not discharged in significant amounts. Inspections also should include diked areas to
ensure that hazardous and toxic chemicals are not discharged from inside diked areas to
waterways. Any liquid, including rainwater, should be examined, and where necessary,
analyzed, before being released from the diked areas to a receiving water.

For sludge and hazardous waste disposal sites, visual inspections should include
examinations for leaks, seepage, and overflows from land disposal sites such as pits, ponds.
lagoons, and landfills. Other procedures and inspection techniques should be considered on j
site-specific basis. Any inspections made or records kept to comply with RCRA may -v
included in the BMP plan by reference.
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Elements of "Inspections and Records," listed below, should be considered in
developing BMP plan:

• Inspection of:
- Storage facilities
- Transfer pipelines
- Loading and unloading areas
- Pipes, pumps, valves, and fittings, tank corrosion (internal and external)
- Windblowing of dry chemicals
- Tank support or foundation deterioration
- Seams along drainage ditches and old tanks
- Deterioration of primary or secondary containment
- Housekeeping
- Drain valves on tanks
- Damage to shipping containers
- Conveying systems for dry chemicals
- Integrity of stormwater collection system
- Leaks, seepage, and overflows from sludge and waste disposal sites.
* Records of all inspections
• Tracking procedures to assure adequate response and corrective actions have been
taken when inspections reveal deficiencies.

8. Security
A security system is needed to prevent accidental or intentional entry to a plant which
might result in vandalism, theft, sabotage, or other improper or illegal use of plant facilities
that could possibly cause as BMP incident. Most plants have security systems to prevent
unauthorized entry leading to theft, vandalism, sabotage, and the like. The BMP plan should
describe those portions of the existing security system which ensure that the pertinent
chemicals are not discharged to receiving waters in significant quantities. Documentation of
the security system may require separate filing from the BMP plan documents to prevent
unauthorized individuals from gaining access to confidential information.

The BMP Committee, plant security manager, plant engineer, or other qualified plant
personnel should evaluate the coverage of the existing security system for those areas of the
plant and the equipment identified by the "Risk Identification and Assessment" specific
requirement as having the potential for significant discharges. They should recommend to
plant management any changes necessary to improve the security system.
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r>

Examples of security measures include: routine patrol of the plant by security guards in
vehicles or on foot; fencing to prevent intruders from entering the plant site; good lighting;
vehicular traffic control; a guardhouse or main entrance gate, where all visitors are required to
sign in and obtain a visitor's pass; secure or locked entrances to the plant; locks on certain
valves or pump starters; and television surveillance of appropriate plant sites, such as plant
entrance, and loading and unloading areas.

Whenever possible, security personnel should be instructed to observe leaks from
tanks, valves, or pipelines while patrolling the plant and also be informed of the procedures to
follow when a spill or other discharge is detected. Many plants use contractor or plant
security personnel who may not be qualified or may not have time to carry out such
surveillance. In such cases, the surveillance can be incorporated in the "Inspection and
Records" specific requirement and should be conducted by production or environmental staff.

Elements of "Security," listed below, should be considered in developing a BMP plan:

• Routine patrols of plant by security personnel
* Fencing
» Good lighting
• Vehicular traffic control
• Controlled access at guardhouse or main entrance gate
• Visitor passes
• Locked entrances
• Locks on certain drain valves and pump starters
• Television monitoring.

9, Employee Training
Employee training programs should instill in personnel, at all levels of responsibility, a
complete understanding of the BMP plan, the processes and materials with which they are
working, the safety hazards, the practices for preventing discharges, and the procedures for
responding properly and rapidly to toxic and hazardous materials incidents. Employee
training meetings should be conducted at least annually to assure adequate understanding or
the objectives of the BMP plan and the individual responsibilities of each employee
Typically, these meetings could be a part of routine employee meetings for safety or fire
protection. Such meetings should highlight previous spill events or failures, malfunctioniru
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equipment components, and recently developed BMP precautionary measures. Training
sessions should review the BMP plan and associated procedures. Just as fire drills are used
to improve the employee's reaction to a fire emergency, spill or environmental incident drills
may serve to improve the employee's reactions to BMP incidents. Plants are encouraged to
conduct spill drills on a quarterly or semi-annual basis. Spill drills serve to evaluate the
employees' knowledge of BMP-related procedures and are a fundamental pan of employee
training.

Of particular importance is the strong commitment and periodic input from top
management to the employee training program to create the necessary climate of concern for
a successful program. A plant manger might accomplish more in a brief, face-to-face,
appearance than an elaborate, impersonal training program would accomplish.

Adequate training in a particular job and process operation is essential for
understanding potential discharge problems. Knowledge of specific manufacturing operations
and how discharges could occur, or have occurred in the past, is important in reducing human
error that can lead to BMP incidents.

The training program also should be aimed at making employees aware of the protocol
used to report discharges and notifying the people responsible for response so that immediate
countermeasures can be initiated. In addition, personnel involved in BMP-incident response
would be trained to use cleanup materials such as sorbents, gelling agents, foams, and
neutralizing agents. As appropriate, they should be educated in safety precautions, in the
side effects of the chemicals they are working with, and in possible chemical reactions.
Operating manuals and standard procedures for process operations should include
appropriate sections of the BMP plan and the spill control program and should be readily
available for reference. Spill response drills, suggestion boxes, posters, and incentive
programs, can be used to motivate employees to be alert to the potential for discharges and
to their prevention.

The employee training program should include records of the frequency, and names and
positions of the employees trained as well as the lesson plans, subject material covered, and
instructors' names and positions. BMP-related training may be combined with other forms of
training, such as safety and fire prevention at the discretion of the plant.
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In addition to permanent personnel, contractors or temporary personnel should be
trained in procedures for preventing BMP incidents since these individuals may be unfamiliar
with the normal operating procedures or location or equipment (pipelines, tanks, etc.) at the
facility. Adequate supervision of contractor maintenance personnel should be provided to
minimize the possibility of BMP incidents resulting from damaging equipment such as buried
pipelines.

Elements of "Employee Training," listed below, should be considered in developing the
BMP plan:

• Meetings held at least annually to assure adequate understanding of program goals
and objectives
• Environmental Incident (Spill) drills used at least semiannually
• Periodic input from management
• Adequate training in particular job and process operation and the effect on other
operations
• Transmission of knowledge of past incidents and causes
• Making employees aware of BMP plans and incident reporting procedures
• Training in the use of sorbents, gelling agents, foams, and neutralizing agents for
cleanup or mitigation of incidents
* Operating manuals and standard procedures
• Making employees aware of health risks of chemicals handled through both the
plant's BMP plan and safety program
• Motivating employees concerning incident prevention and control
• Records of the personnel who were trained, and of the dates, instructors, subject
matter, and lesson plans of the training sessions
• Training and supervision of contractors and temporary personnel.
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BIBLIOGRAPHY
TECHNICAL GUIDANCE ON BMPs IN THE NPDES PROGRAM
Form of Guidance
Technical Paper
Report EPA No.
600/9-79-045
Report
Technical Paper
Case Histories

Technical
Memorandum No. 1

Technical
Memorandum No. 2

Information
Memorandum
Information
Memorandum

Information
Memorandum

Information
Memorandum
Title Date
Best Management Practices for Control of Toxic and 5/9/79
Hazardous Materials; Thron, H.M. et al., presented at the
34th Purdue Industrial Waste Conference, Lafayette,
Indiana
NPDES Best Management Practices Guidance Document; 12/79
Hydroscience Inc., EPA Contract Number 68-03-2568
NPDES Best Management Practice Guidance Document 6/81
(Revised); NPDES Technical Support Branch
Best Management Practices; Useful Tools for Cleaning Up, 4/20/82
Thron, H.M. and Rogoshweski, P.J., presented at the 1982
Hazardous Material Spills Conference, Milwaukee,
Wisconsin
NPDES Best Management Practices; Case Histories; JRS 1/29/83
Associates, Inc., EPA Contract Number 68-01-5052
Technical Guidance on Best Management Practices (BMPs) 4/15/83
in NPDES Permits; Jordan, J.W. to Regional Permit Branch
Chiefs
Technical Guidance on Best Management Practices (BMPs) 3/23/84
in NPDES Permits; Jordan, J.W. to Regional Permit Branch
Chiefs
Best Management Practices (BMPs) in NPDES Permits; 6/3/85
Grubs, Geoffrey to Regional Permit Branch Chiefs
Best Management Practices (BMPs) in NPDES Permits; 8/29/86
Gallup, James to Regional Permit Branch Chiefs
Best Management Practices (BMPs) in NPDES Permits; 8/11/87
Gallup, James to Regional Permit Branch Chiefs
Best Management Practices (BMPs) in NPDES Permits; 8/19/88
Gallup, James to Regional Permit Branch Chiefs
14-33
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PART IV
Permit No. VA 0005215
Page i of 3
BEST MANAGEMENT PRACTICES CONDITIONS
A. General Conditions

For purposes of this part, the terms "pollutant" or "pollutants" refer
to any substance listed as toxic under Section 307(a)(I) of the Clean
Water Act, oil, as defined in Section 311(a)(l) of the Act, and any
substance listed as hazardous under Section 311 of the Act. The
permittee shall develop and implement a Best Management Practices
(BMP) plan which prevents, or minimizes the potential for, the release
of pollutants from ancillary activities, including material storage
areas; plant site runoff; in-plant transfer, process and material
handling areas; loading and unloading operations, and sludge and waste
disposal areas, to the waters of the United States through plant site
runoff; spillage or leaks; sludge or wasce disposal; or drainage from
raw material storage.

2. Implementation

The plan for General Conditions shall be developed within 12 months of
the effective date of this permit. An approval plan for General
Conditions shall be implemented within 24 months of the effective
permit date. Specific Conditions of this plan shall be implemented
within 24 months of the effective permit date.

3. General Requirements

The BMP plan shall:

a. Be documented in narrative form, and shall Include any necessary
plot plans, drawings or maps.

b. Establish specific objectives for the control of pollutants.

(i) Each facility component or system shall be examined for its
potential for causing a release of significant amount of
pollutants to waters of the United States due to equipment
failure, improper operation, natural phenomena such as rain
or snowfall, etc.

(2) Where experience Indicates a reasonable potential for
equipment failure (e.g., a tank overlfow or leakage), natural
condition (e.g., precipitation), or other circumstances to
result in significant amounts of pollutants reaching surface
waters, the plan should Include a prediction of the direc-
tion, rate of flow and total quantity of pollutants which
could be discharged from the facility as a result of each
condition of circumstance.
»
c. Establish specific best management practices to meet the
objectives identified under paragraph b of this section,
14-34
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PART tv
Permit No. VA 0005215
Page 2 of 3

addressing each component or system capable of causing a release
of significant amounts of pollutants to the waters of the United
States, -and identifying specific preventative or remedial measures
to be implemented.

d. Include any special conditions established in Section B of this
Part.

e. Be reviewed by plant engineering staff and the plant manager.

4. Doc uaen tat ion

The permittee shall maintain a description of the BMP plan at the
facility and shall make the plan available to the permit issuing
authority upon request.

5. BMP Plan Modification

The permittee shall amend the BMP plan whenever there is a change in
the facility or change in the operation of the facility which
materially increases the potential for the ancillary activities to
result in a discharge of significant amounts of pollutants.

6. Modification for Ineffectiveness

If the BMP plan proves to be ineffective in achieving the general
objective of preventing the release of significant amounts of pol-
lutants to surface waters and the specific objectives and requirements
under paragraphs b and c of Section 3, the permit and/or the BMP plan
shall be subject to modification to incorporate revised BMP require-
ments.

8. Specific Conditions

The following Specific Conditions shall be implemented within 12 months of
the effective date of the permit.

1. Measures shall be taken to control potential discharges at the
following sites:

Building 1341 - Provide containment for freon and
hydrochloric acid tanks

Incinerator - Direct quench recycle overflow to a
treatment facility

Building 1329 - Control spills at the acid cleaning
facility

St. Juliens Building 332 - Control spills from drummed liquids.
Implement controls to ensure proper
operation of the oil transfer valve (PIV
14-35
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K-l .-
- JU
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PRACTICAL EXERCISE

Best Management Practices (BMPs)

(1) what are the two basic ways that BMPs appear in NPDES permits?
(2) what is the legal authority for imposing BMPs in permits considering the
fact, that no BMPs have been promulgated for specific industries pursuant
to Section 304(e) of the Clean Water Act? _ __

(3} GIVEN THE FOLLOWING SITUATION;

Luster Glass Inc. manufactures auto tempered and laminated glass in
Morris, Illinois. A recent compliance inspection revealed storage tank
number 42 containing 12,000 gallons of gasoline was leaking into the
Illinois River. The State compliance inspector, I. M. Curious, also
noticed generally poor housekeeping at Luster, including retired pumps and
miscellaneous pipes and fittings scattered throughout the plant area,
unidentified solid and liquid spills on roadways and a storage area near
the stream bank consisting of about fifty, 55 gallon drums in various
positions and states of deterioration. When questioned about the nature
and contents of the drums by the State compliance inspector, the Luster
plant manager, Wood U. Leave, replied, "They're some old supplies we
discontinued... some contain. . -nitric acid or some other acid. .. (cough
cough)... how about some lunch Mr. Curious?" As he was abruptly spun 180
degrees by Mr. Leave, Mr. Curious managed to scribble a note at the bottom
of his inspection report "may be a candidate for BMPs in reissued permit."

You are the permit writer assigned to draft Luster Glass Inc. 'a SPDES
permit. After reading the compliance inspection report, you sketch ysur
approach for using BMPs in the reissued permit:

BMP Plan - Conditions at the facility, especially poor housekeeping,
warrant a BMP plan to be developed within six months and implemented
within twelve months of permit reissuance. The BMP Plan should address
each of the nine specific requirements described in the June 1981, NF2ES
BMP Guidance Document with emphasis on _
Site-Specific BMPs

(1) Tank Number 42;
|2) Drum Storage Area;
14-37
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POLLUTION PREVENTION
-------
-------
LEARNING OBJECTIVES
Orientation to Pollution Prevention
Implementation
Tools and Resources
NOTES:
15-1
-------
HIERARCHY OF ENVIRONMENTAL PROTECTION
PRACTICES

• Source reduction

• Environmentally sound reuse and recycling

• Disposal
NOTES:
15-2
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POLLUTION PREVENTION ACT 1990

"Source reduction means any practice which reduces the
amount of any hazardous substance, pollutant or contaminant
entering any waste stream or released into the environment
prior to recycling, treatment or disposal ..."
EPA POLICY STATEMENT

Pollution prevention is the

"Use of processes, practices, or products that reduce or
eliminate the generation of pollutants and wastes, including
those that protect natural resources through conservation
or more efficient utilization."
NOTES:
15-3
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LEGISLATIVE AUTHORITIES AFFECTING
THE LIFE CYCLE OF A CHEMICAL
SARA
SARA
TSCA
Underground Tank*
(RCRA)
Industrial Products
OSHA, FIFRA
Consumer Products
CPSA. FFOCA,
FtFRA
(RCRA)
CAA
CPSA
CWA
FTOCA
FIFRA
HUTA
OSHA
RCRA
SOWA
TSCA
SARA
Clean Air Act
ConwmsrPK
duct Safety Act
Clean water Act
Federal Food, Drug ft Cosmetic Ad
Federal Insecticide, Fungicide 4 Rodentidde Act
Hesardous Meterlele TmnsportaUon Act
Occupational Safety ft Health Ad
Resource Sonservatlon ft Recovery Act
Sele Drtntdng Water Act
Toxic Substances Control Act
Superfund Amendments ft Reauthorliatlon Act
15-4
-------
POLLUTION PREVENTION OPPORTUNITIES IN THE
NPDES PERMITTING PROCESS

• Application review

• BMP plan requirement

• Monitoring conditions
NOTES:
15-5
-------
-------
PERMIT ISSUANCE PROCEDURES
-------
-------
LEARNING OBJECTIVES

The permit issuance process

Documenting development of the permit

EPA/State coordination

Public participation

Modification/termination
NOTES:
16-1
-------
COMMON ELEMENTS OF THE ISSUANCE PROCESS
Permit Application
Filed
Application Review
for Completeness and
Accuracy

Additional
Data Requested
Site Visit Conducted

Prepare Draft Permit
or Deny Application
§124.6
Statement of Basis or
Fact Sheet
§124.7 arid §124.8
Administrative Record
§124.4
Draft Permit Reviewed
by Applicant
Public Notice of Draft
Permit §124.10

Public Hearing
§124.12
Comments Considered
and Draft Permit
Revised
Administrative Record
§124.18
Request for Evidentiary
Hearing §124.74

Permit Issued
(Process Repeats Itself)
Response to Comments
§124.17
16-2
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REASONS FOR GOOD DOCUMENTATION

Streamlines reissuance/compliance-monitoring process

Permanent record of the basis for the permit

Explanation of basis of permit for public, management, permittee,
and attorneys, if appealed

Provide sound basis for modifications and future permits

Requires permit writer to be organized and logical, resulting
in better permits
CHARACTERISTICS OF A GOOD FACT SHEET

Identify party being permitted

Bring forward background and history of permit

Develop rationale for all pertinent permit decisions

Display all calculations and document sources of data

Keep accessible to permitting authority personnel and the public
NOTES:
16-3
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MINIMUM ELEMENTS OF A FACT SHEET
§124.8(b)

Description of facility or activity

Type and quantity of wastes/pollutants

Basis of the draft permit

Statutory/regulatory citations
References to administrative record

Basis of effluent limitations and conditions

Specific explanation of

Toxic pollutant limits
Limits on internal wastestreams
Case-by-case requirements
Limits on indicator pollutants
Regulation of users

Sketch or description of location

State certification

Sewage sludge land application plan

Inappropriateness of requested variances

Permit procedures

Comment period begin and end dates
Procedures for requesting a hearing
Public involvement in final decision

Contact name and telephone
16-4
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CONTENTS OF ADMINISTRATIVE RECORD
§124.9

Application and supporting data

Statement of basis or fact sheet

Documents/items cited in statement of basis or fact sheet

Other items supporting permit development

EIS for new source draft permits
CONTENTS OF ADMINISTRATIVE RECORD
FINAL PERMIT
§124.18

All comments received

Public hearing tape or transcript

Response to comments

Final EIS for new sources

Final permit
NOTES:
16-5
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EXAMPLE
CONTENTS OF THE ADMINISTRATIVE RECORD
A brief explanation follows of the express statutory or regulatory precision on which permit requirements are based,
including appropriate supporting references to the Administrative Record required by 40 CFR S 124.9:
The following items are used to establish the basis of the draft permit:
(1) NPDES Permit No. LA0002933, effective date 2/17/80, expiration date 3/31/81.
(2) Consolidated Permit Application Forms No. 1 and 20 received 4/3/82.
(3) Louisiana Water Quality Criteria, LSCC, 1977.
(4) Louisiana Water Quality Management Plan, Department of Natural Resources, including Appendix D
(Ponchartrain Basin) and Appendix F 'Mississippi River), Phase Q, Vols. L
(5) 40 CFR Part 415 Subpart F, [47 £R 28260, 6/29/83J.
(6) 40 CFR Part 415.65(b) (39 fE 9616, 3/12/74].
(7) Letter White (EPA) to Vlacos (Vulcan) dated 3/29/76.
(8) Letter White (EPA) to Campbell (Vulcan) DAted 6/9/76.
(9) ROC Hale (EPA) to Leonard (Vulcan) dated 11/10/76.
(10) 40 CFR Part 122J9 (d)(l) (48 £R 14146, 4/1/83].
(11) Letters Gordon (Vulcan) to McHam (EPA) dated 5/17/82 and 7/19/81
(12) 40 CFR Part 401.17, 6/4/82.
(13) Letters Gordon (Vulcan) to HaJc (EPA) dated 1/30/8L
(14) Discharge Monitoring Reports 1980-1982.
(15) 40 CFR Part 122.62{a)(3) [48 ffi 14146, 4/1/83].
(16) 40 CFR Part 122.44(1)(2)(1) [48 ER 14146, 4/1/83].
(17) 40 CFR Part 4l5.65(b) [47 £R 28260, 6/29/82].
f 18) 40 CFR Part 415.62(b) [47 FJ8, 28260, 6/29/82].
'19) Final Development Document for Inorganic Chemicals,
EPA 440/1-82/007, June 1982.
(20) Letter Gordon (Vulcan) to Ferguson (EPA) dated 10/30/79.
(21) 40 CFR Part 125J(a)(2)(v) [44 £B 32948, 6/7/89, as amended at 45 £R 33512, 5/19/80].
(22) 40 CFR part 415.63
-------
EPA REVIEW OF STATE PERMITS
§123.24(d)

EPA may not waive review of:

* Major municipal and industrials

• General permits

* Class I sludge facilities

Other (minor) permits which:

Discharge to territorial seas
Affect another State's waters
Cooling water discharges > 500 MGD
Process discharges >0.5 MGD
Primary industry categories
NOTES:
16-7
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PUBLIC NOTICE
§124.10

Purpose of public notice

Types of actions requiring public notice

Tentative denial of application
Draft NPDES permit
Public hearing
Formal appeal of permit
Major program modifications
Granting of evidentiary hearing

Methods applicable to public notice process

Publication in newspaper
Direct mailing

Contents of public notice

Name and address of regulatory authority
Name and address of permittee
Brief description of facility
Name, address, and telephone number of contact
Additional information (EPA-issued permits)

Timing of public notice

After EPA/State review
EPA/State MOA should address

Significant comments must be responded to in writing

Public hearing is always optional
16-8
-------
EXAMPLE FACT SHEET
-------
-------
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT
FACT SHEET
Permittee Name: Luster Glass, Inc.

NPDES Permit
Number: IL0654321

Mailing Address: P.O. Box 319
Morris, IL 60123

Location: 1 River Ridge Drive
Morris, IL 60123

Contact Person: Mr. John Baker, Vice President

Telephone: (312) 834-4536

!• Status of Permit

NPDES Permit No. IL0654321 was issued on August 5, 1984, became
effective on August 31, 1984, and expired on August 31, 1989. The
permittee submitted an NPDES permit application for the renewal of
the permit on March 1, 1989.

II. Facility Description

Luster Glass Inc. operates a manufacturing facility in Morris, IL.
The facility specializes in manufacturing auto glass. On average,
40,000 sq. ft./day of auto tempered glass, and 275,000 sq. ft./day
of auto laminated glass is produced at the facility.

III. Description of Discharge

All wastewater generated at this facility is discharged through
Outfall 001 to the Illinois River. The primary waste streams
discharged through Outfall 001 are process and rinse waters from
the glass manufacturing processes and cooling tower blowdown. The
glass manufacturing process wastewaters from auto glass tempering
(cutting, grinding, polishing edges, bending, and tempering) and
auto glass lamination (cutting, bending, washing, and laminating)
are routed through a wastewater treatment system consisting of oil
and water separators and settling basins. The cooling tower
blowdown is not treated prior to discharge.

IV. Receiving Water

The receiving water for Outfall 001 is the Illinois River, Segment
16 of the Northern Illinois River Basin. Downstream of the
facility, the Illinois River flows approximately 3 miles to Segment
15 of the Northern Illinois River Basin. Following is a summary cf
flow data for Segment 16 of the Illinois River:
16-9
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Fact Sheet
Page 2 of 21

Average Flow - 446.7 cfs
Harmonic Mean Flow - 245.5 cfs
7Q10 - 70.9 Cfs
1Q10 - 58.8 Cfs

The use designations for the Illinois River are given below:

Indigenous Aquatic Life

The applicable water quality standards to protect these uses are
specified the State Water Pollution Control Rules in Part 302
(State Administrative Code, Title 35 - Environmental Protection;
Subtitle C - Water Pollution, Chapter 1; adopted March 17, 1989).
The effluent standards are found in Part 304.
V.
Description of Discharge
a.
Permit Application Summary
The following table summarizes the discharge characteristics of
Outfall 001 as reported in the NPDES permit application dated March
1, 1989:
Parameter
Flow (MGD)
TSS (mg/1)
COD (mg/1)
pH (S.U.)
Oil & Grease (mg/1)
Phosphorus (Ibs/day)
Zinc (mg/1)
Lead (mg/1)
Long-Term
Average
4.563
18.8
ND
6.6 roin.
12
19
0.036
0.025
Daily
Maximum
4.591
50.0
50.0
9.0 max.
22
29
0.07
0.047
Note: Only data for parameters reported above detection limits are
shown above.
b.
Discharge Monitoring Report (DMR) Data
A summary of DMR data is given in Table 1.
from March 1988 through February 1989.
This data was taken
Whole Effluent Toxicity (WET) testing performed during the last
year of the permit term (March 1988 to February 1989) demonstrated
acute toxicity at Outfall 001. Test results indicated a fathead
minnow LC50 of 8 percent and a Ceriodaphnia LC50 of 15.8 percent.
Chronic Toxicity tests also demonstrated toxicity at Outfall 001.
Chronic toxicity test results indicated a fathead minnow NOEC of
1.3 percent and a Ceriodaphnia NOEC of 2.7 percent. A summary of
WET data for Luster is also presented in Table 1.
16-10
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Fact Sheet
Page 3 of 21

VI. Proposed Technology-Based Effluent Limitations

Regulations promulgated at 40 CFR §122.44(a) require technology-
based effluent limitations to be placed in NPDES permits based on
National effluent limitations guidelines and standards, best
professional judgement (BPJ), or a combination of the two.
Discharges from Outfall 001 are subject to effluent limitations
given in 40 CFR Part 426 for the Glass Manufacturing Point Source
Category, and State effluent and water quality standards.

Limits were developed for Luster Glass Inc. based on an evaluation
of the permit application and DMRs. Lead and zinc were detected in
significant concentrations in the discharge as reported in DMRs.
While the previous permit did not contain limits for lead and zinc,
monitoring was required. Thus, technology-based effluent limits
were set for zinc found in the cooling tower blowdown. Technology-
based limits were also established for lead which is found in the
process wastewater, however water quality-based limits were found
to be more limiting (see Section VII of this Fact Sheet).

Effluent mass limits for total suspended solids (TSS), phosphorus,
and oil and grease are based on the best practicable control
technology currently available (BPT) limitations specified for the
Automotive Glass Tempering Subcategory in 40 CFR §426.62 and for
the Automotive Glass Laminating Subcategory in 40 CFR §426.72.
These limitations are shown below:

Automotive Glass Tempering Subcateaorv
Pollutant

TSS
Oil and Grease
Effluent Limits
Monthly Avg. Daily Max.
flb/1000ftfl flb/ioooft2)
0.25
0.13
0.40
0.13
pH shall be within the range of 6.0 to 9.0 standard units.

Automotive Glass Laminating Subcateaorv

Effluent Limits
Monti-
Pollutant
Monthly Avg.
rib/lQQOft2!
Daily Max.
flb/lOOOft2)
TSS
Oil and Grease
Phosphorus
0.90
0.36
0.22
0.90
0.36
0.22
pH shall be within the range of 6.0 to 9.0 standard units.
16-11
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Fact Sheet
Page 4 of 21

Effluent limitations for oil and grease, TSS, phosphorus, and pH
from the process wastewater contribution to Outfall 001 are
calculated using the above effluent limits and the production rates
of 40,000 square feet per day of tempered glass and 275,000 square
feet per day of laminated glass. The TSS effluent limitations for
cooling tower blowdown are based on State Effluent Standards for
TSS in non-process wastewaters, including cooling tower blowdown.
Calculations of the effluent limitations are shown below. It
should be noted that both mass and concentration limits will be
applied to Outfall 001 for oil and grease, TSS, and phosphorus.

Mass Limitations (Monthly Average and Daily Maximum)

Oil & Grease = (40,000 ft2/day (tempered) x 0.13 lb/1000 ft2) +
(275,000 ft2/day (laminated) x 0.36 lb/1000 ft2) = 5.2 + 99 - 104.2
Ibs/day

Concentration Limitations - Outfall 001 (Monthly Average and Da-ily
Maximum)

Oil & Grease = (104.2 Ibs/day) (454 g/ 1 Ib) (1000 mg/ 1 g) (1 gal/
3.785 1)(1 day/ 4.563 106 gal) - 2.74 mg/1
Mass Limitations - Process Wastewater (Monthly Average)

TSS = [(40,000 ft2/day (tempered) x 0.25 lb/1000 ft2) + (275,000
ft2/day (laminated) x 0.9 lb/1000 ft2)]/1000 - 257.5 Ibs/day

Mass Limitations - Process Wastewater (Daily Maximum)

TSS = [(40,000 ft2/day (tempered) x 0.4 lb/1000 ft2) + {275,000
ftz/day (laminated) x 0.9 lb/1000 ftz)]/1000 = 263.5 Ibs/day

Mass Limitations - Cooling Tower Blowdown (Monthly Average)

TSS = (25 mg/l)(0.45 10* gal/day)(1 lb/454,000 mg)(3.785 1/gal) =
93.8 Ibs/day

Mass Limitations - Cooling Tower Blowdown (Daily Maximum)

TSS - (50 mg/l)(0.45 10s gal/day)(1 lb/454,000 mg)(3.785 1/gal) =
187.6 Ibs/day

Mass Limitations - Outfall 001 (Monthly Average)

TSS = 257.5 Ibs/day + 93.8 Ibs/day = 351.3 Ibs/day
16-12
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Fact Sheet
Page 5 of 21

Mass Limitations - Outfall 001 (Daily Maximum)

TSS = 263.5 Ibs/day + 187.6 Ibs/day = 451.1 Ibs/day

Concentration Limitations - Outfall 001 (Monthly Average)

TSS = (351.3 Ibs/day)(454,000 mg/lb)(1 gal/3.785 1)(day /4.S63 106
gal) » 9.23 mg/1

Concentration Limitations - Outfall 001 (Daily Maximum)

TSS = (451.1 Ibs/day)(454,000 mg/lb)(1 gal/3.785 1)(day /4.S63 106
gal) = 11.86 mg/1

Mass Limitations - Outfall 001 (Monthly Average and Daily Maximum)

Phosphorus = 275,000 ftz/day (laminated) x 0.06 lb/1000 ft2) =16.5
Ibs/day

Concentration Limitations - Outfall 001 (Monthly Average and Daily
Maximum)

Phosphorus = (16.5 Ibs/day)(454,000 mg/lb)(1 gal/3.785 1)(day
/4.S63 106 gal) - 0.43 mg/1

pH limits are based on State effluent standards, as follows:

State Effluent Standards

Monthly Avg. Daily Max.
Pollutant/Parameter Range (mq/1) fma/1)

pH 6.0 - 9.0 N/A N/A
16-13
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Fact Sheet
Page 6 of 21
Toxic Pollutants

Zinc and lead were detected in the effluent discharge when the
previous permit was issued. At that time no limits were set, but
a requirement was made to monitor for zinc and lead. Significant
concentrations of zinc (used as a corrosion inhibitor in cooling
water} and lead (from lead soldering of products) have been found,
as reported in DMRs. Therefore, technology-based effluent
limitations are being established and will be included in the draft
permit.

Technology-based effluent limitations for the toxic pollutant zinc
present in the cooling tower blowdown are based on the transfer of
the best available technology economically achievable (BAT)
limitations specified in the Steam Electric Effluent Guidelines and
Standards at 40 CFR §423.13(d)(a). These limitations are shown
below:
BAT Effluent Limitations
Pollutant
Zinc (total)
Monthly Avg.
(ma/I)
1.0
Daily Max.
1.0
Using the average blowdown flow from the cooling towers (0.45 mgd) ,
monthly average and daily maximum mass limitations are calculated
as follows:

Zinc = (1.0 mg/l)(0.45 106 gal/day)(1 lb/454,000 mg)(3.785 1/gal)
=3.75 Ibs/day

Equivalent end-of-pipe concentration effluent limitations are also
being established in the draft permit. Using the total Outfall 001
flow (4.563 mgd), monthly average and daily maximum concentration
limitations are calculated as follows:

Zinc = (3.75 Ibs/day)(454,000 mg/lb)(l gal/3.785 1)(day /4.S63 10*
gal) =0.10 mg/1

Technology-based effluent limitations for lead found in the process
wastewaters are based on transfer of BAT limitations specified in
the Metal Finishing Effluent Guidelines and Standards at 40 CFR
§433.14(a). These limitations, which are based on the performance
of lime precipitation and sedimentation, are shown below.

BAT Effluent Limitations
Pollutant
Lead (total)
Monthly Avg,
fma/1)
0.43
Daily Max.
fma/1)
0.69
16-14-
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Fact Sheet
Page 7 of 21

Due to the potential for dilution of the treated process
wastewaters by the cooling tower blowdown wastewaters, both mass
and concentration limitations are established. Using the average
process flow (4.113 mgd), mass limitations are calculated as
follows:

Monthly Average

Lead = (0.43 mg/1)(4.113 106 gal/day)(1 lb/454,000 rag)(3.785 1/gal)
= 14.74 Ibs/day

Lead - (0.69 mg/1)(4.113 10* gal/day)(1 lb/454,000 mg)(3.785 1/gal)
= 23.66 Ibs/day

Equivalent end-of-pipe concentration effluent limitations are also
being established in the draft permit. Using the total Outfall 001
flow (4.563 mgd), concentration limitations are calculated as
follows:

Monthly Average

Lead = (14.74 Ibs/day)(454,000 mg/lb) (1 gal/3.785 1)(day /4.563 106
gal) = 0.38 mg/1

Lead = (23.66 Ibs/day) (454,000 mg/lb) (1 gal/3.785 1) (day /4.S63 106
gal) = 0.62 mg/1

VII. Proposed Water Quality-Based Effluent Limitations

The State water guality standards require that point source
discharges shall not cause a violation of any applicable water
quality standards nor interfere with the attainment or maintenance
of that water quality which assures the protection and propagation
of a balanced indigenous population of shellfish, fish, and
wildlife and allows recreational activities in and on the water.
In addition, a requirement of the State water quality standards is
that no effluent shall, alone or in combination with other sources,
cause a violation of any applicable water quality standard.

Temperature limits are based on State water quality standards as
follows:
16-15
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Fact Sheet
Page 8 of 21
State WaterQuality Limits
Pollutant/Parameter
Temperature
Toxic Pollutants
Range
Not greater than 2.8°C above ambient, or
1.7°C above the following maximum limits:
in December through March, 16"C (603F)
and in April through November, 32°C (90°F)
Based on evaluation of the NPDES permit application and DMR data
submitted by Luster Glass Inc., the following pollutants and
parameters for which applicable State water quality standards are
available are present in Outfall 001: lead and zinc. Based on the
fact that no other toxic pollutants are expected to be present in
Outfall 001 at significant concentrations, evaluation for
compliance with water quality standards will only be performed for
lead and zinc.

The State water quality regulations require that water quality
standards be achieved under the following critical receiving water
flow conditions:

Chronic water quality standards:
7 day, 10 year return frequency flow (7Q10)

Acute water quality standards:
One-third (1/3) of the 7Q10 flow

The 7Q10 for the Illinois River is 70.9 cubic feet per second (cfs)

The facility provided a study of the outfall which showed that the
outfall quickly achieved complete mixing across the width of the
river. Dilution at the edge of the mixing zone can therefore be
characterized by the complete mixing equation:

Cr = (Cd)(Qd) + (Cs)(Qs)
where
Cr
Cd
Qd
Cs
Qs
(Qd + Qs)

the receiving water concentration,
the effluent concentration,
the effluent flow,
the receiving water background concentration, and
the appropriate receiving water flow.
The receiving water concentrations (Cr) expected in the Illinois
River are calculated using the equation described above, and the
following data:
16-16
-------
Pollutant

Lead
Effluent
Concentration (Cd)*
fmg/11 '

0.38
Fact Sheet
Page 9 of 21

Receiving Water
Concentration (Cs)**
fmq/1)
Zinc
0,21
0.07
* - Maximum daily concentration reported in the application Form 2C
** - Source U.S.G.S. STORET
For comparison with acute water quality standards, receiving water
concentrations are calculated as follows:

Cr (lead) - [(0.38 mg/l}(7.06 cfs) + (0 mg/l)(23.6 cfs)]/(7.06 cfs
+ 23.6 cfs)
= 0.088 mg/1

Cr (zinc) = [(0.21 mg/1)(7.06 cfs) +• (0.07 mg/l)(23.6 cfs)]/(7.06
cfs -t- 23.6 cfs)
= 0.102 mg/1

For comparison with chronic water quality standards, receiving
water concentrations are calculated as follows:

Cr (lead) = [(0.38 mg/1)(7.06 cfs) + (0 mg/1)(70.9 cfs)]/(7.06 cfs
+ 70.9 cfs)
= 0.034 mg/1

Cr (zinc) = [(0.21 mg/1)(7.06 cfs) + (0.07 mg/1)(70.9 cfs)]/(7.06
cfs + 70.9 cfs)
= 0.083 mg/1

The following table compares each receiving water concentration
calculated above with the State Water Quality Standard for aquatic
life protection:
State
Standard
Pollutant

Zinc
Chronic
Acute

Lead
Chronic
Acute
fag/11
110
120
3.2
82
Receiving Water
Concentration
fua/11
83
102
34
88
16-17
-------
Fact Sheet
Page 10 of 21

Since the calculated receiving water concentrations are less than
the criterion for zinc and greater than the criterion for lead,
water quality limits will be necessary for lead, but not for zinc.
It should be noted that the procedure used above does not account
for the variability of the pollutant concentrations in the
effluent. The EPA Technical Support Document for Water Quality-
based Toxics Control recommends accounting for this variability by
calculating the reasonable potential for pollutants to cause
exceedances of water quality standards. Specifically, the
reasonable potential is calculated using the maximum expected
effluent concentration, which is estimated by using a
multiplication factor (F) that incorporates both the coefficient of
variation (CV) and the number of effluent samples collected. If
this methodology were used with the existing data for Luster Glass,
Inc., there would be a reasonable potential for the concentration
of zinc in the discharge to exceed both the acute and chronic water
quality standards, and thus water quality permit limits will also
be calculated for zinc.

The following equation is used to calculate the effluent.
concentrations [which is commonly referred to as the waste load
allocation (WLA)] for lead and zinc that will ensure protection of
the State water quality standard.
Cd
WLA = Cr (Qd + Qs) - (Cs)(Qs)
where
Cd
Cr
Qd
Qs
Cs
Qd

WLA = waste load allocation
the applicable water quality standard
the effluent flow =7.06 cfs
the appropriate receiving water flow
the receiving water background concentration
Based on the following information, the waste load allocations for
lead and zinc are calculated.
Pollutant

Lead
Zinc
Cr = Acute State Water
Quality Standard

0.082 mg/1
0.12 rog/1
Cs = Upstream
Concentration

0 mg/1
0.07 mg/1
Pollutant

Lead
Zinc
Cr = Chronic State Water
Quality Standard

0.0032 mg/1
0.11 mg/1
"Cs = Upstream
Concentration

0 mg/1
0.07 mg/1
16-18
-------
Fact Sheet
Page 11 of 21

Lead (acute) Cd = [(0.082 mg/l)(7.06 cfs 4- 23.6 cfs) - (0
mg/l)(23.6 cfs)] / 7.06 cfs
= 0.36 mg/1

Lead (chronic) Cd = [(0.0032 mg/1) (7.06 cfs + 70.9 cfs) - (0
rag/1)(70.9 cfs)]/ 7.06 cfs
- 0.04 mg/1

Zinc (acute) Cd - [(0.12 mg/1) (7.06 cfs + 23.6 cfs) - (0.07
mg/1)(23.6 cfs)] / 7.06 cfs
= 0.29 mg/1

Zinc (chronic) Cd = [(0.11 ing/l)(7.06 cfs + 70.9 cfs) - (0.07
mg/1) (70.9 cfs)]/ 7.06 cfs = 0.51 mg/1

Given that all State water quality standards are expressed as never
to be exceeded (i.e., water quality-based limits must be protective
of the most stringent waste load allocation), a maximum daily
limitation (MDL) and a average monthly limitation (AML) for lead
and zinc are calculated using the waste load allocations calculated
above. It should be noted that the ratio of daily maximum to
monthly average for the technology-based effluent limitations for
lead and zinc are used to derive the MDL and AML. Specifically,
these ratios are 1.6 for lead and 1.0 for zinc.

Lead - since the chronic WLA is more limiting than the acute WLA
(i.e., 0.04 mg/1 < 0.36 mg/1), it will be used as the basis for
limitations. Since the chronic WLA can never be exceeded, 0.04
mg/1 is used as the MDL. The AML is calculated as follows:

0.04 mg/1
= 0.03 mg/1
1.6

Zinc - Since the acute WLA is more limiting than the chronic WLA
(i.e., 0.29 mg/1 < 0.51 mg/1), it will be used as the basis for
limitations. Since the acute WLA can never be exceeded, 0.029 mg/1
is used as the MDL. The AML is calculated as follows:

0.29 mg/1
=0.29 mg/1
1.0
Comparing the chemical specific water quality-based limits
calculated above with the technology-based effluent limitations
calculated for Outfall 001 (see Section VI above), the water
quality-based limits for lead are more stringent than the-
technology-based limits, so they will be used as the basis fcr
effluent limits in the permit. Since the technology-based effluer.-
limits for zinc are more stuingent than the water quality-base--
16-19
-------
Fact Sheet
Page 12 of 21

limits, the technology-based effluent limits will be used.

Equivalent end-of-pipe mass effluent limitations are also being
established in the draft permit. Using the total Outfall 001 flow
(4.563 mgd}, mass limitations for lead are calculated as follows:

MDL = (0.04 mg/l)(4.563 106 gal/day)(1 lb/454,000 mg)(3.785 1/gal)
=1.52 Ibs/day

AML - (0.03 mg/l)(4.563 106 gal/day) (1 lb/454,000 ing) (3.785 1/gal)
=1.14 Ibs/day

Whole Effluent Toxicity

The previous NPDES permit issued to the Luster Glass facility
contained a requirement for conducting monthly acute and chronic
toxicity tests during the fourth and fifth year of the permit
(March 1988 through February 1989). The test species selected by
the facility was the fathead minnow, based on an initial comparison*
of species sensitivity performed in February 1988. The results of
these toxicity tests were reviewed to determine whether an effluent
limit on toxicity should be developed for the permit.

The concentration of acute and chronic toxicity in the receiving
water is calculated and is then compared to the State water quality
standards. The receiving water concentrations for acute and
chronic toxicity were calculated using the following formula:

Cr = (Cd) (Qd) + (Cs) (Qs)
Where
Cr
Cd
Qd
Cs
Qs
{Qd +• Qs)

receiving water concentration
effluent concentration
effluent flow
receiving water background concentration
appropriate receiving water flow
The following summarizes the toxicity data submitted by Luster
Glass for the period from March 1988 to February 1989:
16-20
-------
Fact Sheet
Page 13 of 21

Toxicity Data (Fathead minnows)

LC50 NOEC
(% effluent) (% effluent)

58.0 50
25.2 3
55.0 10
46.3 30
44.8 25
5.9 1
67.8 10
3.9 1
50.1 30
52.0 10
32.1 3
41.7 30

All toxicity testing by Luster Glass involved the use of upstream
ambient water for the control and diluent, so that in all
calculations, the upstream toxicity is assumed to be zero. The
highest result of chronic toxicity measured was an NOEC equal to -1%
effluent. By dividing 1 into 100, the NOEC is converted to chronic
Toxic Units (TUJ . Similarly for acute toxicity, the highest acute
toxicity was measured at an LC50 equal to 3.9 % which converts to
25.6 TU..

The resultant receiving water concentration (Cr) in toxic units for
both acute and chronic toxicity are calculated using the following
data:

Cs = 0
Qs = 23.6 cfs (one third the 7Q10 for acute protection)
Qs = 70,9 cfs (the 7Qio for chronic protection)
Qd = 7.06 cfs

Cr = (25.6 TU.) (7.06 cfs)/(7.06 cfs + 23.6 cfs)
= 5.9 TU.

Cr = (100 TUJ (7.06 cfs)/(7.06 cfs + 70.9 cfs)
= 9.1 TUC
16-21
-------
Fact Sheet
Page 14 of 21

The State water quality standards for acuta and chronic protection
are summarized below:

State Water Quality Standard for Acute Protection =0.3 TU.
State Water Quality Standard for Chronic Protection =1.0 TUC

WET limits would be necessary since the calculated receiving water
concentrations exceed the state water quality standards for both
acute and chronic protection:

For acute protection 5.9 TU. > 0.3 TU.
For chronic protection 9.1 TUC > 1.0 TUC

Using steady state assumptions, the WLAs were calculated using the
following formula:

Cd = [Cr(Qd + Qs)-(Cs)(Qs)] / Qd

where:
Cd - Concentration of the pollutant in the discharge, or waste
load allocation
Cr = State Water Quality Standard
for chronic protection = 1.0 TUC
for acute protection =0.3 TU,
Qd = Discharge flow =7.06 cfs
Qs = Appropriate receiving water flow
chronic flow (7Q10) =70.9 cfs
acute flow =23.6 cfs
Cs = Receiving water or upstream concentration =* 0

Assuming zero background toxicity, the limits are calculated as
follows:

WLA (acute) = [(0.3 TU.)(7.06 cfs + 23.6 cfs) ] - [(0)(23.6 cfs)]

WLA (Chronic) = [(1.0 TUC)(7.06 cfs + 70.9 Cfs)] - [(0)(70.9 cfs)]
7.06 Cfs
= 11.0
An acute to chronic ratio (ACR) was calculated from the toxicity
data by taking the average ACR from each data set as follows:
16-22
-------
Fact Sheet
Page 15 of 21

LC50 NOEC
f% effluent) f% effluent! ACR

58.0 50 1.16
25.2 3 8.40
55.0 10 5.50
46.3 30 1.54
44.8 25 1.79
5.9 1 5.9
67.8 10 6.78
3.9 1 3.9
50.1 30 1.67
52.0 10 5.20
32.1 3 10.7
41.7 30 1.39
Average 4.5

The acute WLA (in TU,) are converted to TUC using the acute to
chronic ratio (ACR) as follows:

WLA (in TU.J =1.3 TU. * ACR
= 1.3 TU. * 4.5
= 5.9 TU.C

Given that all State water quality standards are expressed as never
to be exceeded (i.e., water quality-based limits must be protective
of the most stringent waste load allocation), a maximum daily
limitation (MDL) and a average monthly limitation (AML) for WET
were calculated using the waste load allocations calculated above.
A ratio of daily maximum to monthly average of 1.6 is assumed for
WET based upon technolgy-based effluent limits for lead.

Since the acute WLA is more limiting than the chronic WLA (i.e.,
5.9 TU.C < ll.O TUC) , it will be used as the basis for limitations.
Since the acute WLA can never be exceeded, 5.9 TUte is used as the
MDL. The AML is calculated as follows:

5.9 TUie
' = 3.7 TUe
1.6

The permittee shall conduct chronic toxicity tests according to
methods outlined in "Short Term Methods for Estimating the Chronic
Toxicity of Effluents and Receiving Waters to Freshwater Organisms"
(EPA 600/4-89 001) .
16-23
-------
Fact Sheet
Page 16 of 21
VIII. Proposed Effluent Limitations
Table 2 summarizes the proposed effluent limitations for Outfall
001. Proposed effluent limitations for zinc are based on BPJ. The
limitation for temperature is based on State water quality
standards. The proposed limitations for lead were calculated above
as chemical specific water quality-based limitations. The
remainder of the effluent limitations are based on BPT/BAT effluent
guidelines at 40 CFR Part 426 and State effluent standards.

IX. Monitoring Requirements

Monitoring for those pollutants expected to be present in Outfall
001 (i.e., TSS, oil and grease, phosphorus, lead, and zinc) will be
required once per week. Except for oil and grease, for which a
grab sample is required, 24-hour composite samples are required.
Temperature is to be monitored continuously during discharge.

Whole effluent toxicity testing for chronic toxicity shall be
conducted 2/month on a 24-hour composite sample of the final.
effluent.
X.
Special Conditions
Luster Glass Inc. will be required to update their existing Best
Management Practices (BMP) plan to address the potential for
leakage of gasoline from Tank Number 42 and nitric acid from the
drum storage area. Specifically, Luster Glass Inc. should
undertake the following two site-specific BMPs and incorporate them
into their plan. First, remedial action must be taken on Tank
Number 42 to repair the damaged tank. The gasoline must be
transferred to another vessel {e.g., tank truck) while the tank is
cleaned, repaired, welded or holes plugged. To prevent
environmental damage at this site in the future, the following BMPs
should be incorporated into the plan: visual inspection, secondary
containment, preventative maintenance, or some combination thereof.
Secondly, the drum storage area must be cleaned up by following
procedures such as the following: inventory the drums to identify
the contents and amounts of chemicals therein; inspect the drums
for deterioration or leaks, and segregate and adequately dispose of
the leaking or deteriorating drums; remove and adequately dispose
of any contaminated soil; neatly stack the remaining drums in a
manner to eliminate hazards to humans or the environment by
isolating the drums from walkways or roadways, placing them on an
impervious pad, covering the storage area, diking the area, moving
the storage area away from the stream or some combination thereof.
16-24
-------
Fact Sheet
Page 17 of 21
XI. Information Sources
While developing effluent limitations, monitoring requirements, and
special conditions for the draft permit, the following information
sources were used:

(1) EPA NPDES Application Forms l and 2C dated October 1980 and
February 1985, respectively.

(2) State Effluent Standards, Part 304 of the State Administrative
Code, Title 35 - Environmental Protection; Subtitle C - Water
Pollution, adopted March 17, 1980.

(3) Division files related to the Luster Glass Inc. NPDES Permit
No. IL0654321.

(4} State Water Quality Standards, Part 302 of the State
Administrative Code, Title 35 - Environmental Protection;
Subtitle C - Water Pollution, adopted March 17, 1980.

(5) EPA Technical Support Document for Water Quality-Based Toxics
Control.

(6) 40 CFR Parts 423, 433, and 426.
16-25
-------
Fact Sheet
Page 18 of 21
Date

03-88
04-88
05-88
06-88
07-88
08-88
09-88
10-88
11-88
12-88
01-89
02-89
TABLE 1
DISCHARGE MONITORING REPORT
LUSTER GLASS INC.

March 1988 through February 1989
Flow (mgd)
Mon. Ava. Daily Max.
4.575
4.554
4.552
4.568
4.585
4.588
4.571
4.568
4.553
4.551
4.550
4.560
4.583
4.567
4.569
4.573
4.589
4.591
4.581
4.572
4.573
4.541
4.561
4.570
TSS
flb/dl

180.4
245.2
429.3
308.7
Oil &
Grease
19
27
88
22
Phosphorus
flb/dl

14
18
29
15
16-26
-------
Fact Sheet
Page 19 of 21
Date

03-88
04-88
05-88
06-88
07-88
08-88
09-88
10-88
11-88
12-88
01-89
02-89
pH
fS.U.l

6.6
7.1
9.0
8.1
TABLE 1 (Continued)
DISCHARGE MONITORING REPORT
LUSTER GLASS INC.

March 1988 through February 1989

Temperature Zinc Lead
{degrees Fl (mq/U Lmv/l)
80
83
78
61
0.21
0.08
0.09
0.06
0. 10
0.17
0. 12
0.38
COD
(ma/li

50
16-27
-------
Fact Sheet
Page 20 of 21
TABLE 1 (Continued)
DISCHARGE MONITORING REPORT
LUSTER GLASS INC.

March 1988 through February 1989
Toxicity Test Data: Unless otherwise indicated, acute toxicity
tests were conducted using fathead minnow and
reported as 48 hr. LC50; chronic toxicity tests
were conducted using fathead minnows and
reported as 7 day NOEC.
DATE

3/88
4/88
5/88
6/88
7/88
8/88
9/88
10/88
11/88
12/88
1/89
2/89
(% effluent)

58.0
25.2
55.0
46.3
44.8
5.9
67.8
3.9
50.1
52.0
32. 1
41.7
NOEC
(% effluent)

50
3
10
30
25
1
10
1
30
10
3
30
Toxicity tests using Ceriodaphnia dubia 48 hour survival
(acute) and 7 day reproduction (chronic)
16-28
-------
Fact Sheet
Page 21 of 21
TABLE 2
PROPOSED EFFLUENT LIMITATIONS
NPDES PERMIT NO. IL0654321
DAILY MAXIMUM
MONTHLY AVERAGE
PARAMETER
Flow (mgd)
TSS
Oil & Grease
Phosphorous
PH
Temperature
Total Lead
Total I _nc
Whole Effluent
Toxicity (WET)
a/ pH shall be
b/ Not greater
LBS/DAY
Report
451.1
104.2
16.5
a/
b/
1.52
3.75
c/
within the
MG/L
—
11.86
2.74
0.43
—
—
0.04
0.10
—
range of
LBS/DAY
Report
351.3
104.2
16.5
—
—
1.14
3.75
C/
MG/L
--
9.23
2.74
0.43
—
—
0.03
0.10
—
6.0 - 9.0 standard units
than 2.8 degrees Centigrade above
ambient, or
1.7 degrees Centigrade above the following maximum
limits:
December 1 through March 31
April 1 through November 30
16 deg C (60 deg F)
32 deg C (90 deg F)
Discharges of effluent with toxicity greater than the
following amounts are prohibited: Maximum Daily Chronic
Toxicity of 5.9 TU,c and Average Monthly Chronic Toxicity
of 3.7 TUe,
16-29
-------
EXAMPLE RESPONSE
TO COMMENTS
16-30
-------
RESPONSE TO COMMENTS
FINAL PERMIT DECISION

This is our response to comments received on the subject draft permit in
accordance with regulations promulgated at 40 CFR Part 124.17.

Permit No. LA0006181

Applicant: Allied Chenical Corporation
P.O. Box 226
Geismar, Louisiana 70734

Issuing Office: U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733

Prepared By: Edward C. McHam, Engineer
Industrial Permits Section (6V-PI)
Permits Branch
Water Management Division
(214) 655-7180

Permit Action: Final permit decision and response to comments
received on the draft permit publicly noticed on
7/7/84.

Date Prepared: 9/5/84

Unless otherwise stated, citations to 40 CFR refer to promulgated regulations
listed at Title 40, Code of Federal Regulations, revised as of 7/1/83.

The following comments have been received on the draft permit:

Letter Dessert (Allied) to Caldwell (EPA) dated 7/30/84

The draft permit establishes biomonitoring requirements at Outfall 004. The
company requests deletion of these requirements.

The request is denied.

The permittee states that biomonitoring will be duplicative and unnecessary
because:

(1) EPA has identified the toxic pollutants of concern.

(2) The proposed permit places BAT limits and monitoring requirements
on these pollutants.
16-31
-------
PERMIT NO. LA0006181
RESPONSE TO COMMENTS
(3) The BAT limits are more restrictive than water quality-based
limitations.

(4) Biomonitoring results could be distorted and masked by the osmotic
stress on test organisms exerted by the salts present in an HF
plant effluent.

The biomonitoring method is a standardized method used throughout EPA Region 6
to measure the toxicity of various effluents which contain toxic components,
The test is not based on water quality impacts of a specific receiving scream.
Under Section 308 of the Clean Water Act, EPA Region 6 has the authority :o
require permittees to support development of data bases such as those
associated with toxics. Therefore, biomonitoring requirements as established
in the draft permit are retained in the final permit.
16-32
-------
Chevron ^, «...•« MU' -> ~- ,-'r; -
Chevron Chemical Company / \ iv^ , , i •. 5 -
PO 3c« ?S. St. James. U 70066 • Phone i£04| 473-7S46
January 12, 1990

0 P Teicnman
'•»"• Mjnjgn
r »f»j»t pfcjRf
" " CERTIFIED MAIL - RETURN RECEIPT f P 965 729 397
Ms. Ellen Caldwell
Permits Branch (6W-PS)
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733

SUBJECT: CHEVRON CHEMICAL COMMENTS
NPDES PERMIT NO. LA0029963

Dear Ms. Caldwell:

We have reviewed draft NPDES Permit No. LA0029963 for Chevron
Chemical's St. James Plant issued for public comment by the EPA on
December 16, 1989. We have the following comments:

1. As represented in the Fact Sheet (Part VIII. Sect ion C 1), we
understand an administrative order will be issued concurrent
with the final permit decision. We understand the
administrative order will establish interim limits which will
be in effect until 2/1/91, when our upgraded effluent treatment
plant will be operational. As a result, we have not reviewed,
and are not providing comments on the draft permit relative to
it being in effect during the interim period (i.e. from final
permit issuance to 2/1/91).

2. We want to clarify that the discharge description included in
Part V of the Fact Sheet is representative of our current
facility discharge. Following completion of our ongoing
facility expansion, the concentration of pollutants in our
discharge will significantly decrease and the discharge flcwrate
will increase from current levels. These changes to our
discharge were detailed in our submittals to the EPA and have
been properly recognized in development of the proposed perr.it
limits.

3. We request that you change the pH of the Outfall 002 frca 9.0
to 10.0. The plant's clarified water and firewater is purchased
and is lime softened with a pH of 10. This water has a high pH
but a low alkalinity and is not hazardous to personnel ncr to
the environment.

In the last 6 months we have had 2 permit e^^b
these water systems. In the first instance, bUj-Bfinply3-washirig
the paved areas of the plant with firewater, we %eceeded the 9.0
pH limit. In the second instance, a number of clarified water
JAN 1 8 '590

.
-------
and firewater lines failed due to the hard December freeze.
This water overflowed the retention pond and again we had a
permit exceedence.

We have developed and have begun implementing a plan to
eliminate continuous sources of high pH water currently
discharged to our retention pond. This work will be completed
by the 1/1/91. We therefore feel that a change of the pH limit
on Outfall 002 from 9.0 to 10.0 would not endanger people nor
the environment and would eliminate nuisance excursions.

We appreciated receiving the well-organized and readable fact sheet
which clearly established the basis for the permit requirements.
Although the proposed permit limits are substantially lower than those
in our previous permit, we expect to be able to achieve and maintain
compliance once our upgraded effluent treatment plant is fully
operational.

If you have any questions or wish to discuss our comments further,
please do not hesitate to contact me or my staff.

Very truly yours,
> P. Teichman
LLR/vho
16-34
-------
PRACTICAL EXERCISE

The Administrative Process
DIRECTIONS;
You are a permit writer and have issued an NPDES permit for Luster Glass Inc.,
a glass manufacturer located on the Illinois River. Luster Glass Inc., unhappy
with your work, seeks an administrative appeal of the permit and in so doing,
raises the following issues:

• The permit is improperly based on the provisions of 40 CFR Part 426
(Glass Manufacturing Point Source Category);

• The effluent limitations for zinc and lead are calculated
incorrectly;

• Luster Glass Inc.'s request to delete the duty to mitigate condition
was improperly ignored;

• The weekly monitoring requirements for lead and zinc are excessive;
and

• The Agency violated its regulations and established policy by
refusing to hold a hearing as requested by Luster Glass Inc.

(1) Assuming Luster Glass Inc.'s appeal is granted, what effect will this have
on the effectiveness of the NPDES permit?

(2) What standard of review should the Hearing Officer use to evaluate the
permit?

(3) You have been called upon to testify on behalf of the Permit Authority.
How do you respond to each of the issues raised by Luster Glass Inc.?

(a) The improper use of regulations:

(b) The calculation of limitations:

(c) The inclusion of the duty to mitigate condition:

(d) The excessive monitoring requirements:

(e) The failure to hold a hearing:
(4) In addition to this logically organized and undeniably scientific
testimony concerning your actions in developing this permit, what other
assistance might you be asked to lend to your attorney?
(5) Once the Hearing Officer has made a decision, what is the next step in the
process of getting the Luster Glass permit final and effective?
16-35
-------
16-36
-------
PERMIT WRITERS ON APPEAL

Witness for permit authority

Source of technical knowledge for attorney

Assist in developing cross-examination questions
NOTES:
16-37
-------
MAJOR MODIFICATIONS
1. Reopener condition
2. Correct technical and legal mistakes
3. Failure to notify interested State
4. New information
5. Alterations justifying new/different conditions
6. New regulations
7. Modification of a compliance schedule (> 120 days)
8. Require POTW to develop pretreatment programs
9. Unsuccessful BPJ treatment installed
10. Address non-limited pollutants
11. Variance request
12. Adjust limits to reflect net pollutant treatment
13. Insert 307(a) toxic or Part 503 sludge use/disposal
14. Establish notification levels
NOTES:
16-38
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1.
2.
3.
4.
5.
6.
7.
MINOR MODIFICATIONS
Typographical errors
More frequent monitoring
Change in interim compliance date (<120 days)
Change in ownership
Change in construction schedule for new source
Deletion of point source outfall
Incorporate approved local pretreatment program

•
•
•
PERMIT TERMINATIONS
Suspend effectiveness in emergency
Terminate for falsifications, recalcitrants or changed conditions
Post public notice intentions and offer permittee a hearing
NOTES:
16-39
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APPLICABLE EFFLUENT STANDARDS
REVIEW EXERCISE

1. Industrial facilities are subject to:
2. POTWs are subject to:
3. Federal facilities are subject to:
4. Industrial storm water is subject to:

5. Municipal storm water is subject to:
6. Combined sewer overflows are subject to:

7. New sources are subject to:
8. New dischargers are subject to:
NOTES:
16-40
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Permit No.: IL0654321

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AUTHORIZATION TO DISCHARGE UNDER THE

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM

In compliance with the provisions of the clean Water Act, as amended, (33
U.S.C. S1251 et seq; the "Act"),

LUSTER GLASS, INC.

is authorized to discharge from a facility located in Morris, Illinois

to receiving waters named the Illinois River

in accordance with discharge point(s), effluent limitations, monitoring
requirements and other conditions set forth herein. Authorization for discharge
is limited to those outfalls specifically listed in the permit.

This permit shall become effective

August 31, 1989

This permit and the authorization to discharge shall expire at midnight,
August 31, 1994.
Signed this day of
Authorized Permitting Official

Director
Water Management Division
Title
16--1
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PART I

Page 2 of 19
Permit No.:
IL0654321
TABLE OF CONTENTS

Cover Sheet—Issuance and Expiratxon Dates

I. Effluent Limitations and Monitoring Requirements

A. Definitions
B. Description of Discharge Points
C. specific Limitations and Self-Monitoring Requirements
(Includes Compliance Schedules as Appropriate)

II. Monitoring, Recording and Reporting Requirements

A. Representative Sampling
B. Monitoring Procedures
C. Penalties for Tampering
D. Reporting of Monitoring Results
S. Compliance Schedules
F. Additional Monitoring by the Permittee
G. Records Contents
H. Retention of Records
I. Twenty-four Hour Notice of Noncompliance Reporting
J. Other Noncompliance Reporting
K. Inspection and Entry

III. Compliance Responsibilities

A. Duty to Comply
B. Penalties for Violations of Permit Conditions
C. Need to Halt or Reduce Activity not a Defense
D. Duty to Mitigate
E. Proper Operation and Maintenance
F. Removed Substances
G. Bypass of Treatment Facilities
H. Upset Conditions
I. Toxic Pollutants
J. Changes in Discharge of Toxic Substances

IV. General Requirements

A. Planned Changes
B. Anticipated Noncompliance
C. Permit Actions
D. Duty to Reapply
E. Duty to Provide Information
F. Other Information
G. Signatory Requirements
H. Penalties for Falsification of Reports
I. Availability of Reports
J. Oil and Hazardous Substance Liability
K. Coast Guard
L. Property Rights
M. Severability
N. Transfers
O. State Laws
P. Water Quality Standard Requirements-Reopener Provision
Q. Toxicity Reopener Provision

V. Special Requirements

A. Best Management Practices (BMP) Plan
B. BMP Implementation
C. Site-Specific BMPs
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PART I

Page 3 of 19
Permit No.: IL0654321

I. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

A. Definitions.

1. The "30-day (and monthly) average," other than for fecal coliform
bacteria and total coliform bacteria, is the arithmetic average
of all samples collected during a consecutive 30-day period or
calendar month, whichever is applicable. Geometric means shall
be calculated for fecal coliform bacteria and total coliform
bacteria. The calendar month shall be used for purposes of
reporting self-monitoring data on discharge monitoring report
forms.

2. The "7-day (and weekly) average," other than for fecal coliform
bacteria and total coliform bacteria, is the arithmetic mean of
all samples collected during a consecutive 7-day period or
calendar week, whichever is applicable. Geometric means shall be
calculated for fecal coliform bacteria and total coliform
bacteria. The 7-day and weekly averages are applicable only to
those effluent characteristics for which there are 7-day average
effluent limitations. The calendar week which begins on Sunday
and ends on Saturday, shall be used for purposes of reporting
self-monitoring data on discharge monitoring report forms.
Weekly averages shall be calculated for all calendar weeks with
Saturdays in the month. If a calendar week overlaps two months
(i.e., the Sunday is in one month and the Saturday in the
following month), the weekly average calculated for that calendar
week shall be included in the data for the month that contains
the Saturday.

3. "Daily Maximum" ("Daily Max.") is the maximum value allowable in
any single sample or instantaneous measurement.

4. "Composite samples" shall be flow proportioned. The composite
sample shall, as a minimum, contain at least four (4) samples
collected over the compositing period. Unless otherwise
specified, the time between the collection of the first sample
and the last sample shall not be less than six (6) hours nor more
than 24 hours. Acceptable methods for preparation of composite
samples are as follows:

a. Constant time interval between samples, sample volume
proportional to flow rate at time of sampling;

b. Constant time interval between samples, sample volume
proportional to total flow (volume) since last sample. For
the first sample, the flow rate at the time the sample was
collected may be used;

c. Constant sample volume, time interval between samples
proportional to flow (i.e., sample taken every "X" gallons
of flow); and,

d. Continuous collection of sample, with sample collection rate
proportional to flow rate.

5. A "grab" sample, for monitoring requirements, is defined as a
single "dip and take" sample collected at a representative point
in the discharge stream.
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PART I

Page 4 of 19
Permit No.: IL0654321

6. An "instantaneous" measurement, for monitoring requirements, is
defined as a single reading, observation, or measurement.

7. "Upset" means an exceptional incident in which there is
unintentional and temporary noncompliance with technology-based
permit effluent limitations because of factors beyond the
reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error,
improperly designed treatment facilities, inadequate treatment
facilities, lack of preventive maintenance, or careless or
improper operation.

8. "Bypass" means the intentional diversion of waste streams from
any portion of a treatment facility.

9. "Severe property damage" means substantial physical damage to
property, damage to the treatment facilities which causes them to
become inoperable, or substantial and permanent loss of natural
resources which can reasonably be expected to occur in the
absence of a bypass. Severe property damage does not mean
economic loss caused by delays in production.

10. "Director" means Director of the United States Environmental
Protection Agency's Water Management Division.

11. "EPA" means the United States Environmental Protection Agency.

12. "Sewage Sludge" is any solid, semi-solid or liquid residue that
contains materials removed from domestic sewage during treatment.
Sewage sludge includes, but is not limited to, primary and
secondary solids and sewage sludge products.

13. "Acute Toxicity" occurs when 50 percent or more mortality is
observed for either test species (See Part I.e.) at any effluent
concentration. Mortality in the control must simultaneously be
10 percent or less for the effluent results to be considered
valid.

14. "Chronic Toxicity" occurs when the survival, growth, or
reproduction, as applicable, for either test species, at the
effluent dilution(s) designated in this permit (see Part I.e.),
is significantly less (at the 95 percent confidence level) than
that observed for the control specimens.
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PART I

Page 5 of 19
Permit No.: IL0654321

B. Description of Discharge ...Points

The authorization to discharge provided under this permit ia limited to
those outfalls specifically designated below as discharge locations.
Discharges at any location not authorized under an MPDES permit is a
violation of the Clean Water Act and could subject the person{8}
responsible for such discharge to penalties under Section 309 of the Act.
Knowingly discharging from an unauthorized location or failing to report an
unauthorized discharge within a reasonable time from first learning of an
unauthorized discharge could subject such person to criminal penalties as
provided under the clean Water Act.

Outfall
Serial Number Description of Discharge^ Point

001 Discharge of effluent from the wastewater treatment
oil/water separator and settling basins, and cooling
tower blowdown to the Illinois River.
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PART I

Page 6 of 19
Permit No.: IL0654321

C. Specific Limitations and Self-Monitoring Requirements

1. Effluent Limitations (Outfall 001)

Effective immediately and lasting through the life of the permit, the
permittee is authorized to discharge from Outfall 001. Such
discharges shall be limited by the permittee as specified below:
Effluent
Parameter

Total Suspended Solids,
Ib/day
mg/1

Oil and Grease,
Ib/day
mg/1

Total Phosphorus,
Ib/day
mg/1

Total Zinc,
Ib/day
mg/1

Total Lead,
Ib/day
mg/1

Whole Effluent Toxicity
(WET), TUe b/

Temperature
2 0-Day a/
Average

K/A
351.3
9.23
104.2
2.74
16.5
0.43
3.75
0.1
1.14
0.03
3.7

£/
Daily a/
Maximum

N/A
451.1
11.86
104.2
2.74
16.S
0.43
3.75
0.1
1.52
0.04
5.9

£/
There shall be no discharge of floating solids or visible foam in other than trace
amounts.

a/ See Definitions, Part I.A. for definition of terms.

b/ The permittee shall demonstrate compliance with WET requirements specified
in Part I.e.3 of this permit.

c/ pH shall not be less than 6.0 s.u. nor greater than 9.0 s.u.

d/ Temperature shall not be greater than 2.8 degrees Centigrade above ambient,
or 1.7 degrees Centigrade above the following maximum limits: from
December 1 through March 31, 16 degrees Centigrade (60 degrees Fahrenheit)
and from April 1 through November 30, 32 degrees Centigrade (90 degrees
Fahrenheit).
16-46
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PART I

Page 7 of 19
Permit No.: IL06S4321
c. Specific -Limitations and Self-Monitoring Requirements (Cont.1

2. Self-Monitoring Requirements (Outfall 001)

As a minimum, upon the effective date of this permit, the following
constituents shall be monitored at the frequency and with the type of
measurement indicated; samples or measurements shall be representative
of the volume and nature of the monitored discharge. If no discharge
occurs during the entire monitoring period, it shall be stated on the
Discharge Monitoring Report Form (EPA No. 3320-1) that no discharge or
overflow occurred.
Effluent
Parameter

Total Suspended Solids

Total Phosphorus

Whole Effluent Toxicity
•(WET), Chronic

Daily
Sample Type a/

Instantaneous or Continuous

24-Hour Composite

24-Hour Composite

24-Hour Composite

24-Hour Composite

24-Hour Composite

Continuous or Grab
Sampling by the permittee -for compliance with the monitoring requirements
specified above shall be performed at the following locations(s): within
100 feet of Outfall 001 to the Illinois River.

a/ See definitions, Part I.A.

b/ Flow measurements of effluent volume shall be made in such a manner that
the permittee can affirmatively demonstrate that representative values are
being obtained.
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PART I

Page 8 of 19
Permit No.: IL06S4321

C. Specific Limitations and Self-Monitoring RequirementsfCont.)

3. Whole Effluent Toxicity Testing - Chronic Toxicity

Starting the effective date of this permit, the permittee shall
conduct biweekly chronic toxicity tests on a 24 hour composite sample
of the final effluent. If chronic toxicity is detected, the permittee
shall conduct a Toxicity Reduction Evaluation, according to
specifications in Part I.e.4 of this permit. Test species shall
consist of Pimephales promelas (Fathead minnows). The chronic
toxicity tests shall be conducted in general accordance with the
procedures set out in the latest revision of "Short-Term Methods for
Estimating the Chronic Toxicity of Effluents and Receiving Haters to
Freshwater Organisms", EPA/600-4-89-001. If control mortality exceeds
20 percent, the test shall be considered invalid. Chronic toxicity
occurs when the No Observed Effect Concentrations (NOECs) (calculated
within a 95 percent confidence interval) exceed(s) the permit
limit(s). Test results shall be reported along with the Discharge
Monitoring Report (DMR) submitted for the end of the calendar period
during which the whole effluent test was run. The report shall
include all the physical testing as specified and shall report test
conditions, including temperature, pH, conductivity, mortality, total
residual chlorine concentration, control mortality, and statistical
methods used to calculate an NOEC.

If the results for one year (26 consecutive weeks) of whole effluent
testing indicate no chronic toxicity, the permittee may request- the
permit issuing authority to allow the permittee to reduce testing
frequency. The permit issuing authority may approve/ partially
approve, or deny the request based on results and other available
information.

4. Toxicity Reduction Evaluation (TRE)

If the permittee fails to meet toxicity requirements specified in this
permit, the permit issuing authority shall determine that a TRE is
necessary. The permittee shall be so notified and shall initiate a
TRE immediately thereafter. The TRE shall include a TRE Test Plan
that must be submitted to the permitting authority within 60 days
after notification of a TRE requirement. The permitting authority
will then establish a deadline for compliance. The purpose of the TRE
will be to establish the cause of the toxicity,' locate the source(s)
of the toxicity, and control or provide treatment for the toxicity
prior to the deadline.

If acceptable to the permit issuing authority, this permit may be
reopened and modified to incorporate any additional numerical
limitations, a modified compliance schedule if judged necessary by the
permit issuing authority, and/or a modified whole effluent protocol.

Failure to conduct an adequate TRE, or failure to submit a plan or
program as described above, or the submittal of a plan or program
judged inadequate by the permit issuing authority, shall in no way
relieve the permittee from the deadline for 'compliance contained in
this permit.
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PART II

Page 9 of 19
Permit No.: IL0654321

II. MONITORING, RECORDING AND REPORTING REQUIREMENTS

A. Representative Sampling. Samples taken in compliance with the
monitoring requirements established under Part I shall be collected
from the effluent stream prior to discharge into the receiving waters.
Samples and measurements shall be representative of the volume and
nature of the monitored discharge.

B. Monitoring Procedures. Monitoring must be conducted according to test
procedures approved under 40 CFR Part 136, unless other test
procedures have been specified in this permit.

C. Penalties for Tampering. The Act provides that any person who
falsifies/ tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this
permit shall, upon conviction, be punished by a fine of not more than
$10,000 per violation, or by imprisonment for not more than two years
per violation, or by both.

D. Reporting of Monitoring Results. Effluent monitoring results obtained
during the previous month(s) shall be summarized for each month and
reported on a Discharge Monitoring Report Form (EPA No. 3320-1),
postmarked no later than the 28th day of the month following the
completed reporting period. If no discharge occurs during the
reporting period, "no discharge" shall be reported. Until further
notice, sludge monitoring results may be reported in the testing
laboratory's normal format (there is no EPA standard form at this
time), but should be on letter size pages. Legible copies of these,
and all other reports required herein, shall be signed and certified
in accordance with the Signatory Requirements (see Part IV), and
submitted to the Director, Water Management Division and the State
water pollution control agency at the following addresses:

original to: United States Environmental Protection Agency
Attention: Water Management Division
Compliance Branch

t copy to: State Department of Health
Attention: Permits and Enforcement

E. Compliance Schedules. Reports of compliance or noncompliance with, or
any progress reports on interim and final requirements contained in
any Compliance Schedule of this permit shall be submitted no later
than 14 days following each schedule date.

F. Additional Monitoring by the Permittee. If the permittee monitors any
pollutant more frequently than required by this permit, using test
procedures approved under 40 CFR 136 or as specified in this permit,
the results of this monitoring shall be included in the calculation
and reporting of the data submitted in the DMR. Such increased
frequency shall also be indicated.

G. Records Contents. Records of monitoring information shall include:

1. The date, exact place, and time of sampling or measurements;

2. The initials or name(s) of the individual(s) who performed the
sampling or measurements;

3. The date(s) analyses were performed;

4. The time(s) analyses were initiated;
16-49
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Page 10 of 19
Permit No.: IL0654321

5. The initials or name(s) of individual(a) who performed the
analyses;

6. References and written procedures, when available, for the
analytical techniques or methods used; and,

7. The results of such analyses, including the bench sheets,
instrument readouts, computer disks or tapes, etc., used to
determine these results.

H. Retention of Records. The permittee shall retain records of all
monitoring information, including all calibration and maintenance
records and all original strip chart recordings for continuous
monitoring instrumentation, copies of all reports required by this
permit, and records of all data used to complete the application for
this permit, for a period of at least three years from the date of the
sample, measurement, report or application. This period may be
extended by request of the Director at any time. Data collected on
site, copies of Discharge Monitoring Reports, and a copy of this NPDES
permit must be maintained on site during the duration of activity at
the permitted location.

I. Twenty-four Hour Notice of Noncompliance Reporting.

1. The permittee shall report any noncompliance which may seriously
endanger health or the environment as soon as possible, but no
later than twenty-four (24) hour a from the time the permittee
first became aware of the circumstances. The report shall be
made to the EPA Emergency Response Branch at (312) 293-1788 and
the State at (312) 370-9395.

2. The following occurrences of noncompliance shall be reported by
telephone to the EPA Compliance Branch at (312) 293-1589 and the
State at (312) 331-4590 by the first workday (8:00 a.m. - 4:30
p.m. ) following the day the permittee became aware of the
circumstances:

a. Any unanticipated bypass which exceeds any -effluent
limitation in the permit (See Part III.G.. Bypass of
Treatment Facilities.);

b. Any upset which exceeds any effluent limitation in the
permit (See Part III.H., Upset Conditions.); or,

c. Violation of a maximum daily discharge limitation for any of
the pollutants listed in the permit to be reported within 24
hours.

3. A written submission shall also be provided within five days of
the time that the permittee becomes aware of the circumstances.
The written submission shall contain:

a. A description of the noncompliance and its cause;

b. The period of noncompliance, including exact dates and
times;

c. The estimated time noncompliance is expected to continue if
it has not been corrected; and,

d. Steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance.
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PART II

Page 11 of 19
Permit No.: IL0654321

4. The Director may waive the written report on a case-by-case basis
if the oral report has been received within 24 hours by the
Compliance Branch, Water Management Division by phone, (312) 293-
1589.

5. Reports shall be submitted to the addresses in Part II. D. .
Reporting of Monitoring Results.

J. Other Noncompliance Reporting. Instances of noncompliance not
required to be reported within 24 hours shall be reported at the time
that monitoring reports for Part II.D. are submitted. The reports
shall contain the information listed in Part II. I. 2.
K. Inspection ^nd Entry. The permittee shall allow the Director, or an
authorized representative, upon the presentation of credentials and
other documents as may be required by law, to:

1. Enter upon the permittee's premises where a regulated facility or
activity is located or conducted, or where records must be kept
under the conditions of this permit;

2. Have access to and copy, at reasonable times, any records that
must be kept under the conditions of this permit;

3. Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations
regulated or required under this permit; and,

4. Sample or monitor at reasonable times, for the purpose of
assuring permit compliance or as otherwise authorized by the Act,
any substances or parameters at any location.
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PART III

Page 12 of 19
Permit No.: IL0654321

III. COMPLIANCE RESPONSIBILITIES

A. Duty to Comply. The permittee must comply with all conditions of this
permit. Any permit noncompliance constitutes a violation of the Act
and is grounds for- enforcement action; for permit termination,
revocation and reissuance, or modification; or for denial of a permit
renewal application. The permittee shall give the Director advance
notice of any planned changes at the permitted facility or of an
activity which may result in permit noncompliance.

8. Penalties for Violationsof Permit Conditions. The Act provides that
any person who violates a permit condition implementing Sections 301,
302, 306, 307, 308, 318, or 405 of the Act is subject to a civil
penalty not to exceed $25,000 per day of such violation. Any person
who willfully or negligently violates permit conditions implementing
Sections 301, 302, 306, 307, or 308 of the Act is subject to a fine of
not less than $5,000, nor more than $50,000 per day of violation, or
by imprisonment for not more than 3 years, or both. Except as
provided in permit conditions in Part III.G.. Bypass of Treatment
Facilities and Part III.H.. Upset Conditions, nothing in this permit
shall be construed to relieve the permittee of the civil or criminal
penalties for noncomplLance.

C. Need to Halt or Reduce Activity not a Defense. It shall not be a
defense for a permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to
maintain compliance with the conditions of this permit.

D. Duty to Mitigate. The permittee shall take all reasonable steps to
minimize or prevent any discharge in violation of this permit which
has a reasonable likelihood of .adversely affecting human health or the
environment.

E. Proper Operation and Maintenance. The permittee shall at all times
properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by
the permittee to achieve compliance with the conditions of this
permit. Proper operation and maintenance also includes, adequate
laboratory controls and appropriate quality assurance procedures.
This provision requires the operation of back-up or auxiliary
facilities or similar systems which are installed by a permittee only
when the operation is necessary to achieve compliance with the
conditions of the permit. However, the permittee shall operate, as a
minimum, one complete set of each main line unit treatment process
whether or not this process is needed to achieve permit effluent
compliance.

F. Removed Substances. Collected screenings, grit, solids, sludges, or
other pollutants removed in the course of treatment shall be buried or
disposed of in such a manner so as to prevent any pollutant from
entering any waters of the state or creating a health hazard. Filter
backwash shall not be directly blended with or enter either the final
plant discharge and/or waters of the United States.

G. Bypass of Treatment Facilities:

1. Bypass not exceeding limitations. The permittee may allow any
bypass to occur which does not cause effluent limitations to be
exceeded, but only if it also is for essential maintenance to
assure efficient operation. These bypasses are not subject to
the provisions of paragraphs 2. and 3. of this section.
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PART III

Page 13 of 19
Permit No.: IL0654321
2. Notice:
a. Anticipated bypass. If the permittee knows in advance of
the need for a bypass, it shall submit prior notice, if
possible at least 60 days before the date of the bypass.

b. Unanticipated bypass. The permittee shall submit notice of
an unanticipated bypass as required under Part II.I..
Twenty-four Hour Reporting.

3. Prohibition of bypass.

a. Bypass is prohibited and the Director may take enforcement
action against a permittee for a bypass, unless:

(1) The bypass was unavoidable to prevent loss of life,
personal injury, or severe property damage;

(2) There were no feasible alternatives to the bypass,
such as the use of auxiliary treatment facilities,
retention of untreated wastes, or maintenance during
normal periods of equipment downtime. This condition
is not satisfied if adequate back-up equipment should
have been installed in the exercise of reasonable
engineering judgement to prevent a bypass which
occurred during normal periods of equipment downtime
or preventive maintenance; and,

{3} The permittee submitted notices as required under
paragraph 2. of this section.

b. The Director may approve an anticipated bypass, after
considering its adverse effects, if the Director determines
that it will meet the three conditions listed above in
paragraph 3.a. of this section.

H. Upset Conditions.

1. Effect of an upset. An upset constitutes an affirmative defense
to an action brought for noncompliance with technology based
permit effluent limitations if the requirements of paragraph 2.
of this section are met. No determination made during
administrative review of claims that noncompliance was caused by
upset, and before an action for noncompliance, is final
administrative action subject to judicial review (i.e.,
Permittees will have the opportunity for a judicial determination
on any claim of upset only in an enforcement action brought for
noncompliance with technology-based permit effluent limitations) .

2. Conditions necessary for a demonstration of upset... .A permittee
who wishes to establish the affirmative defense of upset shall
demonstrate, through properly signed, contemporaneous operating
logs, or other relevant evidence that:

a. An upset occurred and that the permittee can identify the
cause(s) of the upset;

b. The permitted facility was at the time being properly
operated;

c. The permittee submitted notice of the upset as required
under Part II.I., Twenty-four Hour Notice of NoncompIlance
Report ing; and,

d. The permittee complied with any remedial measures required
under Part III.P., Duty to Mitigate.
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3.
PABT III

Page 14 of 19
Permit No.: IL0654321

Burden of proof. In any enforcement proceeding, the permittee
seeking to establish the occurrence of an upset hae the burden of
proof.
I. Toxic Pollutants. The permittee shall comply with effluent standards
or prohibitions established under Section 307(a) of the Act for toxic
pollutants within the time provided in the regulations that establish
those standards or prohibitions, even if the permit has not yet been
modified to incorporate the requirement.

3- Changes in Discharge of Toxic Substances. Notification shall be
provided to the Director as soon as the permittee knows of, or has
reason to believe:

1. That any activity has occurred or will occur which would result
in the discharge, on a routine or frequent basis, of any toxic
pollutant which is not limited in the permit, if that discharge
will exceed the highest of the following "notification levels":

a. one hundred micrograms per liter {100 ug/L);

b. Two hundred micrograms per liter (200 ug/L) for acrolein and
acrylonitrile; five hundred micrograms per liter (500 ug/L)
for 2,4-dinitrophenol and for 2-methyl-4, 6-dinitrophenol;
and one milligram per liter (1 mg/L) for antimony;

c. Five (5) times the maximum concentration value reported for
that pollutant in the permit application in accordance with
40 CFR 122.21(g)(7); or,

d. The level established by the Director in accordance with 40
CFR 122.44(f).

2. That any activity has occurred or will occur which would result
in any discharge, on a non-routine or infrequent basis, of a
toxic pollutant which is not limited in the permit, if that
discharge will exceed the highest of the following "notification
levels":

a. Five hundred micrograms per liter (500 ug/L);

b. One milligram per liter (1 mg/L) for antimony:

c. Ten (10) times the maximum concentration value reported for
that pollutant in the permit application in accordance with
40 CFR 122.21(g)(7); or,

d. The level established by the Director in accordance with 40
CFR 122.44(f).
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PART IV

Page 15 of 19
Permit No.: IL0654321
IV. GENERAL REQUIREMENTS
A. Planned Changes. The permittee shall give notice to the Director as
soon as possible of any planned physical alterations or additions to
the permitted facility. Notice is required only when:

1. The alteration or addition to a permitted facility may meet one
of the criteria for determining whether a facility is a new
source as determined in 40 CFR 122.29(b); or

2. The alteration or addition could significantly change the nature
or increase the quantity of pollutants discharged. This
notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification
requirements under Part IV.A.I.

B. Anticipated Noncompliance. The permittee shall give advance notice of
any planned changes in the permitted facility or activity which may
result in noncompliance with permit requirements.

C. Permit Actions. This permit may be modified, revoked and reissued, or
terminated for cause. The filing of a request by the permittee for a
permit modification, revocation and reissuance, or termination, or a
notification of planned changes or anticipated noncompliance, does not
stay any permit condition.

D. Duty to Reaoplv. If the permittee wishes to continue an activity
regulated by this permit after the expiration date of this permit,'the
permittee must apply for and obtain a new permit. The application
should be submitted at least 180 days before the expiration date of
this permit.

E. Duty to Provide Information. The permittee shall furnish to the
Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking
and reissuing, or terminating this permit, or to determine compliance
with this permit. The permittee shall also furnish to the Director,
upon request, copies of records required to be kept by this permit.

F. Other Information. When the permittee becomes aware that it failed to
submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or any report to the
Director, it shall promptly submit such facts or information.

G. Signatory Requirements. All applications, reports or information
submitted to the Director shall be signed and certified.

1. All permit applications shall be signed as follows:

a. For a corporation: by a responsible corporate officer;

b. For a partnership or sole proprietorship: by a general
partner or the proprietor, respectively;

c. For a municipality, state, Federal, or other public agency:
by either a principal executive officer or ranking elected
official.

2. All reports required by the permit and other information
requested by the Director shall be signed by a person described
above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:

a. The authorization is made in writing by a person described
above and submitted to the Director, and,
16-55
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PART IV

Page 16 of 19
Permit No.: IL0654321

b. The authorization specified either an individual or a
position having responsibility for the overall operation of
the regulated facility or activity, such as the position of
plant manager, operator of a well or a well field,
superintendent, position of equivalent responsibility, or an
individual or position having overall responsibility for
environmental matters for the company. (A duly authorized
representative may thus be either a named individual or any
individual occupying a named position.)

3. Changes to authorization. If an authorization under paragraph
IV.G.2. is no longer accurate because a different individual or
position has responsibility for the overall operation of the
facility, a new authorization satisfying the requirements of
paragraph IV.G.2. must be submitted to the Director prior to or
together with any reports, information, or applications to be
signed by an authorized representative.

4. Certification. Any person signing a document under this section
shall make the following certification:

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

H. Penalties for Falsification of Reports. The Act provides that any
person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to
be maintained under this permit, including monitoring reports or
reports of compliance or noncompliance shall, upon conviction be
punished by a fine of not more than $10,000 per violation, or by
imprisonment for not more than two years per violation, or by both.

I. Availability of Reports. Except for data determined to be
confidential under 40 CFR Part 2, all reports prepared in accordance
with the terms of this permit shall be available for public inspection
at the offices of the State water pollution control agency and the
Director. As required by the Act, permit applications, permits and
effluent data shall not be considered confidential.

J. Oil and Hazardous Substance Liability. Nothing in this permit shall
be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or
penalties to which the permittee is or may be subject under
Section 311 of the Act.

K. Coast Guard. If the Permittee operates its facility at certain times
as a means of transportation over water, the Permittee shall comply
with any applicable regulations promulgated by the Secretary of the
department in which the Coast Guard is operating, that establish
specifications for safe transportation, handling, carriage, and
storage of pollutants.

L. Property Rights. The issuance of this permit does not convey any
property rights of any sort, or any exclusive privileges, nor does it.
authorize any injury to private property or any invasion of personal
rights, nor any infringement of federal, state or local laws or
regulations.
16-56
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PART IV

Page 17 of 19
Permit No.: IL0654321

M. Severabilitv. The provisions of this permit are severable, and if any
provision of this permit, or the application of any provision of this
permit to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit,
shall not be affected thereby.

N. Transfers. This permit may be automatically transferred to a new
permittee if:

1. The current permittee notifies the Director at least 30 days in
advance of the proposed transfer date;

2. The notice includes a written agreement between the existing and
new permittees containing a specific date for transfer of permit
responsibility, coverage, and liability between them; and,

3. The Director does not notify the existing permittee and the
proposed new permittee of his or her intent to modify, or revoke
and reissue the permit. If this notice is not received, the
transfer is effective on the date specified in the agreement
mentioned in paragraph 2. above.

O. State Laws. Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from any
responsibilities, liabilities, or penalties established pursuant to
any applicable state law or regulation under authority preserved by
Section 510 of the Act.

P. Reopener Provision. This permit may be reopened and modified
(following proper administrative procedures) to include the
appropriate effluent limitations (and compliance schedule, if
necessary), or other appropriate requirements if one or more of the
following events occurs:

1. Water Quality Standards; The water quality standards of the
receiving water(s) to which the permittee discharges are modified
in such a manner as to require different effluent limits than
contained in this permit.

2. Wastelpad Allocation; A wasteload allocation is developed and
approved by the State and/or EPA for incorporation in this
permit.

3. Water Quality Management Plan; A revision to the current water
quality management plan is approved and adopted which calls for
different effluent limitations than contained in this permit.
16-57
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PART IV

Page 18 of 19
Permit No.: IL0654321

Q. Toxlcitv Limitation-Reopener Provision. This permit may be reopened
and modified (following proper administrative procedures) to include
a new compliance date, additional or modified numerical limitations,
a new or different compliance schedule, a change in the whole effluent
protocol, or any other conditions related to the control of toxicants
if one or more of the following events occur:

1. Toxicity was detected late in the life of the permit near or past
the deadline for compliance.

2. The TRE results indicate that compliance with the toxic limits
will require an implementation schedule past the date for
compliance and the permit issuing authority agrees with the
conclusion.

3. The TRE results indicate that the toxicant(s) represent
pollutant(s) that may be controlled with specific numerical
limits, and the permit issuing authority agrees that numerical
controls are the most appropriate course of action.

4. Following the implementation of numerical controls on toxicants,
the permit issuing authority agrees that a modified whole
effluent protocol is necessary to compensate for those toxicants
that are controlled numerically.

5. The TRE reveals other unique conditions or characteristics which,
in the opinion of the permit issuing authority, justify the
incorporation of unanticipated special conditions in the permit.
16-58
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PART V

Page 19 of 19
Permit No.: IL0654321

V. SPECIAL REQUIREMENTS

A. Best Management Practices (BMP} Plan

A BMP plan shall be developed within six months of permit reissuance,
addressing each of the nine specific requirements described in the
June 1981 EPA document, NPDES BMP Guidance Document. Emphasis shall
be placed on good housekeeping practices, visual inspection, and
preventative maintenance.

The BMP plan shall be written up and delivered to the U.S.
Environmental Protection Agency no later than February 5, 1990.

B. BMP Implementation

The BMP plan shall be fully implemented within twelve months of permit
reissuance. An implementation report shall be delivered to the U.S.
Environmental Protection Agency no later than August 5, 1990.

C. Site-Specific BHPs

The following site-specific BMPs shall be included:

1. Tank Number 42: Remedial action is required to repair the damaged
tank. This shall include transfer of the contents to another
vessel (e.g., tank truck), cleaning the tank, and repairing,
welding, or plugging the hole. To prevent environmental damage
in the future, secondary containment is required. Monthly visual
inspections and/or preventative maintenance shall be conducted.

2. Drum Storage Area: The drums shall be inventoried to identify
the contents and amounts of chemicals therein. The drums shall
be inspected for deterioration or leaks. They shall be
segregated and any leaking or deteriorating drums shall be
disposed of or repaired. Any contaminated soil shall be removed
and adequately disposed of. The remaining drums shall be neatly
stacked in a manner to eliminate hazards to humans or the
environment by isolating the drums from walkways or roadways,
placing them on an impervious pad, covering the storage area,
diking the area, moving the storage area away from the river, or
some combination thereof.
16-59
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COMPLIANCE AND ENFORCEMENT
-------
-------
LEARNING OBJECTIVES

Common errors in permits

Data management considerations (PCS)
Enforcement tools and considerations
Citizens and enforcement
COMMON ERRORS AND OMISSIONS
Not:
Issuing permit to correct entity

Ensuring limits are defensible and compatible with PCS

Covering all outfalls

Imposing adequate monitoring or specifying type, frequency
and location

Using special conditions

Requiring routine DMRs and specifying signatory

Including all standard conditions

Incorporating Federal Regulations without further explanation

Using precise language
NOTES:
17-1
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PCS LEARNING OBJECTIVES

Basic understanding of PCS system

Development process
Data elements
Sources of assistance

Permit writer's responsibilities
PCS POLICY
Adopted - October 1985

Designates PCS as the official NPDES data system

Requires EPA Regions to use

Requires NPDES States to use or have interface capability
NOTES:
17-2
-------

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17-3
-------
PCS ASSISTANCE
Region/State experts

EPA HQ/PCS hotline [(202) 260-8529]

PCS publications
Other methods
PCS PUBLICATIONS
General retrieval manual
Inquiry user's guide

Data element dictionary

Data entry/edit manual

Manager's guide to PCS
NOTES:
17-4
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PERMIT QUALITY REVIEW CHECKLIST
CHECKLIST A-l
Procedural Requirements: ADMINISTRATIVE RECORDS

1. List any of the following items that have been omitted
inappropriately from the file.

a. Permit application and any supporting data furnished by
applicant;
b. Draft permit;
c. Statement of basis or fact sheet;
d. All documents cited in statement of basis or fact sheet;
e. If a new source, any environmental assessment,
environmental impact statement, finding of no significant
impact or environmental information document and any
supplement to an Eis that was prepared;
f. All comments received during public comment;
g. Tape or transcript of any hearings held and any written
materials submitted at hearing;
h. Response to significant comments raised during comment
period and/or hearing;
i. Final permit;
j. Explanation of changes from draft to final permit;
k. Where appropriate, materials relating to
o Consistency determinations under the CZMA
o Consultation under the Endangered Species Act
o Determination under section 403(c) of the CWA
17-5
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CHECKLIST A-2
Procedural Requirements: PUBLIC NOTICE AND COMMENT
Question

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 public hearing held?
(If "no", skip to #4)

was a notice of public hearing issued at least 30 days prior
to hearing?

Was a summary response to significant comments raised during
comment period and/or hearing prepared and issued at time of
final permit decision?
CHECKLIST A-3
Procedural Requirements: STATE CERTIFICATION
Question
1. Was a state certification or waiver of state certification
received?
2. List any conditions in the state certification not included
in the permit. Indicate any reasons provided for omissions.
17-o
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CHECKLIST A-4
Procedural Requirements: RECORDS OF MODIFICATION

1. Does the permit documentation indicate that the permit was
modified, revoked or reissued?
(If "no", skip to Checklist A-5)

2. Was the permit modified pursuant to 40 CFR 122.62(a)? If
"yes", specify the basis identified in the permit
documentation: (alteration; new information; new
regulations; compliance schedules; variance request; 307(a)
toxic standard; net limits; reopener; nonlimited pollutants
(level of discharge of any pollutant no limited in permit
exceeds the level which can be achieved by technology-based
treatment); use ore manufacture of toxics (permittee has
begun or expects to begin to use or manufacture a toxic .
pollutant); notification levels (permit has been modified to
establish a "notification level")

3. Did cause exist for modification or revocation and
reissuance pursuant to 40 CFR 122.62(b)?
Specify cause:
a. Cause exists for termination, as provided in 40 CFR
122.64 (noncompliance; misrepresentation of or failure to
disclose facts; endangerment to human health or
environment; change in condition);
b. Transfer of permit;
c. Other (specify)

4. Does the permit documentation indicate that the procedures
of 40 CFR 124.5 for permit modification, revocation and
reissuance or termination were followed?
CHECKLIST A-5
Procedural Requirements: ENFORCEMENT CONSIDERATIONS

1. Does the permit documentation indicate that any enforcement
actions have been taken?
Briefly describe (nature of action(s), date(s)):
2. Did the Regional Counsel review or sign off on the permit?
17-7
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CHECKLIST B-l
Permit Conditions: BOILERPLATE
Question
Identify whether the following general conditions have been
incorporated into the permit, either directly or by
reference to 40 CFR Part 122.41 (or, if permit was issued
prior to April 1983, by reference to 40 CFR Parts 122.7 and
122.60). Identify any variation from the regulation language
in 122.41.
a
b
c
d
e
f.
g.
h.
i.
j.
k.
1.
m.
Duty to comply;
Duty to reapply;
Duty to halt or reduce activity;
Duty to mitigate;
Program operation and maintenance;
Permit actions;
Property rights;
Duty to provide information;
Inspection and entry;
Monitoring and records;
Signatory requirement;
Reporting requirements;
Bypass; and
n. Upset
included
„.. of the
specify missing item(s):
reference, is the
provided? If
(Skip to 15)
Does the permit require notification to the Director as soon
as the permittee knows or has reason to believe that any
activity has occurred or will occur which would result in
the discharge of any toxic pollutant, if that discharge will
exceed the "notification levels1!* specified in 40 CFR Part
122.42(a)(1)?

Does the permit require notification to the Director as soon
as the permittee knows or has reason to believe that it has
begun or expects to begin to use or manufacture as an
intermediate or final product or byproduct any toxic
pollutant which was not reported in the permit application?

Is the permit effective for a fixed term which does not
exceed 5 years from date of issuance?
17-8
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CHECKLIST B-2
Permit Conditions: SPECIAL CONDITIONS
Question
1. Are any special conditions requiring best management
practices (BMPs) included in the permit? Identify and
specify reason for inclusion (part of guideline, substitute
for numeric limitations, etc.)*

2. Does the permit application indicate that permittee does or
expects to use or manufacture any toxic substance as an
intermediate or final product or byproduct? (See Form 2C,
Item VI-A.) Have any conditions for the substances so
indicated been included in the permit? If not, does permit
documentation explain the omission?

3. Does the permit application indicate that there are
intermittent discharges at the outfall? (See Form 2C, Item
II-C) Are they addressed in the permit? Identify any
unexplained omissions.

4. Does the permit include any biological toxicitv testing
requirements? Briefly describe the requirements and their
basis.

5. Does the permit include any limitations or conditions, for
internal waste -streams? Describe the- limitations/conditions
and the circumstances that make them necessary.
17-9
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CHECKLIST C-l
Effluent Limitations: TRANSLATING THE PERMIT APPLICATION
TO PERMITLIMITATIONS

Introduction: Question #1 applies to all outfalls. For the
remaing questions, complete one checklist for each individual
outfall selected by the review team for review.

1. Have a set of effluent limitaions or conditions been
included in the permit for every outfall? (See Form 2C, Iter.
III-B)

2. For which pollutants are limitations or conditions included
in the permit for: (Identify in an attachment)
a. BPT;
b. BAT; and
c. BCT?

3. Are there pollutants for which limitations or conditions are
not included but which might be appropriate to limit?
Identify the pollutants and the reasons for including
limitations.
CHECKLIST C-2
Effluent Limitations: BASIS FOR LIMITATIONS

Introduction; Complete one checklist for each individual outfall
selected by the review team for review.

1. Are the pollutant limitations based on any of the following:
a. BPT;
b. BCT;
c. BAT;
d. KSPS;
e. Water quality standards?
f. Previous permit
g. Other
(Specify)
Are limitations for all pollutants in continuous discharges
expressed as both maximum daily values and average monthly
values? (If "yes", skip to 14)

List those pollutants for which either limit is omitted,
where the omission is inappropriate.

List any pollutants limited by mass or concentration that
should have been limited In the other form and indicate the
reason it should have been listed in the other form.
17-10
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CHECKLIST C-3
Effluent Limitations: APPLICABLE EFFLUENT GUIDELINES

Introduction; Complete one checklist for each individual outfall
selected by the review team for review, if effluent guidelines
are applicable.

1. Were promulgated effluent guidelines applicable to the
source category at the time permit was under consideration?
(See Form l, Items III and XII) (If "no", skip to Checklist
c-4) If not, does the permit contain a reopener clause?

2. WEre effluent guideline limitations used as a basis for
permit effluent limitations at the outfall.

3. Did the permittee receive a variance based on the presence
of "fundamentally different factors" from those on which the
guideline was based? (If "yes", skip to Checklist C-4)

4. Are applicable effluent guidelines limitations based on
production?
(If "no", skip to #9)

5. Was production basis in the permit a reasonable measure of
average actual production, not design production capacity?
(See Form 2C, Items III-B and C.)
Specify production basis:
a. Maximum production during high month of previous
year;
b. Monthly average for the highest of previous;
c. Other: .
17-11
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CHECKLIST C-3 (continued)
Effluent Limitations: APPLICABLE EFFLUENT GUIDELINES
Question

6.
10,
Does the permit documentation indicate the means used to
determine actual production?
Specify:
a. In permit application;
b. Other:_ •

Does the permit documentation indicate that the permit
writer conducted any follow-up activites to confirm
production estimates?

Have alternate permit limitations been included to address
different production levels?
Specify the number of tiers of limits:

Are all pollutant limitations in the applicable guidelines
included in the permit? List any that are not.

Was the adjustment formula for disposal to wells, POTW's, or
land application applicable (40 CFR 122.50)? (If "no", go to
C-4) Was it used?
17-12
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CHECKLIST C-4
Effluent Limitations: BEST PROFESSIONAL JUDGMENT
Introduction; This, checklist is intended to point review team
inquiry toward those questions which can help in determining
whether or not the BPJ analysis was "reasonable1*. Review team
should provide a qualitative explanation of the limitation
development process on the evaluation form. Complete one
checklist for each individual outfall selected by the review team
for review.

1. Is a BPJ analysis (for BPT, BAT, or BCT) missing where it
seems to be required? Identify the outfall, pollutant(s),
and type of limitation.

2. Indicate which of the following sources were used in
establishing any BPJ limitations:
a. Promulgated Guideline
b. Proposed Guideline
c. Development Document
d. Treatability Manual
e. Other (specify)

3. Identify any significant sources not used which should have
been.

4. Indicate what method was used to establish BPJ/BCT for
conventional pollutants.

5. - Have effluent guidelines been promulgated since the time cf
permit issuance? If "yes", indicate the relative stringency
of guideline limitations in permit:_
(Note if unable to determine this.)
17-13
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CHECKLIST C-5
Effluent Limitations: WATER QUALITY BASED LIMITATIONS

Introduction: This checklist is intended to point review team
inquiry toward those questions which can help in determining
whether or not the water quality analysis was "reasonable.1*
Review team should provide a qualitative explanation of the
limitation development process on the evaluation form. Complete
one checklist for each individual outfall selected by the review
team for review.

1. Is a water quality analysis missing where it seems to be
required? Identify outfalls(s) and pollutants.

2. Identify type of water quality limitation in permit (:free
from", numerical, or both).

3. Is basis of the water quality based limitation identified in
the permit file?
Specify:
a. State certification
b. Water quality modeling
c. Other:

4. Were water quality standards included in the permit in lieu
of effluent limitations?

5. Have all applicable water quality standards toward which
water quality-analysis is directed been clearly identified?

6. Are current water quality conditions clearly identified?
If possible, specify basis:
a. Actual water quality
b. Estimated water quality

7. Does the permit document that water quality-based
limitations are at least as stringent as BPT, BCT, or BAT
standard?

8. Were water quality modeling and a mixing zone used in
establishing the limitation?
(If "no", skip to #20)
b. Inputs to Quantitative Analysis:

9.
Has the outfall discharge rate used in analysis been clearly
identified? (See Form 2C, Item II)
a. Average discharge rate
b. Maximum discharge rate
c. Other: s __
17-14
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CHECKLIST C-5 (Continued)
Effluent Limitations: WATER QUALITY BASEO LIMITATIONS
10. Has the stream flow rate used in the analysis been clearly
identified? If possible, specify whether:
a. Low flow rate (years of record)
b. Average flow rate
c. Other:

11. Was the analysis directed toward water quality within a
nixing zone? (If "yes", skip to 113)

12. Was the analysis directed toward water quality beyond the
mixing zone (i.e., wasteload allocation modeling)
(If "yes", skip to |17)

c. Quantitative Analysist Mixing Zone

13. Are the size and configuration of the mixing zone clearly
identified?

14. Has the water quality model used been clearly identified?
Specify!

15. Were the impacts of other major dischargers taken into
account in the analysis?

16. Does the permit documentation demonstrate that, based on
modeling conclusions,- applicable water quality standards
were met in the mixing zone?
(If "yes", skip to 120)

d. Quantitative Analysis; Wasteload Allocation

17. Has the water quality model used been clearly identified?
Specify: ; :

18. Were the impacts of other major dischargers taken into
account in the analysis?

19. Does the permit documentation indicate the level of
discharges and limitations assumed for other major sources?

20. Does the permit documentation demonstrate that, based on
modeling conclusions, applicable water quality standards are
met? If not, does the permit documentation explain why the
limitation was used in spite of modeling results?
Specify: ___^__
17-15
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CHECKLIST D-l
Monitoring Requirements: DISCHARGE SAMPLING

Introduction; Complete one checklist for each individual outfall
selected by the review team for review.

Question
1.
2.
3,
Does the permit require monitoring for every pollutant for
which limitations are included in the permit? List any
inappropriate omissions.

Does the permit stipulate, either in the general conditions
or in the permit limitations, that monitoring for all
pollutants with limitations be conducted according to test
procedures approved under 40 CFR Part 136? Identify any
exceptions.

Does the permit require monitoring the volume of effluent
discharged from the outfall? If not, is an explanation
provided?

Are effluent sampling frequencies specified for every
pollutant for which monitoring is require? Specify for each
pollutant (e.g., daily, weekly, quarterly, etc.):
CHECKLIST D-2
Monitoring Requirements: DISCHARGE REPORTING
Question

1.
Are there any pollutants for which discharge monitoring
reports are not required at least once a year? List them.

Is reporting on discharge monitoring report (DMR) forms
required?

Specify discharge reporting frequency or frequencies
required in permit for the outfall under review (e.g.,
monthly, quarterly, etc.):
17-..o
-------
CHECKLIST E-l
compliance Schedules: INCLUSION IN PERMIT

Introduction; Complete one checklist for each individual outfall
selected by the review team for review.

1. Does the permit include a compliance schedule(s) for each
outfall which is not in compliance with the limitations
specified in the permit?

2. Does the permit documentation provide an explanation of why
compliance schedules were not included where necessary?
Identify if an explanation was not provided.
CHECKLIST E-2
Compliance Schedules: INTERIM AND FINAL REQUIREMENTS
Question

1,
Are distinct interim requirements -(milestones) with specific-
dates included in compliance schedule(s)?

Does the compliance schedule provide for compliance by
ceasing the regulated activity? If so, is a date certain
identified?

Does the compliance schedule include:
a. A date certain for the permittee to decide whether or
not to cease the regulated activity;
b. A compliance schedule in the event that the decision is
to continue the regulated activity, and
c. A schedule for cessation of the regulated activity in
the event that the decision is to cease the activity?

Is the time between each interim date in the compliance
schedule(s) less than one year? If not, does the permit
specify interim dates for submission of reports?

Does the compliance schedule provide for final compliance by
the appropriate time? (7-1-84 in most cases)

Has the source received a section 301(k) (innovative
technology) waiver to extend the compliance date up to
7-1-87?

Was an ECSL or Section 309(a)(5)(A) order with a compliance
schedule ever issued? If so:
a. Did the facility meet the criteria for issuance of the
ECSL/order?
b. Was the facility in compliance with the ECSL/order?
c. Was a subsequent enforcement action brought?
17-17
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TOOLS TO DETER VIOLATORS
Informal contacts
Notice of violation
Administrative orders
Civil suit
Criminal suit
Termination
CITIZENS AND ENFORCEMENT
* Section 505 allows citizen suits (civil action) after 60-day notice
to EPA/States and permittee
• Penalties to U.S. or State Treasury
• Citizens can recover court costs
• Supreme Court: Gwaltnev decision

NOTES:
17-18
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EPAfs PRINCIPLE ENFORCEMENT ACTIONS
(see §122.41(a))

Administrative Order

Schedule for compliance
Interim limits
APO Class I/H ($25,000/$125,000)

Brought in U. S. District Court
Injunction
Judicially enforceable schedule
Civil penalties (up to $25,00 per day per violation)

Criminal Action

Negligent violations* ($2,500 - $25,000 and 1 yr. imprisonment)
Knowing violations* ($5,000 - $50,000 and 3 yrs. imprisonment)
Imminent endangerment* ($250,000 and 15 yrs. imprisonment)

'Doubles for second or subsequent violations
NOTES:
17-19
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         United States
         Environmental Protection
         Agency
Office of Wastewater Enforcement and Compliance
Washington, DC 20460
August 1992
  &EPA  U.S. EPA NPDES
         BASIC PERMIT WRITERS'
         COURSE

         WORKBOOK
V
X
                          O Printed on recycled paper

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             COURSE ORGANIZATION


      The course is designed around the process  of issuing a

permit...from receipt of the application form, to the

development of effluent limitations, monitoring conditions

and special  conditions and, ultimately, issuance of the permit.
                HEADQUArTERS U
                £NV!S,":' i-^ifAl PF>
-------
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             TABLE OF CONTENTS
SECTION


    1

    2

    3

    4

    5

    6

    7

    8
   10

   11

   12

   13

   14

   15

   16

   17
                  TITLE


NPDES Program Overview/Background

The Application Process

Standard Permit Conditions

Effluent Limitations Guidelines-Based Limits

Overview of Variances to Effluent Guidelines

Best Professional Judgment-Based Limits

Water Quality Standards

Determining the Need for and Derivation of
Water Quality-Based Limits

Monitoring Conditions and Analytical
Methods

Municipal NPDES Permit Development

Municipal Sludge Permit Conditions

Storm Water Permitting

Combined Sewer Overflow (CSO) Permitting

Special Permit Conditions

Pollution Prevention

Permit Issuance Procedures

Compliance and Enforcement
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  PRIMARY COURSE REFERENCES
Text
Workbook
Code of Federal Regulations (CFR)

EPA Quality Criteria for Water 1986 (Gold Book)

EPA Technical Support Document  (TSD) for
Water Quality-Based Toxics Control

EPA Permit Writer's Guide to Water Quality-Based
Permitting for Toxic Pollutants

EPA Abstracts of Industrial NPDES Permits

EPA Treatability  Manual

EPA NPDES Best Management Practices
Guidance Document

EPA Case-by-Case Permitting of Municipal
Sewage Sludge
Additional Miscellaneous Guidance
Practical Exercises
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NPDES PROGRAM OVERVIEW/
      BACKGROUND
-------
-------
         LEARNING OBJECTIVES

NPDES Program Overview

Statutory Evolution

NPDES Program Implementation
    NPDES STATUTORY FRAMEWORK

All "point sources"

"Discharging pollutants"

Into "waters of the States" must obtain an NPDES
permit from EPA or an approved State



  OVERVIEW OF THE NPDES PROGRAM

What is a permit?

Universe of permittees

Contents of a permit

Methods for developing permit limits

Universe of regulated pollutants

Overview of the issuance process
                      1-1
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                      WHAT IS A PERMIT?

          It is a license ...

          Issued by the government to persons conducting business in the
          United States

          Granting permission to do something which would be
          illegal in the absence of the permit

          There is no right to a permit and it is revocable for
          cause (noncompliance)

          For our purposes, NPDES permit is license to discharge
          CLASSIFICATION OF NPDES FACILITIES

          Municipals (POTWs)

              Majors (> 1 MGD design flow)
              Minors

          Non-Municipal

              Majors (> 80 points)
              Minors
NOTES:
-------
         CLASSIFICATION OF MAJOR AND MINOR
                   INDUSTRIAL PERMITS

         Toxic pollutant potential

         Flow/stream flow volume

         Conventional pollutants

         Public health impact

         Water quality factors

         Proximity to near coastal waters
             DISTRIBUTION OF DISCHARGERS
               TOTAL DISCHARGERS: 64,229

         Municipals (15,605)

              Majors: 3,857
              Minors: 11,748

         N?on-Municipal (48,624)

              Majors: 3,275
              Minors: 45,349

         Percentage of permittees

              Industrials : 76%
              Municipals: 24%
NOTES:
                                1-3
-------
        CONTENTS OF THE PERMIT

Cover sheet

Effluent limitations

     Effluent  Adelines (Non-municipal)
     Best Professional Judgment (Non-municipal)
     Secondary treatment (Municipal)
     Water Quality (Municipal and non-municipal)

Monitoring requirements

Standard conditions

Special conditions

     Best Management Practices (Generic)
     Best Management Practices (Storm water-specific)

Other conditions (Municipal)

     Pretreatment program
     Combined Sewer Overflows
     Municipal sludge
   METHODS TO DEVELOP EFFLUENT
        LIMITATIONS IN PERMITS

Effluent limitations guidelines

Water quality standards

Best professional judgment
                      1-4
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               CWA CLASSES OF POLLUTANTS

          Conventional pollutants

               BOD
               TSS
               Oil and Grease
               Fecal coliforms
               pH

          Toxic pollutants
               Heavy metals
                    Copper
                    Lead
                    Zinc
                    Nickel
                    Chromium
                    Etc.

               Organic chemicals
                    Benzene
                    1,2 - Dichlorobenzene
                    Carbon tetrachloride
                    Etc.

          Nonconventional pollutants

               Ammonia
               Chlorine
               Toxicitv
NOTES:
                                   1-5
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PERMIT ISSUANCE PROCESS
         Permit Application
       Permit and fact sheet
          development

       Effluent limits
       Monitoring conditions
       Standard conditions
       Special conditions
           Public notice
        and public comments
        Administrative record
            Final permit
            Compliance
-------
                  FWPCA -1972 AMENDMENTS

          Established NTDES and pretreatment programs

          Incorporated permits from 1899 Act and standards
          from 1965 Water Quality Act

          Dischargers must identify themselves

          Permits are privilege • not a right

          Effluent limits must be both technology based and water
          quality based

          Compliance deadlines are specified

               7/1/77 for BPT and water quality standards,
               7/1/83 for BAT

          Maximum duration is 5 years

          States and public must be involved in issuance process

          Established significant penalties for permit violations

          Indicated that permit compliance is a shield

          Provided for State programs

          Established Construction Grants Program for POTWs
NOTES:
                                      1-7
-------
                NRDC CONSENT DECREE -1976

          EPA sued by the NRDC, and other environmental
          and industrial groups

          Established the list of 129 (now 126) priority pollutants

          Established 34 industrial categories to be regulated
          by NPDES and pretreatment

          Required development of BAT effluent guidelines and
          categorical pretreatment standards by 1983
          CLEAN WATER ACT AMENDMENTS -1977

     •     Adopted the provisions of the NRDC consent decree,
          including "toxic" pollutants

     •     Established BCT for conventional pollutants

          Extended BAT/BCT compliance deadlines (7/1/84)

     •     Clarified that Federal facilities are subject to State
          programs

          Authorized EPA to approve local pretreatment programs

     •     Required NPDES States to modify their programs to
          include pretreatment oversight

NOTES:
                                    1-3
-------
             WATER QUALITY ACT -1987

     Extends compliance deadline again (3/31/89)

     Specifies storm water permitting requirements

     Increases civil and criminal penalties and makes
     administrative fines available to EPA

     Designates that Indian tribes be considered "States"

     Creates the Federal sludge management program

     Phases out construction grants program

     Creates new programs for nonpoint sources (runoff)
              NPDES IMPLEMENTATION
Before approval:
          EPA issues permits

          EPA conducts compliance and monitoring activities
          EPA enforcement
After approval:
          States implement as above

          EPA role = oversight

               Grants
               Administrative, technical and legal support
               training
               Enforcement as necessarv
                                1-9
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       SNAPSHOT:  NPDES PROGRAM APPROVALS
         Eligible jurisdiction*

         NPDES approved

         Pretreatment approved

         Federal facility approved

         General Permits approved
    *Not including Indian tribes
57

39

27

34

28
           NPDES ACCOMPLISHMENTS TO DATE

         $70 Billion • POTWs (1972)

         75% construction completed
         65,000 permits issued

         75% water - fish/swimmable

         361,000 + miles of streams and 12 million lake acres fully support
         their designated uses

         Stil! experiencing 350 fish kills per year; fishing bans due
         to pollution in 21 States
NOTES:
                             1-10
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                       EPA ORGANIZATION: HEADQUARTERS
                                      Administrator
                                      Office of Water
Water Science and
  Technology
  Wastewater
Enforcement and
  Compliance
Wetlands, Oceans
 and Watersheds
                                                               I
Ground Water and
 Drinking Water
 Policy and
 Resources
Management
   Permits Division
                 Enforcement
                  Division
                                 Mundpal
                              Support Division
 • NPDES Permits Policy
 * State Programs Approval
 * Pretreatment Implementation
 • Sludge Permits Policy
            Compliance and Enforcement Policy
            Inspections and Sampling
            Administrative/Judicial Case Review
            Data Mangement
                          • Municipal Assistance
                          • Construction Grants/
                            State Revolving Funds
                                         1-11
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                EPA ORGANIZATION:   REGIONS
      Lawyers
Drinking
 Water
                                   Regional
                                 Administrator
                Water
             Management
               Division
Groundwater
                       Air
                             Waste
Dredge and
Fill/Ocean
 Dumping
 Water
 Quality
Standards
Permits
Enforcement
                                    1-12
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                        BPDBS TERMINOLOGY
APPLICATION FORM - Any of the federal forms  (or State forms)
                   required to be filled out by a discharger
                   prior to issuance of a permit.

BAT -     Best Available Technology Economically Achievable
          (applies to non-conventional and toxic pollutants)

BCT -     Best Conventional Pollutant Control Technology (applies
          to conventional pollutants)

BPT -     Best Practicable Control Technology Currently Available
          (generally applies to conventional pollutants and some
          metals)

BMP -     Best Management Practices; measures supplemental to
          numerical effluent limitations to control discharges
          from storage piles/ spills, leaks, etc. Frequently,
          BMPs are procedural or qualitative rather than
          quantitative.

BOD -     Biochemical Oxygen Demand; a pollutant commonly limited
          in NPDES permits.

BPJ -     Best Professional Judgement; the broad authority of the
          Act authorizing the development of permits conditions
          on a case-by-case basis in the absence of national
          standards.

CFR -     Code of Federal Regulations where effluent limitations
          guidelines, the NPDES regulations etc. are found.

CONVENTIONAL POLLUTANT(s) - BOD, TSS, fecal coliform, oil and
                            grease, and pB.
EFFLUENT LIMITATIONS -
                       The limit (usually daily maximum and
                       monthly average)  on a pollutant required
                       to be met by the permit expressed as mass
                       (Ibs/day) or concentration (mg/1).
EFFLUENT LIMITATION GUIDELINE -
                                A national standard prescribing a
                                limit on specific pollutant (in
                                Ibs/day or mg/1) from point
                                sources in a particular
                                industrial category (e.g. textile
                                mills).

INDIRECT DISCHARGERS - those facilities which discharge waste
                       water to receiving waters indirectly
                       i.e. through a POTW  (also termed 'IUs';
                               1-13
-------
MAJOR PERMIT - any permit(ee) with a design flow of 1HGD or
               greater  (municipal)
               any permit(ee) which scores 80 or greater on the
               major/minor permit classification scale
               (industrial)

MINOR PERMIT - any permit which is not a major permit.

MIXING ZONE -  an allocated impact area in a water body where
               numeric water quality criteria can be exceeded as
               long as acutely toxic conditions are prevented.

NONCONVENTIONAL POLLUTANT - any pollutant which is neither a
                            conventional nor a toxic pollutant
                            (ex. manganese, ammonia, etc.)

NPDES - The National Pollutant Discharge Elimination System
        prescribed by Section 402 of the Clean Hater Act.

NRDC CONSENT AGREEMENT - 1976 Settlement agreement between EPA
                         and the National Resources Defense
                         Council concerning the control of toxic
                         pollutants through BAT effluent
                         guideline and categorical pretreatment
                         standards.

NSPS - New Source Performance Standard

pH - a measure of acidity or alkalinity (pH 7 is neutral) of a
     waste water; a common pollutant limited in NPDES permits.

POINT SOURCE - a discrete conveyance such as a pipe, ditch, etc.
               contributing pollutants to the environment.

POLLUTANT - a contaminant introduced into a receiving water which
            is subject to technology-based or water quality-based
            effluent limitations in the permit.

POTW - Publicly Owned Treatment Works, usually consisting of
       primary and secondary (biological) treatment.

PRIMARY INDUSTRY - an industry listed in the NRDC consent
                   agreement (also in Appendix A of 40CFR
                   Part 122)

PRETREATMENT - the treatment of Wastewater by contributors to a
               POTW before the wastewater reaches the POTW.
                                1-14
-------
PSES - Pretreatment Standards for Existing Sources

PSNS - Pretreatment Standards for New Sources

TOXIC POLLUTANT - Any of the 129 priority pollutants (organic
                  chemicals, metals, etc.) which are neither
                  conventional nor non-conventional.

TOXICITY TEST - A measure of the toxicity of a chemical or an
                effluent using living organisms by determining
                the response (survival, reproduction, growth,
                etc.) of an exposed organism to the chemical or
                effluent.

TSS - Total suspended solids; a pollutant commonly limited in
      NPDES permits.

VARIANCE - A waiver establishing alternative limitations or time
           extensions for a specific facility. Several different
           variances and time extensions are available under the
           CWA upon satisfaction of very specific criteria.
WATER QUALITY CRITERION -
                          Elements of state water quality
                          standards, expressed as concentrations,
                          levels, or narrative statements
                          representing a quality of water that
                          supports a particular use (drinking,
                          contact recreation, cold water fishery,
                          etc.)

                          Provisions of State or Federal law
                          which consist of a designated use or
                          uses for the water of the United State
                          and water quality criteria for such
                          waters based upon such uses.

WATER OF THE U.S. - All waters which are used, were used, or may
                    be used in interstate or foreign commerce,
                    including all water subject to the ebb and
                    flow of the tide and wetlands.
WATER QUALITY STANDARD -
                               1-15
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THE APPLICATION PROCESS
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                   LEARNING OBJECTIVES




         Types of NPDES Application Forms



         EPA Application Form 2C




         Accuracy and Completeness
              The NPDES process is initiated when a point source files




         application forms requesting a permit.








NOTES:
-------
       EPA APPLICATION FORMS FOR NPDES PERMITS
     FORM
     TITLE/APPLICABILITY
  LAST
REVISED
REGULATION
    CITE
       A
     SHORT

       2B
       2C
       2D
       2E
       2F
     NONE
                 General information
                 New and existing major POTWs
New and existing minor POTWs
New and existing animal feeding
operations and aquatic animal
production facilities

Existing manufacturing, commercial,
mining, and silviculture! discharges

New manufacturing, commercial,
mining, and silvicultural discharges

Manufacturing, commercial, mining,
and silvicultural facilities that
discharge only non-process wastewater

Stormwater discharges associated with
industrial activities

Stormwater discharges from
municipal separate storm sewers
serving a population of greater than
100,000
                                     1980
                                    1973'
  1973
  1980
  1984
  1984
  1986
  1990
                122.21(0
   reserved

   122.21(1)
   reserved

   122.21(1)
   122.21(g)


   122.21(k)


   122.21(h)



   122.26(c)


   122.26(d)
 *Currently being revised
NOTES:
                                            2-2
-------
                         KEY DEFINITIONS

          New Discharger - Any building, structure, facility, or installation:

                From which there is or may be a discharge of pollutants
                That did not commence discharge at the site prior to
                August 13.1979
                Which is not a "new source"
                Which has never received a finally-effective NPDES permit

          New Source - Any building, structure, facility, or installation from
          which there is or may be a discharge of pollutants, the construction
          of which commenced:

                After promulgation of effluent limitations guidelines and
                standards applicable to such source, or
                After proposal of effluent limitations guidelines and
                standards,  but only if the standards are promulgated within
                120 days of proposal

          Existing Source * Any building, structure, facility, or installation
          from which there is a discharge of pollutants which is not a new
          discharger or new source.
NOTES:
-------
        MAJOR COMPONENTS OF FORM 2C
I.    Outfall location
II.   Flow, sources of pollution, treatment technologies




III.  Production information (if applicable)




IV.   Improvements (if applicable)
V.   Intake and effluent characteristics
VI.  Potential discharges not covered by analysis




VII.  Biological testing data
VIII. Contract analysis information
IX.    Certification/signature
 APPLICATION FORM: REVIEW FOR ACCURACY
Most common mistakes:
     Guideline production and flow rates




     Long term average, daily average, and daily maximum values




     Decimal point errors




     Wrong concentration units




     Reported values are below known detection limits
                                 2-4
-------
  APPLICATION FORM:  REVIEW FOR COMPLETENESS

     •    Common omissions

             Map required in Form 1
             Flow diagram required in Form 2C

     •    Other omissions

             Required metals
             Required GC/MS fractions
             Expected toxics
             Production rates

NOTES:
                                  2-D
-------
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GIVE
REQUIREMENT:
QUESTIONS:
                              PRACTICAL EXERCISE

                     Review of NPDES Permit Applications

            NPDES  Application  Forms 1 and 2C from Luster Glass  Inc.

                  Review the  permit  applications from  Luster  Glass Inc.  and
                  answer the questions  below.
(1)


(2)

(3)

(4)
(8)
      Is this  facility  a POTW or  does  it have a concentrated  animal  feeding
      operation? 	
      Who is Mr. Ceccarelli?
      What does Luster Glass Inc. make?
      Did the proper official sign the application form?
      How do you know? ^^^_^^^^^^^^^^^_^^^^^^_^^___^_^_
(5)   To what body of water  does  Luster Glass Inc. discharge its process water?


(6)   How many outfalls are there at Luster Glass? 	

(7)   Has the company collected any data on the toxicity of its wastewater?
      Does Luster Glass Inc. have its own analytical laboratory for the analysis
      of  priority  pollutants?  	

      Based  on your cursory review of the application, which  pollutants  would
      you limit  in  a permit for Luster Glass  Inc.?
 1C)   Based en the water flow schematic included in the permit application, what
      wastewaters are treated at Luster Glass Inc.?  What is the total treated
      wastewater flow?  	        	    	
(11)  What  is  the wastewater  flow after  treatment shown  on the  water  flow
      schematic?


(12)  Does wastewater flow into treatment equal wastewater flow out of treatment
      on the water flow schematic?
                                     2-11
-------
2-12
-------
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  M. POLLUTANT CHAMACTEftlSTICS
   INSTRUCTIONS: Complcn A throujh J to dflttmtim whtthw you mti to ubmit §ny ptnnit •pplieatiofl form to tta EPA. If you imwtr '>•" to any
   quotient, you muB Bjbmrt thit form and tht lupplnnintit form lifttd in tiM ptnmtma following tht qutRion. Mart "X" in KM box in tht third column
   if ttii wpplimtntal form a irachtd. If you tnwwr "no" to nch quoRion. you nwd not xbrnrt my of then formt. You mty mami "no* if your activity
   it cxdudid from pormit raquircmtnti; «M Saetion C of tfw ioftrurtont Sat olio. Saeton 0 of tht imnictiom for btfmrtion* of taM-toad t»riK
                         QUHTIOM*
  A. If thit facility a  PubfKiy
     wnicn rwuitt m • diechenje to mat en of tfw
     (FORM 2AI
                                                                                         *f «• UX? (FOflM 28)
  C. It ih<« i fKiiiTv wriich currently rnulti in
     to wvun of VM U.S. other thin thott dt«crib«J in
     A or BIPOX? (PORM2C)	^_^
                                                                   D. li th« « propo»>d txalffy
                                                                      in A or t a6ai»j othlefl niH rwuft m •
                                                                                             JQ1
  E. Oo» or will thn fMilitv f«T. nor». or dnpOM of
                 ra? (FO«M 3)
                                                                      F. Do you or will you inject at tfttt facility indunriai or
                                                                         taming.
                                                                         undergn
                                                                                    one  quarter mile of the well bore.
                                                                                1 lowrca* of drinking water? (FORM 41
G  Do you or will you in^ecr ft fnit facility any produced
   wfttr or other fluidi whicn ar* brought to the ttjrfece
   in connection with conventional oil or natural on pro-
   duction, miect fluidi mad fey enhanced recovery of
   oil or neturel get, or miect fluid* for itorag* of liquid
   hydreqroom? IFORM 41
   li thu facility •  proooted muu«aiy
  I.  li  tnn Tecility a proooted muut»»y ewnae which n
     on* o< tne 28 induttriei eategoriei lined in ttt* in-
     nrvctiont  end wfiich will potentially emit 100 tom
     oer year  o< any nr pollutant  regulated under the
     Clean Air  Act and may  affect  or be located in an
     attainment ere*' (FORM &
                                                                      H. Oo you or «v«l you mjact at A* facHtty ftuidf for «e-
                                                                         oW  prooavai well at mMng of wlfur by the Fraaeti
                                                                         tirnran. aokjtton mining of nrinanti. in rini eombu*-
                                                                         lion of foaail fuel, or iauu»ari of aaoHiamai energy?
                                                                         (FORM 41
                                                                    J.  li tfiit facility a
                                                                       NOT on* of the 2* Ki
                                                                       inMrucoom and which wW potantMly amir 200 font
                                                                       par year of any air pollutant lagtMtad under the Clean
                                                                       Air Act and may affaui or be located in an atlahaiiani
                                                                         a? (FORM B!
 »L MAME OF FACILITY
             LUSTER  GLASS  INC.
            CECCAREUI IVO ENV.  COORD.
 V. FACILITY MAILING AOOHEM
                  *. arnccT. KOUTC NO. on OTMCK srtCIFIC
                           e. COUMTV KAM
                             C. CITY OK TOWN
f»A Form 3610-1 (Rev. 1O-K)
                                                                                                                 CONTINUE OS
                                                       2-13
-------
                 THE f BQNT
 VIL SK C00CS **«•»«. *i
                     GLASS MANUFACTURING
 VIII. OPERATOR INFORMATION
           i—i—r~!—i—i—i—:—i—i
                     LUSTER GLASS INC
                                                                                                            X3 YES _J N
                                                                                                             4<
       c. STATUS or OPCHATOH tEiutr rt» ftprotrun ttmr oifo riw vwntfr MX; V O»«r .
                        • PUBLIC fort*r rtwfl ftdtml ormitl
                      O • OTHER r>P«lr»
S-STATE
   PRlVATf
                                                       i—i—i—n—n—n
                   i—i—rn—i
                     PO BOX 319
                           F. CITY OH TOWN
                                                                                          If 0M facility looncd on ina«n linos?
                                                                                             O YES     QD NO
 X. EXISTING ENVIRONMENTAL KHMI
      A. NPOIS iDiteHirra m Surfme*
      m. uie tVmU>i>vund Inaction vf FJuiOti
          e. Hen A iHatniout »«nrij

  Attach to thfe application a topographic map of the area extending to at leatt one mile beyond property boundaries. The map mutt thow
  the outline of the facility, the location of aach of to existing and prppoaad intake and diecharge structural, each of rb hazardout;
  treatment, storage, or disposal facilities, and aach wail where it injetjtt fluidi underground. Include all apringt. nVan and other
  water bodies in the map area. See instructions for precise requri
 x'l. NATURE Of BUSINESS fpww* »ftri*
            AUTO  TEMPERED AND AUTO  LAMINATED GLASS MANUFACTURED
 XIII. CERTIFICATION toe MNtruciteneJ
  I artHy undtr panatty of law that I fuv9 ptnontlly t*minmt»ndmn rarmMar with ffte infomrion mtbmrmd in tfiit tppiwor ,
  atttcfinwitt md thit, oaaatf on my inquiry of thorn ptnont imrr+dmty nagona/afc for obuinirti tr» informttion contt#ve ttut th* informttion it trut. tceuntt md comptfo. I am amaw tftet ttarv are vgnffictm pena/ties tor a-^-i/rr/m
  ftlm information, including th» pottt'oility of tint and impritonmmnt,                                                            ,
                                                                                                       |C. OAT» V -iTT	
 A. «AMI • OFFICIAL. TIT1.I

          JOHN BAKER
          VICE PRESIDENT
 COMMENTS FOR OFFICIAL USE ONLY
EPA Form 3510-1 IRr.. )Q-K\ Re
-------
I
              2-15
-------
fit

a
—<
o
UJ
                             \
           2-16
                                          _j
-------
  For «Mti our««ii, i'«t ir»e tmtuO* »nd ioo»tua» of m locnion to ih« n«»rtn
                                                                 ano tfie rujm«. of m* ntctivinf i»«iar.
4 J5UTr_ALL"', 	 . LATITUOI
I •.-
C. L.
3NOITUOC
O
• KCCIV
HO ««T««
,~~,
    001
42
                   36
98
                                                          30
1LLIHOIS RIVER
 II  FLOWS. SOURCES Of POLLUTION, AHO TREATMENT TECHNOLOGIES^
 A  Arjc^  * line drawing mowing int wittr flow tnrougn ih« tcciiiTV >naic«Tt wuroit of mtiKe witcr. optrmoni contributing wiitewiter to tn« «<'IUCM.
    ana ireatmant unitj iitxiet) to eorrnpond to tti» mort (MuiltO ducnotioni in Ittm  8. Construct * wittr b«inci on ttw 1in« driwin; bv »nown^ jv~jg»
    dowi bctvvMn mUKn. ootrstiont, trMtmcnt units, ano outt«lli. If t wttar txianct annot b» drtirmmcd It.g.. for ctrwin mining tcentirti o'OvrQi >
    Oicton*! dctcriotion of tti» n«turt »ncj amount of my aouron ol wntf ano tny collection or tr«Btm*nt i
 B. For MCA ourtall. providt a ancription of: (1) AH oofntioni coninbutinq wmewater to tt>a «rflu«ni. including proem w«t*wmr. unitary
    cooling water, tnd  norm w*t*r runoff: 12) Th« tvvrag* flow contribute bv «acf< operation; *no (3) The tr««tm*nt rvearavd by tha wntrm*i*r. Continue
    on addition*! lhacti if ne
 i. out-
 'ALl-NC
  litltl
                       1  O»EttAT1ONItl CONTHIBUTINQ FLOW
                                                                                                   J. TKCATMCMT
                     • OPEMATIOM ''ItI
                                           O. AVCHACK FL.OW
                                              'mribtfr unit*/
                                                                                                    I.IST COOES mo*
                                                                                                       TAIir 2C 1
   001
PROCESS FLQbIS
                                                                              011/Wattr Separator
                                                                              Settling  Basins
           Cooling  Tower  Slowdown
                                        i   0.45 MGD
                                                                              MIXIHG WITH OTHER STREAMS
                                                                                                                        1.0
EPA Form 3510-2C iR«v  285,
                                                                       or i
                                                         2-17
-------
*-.«7.- - ^- J ---- U -. --  - ^m. ---- tw.
                                                                        HA - - --     ..— .. ^ |

                                                                                ~ we ffp 10 Strife* ////
                                                           i  FREQUENCY
                                                                                                      « FLOW
 i  OUTFALL]
  NUMBER   ;
                     2 OfCRATION'J
                  CONTRIBUTING FUOW
                           • ial •
                                                         »C » WI t M
                D MOMTMftf
                »«H VIA* t-
                                                                                           MATS       a TOTJt^
                                                           •jjprn'v   •.   i«p*ri/v   '  '•*•

    N/A
                        It/A
        N/A        N/A       N/A     .   N/A        N/A        N/A
                                                                                                                              S/A
III PRODUCTION
 -  Doei if '•' „?••: jv-o* ••"€ .w.jjt.on Dfomu'9»«e o> EPft jno*' Section 304 0' tut 4i«*n W»i«f Act iOOiy to your l«cn.tv>
  6  Arc tne iimitationi m tnt IPO"CM»I
          ~ TC* .fO-ne.Tit /tr-, /// C
                                iueni gu««'rne *>Dr«uo " t»rm> o' prooucrion tor Qtfitr TtttfUf of aetftnoni ?
t* »oi. »"s*ena  vcs TO nem HI-6 »st :nequ«niit> wruen rep'i*»nti »r aciual m««su'«m«nto4your I
us«3 in :ri< »ponc»o>« e"'u*"i guioenn* and motcne in* »t*wnw3 euTtmi
                                                                                                          expresseo t
                                          1 AVEflAGE DAILY PaCDuCTlQN

                                                              c ^»«MATIO«
                                        I"
                                                                                                                 2  i'flCTlD
                                            |
                                                                           ttpectfyt
     40,000
   275,000
                       Ft '/DAY
                       FtVOAY
AUTO  TEMPERED SUSS
AUTO  LAMINATED SUSS
                                                                                                                    001
     jre- •••3-— f- (s, c— »-• p-
     -'  s *^-   — rec ::  :>e"" : l
                                      or »ny cm*- »-»
                                                                                   iic lo' int eo'-«--jetioi. JDO-J: •; -• -;T-S- C" :• A*SI*
                                                                         iav (fltci tne Qitcnarges aeic'-wc  • •" ; sir :*• ;^7 '* s *: jGf5

                                                                             "^NO iffo  to tttm /V' £,
  ,OfNT,r, CATION o» eo^o.no
                           .no-.l   » AFF.CT
   ~~~ DS-.  • ru ~«, a"ic- sac • :'a !"••!! 3f<;  c

   c a*^*c 5C^PC-'*i *0' cc"j"«iC' o*
                                      MAIIK  X  1 r 0 1 SC • ' •- 1 0 N
                                                                      • o'' :ont'C O'OOf*^! -O' QTfif r**ifQnr~*f-3 ,'C


                                                                      ONAl. COHTWOl. KtOC«Al«m If ATTAC»CC
    Form 3510 2C :«»v 2 85'
                                                                 2-18
-------
CONTINUED EHQM »AGE
 V. INTAKE AND EFFLUENT CHARACTERISTICS
  A. S. & C   $*• mftrurtioni o*for* proeMding — ComOMt* on* wt of I»OIM for »»cn ourt*ll — Annouti tm outlill numo*r m in*
             MOTE.  TaD'M V-A. V-B. *"d V-C*n> inciu«:• O«iow 10 eo or * component of a suosunce wnicn you Currently us* or manufacturt »»in int*rm*oi*l* or finai ptMuc: or
  tryproouct?
          ZINC
EPA Form 3S10-2C .H*y 2-85r
                                                           2-19
-------
 CONTINUED FROM THt PRONT
      BIOLOGICAL TOilCfTY TWINO OAT
                                 to MM* trm my OKMopcM MI for •CUB or ctramc toxtcny
In i mil MI to ywir dlMOint wrtfwo tfw I«K 3 v«*ra?
                                                                                             on WJY o* your ancfi«rg« a' on j


                                                                                         10 Ho to Sfcrlon '.'Ills
            Whole Effluent Toxiclty  -

            Acute and  chronic Whole  Effluent ToxfcKy  tests were conducted to
            satisfy  an NPDES permit  requirement for biomonitoring.  Initially,
            in February 1986, a sample  was analyzed for  acute and chronic
            toxicity using both Cerlodaphnia dubla and Plnephales pronelas
            (Fathead minnows).  The  results indicated  that  Fathead minnows were
            the more sensitive of the two species and  were  used in subsequent
            tests.   Chronic toxidty to Fathead minnows  varied from 1.31 to
            3.51  Acute toxicity varies from 6.1 to 24.81.   A total of 12
            monthly  samples were analyzed for acute and  chronic toxictty over
            the course  of one year.  Results are presented  in Table 3.
VU1CONTRACT ANALYSIS INFORMATION
  W«r* tny of . rdf ft tut* iaocrvfor? or ^rm frtfjowj
                                                                                      	"O (to 10 S«c(ion IXi
                                                       t AOOHCI*
                                                                     e. TrLiPueNc	T""
                                                                     rartB coat « no /
       MEASUREMENT U8S
                            113  RIVER PARKWAY
                            CHICAGO. IL
                            60020
                                                                                   312-684-2121
•  129 PRIORITY POLLUT!
\  BOO, TOC, COO.  TSS.
'  CO, PHOSPHORUS,
  CADMIUM, LEAD
 / certify undtr ptmOy ofliwthtt Utit 4ocum»fH »na til »n tenants weft preptrfa untifr my direction Of Supfrrttion in tccorOtnce with t j *ste>- :f s -;-te '.a
    r* tfttl au*irfi»dpfftOfin»/pfeo»ftYg»lfy»> •na»*»lu»tc 'he information su6mm*l. Bftfdonmy inquiry of th9O*r*on or persons omo mar-aye ."•• <. ,nfr, or
                                                                                                                        ,.
 / im «w«/-« tfiu tt*r» »r» tignitietat ptnttlits for sut>m,nmg 'use information, including tftt poiutM/ity of lint and imprtionmtm tor tno~"-z . o-a- :-s
    JOHN  BAKES. VICE  PRESIDENT
                                                                                         B PHONC NO
                                                                                           312-834-4536
                                                                                        I O  O»T£ SIGNED
EPA Form 3510 fC lB»v 2-85}
                                                          PftCE 4 OF
                                                             2-20
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                                      2-29
-------
-------
STANDARD PERMIT CONDITIONS
-------
-------
                   LEARNING OBJECTIVES

         Role of "boilerplate"

         Methods for placing conditions in permits

         Type of conditions
         STANDARD CONDITIONS IN THE PERMIT

         Standard conditions must appear in every NPDES permit.

         Standard conditions may be placed in permits verbatim or by
         incorporating them by reference.(§ 122.41)
             TYPES OF STANDARD CONDITIONS
         Responsibilities of permittee

         Testing procedures
         Records retention
         Reporting requirements
         Penalties for noncompliance
NOTES:
                                   3-1
-------
    RESPONSIBILITIES OF PERMITTEE

Duty to comply

Proper O & M

Duty to mitigate

Need to halt or reduce activity not a defense

Duty to allow inspections/entry

Duty to reapply

Duty to provide information


       REPORTING REQUIREMENTS

More frequent monitoring

24 hour report of endangerment

Changed circumstances

     Plant alteration/addition
     Changed pollutants/flow/production
     Sludge use/disposal method

Anticipated noncompliance

Signatory/certification

Upset/bypass reports

Provide information as needed
                          3-;
-------
NOTES:
              OTHER STANDARD CONDITIONS




         Nontransferability




         Enforcement penalties




         Monitoring and records




         Bypass




         Upset




         Permit actions




         Property rights
                               3-3
-------
3-4
-------
                              PRACTICAL EXERCISE

                        Identifying Standard Conditions
                        Applicable to All  NPDES Permits
DIRECTIONS;
Listed below are examples of standard conditions that apply to all NPDES permits.
Using  the  Code of  Federal  Regulations, look up each standard  condition and
provide the proper regulatory citation and a brief description of the permittee's
obligation.   {Hint:  All standard conditions may be found in 40 CFR §122.41.)
Group A

(1)   Duty to Reapply [ S
(2)   Bypass
(3)   Permit Transfers ( 5
(4)   Twenty-four Hour Reporting [ S
(5)   Duty to Mitigate { S
Group B

(1)   Inspection and Entry [  S
                                   3-5
-------
 (2)   Upset  [
 (3)   Planned Changes ( S
(4)   Permit Actions [ S           ]
(5)   Need to Halt or Reduce Activity not a Defense [  S
Group C
(1)   Duty to Comply [ S
(2)   Proper Operation and Maintenance (  S           3
(3)   Monitoring Reports
(4)   Signatory Requirements ( S
(5)   Monitoring and Records [  S
                                       3-6
-------
 EFFLUENT LIMITATIONS
GUIDELINES-BASED LIMITS
-------
-------
             LEARNING OBJECTIVES

   What an effluent guideline is

   How effluent guidelines are developed

   What the relationship is between:

        Effluent guidelines, SIC codes, industrial categories,
        industrial subcategories, and CFR subparts

   How to calculate permit limits using an effluent guideline
 DEVELOPMENT OF EFFLUENT LIMITATIONS
              FOR NPDES PERMITS
Develop Water Quality-Based
       Limitations
 Develop Technology-Based
       Limitations
Effluent Guidelines
Best Professional Judgment
                   Compare Limitations
                          I
                  Apply the Most Stringent
                           4-1
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            EFFLUENT LIMITATIONS GUIDELINES
          Definition
                Effluent limitations guidelines are National standards
                prescribing allowable discharges of pollutants from
                industrial point source categories corresponding to
                various levels of treatment or control technologies
                (BPT, BCT, BAT, PSES, PSNS and NSPS).

          Scope

                Guidelines are established for most primary and some
                secondary industries.

          CWA Section 304(m)

                Guidelines may be developed for new or additional
                industries, such as:

                     Solvent recyclers
                     Barrel  reclaimers
                     Tank car/truck cleaners
                     Industrial laundries
NOTES:
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    EFFLUENT GUIDELINES DEVELOPMENT PROCESS

     •     Define industry

     •     Collect data

               308 questionnaire
               Sampling and analysis program

          Major regulatory tasks

               Subcategorization
               Select pollutant parameters
               Assess representative treatment technologies
               Compute effluent limits
               Estimate compliance costs
               Select option for guidelines
               Produce development documents
               Perform economic and environmental impact analysis
               Assemble record
               Promulgate effluent guidelines
NOTES:
                                4-3
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           Fedtral  Reyater  /  Vol. 52.  N'o. 214  /  Thursday.  November 5.  1987 / Rules  and
                                                       Regulations    425*3
  induding tht 45 "priority" toxic
  pollutant* and daaat* of pollutant*.
    Under tht Act tht EPA it required to
  establish stvtnl difftmt kind* of
  effluent Unutttiont guideline* and
  standards. They u* suounanztd bhtfly
  below:
  J. Best Practicable Control Technology
  Currently AvailabrelBPTj
    BPT effluent limitations guidelines art
  generally based on the average of the
  best existing performance by plant* of
  vinous sizes, age*, and unit processes
  within the category or subcategory for
  control of familiar (i.e.. conventional)
  pollutants.
   In establishing BPT effluent
 limitations guidelines. EPA consider*
 the total cost in relation to the effluent
 reduction benefit*, the age of equipment
 and facilities involved, the processes
 employed process changes required,
 engineering aspect* of the control
 technologies, and non-water quality
 environmental impacts (including energy
 requirements). The Agency considers
 the category-wide or subcategory-wide
 cost of applying the technology in
 relation to tht effluent reduction
 benefits.

 2. Best Available Technology
 Economically Achievable (JBATl
   BAT effluent limitations guidelines, in
 general represent the best existing
 performance in the category or
 subcategory. The Act establishes BAT
 as the principal national means of
 controlling the direct discharge of toxic
 and nonconventional pollutants to
 navigable waters.
   In establishing BAT. the Agency
 considers  the age of equipment and
 facilities involved, the processes
employed, the engineering aspects of tht
control technologies, process change*.
 the cost of achieving such effluent
reduction, and non-water quality
environmental impacts.
3. Best Conventional Potlutant Control
Technology (BCD
  The 1977 Amendment* to tht Clean
Water Act added section 301(bK2)tE).
establishing "best conventional
pollutant control technology" (BCT) for
the discharge of conventional pollutant*
from existing industrial point sources.
Section 304(a)(4| designated the
following as conventional pollutants:
BOD. TSS, fecal coliform. pH. and any
additional pollutant* defined by tht
Administrator as conventional. The
Administrator designated oil and grease
a conventional pollutant on July 30.1979
(44FR+4S01).
  BCT is not an additional limitation but
replace* BAT for the control of
 conventional pollutants. BAT remain* in
 effect for the toxic and nonconventionai
 pollutants. In addition to other factors
 specified in section 304fb|(4)(B]. the Act
 requires that the BCT effluent
 limitation* guidelines be assessed in
 jght of a two part "cost-
 reasonableness" test American Paper
 Institute v. EPA. 860 F.2d 954 (4th Cir.
 1981). The first test compares the coit
 for private industry to reduce its
 discharge of conventional pollutants
 with the cost to publicly owped
 trenment work* for similar levels of
 reduction in their discharge of these
 pollutants. The second test examine* tht
 cosf-effeetivene** of additional
 industrial treatment beyond BPT. EPA
 must find that limitations are
 "reasonable" under both tests before
 establishing them aa BCT. In no cast
 may BCT be Itsa stringent than BPT.
  EPA ha* promulgated a methodology
 for establishing BCT effluent {imitation*
 guideline* (51 FR 24974. July 8. 1986).
 4. \aw Sanre^ Performance Standard*
 iNSPSI
  NSPS art based on tht performance of
 the best available demonstrated
 technology. New plant* have tht
 opportunity to install tht best and mo*t
 efficient production processes and
 wastewater treatment technologies. As
 a result NSPS should represent tht most
 stringent numerical value* attainable
 through the application of best available
 demonstrated control technology for all
 pollutant* (toxic conventional and
 nonconventional).
 5 Preireatment Standards for Existing
Sources      ""^ -
  PSES art designed to prevent the
discharge of pollutants that pas*
through, interfere with, or are otherwise
incompatible with tht  operation of
publicly owned treatment work*
(POTWs). The Clean Water Act requires
pretreatment standard* for pollutant*
that pass through POTWs oil interfere
with POTWs' treatment processes or
sludge disposal method*. The legislative
history of the 197? Act indicate* that
preireatment standards are to be
technology-based and  analogous to the
BAT effluent limitations guidelines for
removal of toxic pollutants. For the
purpose of determining whether to
promulgate national category-wide
p re treatment standard*. EPA generally
determines that there is pas* through of
a pollutant and thus a  need for
categorical standards if the nation-wide
average percentage of  a pollutant
removed by well-operated POTWs
achieving secondary treatment is less
than the percent removed by the BAT
model treatment system. The General
                                                         4-4
Pretreatment Regulation*, which *-.»!
forth the framework for categorical
pretreatment standards, are founa «t 4 L
CFR Part 403. (Those regulations cont«
a definition of pass through that
addresses  localized rather than national
instances of pass through and does n:t
use the percent removal comparison test
described above. See 52 FR 1586.
January 14.1987.]

9. PretreaiT.er.t Standards for New
Sources i PSNS1

  Like PSES. PSNS are designed to
prevent tht discharge of poUuunts :h*t
pas* through, interfere with, or are
otherwise incompatible with the
operation of a POTW. PSNS are to be
issued at the same time as NSPS. New
indirect dischargers, like new direct
dischargers, have the opportunity to
incorporate in their plant the best
available demonstrated technologies.
The Agency considers tht same factor*
in promulgating PSNS as it consider! n
promulgating NSPS

8. Overview of the (ndustr/

  The OCPSF industry is large'and
diverse, and many pLint*  m the.ir.du-  -v
art highly complex. This industry
manufactures over 29.000  different
organic chemical*, plastic*, and
synthetic fibers. However, lets than h.> :
of these product* art produced :n excf
of 1.000 pound* per year. The industry
include* approximately 750 facilities
whose principal or primary production
activities are covered under the OCPSF
SIC groups. There sre approximate:) ."",
other plants which are secondary
producers of OCPSF products, i.e..
OCPSF production is ancillary to their
primary production activities. (As
discussed  above in this preamble, this
regulation covers OCPSF discharges
from secondary producers, with carters
exception*.) Thus the total number of
plants to be regulated totally or in pan
by the OCPSF industry  regulation is
approximately 1.000, Secondary OCPSF
plants may be part of other chetmul
producing industries such as the
petroleum refining, inorganic che-n-j s,
Pharmaceuticals, and pesticides
industries  as well as chemical
formulanon industries such as the
adhestves and sealant*, the paint =-:
ink. and the plastics molding and
forming industries.
  Some plants produce  chemica.3  -
large volumes while others procucf  - .
small volumes of "specialty" cfce-  •  -
Large volume production tends -3  --•
continuous processes. Continue--)
processes  are generally more e:r.  -
than batch processes :n minim:; ~:
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u
o
c*

C
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   CONSIDERATIONS INVOLVED IN USE OF EFFLUENT
                          GUIDELINES

          Determination of proper category and subcategory

     •     Proper use of applicable guidelines to the category or subcategory

     •     Classification of plants which fall under more than one subcategory

     •     Determination of appropriate measures of production or flow

     •     Use of alternative limits
         Application of mass vs. concentration limitations
NOTES:
                              4-6
-------
Page No. 1
03/26/91
BK
SIC Code Cross Reference
and Comparison of New


• Toxtcity Numbers with Old Values
1972/
1977
SIC
Code
211
212
213
213
214
214

219
241
241
Is,

252
253
254

259
259
271

272
279
279
291

721
721
*

921

1987
SIC 1987
Code Title
211 BEEF CATTLE FEEDLOTS
212 BEEF CATTLE, EXCEPT FEEDLOTS
213 HOGS
213 HOGS
214 SHEEP AMD GOATS
214 SHEEP AND GOATS

219 GENERAL LIVESTOCK, NEC
241 DAIRY FARMS
241 DAIRY FARMS
251 BROILER, FRYER AMD ROASTER
CHICKENS
252 CHICKEN EGGS
253 TURKEY AND TURKEY EGGS
254 POULTRY HATCHERIES

259 POULTRY AND EGGS, NEC
259 POULTRY AND EGGS, NEC
271 FUR-BEARING ANIMALS AND
RABBITS
272 HORSES AND OTHER EOJINES
273 ANIMAL AOUACULTURE
279 ANIMAL SPECIALTIES, NEC
291 GENERAL FARMS, PRIMARILY
LIVESTOCK
721 CROP PLANTING & PROTECTION
721 CROP PLANTING I PROTECTION
291 GENERAL FARMS, PRIMARILY
LIVESTOCK
921 FISH HATCHERIES AND PRESERVES


CFR EGO
Part Code
412 A
NR
412 A
NR
412 A
NR

NR
412 A
NR
412 A

412 A
412 A
NR

412 8
NR
NR

NR
NR
NR
NR

NR
NR
NR

NR


Sub-title

All Feedlots Except Ducks
Beef Cattle not in Feedlots
All Feedlots Except Ducks
Hogs not in Feedlots
All Feedlots except Ducks
Sheep and Goats not in
Feedlots
General Livestock Farms
All Feedlots Except Ducks
DAIRY CATTLE NOT CONFINED
All Feedlots Except Ducks

All Feedlots Except Ducks
All Feedlots Except Ducks
Hatcheries Without Poultry
Feeding
Ducks
Other Poultry Farms







Crop Dusting £ Spraying
Crop Planting/Cultivation
«

4-7
Did New
Tox. NO. Toxicity No.
(converted)

1
1
1
1
1
1

1
1
1
1

1
1
1

1
1
1
*
1
1
1
1

6
1
1
-
1
Toxicity
Nuifcer
Reference

2
2
2
2
2
2

2
2
2
2

2
2
2

2
2
2

2
2
2
2

2
2
2

2
-------
Page No.
03/26/91
1972/
1977
SIC
Code
1011
1021
1031
1041
1041
1044
1051
1061

1061

1061

1061

1081
1092
1094
1094
1099
1099
1099
1099
1111
1111

1111
1111


1987
s:c
Code
1011
1021
1031
1041
1041
1044
1099
1061

1061

1061

1061

1081
1099
1094
1094
1099
1099
1099
1099
1231
1231

1231
1231

2


1987
Title
IRON ORES
COPPER ORES
LEAD AND ZINC ORES
GOLD ORES
GOLD ORES
SILVER ORES
METAL ORES, NEC
FERROALLOY ORES, EXCEPT
VANADIUM
FERROALLOY ORES, EXCEPT
VANADIUM
FERROALLOY ORES, EXCEPT
VANADIUM
FERROALLOY ORES, EXCEPT
VANADIUM
METAL MINING SERVICES
METAL ORES, NEC
URANIUM -RADIUM -VANADIUM ORES
URANIUM -RADIUM -VANADIUM ORES
METAL ORES, NEC
METAL ORES, NEC
METAL ORES, NEC
METAL ORES, NEC
ANTHRACITE MINING
ANTHRACITE MINING

ANTHRACITE MINING
ANTHRACITE MINING

SIC Code Cross Reference
and Comparison of New
Toxicity Numbers with Old Values '


CFR
Part
440
440
440
440
440
440
440
440

440

440




440
440
440
440
440
440

434
434

434
434



ECD
Code
A
J
J
J
M
J
S
F

G

J

NR

NR
D
C
H
E
1
K
NR
B
C

D
E



Sub-title

Iron Ore
Cu, Pb, Zn, As, Au, Ho Ores
Cu, Pb, Zn, As, Au, Mo Ores
Cu, Pb, Zn, Ag, Au, Mo Ores
Gold Placer Mines
Cu, Pb, Zn, Ag, Au, Ho Ores
Aluminum Ore
Tungsten Ore

Nickel Ores

Cu, Pb, Zn, Ag, Au, Ho Ores

Ferroalloy Ores, NEC

Exploration/Development
Mercury Ores
Uranium- Radium -Vanadium Ores
Vanadium Ore
Titanium Ores
Antimony Ore
Platinum Ores
Metal Ore, NEC
Coal Preparation Plants
Acid or Ferruginous Mine
Drainage
Alkaline Mine Drainage
Post Mining Areas
4-G
Old New
Tox. No. Toxicity NO.
(converted)

7
10
10
10
5
10
10
6

8

7

8

8
8
9
8
4
8
8
8
6
5

5
5

Toxicity
Number
Reference

1
1
1
1
7
1
1
1

2

1

2

2
2
1
2
1
2
2
2
2
2

2
2

-------
                  Rtfisttr   Vol. 52.  So. 214  ,'  Thunday. Novembtr S. \997 I Suits  and Rtfuiattcns
xmv
aod Modirkattoa*
  One* tit OCPS7 rtfjuUttoa a in
effect tht nam«ncai efflata* ttautationa
for tht appropriate tuhatavory auat b«
applied A tU Federal UHt Stiui NPOES
permiu thtrtafttr nautd 10 OC75F
airtet diachantn. Tht prtcrtttnunt
vanotrt* are atrtctiy applicable to
indirect dischargers and bteomt
effective <• discusatd in  I 414.12 of tht
regulation.
   For the BPT effluent bmitauona, tht
or.iy exception to tht linuttuont
contained in tht regulation n EPA's
 'fundamentally difftrtat facton"
variance. Stt £ /. dufont d» Ntmoun
and Co. v. Train. 430 U.i 112 (1977);
 Weyimatusv Co. v. CcttJt. tupn. Thu
ver.anct rtcogiuzn factor* concerning t
particular discharger that an
fundamtntally difftnnt from tht ftcton
considtrtd la thit rulemaking. Howtvtr.
the economic ability of tht individual
operator to meet tht compiianct coat for
BPT standard! ia not a eoiuidtnnoa for
granting • vtnanct. Stt National
Crjsh*} Slant Auociaaaa v. EPA. 44fl
U.S. 54 (19*0), Although thi! variance
ciauM waa ongwally san  forth in EPA'i
1971-1978 cattfoncal industry
regulation*, it ia now tncludtd in tfat
gtntni N7DES regulation! aad will not
bt indudtd ta tht OGPSP or other  	
specific induatry regulation*. Stt 40 CTR
Part 125. Subpart 0.
  Tht BAT limitations in  thia regulation
also an subjtet to EPA't
•fundamentally difftnnt  facton"
vananc*. Howtvtr. itcnon 306 of tht
Water Quality Act of 1987 addtd a ntw
secuon 301(n| to tht Act which
somewnat lama tht availability of FDF
variances from BAT efTtutnt limitaoon*
gu:d*iiAtt. An PDF appucauoa rauat bt
based loitiy on information and
suppornng data lubnutttd to EPA dunnf
the ruiemaiuai ttcabiuhinf tht
iiTutanonj that ducutatd tht
fundtmtnully different facton. or oo
inlormaooB and luppontnf data that th«
applicant did not havt * rtaaoaabit
opportunity to aubnit dunaf tht
r;temakin>, Tht alttmativ* rtquirtmtnt
mutt bt no itsa atnnftat  than (uatifitd
by tht fundamental dJftnaet aad ouat
not rtsuli in aarkadly man advent
non-water quality tovtronntntai
impact! than thoft eoajidtnd by EPA
ji citabluhinf tht fudtUnt.
  Indirect diachargtn lubitct to PSES
are alto eligible for tht "fundamentally
d.fTerent facton" vananca. Stt 40 CTR
403-13. They art tubitct to esatntiatly
the tamt new statutory proviaiont for
PDF variance* at ditcuaatd above for
BAT.
  Resden thouid note that EPA hat not
vet amended itt TOF vananee regulation
to conform to tht proTitioiu of the
Wattr Quality Act of 19S7. Tht
refutation promulgated today rtftn to
tht tuannf rtf ulatory ateaona.
Howtvtr. EPA rtcsfBuat that tha ntw
jectioa 301(n) of tha Act ovtmdtt tht
exiaunf PDF rvfuiaooo to tht extent of
any uncoiuiattncy. aad EPA doti intend
to modify tht FDF rtguiauon to conform
to tht ntw statutory rtquirtatnts.
  Indirect ducnafitn tubitct to PSES
and PSNS are eiifiblt for ertdiu for
toxic pollutant* removed by a POTW.
Set stetion 307(b) of tht CYVA and 40
CFIt 403.7. The removal otdita
refuiaaon waa remanded to EPA ia
.\aiufaJ RMOunti Dif»nt9 Council v.
EPA. 79) fid 289 (3rd Or. 19M). Tht
court htld that tomt  of tht mtaaa by
which EPA contidered local POTW
removal efflclenott win sol
sufficiently ttnnatnt  aad that crtdlta for
POTW rtmovala may not bt authoriztd
unoi compnhtnatvt rtfulabo&a for tht
utt and disposal of iludft art
promulgated undtr section 409(dl of tht
CWA. Howtvtr. it should bt noted that
pretreannent ttandardj for the OCPSP
industry. Itkt other cattfoncal
prttrtaratnt standarda.  havt btta
promulgated based upon tht
assumptions that indirect discharjtrt
will bt rtqujrtd to comply with tfat
standards without removal credits, and
thus that they an subjtet to tht full
costs of complying with PSES.
XTV. Impltmantirinn of ^•«'»-•''•*• and
Staaojr*

A. Flow Baai*
  Tht limitations promulgated today art
conctntnnon-b**td aad thua do set
rtfulatt flow. Tht ptmut wnttr  mutt
utt a naaonabia tatimatt of proetaa
wasttwattr flowa aad tht conctttntiot)
tiButaoona to dtvtlop maaa UmtUbon
for tha NPDE3 ptttmt Proctsa
wasttwattr diacharft ia defined la tht
rtfulaooa (40