United States Environmental
Protection Agency
Office of Water
Office of Water
Enforcement and
Washington, DC
(EN-335)
Permits
20460
PRETREATMENT BULLETIN
Date: March 6, 1987
No. 2
SECOND
PRETREATMENT
BULLETIN
ISSUED
In response to a Pretreatment Implementation Review Task Force
(PIRT) recommendation, the Office of Water Enforcement and
Permits (OWEP) established a pretreatment bulletin, this issue
being the second. The bulletins are issued on an as-needed
basis to transmit policy, guidance, regulatory changes and
other specific information to all pretreatment POTWs to assist
them in the development and implementation of pretreatment
programs.
GENERAL
PRETREATMENT
REGULATIONS
REGULATORY CHANGES
On June 4, 1986, EPA promulgated technical amendments to the
General Pretreatment Regulations (40 CFR Part 403). {51 FR 20426).
This amendment was necessary to correct typographical errors,
erroneous cross-references to the NPDES permit regulations
(40 CFR Part 122), and inadvertent omissions in the General
Pretreatment Regulations. This action also makes several other
minor revisions that clarify the regulations, remove inconsistencies,
and update certain other provisions in response to developments
which have occurred since their promulgation.
On June 12, 1986, EPA proposed in the Federal Register a number
of revisions to the General Pretreatment Regulations. (51 FR 21454).
The proposed revisions are intended to clarify existing regulations,
respond to recommendations of the Pretreatment Implementation
Review Taskforce, and conform the pretreatment regulations to the
corresponding NPDES permit regulations and changes to them promulgated
on September 26, 1984. (49 FR 37998).
The June 12, 1986 Federal Register notice proposed significant
changes to the General Pretreatment Regulations. Any person who is
concerned with these regulations should obtain a copy of the
June 12 Federal Register for his or her use and information.
Responding to several requests to extend the comment period
beyond the August 11, 1986 closing date, EPA extended the comment
period to September 22, 1986 (51 FR 29950). The Agency is
currently reviewing all comments on the proposed revisions and
anticipates promulgation of a final rule in late 1987.
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REVISION OF Appendix D to the General Pretreatn nt Regulations lists
APPEND]J( D— wastestreams that are considered to be dilute for purposes
GENERAL of using the C rüined wastestream fornula. EPA pranulgated
PRmRr revisions to Appendix D on October 9, 1986 (51 FR 36368).
REX3ULATIONS The final n ile updates the Appendix D list and corrects errors
in the original list.
N ñ SOU1 E, On February 10, 1984, in response to a decision by the U.S.
INTERFERENCE Q irt of Appeals for the Third Circuit ren nding the definitions
AND PASS to the Agency, EPA published a final rule &n the Federal Register
THL JU H which suspended the definitions of: new sources [ 403.3(k)] ,
DEFINITIONS interference [ 403.3(i)] and pass throu h [ 403.3(n)]. The new
source definition was published as a final rule on July 10,
1984. On June 19, 1985, the Agency proposed in the Federal
Register new definitions for both interference and pass through
(40 CFR § 403.3(j) and (n), respectively). (50 FR 25526).
The final rule pranulgating the new interference and pass through
definitions in the general pretreatxr nt regulations was pub-
lished on January 14, 1987 (52 FR 1586). The new definitions
replace those suspended by the Agency in February 1984.
The definitions are ixr ortant for determining when an industrial
user has violated the general prohibitions against pass through
and interference (or the specific prohibitions in §403.5(b)(3),
(4), and (5)) and when P(YIWs nust develop local limits under
§403.5(c).
The final rule also creates t affirnative defenses tc violations
of the general and specific prohibitions. Generally, an industrial
user nay assert an affirn tjve defense if either 1) it was in
conpliance with local limits designed to prevent interference
and pass through; or 2) its discharge had not changed substantially
fran the period prior to the pass through or interference problei s
during which the P01W was in regular caipliance with its permit.
Neither affirnatjve defense uld be available, hc qever, if the
industrial user knew or had reason to kncM that its discharge
ould cause pass through or interference.
SLUDGE New amendneritg to the Clean Water Act require that permits issued
R X]UIATIONS to treatrr nt works contain limits for sludge use and disposal.
Q.irrently, limits for only cadmium and PCB concentrations have been
pratiulgated (40 CFR 257). EPA is scheduled to issue proposed reg-
ulations on other toxic pollutants of concern by August 31, 1987.
Prior to the praiulgation of criteria, sludge permit limits will be
set on a case—by—case basis and issued by EPA Regions unless indivi-
dual State permit limits have been approved. EPA will issue draft
guidance on setting case—by-case sludge limits in FY 1987. EPA
will develop regulations governing the incorporation of sludge
criteria in NPDES permits, and regulations setting forth criteria
for approvable State sludge permitting programs, which m y be
NPDES or non-NPDES.
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REMOVAL On April 30, 1986 the United States Court of Appeals for the
CREDITS Third Circuit upheld the Natural Resources Defense Council’s
challenge to EPA’s removal credit regulation ( NRDC vs. EPA,
No. 84—3530). The Court struck down the amerx3e5 regulation
on four separate grourds:
(1) EPA’s new definition of a PcYIW’s “consistent removal”
rate failed to implement the requirements of the Clean
Water Act ard therefore was invalid;
(2) EPA failed to justify deletion of the previously
promulgated combined sewer overflow a:ijustment;
(3) EPA’s provision specifying the modification arx with-
drawal process of a POIW’s removal credits was illegal; ar 1
(4) EPA cannot, in the absence of § 405 sludge regulations,
authorize the granting of removal credits to PO1 s urx3er
S 307(b)(l) of the Act.
On February 23, 1987, the Supreme Court rejected all appeals
of the Third Circuit ruling. EPA will be proposing a revised
regulation in the near future. EPA is proceeding with the
develop ent of sli ge regulations (see article on page 2 of
this bulletin).
DC 4ESTIC On August 22, 1986, EPA announced it was planning to propose new
SEWAGE STUDY regulations to improve the control of hazardous wastes
discharged by irr ustry to PCYIWs. The announcement was contained
in an Mvance Notice of Public Rulemaking (ANPRM) (51 FR 30166).
The ANPPII solicited coøui ent on a broa5 range of regulatory ar 3
program changes in response to the stu3y. Among the proposals were
changes to the general pretreatment program an categorical
pretreatment stardards, improved procedures for water quality
ard sludge management, ard more extensive research in other areas,
incl ing air emissions from treatment plants ard grourdwater
contamination. A summary of public comments on the ANPRM shows
four general areas of response:
the commenters (a majority of whom were P(YIWs) expressed
overwhelming support for retaining the Domestic Sewage
Exclusion ard preference for regulating hazardous waste mixed
with domestic sewage urder the CWA rather than urder RCRA.
Environmental groups expressed serious concern about weaknesses
in the pretreatment program ard suggested furdamental changes
ard reserved comment on repealing the Domestic Sewage Exemption.
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D 1ESTIC ° the commenters, while supporting various improvements in the
SEWAGE pretreatment program to improve the control of hazardous
STUDY (con’t) wastes, often expressed skepticism about the existence of a
major environmental crises in this area which would justify
a major revamping of the program. They were concerned about
using limited PO’IW resources for a perceived rather than real
problem. Several stressed the importance of fate an3 effects
research in order to document the existence of actual negative
impacts of specific pollutants.
o many commenters urged giving PO IWs maximum flexibility in
implementing any program changes that are eventually ma e.
This flexibility will allow them to tailor requirements to
problems (particularly interference) peculiar to their
localities.
o at the same time, many commenters wanted EPA to assume the
burden of conducting research ar 3 issuing technical guidance
to help develop controls which are technically ani legally
justified.
EPA is now in the process of evaluating rulemaking options ar
expects to issue a Federal Reqister notice in April 1987
summarizing the public comments on the ANPRM ar explaining
how the Agency will respor to the recommerx:lations of the
Domestic Sewage StLx5y.
Copies of the Domestic Sewage Study may be purchased from the
National Technical Information Service in Springfield, Virginia
(document no. PB86184017/AS).
DEFINITION In EPA’S Pretreatment Com liarice Monitoring ar 3 Enforcement
OF SIGNIFICANT Guidance, the term Significant Noncompliance for industrial users
NONCOMPLIANCE is specifically defined. This definition can be used for:
O establishing appropriate enforcement priorities arxi actions
o reporting information from PO’IWs to Approval Authorities
For newspaper listings, a similar term, “Significant Violations”,
is alreedy defined in the General Pretreatment Regulations. In
the future, EPA plans to propose to amend the General Pretreatment
Regulations to remove the term “Significant Violations”. The
single definition of Significant Noncompliance will then be used
for enforcement priorities, reporting, arxi publishing a list of
noncornpliant industrial users in the newspaper.
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CATEGORICAL SFANDAPDS
IMPLEMENTATION Each categorical pretreatlierit standard is published by EPA as
OF NATIONAL a separate regulation. The standards contain limitations for
CATEX3ORIC A L pollutants camDnly discharged within each specific industrial
PRE REMMENT category. AU firr regulated under a particular industry
STANDARDS category are required to ccxrply with these standards, no rratter
where they are located. Table 1 (on Page 6) lists the 21 industrial
categories and the status of the categorical pretreatri nt
standards. One hundred twenty-six toxic pollutants are being
considered for regulation in these 21 industrial categories.
Final dates for cc liance with categorical pretreatnent standards
have passed for the following industry categories:
° Timber Products Processing
o Electroplating (both integrated and nonintegrated facilities)
o Iron and Steel Manufacturing
° Inorganic Chemicals Manufacturing (Phase I)
o Pulp, Paper, and Paperboard
o Builders’ Paper and Board Mills
° Steam Electric Pc ier Generating
• Electrical and Electronic Cc onents (Phase I)
o Petroleum Refining
o Metal Finishing
o Leather Tanning and Finishing
o Porcelain Enaneling
o Coil Coating (Phase I and II)
o Copper Forming
o Aluminum Forming
o Pharrraceuticals Manufacturing
Control Authorities ir&ist ensure that industrial users subject
to the pretreatrrent standards for existing sources for the above
industry categories caiply, and continue to coriply, with the
applicable standards after the appropriate final conpliance date.
See Table 1 (on page 6) for the applicable date for each of the above
categories. All new sources in any regulated industry category
nust carply with app’icable pretreatrrent standards when they
start their discharge.
To assist Control Authorities in iriplenenting these categorical
pretreatment standards, EPA has prepared guidance rrenuals for
specific industry categories. Manuals are currently available
for the Electroplating/Metal Finishing and Iron and Steel
Manufacturing categories (see document request form elsewhere
in this bulletin). These n nuals are designed for use by both
Control Authorities and industrial users. CWEP is tentatively
planning, in conjunction with EPA’s Industrial Technology Division
(ITD), to develop guidance n nuals for urplenenting the categorical
standards for several additional categories, including Battery
Manufacturing and Metals Forming. Additionally, EPA continues
tr sponsor seminars throughout the country on the categorical
pretreatment standards for specific industry categories. Check
with your EPA Regional or State pretreatment contact for further
inforn tion on seminars in your area.
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TABLE 1
National Categorical Pretreatment Standards
Milestone Dates
Date Issued Baseline Monitoring PSES’
In Federal Effective Report Due Compliance Final Compliance
Industry Category Register Date Date Date Date
Timber Products Processing 1-26—81 3-11-81 9-26-81 1-26—84 4—26-84
Electroplating 2 1-28-81 3-30-81 9-26-81 4-27-84 7-26—84
(Nonintegrated) (t4onintegrated) (Noni ntegrated)
6-25-83 6- 30-84 9-28-84
(Integrated) (Integrated) (Integrated)
Iron & Steel 5-27-82 7-10-82 4-6—83 7-10—85 10-8-85
Inorganic Chemicals
Phase I 6-29-82 8-12-82 5-9-83 (See Note (See Note
Phase II 8-22—84 10-5-84 4-3—85 1 Below) 1 Below)
Petroleum Refining 10—18-82 12-1-82 5-30-84 12-1-85 3-1-85
Pulp & Paper Mills 11—18-82 1-3—83 7-2—83 7-1—84 9-29—84
Builders Paper & Board MIlls 11—18-82 1-3—83 7-2—83 7-1—84 9-29-84
Steam Electric 11—19-82 1-2—83 7-1—83 7-1—84 9-29—84
Power Plants
Leather Tanning & 11—23-82 1-6—83 7-5—83 11-25-85 2-23—85
Finishing
Porcelain EnamelIng 11—24-82 1-7-83 7-6-83 11-25-85 2-23—85
Coil Coating (Phase 1) 12—1-82 1-17-83 7-16—83 12-1—85 3-1—85
—Steel Basis Material
—Aluminum Basis Material
Electrical & Electronic 4-08-83 5-19—83 11-15-83 7-1-84 9-29-84
Components (Phase I) 11-8—85(As) 2-6—85(As)
-Semi conductors
—Electronic Crystals
Metal Finishing 7-15-83 8-29—83 2-25-84 2-15—86 5—16-86
Copper Forming 8-15-83 9-26-83 3-25-84 8—15—86 11-13-86
Aluminum Forming 10—24-83 12-7—83 6-4—84 10-24-86 1—22—87
Pharmaceuticals 10—27-83 12-12-83 6—9—84 10-27—86 1-25—87
Coil Coating (Phase II) 11—17-83 1-2—84 6-30—84 11-17—86 2-15—87
—Canmak I ng
Electrical & Electronic 12-14-83 1-27—84 7-25-84 7-14—87 10-12-87
Components (Phase II)
—Cathode Ray Tube
—Luminescent Materials
Nonferrous Metals
Manufacturing
Phase I 3-8-84 4-23-84 10-20-84 3-8-87 6-7-87
(Subparts A—H)
Phase II 9-20-85 11-4-85 5-3—86 9—20—88 12-19-88
(Subparts N-AE)
Battery ManufacturIng 3-9—84 4-23-84 10—20-84 3-9—87 6-7—87
Nonferrous Metals Forming 8—23-85 10-7—85 4-5—86 8—23—88 11-21-88
and Metal Powders
Pesticide Chenil cals ******************** REMAND
Metal Molding and Casting 10—30—85 12-13-85 6-11-86 10-31-88 1-29-89
Note 1: Final compliance date for Subparts A.B,1.AL.AR,BA, AND BC is July 20. 1980.
The compliance date for Subparts AJ,AU,BL,BM,BN, AND 80, except for discharges
from copper sulfate or nickel sulfate manufacturing operations, is August 22, 1987.
The compliance date for discharges from copper sulfate and nickel sulfate
manufacturing operations and for all Subparts in Part 415 not previously specified
is June 29, 1985.
‘PSES - Pretreatment Standards for Existing Sources
2 Existlng job shop electroplaters and independent printed circuit board manufacturers
must comply with only the electroplating regulations. All other Electroplating
operations are now covered by the metal finishing standards.
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CHANGES TO As a result of litigation and settlement agreements, various
CATEGORICAL regulatory changes effecting the categorical pretreatment standards
PRETREATMENT listed below have occurred recently or are expected to occur in the
STANDARDS near future. Additional information regarding changes in the
following specific categories may be obtained by referring to
the listed Federal Register notice.
Aluminum Forming
— proposed amendments March 9, 1986 (51 FR 9618)
— final amendments expected February 1987
— primary issue: flow basis of mass limits.
Copper Forming
— tinal amendments to exclude Cu—Be alloys published March 5, 1986
(51 FR 7568)
- proposed regulations for new Beryllium alloy subcategory expected
summer 1987.
Nonferrous Metals Forming
— negotiations with litigants still in progress. Remaining issues
expected to be settled soon.
— proposed amendments expected by summer 1987
- issues include flow, pollutants regulated, treatment effective-
ness, cost, economic impact.
Nonferrous Metals Manufacturing- Phase I
- negotiated settlement agreements for Primary and Secondary
Aluminum have been reached. Amendments proposed May 20, 1986
(51 FR 18530)
— final amendments expected April 1987
— Primary Tungsten (treatment effectiveness of ammonia steam
stripping) settlement agreement has been reached. Proposed
amendments expected April 1987.
Nonferrous Metals Manufacturing— Phase II
— settlements with 6 of 10 parties have been reached. If settle-
ments are not reached with remaining parties early in 1987,
litigation will be pursued
— issues include cost, amonia air stripping treatment effective-
ness, analytical methods
— Primary Rare Earths subcategory voluntary remand to remove one
direct discharger expected February 1987. All other regulations
remain in effect.
Battery Manufacturing
— final settlement reached. Regulations amended August 28, 1986
(51 FR 30814)
— issue was flow adjustment for battery washing
Leather Tanning and Finishing
— iina settlement completed. Proposed amendments expected to be
published February 1987
- proposed amendments will include new analytical method for
sulfide and revisea applicability language for small plants
not required to comply with PSES chromium standards.
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RE2IAND OF On Ortober 4, 1985, EPA pranulgated a final regulation
PESTICIDE establishing pretreatment standards for existing sources (PSES)
MANUFPIC ’ftJRI and pretreatment standards for new sources (PSNS) for the
EFFLUE pesticide ch nicals point source category (50 FR 40672).
GUIDLINES
REGULATION EPA was sued by several parties who challenged various aspects
of the 1985 pesticide regulation. To resolve the litigation, on
July 21, 1986, EPA and the several petitioners filed a joint
InDtion for voluntary remand of the rulemaking in the U.S. Court
of Appeals for the Eleventh Circuit requesting that the Court
remand the 1985 pesticide regulation to EPA. On July 25, 1986,
the Court dismissed the litigation in accordance with the Joint
notion for voluntary remand. This means that the 1985 pesticide
regulation is no longer effective (as of July 25, 1986). Efforts
are underway to decide on the scope of and deadlines for a study
to reconsider the regulation and to undertake further rulemaking.
The study will caipletely reconsider and revise as necessary all
aspects of the regulations, and will include
— a new industry questionnaire
- plant sampling for an expanded list of analytes and other
pesticides
- revised and upiated engineering, econanic and environmental
assessments.
The nrst likely option at this time, presented to environmental
groups and industry, is to study manufacturers and formulaters
together, resulting in final regulations in about five years (1992).
EPA will publish a Federal Register notice in the near future
informing the public of this matter.
Indirect dischargers in the pesticide chemical industry continue
to be regulated by the general pretreatment regulations. The
control authority should set pretreatment standards in accordance
with local and other general pretreatment requirements.
SGIEIYJLE FOR The Organic Q-iemicals, Plastics, and Synthetic Fibers (OCPSF)
THE 0 ANIC industry includes approximately 500 indirect discharging
cI-EE 1ICpLs, facilities which manufacture over 25,000 different products.
PLASTICS, AND -
SYNmE’rIC The OCPSF regulation is one of the last of the 28 regulations
FIBERS FINIIL required by the Natural Resources Defense Council (NREX) Consent
REGULATION Decree (N IX vs. Train et al.). The Agency proposed regulations
for this industry on March 21, 1983, and noted that there re
deficiencies in our data base that uld require collecting
additional information. The Agency subsequently conducted
additional toxic pollutant sampling at twelve OCPSF plants and
surveyed 3,300 establishments believed to be OCPSF manufacturers.
On July 17, 1985, the Agency published a Notice of New Information.
This notice was essentially a reproposal and set forth a variety
of regulatory options which limit up to 70 of the 126 toxic
pollutants. Some issues addressed in this notice include altern-
ative limitations/controls for PSES for small plants, the nod!—
fication of the P01W pass-throuc analysis, consideration of metals
and cyanide rertoval technologies, and consideration of package
biological treatment for PSES.
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SCHEI1JLE FOR On December 8, 1986, the Agency published a Notice of Availability
THE OI ANIC and Request for Catirents on additional new information (51 FR 44082).
CHFMICALS, The close of caiirent period was February 6, 1987. The riost recent
PLASTICS, AND Court-ordered deadline for this regulation was December 31, 1986.
SYNThETIC Hci ,ever, EPA was unable to neet this deadline due to the need
FIBERS FINAL to obtain public c ment on the additional new information.
RDGULATION EPA sought to revise the promulgation date to August 1987, and
(con t) sut nitted a new affidavit containing this date to the Ca irt on
December 5, 1986. The Court has approved this revised schedule.
GUIDANCE MATERIAL
PBErRE A’IME fl’ The Pretreatxtent Cc liance Monitoring and Enforcerrent (cCME)
CCt4PLIANCE Guidance was signed by the Director of the Office of Water
MONflORIt’TG AND Enforcenent and Permits (GiJEP) on July 25, 1986. Printed ccpies
E2 1FO1 FMENT of this guidance are being sent from the U.S. EPA Regional
GUIDANCE Offices to States and PO ’lWs with approved pretreatnent programs.
This guidance is intended to be a ccitprehensive guide to pre—
treatnent in leirentation, particularly on-going cc liance
rionitoring and enforcerrent activities.
The guidance was developed to address several administrative
functions that are required of POIWs by regulation. The P alE
Guidance provides a discussion of the foll 4ng topics:
o establishing seif-rionitoring requirenents for lU’s
o establishing sarrpling frequencies for lU’s
o sanpling and inspection procedures for PCIIWs
o reviewing industrial user reports
° determining industrial user cclTpliance status
o setting priorities for enforcenent actions
reporting P0 1W activities to the Approval Authority
It establishes a definition of Significant Industrial User (SIU)
for use by the Control Authorities in targeting primary imp-
lenentation activities and recoiniends a definition of Significant
Noncar liance (SNC) to be applied in evaluating industrial user
performance in complying with effluent and reporting requirenents
as well as carpliance schedules.
To increase the effectiveness of the National program and achieve
consistent enforcenent across the nation, reporting at all levels
-- industrial user, P01W, and State — will be an on-going and
significant activity. Such reports will be a necessary component
t iards determining national conpliance with pretreatnent standards.
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PRETREATMENT AS indicated, the Guidance establishes common definitions which
COtIPLIANCE can be used as the basis for consistent reporting and provides
MONITORING AND a recommended format for collection of data from Control Authorities
ENFORCEMENT on at least an annual basis.
GUIDANCE
(con’t) The reporting system and the definitions of SNC and SIU are issued
as guidance. However, it is the goal of OWEP to establish a
national reporting system based on the concepts in this document.
A Pretreatment Permits and Enforcement Tracking System is now
under developnent which will require some information which could
be developed through the use of the Pretreatment Performance
SuiruTary found in the PCME Guidance. Approval Authorities should
anticipate such requirements and strongly consider requiring
Control Authorities to plan for implementation of this reporting
system with associated definitions.
To assist Control Authorities in gaining proficiency with
compliance monitoring and enforcement activities, Regions and
delegated States are encouraged to conduct training workshops
providing practical examples of these activities. OWEP is
prepared to jointly develop and conduct such workshops with the
Regions and States and is developing training materials which
can be used by them.
PO’IW PROGRAM EPA is developing criteria for tracking violations of POTW
IMPLEMENTATION — pretreatment implementation requirements. The criteria would be
REPORTABLE used by EPA and States to establish consistent implementation of
NONCC 1PLIANCE P01W programs, to report on progress of the National Pretreatment
program, and to evaluate the effectiveness of EPA and State enforce-
ment programs. The criteria cover four areas of P01W program
implementation: IU control mechanisms; compliance monitoring and
inspections; P01W enforcement; and P01W reporting to the Approval
Authority. EPA will study and refine the criteria during 1987 and
prepare changes to regulations for Noncompliance Reporting (40 CFR
part 123.45).
EPA has the following recommendations to P(YIWs for compliance
monitoring and enforcement. All PO’lW Control Authorities are
encouraged to have written procedures and ability for:
1) Maintaining an inventory of non-domestic contributors to the
sewer system that are subject to their PO’IW pretreatment
program and a schedule of reports required to be submitted by
those contributors to the Control Authority.
2) Initial screening (i.e., pre—enforcement evaluation) of all
compliance information to identify lu violations of applicable
pretreatment, slixige, or hazardous waste requirements and to
establish priorities and timeframes for further substantive
technical evaluation and/or appropriate enforcement response
for those violations.
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P01W PROGRAM 3) When warranted, cOr 5ucting a substantive technical evaluation
IMPLEMENTATION — following the initial screening of all relevant compliance
REPORTABLE information to assist the determination of an appropriate
NONC 4PLIANCE response by the Control Authority.
(con’t)
4) Maintaining a management information system which supports
the compliance evaluation ar 3 enforcement activities of the
P01W.
5) Inspectin9 the treatment facilities aria sampling the wastewater
contributions of all significant ir ustrial users at least
annually; ar
6) Enforcing requirements for pretreatment an3 slt ge that apply
to non-domestic contributors in a consistent arx5 equitable
manner that prorrotes compliance a the quick resolution of
noncompliance.
UPGRADED An up9ra ed version of PRELIM, EPA ’s local limits computer program,
PREEJIM will be available shortly from your EPA Regional Pretreatment
PROGRAM Coordinator free of charge. The PRELIM program is intended to
AVAILABLE facilitate the development and modification of P0Th pretreatment
programs and numeric limitations by simulating the methodology and
calculations normally used in the limit—setting process. PRELIM
also contains several databases that are often needed by those
responsible for preparing local limits. The program can be useful
to cities, municipalities, PO’IWs or consultants for developing or
revising local numeric limitations, ar id by States arid EPA personnel
for reviewing the proposed specific pollutant limits in P01W pretreat-
ment program submissions. PRELIM output is divided into two sections
which can be run arid displayed separately or in combination.
These two sections are:
1. Calculation of maximum loading of any pollutant that a P01W
can accept while continuing to meet its environmental criteria
2. Computation of several alternatives for allocating that
loading among the industrial contributors to the P01W.
The upgraded version of PRELIM, PRELIM Version 3.0, incorporates
the following features not included in previous PRELIM versions
(i.e., Versions 1.0, 2.0—2.2):
o PREIJIM Version 3.0 accepts P01W data entry in full screen
editing format. This format will permit novement of the
computer’s cursor across an entire screen, simplifying the
correction of data entry errors.
o PRELIM Version 3.0 data files do not overwrite previous PRELIM
data files, but are saved under user_supplied names. This
modification allows the PRELIM user to concurrently save input
data from multiple PRELIM runs.
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o PRELIM Version 3.0 output provides the user with loading summary
tables by pollutant. These tables provide a ready comparison
of allowable headworks loadings with current headworks loadings,
as per EPA’s local limits policy. This loading summary table
also indicates each industrial user’s current compliance status
with the PRELIM-derived local limits.
o PRELIM Version 3.0 allows the user to display PRELIM outputs on
the computer screen as well as to print the output.
In addition, all PRELIM default databases for water quality criteria,
sludge criteria, removal rates and process inhibition values were
reviewed and updated prior to incorporation in PRELIM Version 3.0.
The system requirements remain unchanged from the previous
version of the software. A minimum of 256K RAM is required, and
the system must operate under MS-DOS. The program will execute
utilizing either Microsoft BASIC© or GWBASIC© software. However,
please note, PRELIM will not execute on Leading Edge® personal
computers because access commands in BASIC are not compatible.
Changes may be made to the PRELIM code to accornodate this, but we
advise you contact your dealer for specific inquiries. The User’s
Guide provides information on running PRELIM, as well as on preparing
information necessary to run the program. The manual provides a
step—by—step guide for executing the program, and describes how to
utilize and interpret PRELIM output. Users of this program should
be familiar with the procedures and methodologies for setting
local effluent limits. PRELIM, like any computer program, cannot
replace sound judgernent where input or output interpretation is
needed.
Section 403.5(c) of the General Pretreatment Regulations provides
that POTWs required to establish local pretreatment programs
must develop and enforce specific limits to implement the general
prohibitions against pass—through and interference [ 403.5(a)]
and the specific prohibitions listed in §403.5(b).
To address development of local limits, EPA has undertaken three
major steps:
1. developed a computer program (PRELIM) to assist POTWs in
calculating local discharge limitations (see previous article
regarding the availability of an upgraded version of PRELIM)
UPGRADED
PRELIM
PROGRAM
AVAI LABLE
(con’t)
LOCAL LIMITS
TECHNICAL
GUIDANCE
2. issued a memorandum,
mi nimum requl rernents
POTWs (see document
bulletin to request
dated August 5, 1985, specifying
for development of local limits by
request list on the last page of this
a copy), and
3. initiated the development of a guidance manual on local limits.
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LOCAL LIMITS This manual, the Guidance Manual on the Development of Local
TECHNICAL Discharge Limitations Under the General Pretreatment Regulations,
GUIDANCE is expected to be issued during the summer of 1987. It will be
(con’t) made available to all pretreatment POTWs, State and EPA Regional
personnel. It will draw upon and update guidance previously issued
by the Agency on the control of industrial discharges, provide
approaches for evaluating the problem potential of pollutants discharged
to the sewers, and present new methodologies for deriving discharge
standards for toxic organic pollutants. This document will contain
numerous figures, reference tables, example calculations and case
studies designed to expand upon and illustrate information provided
in the text. The guidance manual will be designed to provide the
reader with a comprehensive reference on local limits development
and implementation methodologies.
GUIDANCE In response to a Pretreatment Implementation Review Taskforce
MANUAL ON (PIRT) recommendation that EPA develop guidance to help POTWs
PREVENTING understand how to identify an interference problem and track it
INTERFERENCE back to the source, the Agency is preparing the Guidance Manual
for Preventing Interference at POTWs . Based on a literature review
and 17 case studies, the manual discusses how to identify/detect
interference, determine the source, and how to prevent it. A review
of the content of the draft manual provides the following overview:
o results of the 17 case studies reveal
(1) most interference problems are caused by conventional
pollutants
(2) problems involving toxics are usually related to isolated
or intermittent discharges which are hard to track to the
source
o the manual is focused on interference problems involving permit
violations
o the importance of distinguishing interference problems from poor
plant operation is stressed
o inspection and monitoring of the P01W processes and wastestreams
is emphasized under “detecting interference” sections
o u monitoring, collection system tracking programs, and methods
for detecting illegal discharges and midnight dumping are
discussed under “source identification” sections
o alteration of P01W treatment plant processes to reduce the impact
of interference—causing substances, pretreatment, local limits,
accidental spill plans, regulation of waste haulers, and enforce-
ment are discussed under “mitigation” sections.
The anticipated final issuance date for the manual is Spring 1987.
Copies will be made available to all pretreatment POTWs, State
and EPA Regional personnel.
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IU INSPECTOR EPA has awarded a training grant to California State University,
TRAINING Sacramento (CSUS), to develop a self—study course for P01W
COURSE UNDER pretreatment program industrial user (IU) inspectors. Dr. Kenneth
DEVELOPMENT Kern, the project director, has previously developed several
popular self-study courses for P01W and water quality personnel.
Among them are: Operation of Waste ,ater Treatment Plants and
Operation and Maintenance of Wastewater Collection Systems .
Dr. Kern has selected a group of experienced P01W pretreatment
program personnel to aid in developing the course manual. The draft
chapters will be edited by educational and reading comprehension
experts, reviewed by the original authors and integrated with
illustrations and questions into a technically and educationally
sound training course. The course will then go through extensive
review and field testing by experienced pretreatment personnel
throughout the country, representing a wide variety of POTWs, as
well as State and EPA Regional Office pretreatment programs.
After the final modifications are completed, the manual will be
printed by the University and used as a basis for a correspondence
course. CSUS will grade exams, provide consultation services, and
award Continuing Education Units (CEUs) for those who successfully
complete all requirements. It is expected that the manual will also
be used by community colleges and other organizations as a text for
classroom pretreatment training courses.
The course is expected to be available through CSIJS late in 1988.
For further information, contact Pete Eagen of the Permits Division
at EPA Headquarters ((202) 475—9529).
GUIDANCE ON The Office of Water Enforcement and Permits will develop
PREPARATION guidance to assist Control Authority personnel in the
AND ISSUANCE preparation and issuance of permits to its industrial users.
OF PERMITS TO It is anticipated that this guidance will be based on EPA’s
INDUSTRIAL Training Manual for NPDES Permit Writers (March 1986). The
USERS manual will also discuss a few selected POTW permit programs,
how permits are developed, standard conditions, monitoring,
etc. The guidance is expected to be completed in the fall of
1987.
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The documents listed on this request sheet are available on a
liinitei basis from EPA. Before requesting any, please check
to make sure your office doesn’t alreaiy have a copy. To
obtain a copy of any of the fol1 ing documents, please provide
your name arxi a1dress, check the requested document(s), arKi return
the information to:
Chuck Prorok
U.S. Environmental Protection Agency
401 M Street, SW (EN-336)
Washington, DC 20460
Name:
kidress:
Guidance Documents
Pretreatment Bulletin No. 1 (September 30, 1985)
Guidance Manual for Electroplating and Metal
Finishing Pretreatment Standards
Guidance Manual for Iron and Steel Manufacturing
Pretreatment Stan:iards
Guidance Manual for Implementing Total Toxic Organic
(Pro) Pretreatment Standards
RCRA Information on Hazardous Wastes for POIWs
Guidance t4anual for the Use of Production—Based
Pretreatment Standards and the Combined Wastestrearn
Formula
Pretreatment Corrpliance Monitoring and Enforcement
Guidance
Memorandum: Local Limits Requirements for P0 1W Pretreatment
Programs (August 5, 1985)
Overvi , of the National Pretreatment Program (uçdatei
periodically)
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