United States Environmental
                 Protection Agency
                Office of Water
                                               Office  of Water
                                                Enforcement and Permits
                                               Washington,  DC   20460
                               PRETREATMENT   BULLETIN
                Date; November 6, 1987
                                                                         No. 3
                Pretreatment Bulletins,  this being the third to date,  are issued on
                an as-needed basis to transmit policy, guidance, regulatory changes
                and other specific information to all pretreatment POIWs to assist
                them in the development and implementation of pretreatment programs.
 On February  4,  1987, Congress enacted amendments to  the  Federal  Clean
 Water Act.   These amendments  (contained  in the Water Quality Act of
 1987)  generally reinforce the pretreatnvent program requirements  and add
 greater enforcement authority to EPA.  The areas of  the  amendments  most
 significant  to  pretreatment are:

   increasing the civil penalty authority of EPA fron $10,000 per day for
   each violation to $25,000 per day for each violation  (§313)

   changing the  criminal penalty from a misdemeanor to a% felony  (§312)

   clarifying that IU violations of the requirements  in a local pretreat-
   ment program  are Federally enforceable (§312 and 313)

   adding two classes of administrative penalties of  up to $25,000 for a
   Class I penalty or $125,000 for a Class II penalty.  This  provision of
   the  Act substantially reduces the procedures for EPA's assessment of
   fines (§314)

 0  requiring  EPA to promulgate sewage sludge regulations  including specific
   numeric criteria for various uses or disposal practices.   The  sludge
   requirements  are to be implemented  either through the NPDES permit or
   an alternative State sludge permit program.  Until final national rules
   are  promulgated,  EPA is directed to make case-by-case  determinations  on
   appropriate requirements for a POTWs sludge management (see article
   on page 2 of  this bulletin regarding the status of sludge  requlation
   development)  (§406)

 0  requiring EPA to report to Congress on the pretreatment program and
   means of improving its effectiveness.  The report  is due in four  years

   requiring the Administrator of EPA to ensure that  an adequate  number  of
  employees are working within the pretreatment program  to enable better
   implementation of pretreatment requirements and overview of approved
   local POTW programs (§309).

The full text of the Water Quality Act of 1987 can be found  in the
Congressional Record and will be published in'the United States  Code.


IXtIESTIC The E) *i stic Sewage Study (DSS) was sulznitted to Congress by EPA in
SEWAGE S’IUDY response to Section 3018(a) of the Resource Conservation and Recovery
Act (RCRA). That provision directed the Agency to report to Congress
on wastes discharged to P(YIWs through sewer systems that are exei t
fran regulation under RCRA as a result of the Dcn stic Sewage Exclusion.
On June 22, 1987, EPA issued a Federal Register notice (52 FR 23477)
which sunir arizes the principal public carments on the Agency’ s prelim-
inary approaches to fulfilling the recaniendations of the E S. This
notice also discusses the program and research activities which EPA has
under way to aid in this effort. Changes to the General Pretreatment
Regulations to implement sane t S recctrnendations are scheduled to be
proposed in the Spring of 1988.
SLULGE The 1987 amendments to the Clean Water Act (CWA) require that permits
REGULATIO ?TS issued to treatment works contain sludge standards. EPA is scheduled
to issue proposed standards for pollutants of concern in sewage sludge
in March 1988. EPA also will be proposing regulations for incorporat-
ing sludge standards in NPDES permits and for State sludge management
progrartis in December 1987. The 1987 CWA amendments also state that,
prior to developient of the standards, the ? ministrator rrust put sludge
conditions in permits issued to POThs or take other appropriate action
to protect pt. blic health and the environment. To meet this requirement,
EPA and States will begin incorporating sludge conditions, developed
on a case—by-case basis , in fIWs’ NPDES permits as they expire and
are reissued. EPA has developed a “Strategy for Interim Irnplenentation
of Sludge Requirenerits in Permits Issued to PCTIWs”. In addition,
EPA is preparing guidance to permit writers on developing interim
case-by-case sludge requirements. Public notice of availability of
each of these documents for public can nent is expected to be published
in the Federal Register in the Fall of 1987.
FDF VARIANCES Before passage of the Water ia1ity Act of 1987 (WQA), EPA had provided
FOR INDIRECr for a fundamentally different factors (FDF) variance frcm pretreatment
DISCI-IP .RGEFS standards for indirect dischargers. Procedural and substantive regulat-
ions were contained in 40 CFR §403.13.
Section 306 of the WQA codified (into section 301(n) of the Clean Water
Act), and in sate cases changed, EPA’s existing FDF decision making
criteria and procedures. For indirect dischargers, FDF variances are
available fran pretreatment standards for existing sources for conven-
tional, nonconventiorial, and toxic pollutants. The statute established,
among other requiren nts; (1) four statutory criteria ( 301(n)(l)),
(2) time limits for applications within 180 days after the standard is
established or revised ( 3Ol(n)(2)), and (3) time limits on decision
making within 180 days after submittal of a variance request ( 3O1(n)(3))
Legislative history indicates these provisions are se1f-iit 1ementing
and should be used instead of existing regulations, to the extent the
provisions are inconsistent with existing regulations. EPA intends to
propose changes to the General Pretreatment Regulations to make them
consistent with the new provisions of the Clean Water Act. For further
information, contact Gary Hudiburgh at (202) 475—9531.

PE7IOVALJ On pri1 30, 1986, the United States Court of Appeals for the Third
CREDITS Circuit upheld the Natural Resources Defense Council’s challenge to
REGULATIC4 T EPA’s rerroval credit regulation (see Bulletin No. 2). The effect
UPDATE of the Third Circuit ruling was to invalidate several provisions of
1984 renoval credits art ndments, thus leaving in effect the 1981
versions of those provisions. The current status of the renoval
credits regulation is:
1) portions of the 1984 amendmants not invalidated by the Third
Circuit remain in effect, and
2) the 1981 versions of the invalidated regulatory provisions are
in effect.
Since the 1986 published version of 40 CFR §403.7 did not accurately
reflect the current status of the renoval credits regulation in wake
of the Third Circuit’s decision, on November 5, 1987, EPA published a
revised version of the rule (52 FR 42434).
Announcing the status of this rule does not in itself entitle EPA to
authorization of rerroval credits. EPA rrn.ist still ca ly with the
Third Circuit’s ruling requiring a rrcre comprehensive set of sludge
regulations under section 405 of the Act as a precondition for
granting renoval credits. EPA is working to comply with that ruling
and will be proposing an extensive set of sludge guidelines under
the authority of Section 405(d) (see article on page 2 of this bulletin).
Until the sludge regulations are prorra.ilgated, rio PCYIW can be authorized
to grant raroval credits. On September 1, 1987, previously existing
renoval credits becanE invalid, and industrial users (lUs) were required
to achieve ccii 1iance with categorical pretreatnent standards without
renoval credits. Control Authorities (CA’s) should reissue IU permits
or ncxlify control rrechanisms to incor rate a coripliance schedule.
Alternatively, the CA may issue an administrative order or similar nech—
anism that contains an appr riate schedule. Whatever vehicle is used,
the schedule should be set by the CA specifying the earliest possible
date by which the Iii can feasibly attain ccxrpliance. EPA will be
issuing rerroval credits enforcenEnt guidance shortly.
IMPLEMENTATI Since the publication of the last pretreatnent bulletin in March
OF W TICtIAL of this year, final dates for carpliance with categorical pretreat-
CATEGORICPIL ment standards have passed for the follcming industry categories:
STANDARDS ° Nonferrous Metals Manufacturing- Phase I (Subparts A-M) 6/7/87
o Battery Manufacturing 6/7/87
In addition, the final date for compliance with the Electrical and
Electronic Ccmponents (Phase II) standards for the Cathode Ray Thbe
and Luminescent Materials Subcategories was 7/14/86. The 90-day
Compliance Reports for these subcategories were due on 10/12/86.
Please note, Pretreatn nt Bulletin No. 2 (page 6) incorrectly stated
these milestone dates as occurring in 1987, rather than 1986.
(continued on next page)

IMPLE 1 TATION EPA continues to prepare guidance manuals for impleinentating
OF NATIONTL categorical standards for specific industry categories. These
CATEX3OPJCAL manuals are designed for use by Control Authorities and industrial
PRFrREPTMENI’ users. The gui dance manual for the Battery Manufacturing category
STANDT tRDS was issued in August 1987 (see document request sheet on page 13 of
(con’t) this bulletin to receive a copy). Guidance or the Nonferrous Metals,
Ccpper, and Aluminum Forming industry categories, to be covered in
one manual, is expected out later this year (see document request
sheet on page 13 of this bulletin to receive this publication when
it is available).
CPITD3ORICAL Pretreatment Standards for the Organic Chemicals, Plastics, and
STANDARDS Synthetic Fthers industry were published in the Federal Register on
UPDATE ‘Tovernber 5, 1987 (52 FR 42522). These standards cover the following
subcategories: rayon fibers, other fibers, thern plastic resins,
thermosetting resins, coimi dity organic chemicals, bulk organic
chenti cals, and specialty organic chemicals.
Certain key dates should be noted, as follows:
o Baseline nitoring Reports are due on June 20, 1988.
o Conpliance must be achieved by November 5, 1990.
• 90-day cou liance reports are due on February 5, 1991.
EPA is also assessing the need for additional dategorical standards
for the following industries:
o hazardous waste treaters
o solvent reclaimers
o barrel reclaimers
o waste oil reclaimers
o equipment manufacturers and rebuilders
° paint manufacturers
0 transportation
0 industrial laundries
° hospitals
o textiles
O tizr ber
0 pharmaceutiCals
By the end of 1987, decision documents, which include a rationale for
whether the Agency will continue further work to establish categorical
standards, will be published for hazardous waste treaters, solvent
reclaimers and pharmaceuticals. Data for the remaining industries
will be available in summary form at the same time.
Categorical standards for the Pesticides Industry are scheduled to
be issued in 1992.

For some industries, EPA issued standards that simply refer to the
General Pretreatment Regulations. There has been confusion and
inconsistencies in identifying whether such industrial users (lUs)
are categorical. In the Textile category, for example, PSES requires
that lUs “rtust cc ply with 40 CFR Part 403”. Such lUs, which have
no categorical limits beyond the General Pretreatment Regulations,
are not considered categorical lUs.
H iever, for Pharmaceutical Manufacturing, PSES applies to facilities
“where cyanide is used or generated”, but requires a certificati.on
if cyanide is not used or generated. Pharmaceutical facilities (and
in a similar manner Pulp, Paper, and Paperboard facilities) are
considered categorical even if the requirement is simply a certif-
ication. Such certifications ra st be su1 itted as part of semi-annual
Noncategorical lUs are still subject to the General Pretreatment
Regulations, local limits, and may still be considered significant
lU’s which warrant ircriitoring and reporting.
The Pretreatment Implementation Review Task Force (PIRr), while recog-
nizing that, at a minJ nim, research and development (R&D) facilities
are covered by national prohibitive standards, local prohibitive
standards, and local limits, reca mended EPA issue guidance as to
whether these facilities are regulated by categorical pretreatment
standards. To respond to the PIR recni rendation and to correct pre—
vicxisly conflicting interpretations provided to EPA Regions, the Office
of Water and the Office of General Counsel recently completed a thorough
review of the applicability of categorical pretreatment standards to
stand alone R&D facilities.
Based on the records supporting the categorical pretreatiTerit
standards, EPA has determined that stand alone R&D facilities are
not subject to the categorical standards currently pranulgated.
For a plant to be considered a stand alone R&D facility, there
should be no ccmTercial sale of products made at the facility. This
position is stated in a letter from Ms. Rebecca W. Uanmsr, Deputy
Assistant A fliinjstrator for Water, June 26, 1987.
EPA reserves the right to issue specific categorical standards
which are applicable to stand alone R&D facilities -- hc iever, such
activity is not currently underway. The lack of currently appli-
cable categorical standards does not mean that pollution controls
are not necessary. Noncategorical indirect dischargers are still
required to caply with the General Pretreatment Standards (General
and Specific Prohibitions) and with limits that may be established
by local or State authorities. When local or State authorities
address needed pollution controls for noncategorical industrial
users, EPA does consider the categorical standards and the accom-
panying development documents as excellent guidance on the performance
of pollution control technologies. HcMever, other site-specific
factors may be considered in setting limits (potential for inter-
ference or pass through, raw waste load, age, size, land availability,
flcw, non—water quality impacts, energy, and costs).

P ME In July 1986, the Office of Water Enforcement and Permits issued the
TRAINING “Pretreatment Compliance Monitoring and Enforcement Guidance” manual
MATERIALS (see document request sheet on page 13 of this bulletin to receive a
copy). This document offers assistance and guidance to Control Auth-
orities in implementing their pretreatment programa by providing:
o A definition of Significant Industrial Users (SIUs)
o Recoin nded industrial user nonitoring frequencies
o Guidance on semi—annual reports by industrial users
o A definition of Significant Noncompliance (SNC) for industrial users
o A description of EPA’s “Enforcement Management System” as a guide
for Control Authorities
o A Pretreatment Performance Surrmary, that EPA reconvnends Approval
Authorities make part of annual report requirements.
To promote the use of definitions and procedures within the guidance,
EPA has developed the Pretreatment Compliance Monitoring and Enforce-
ment Training Course Instructor’s Manual . The training materials are
intended for use by EPA and States when conducting pretreatment com-
pliance monitoring and enforcement training workshops for Control
Each EPA Regional office. will receive a complete copy of the training
manual with slides. This manual should be reviewed by EPA Regions and
States planning to conduct a pretreatment seminar during the next 12
months. Regions and States are encouraged to give presentations using
in—house personnel. Hcygever, EPA headquarters is willing to provide
speakers for any of the subject areas. Three pilot training workshops
have been held in Pittsburgh, PA; Richmond, VA; and Baltimore, MD.
Control Authorities should contact their State or EPA Regional office
regarding availability/scheduling of training workshops in your area.
PCME To aid U1’Ws and States in implementing the Pretreatment Program, and
SOFIWARE in particular the Agency’s guidance on Pretreatment Compliance Monitor-
ing and Enforcement (PCME), EPA is developing F(ME computer software
for IBM® (and compatible) personal computers. The software (with
accompanying user’s manual) currently performe these basic functions:
1) Serves as a computerized mechanism for storing general infor-
mation (name, address, outfall and IU code), effluent limits,
and monitoring data on industrial users.
2) Identifies instances of noncompliance and evaluates whether
industrial users are in significant noncompliance (based on the
definition in the guidance document).
3) Prepares summery reports on industrial users, monitoring data,
and compliance status.
(continued on next page)

PCIE EPA is nc i expanding the capabilities of the software to track all
SOFIWARE the it s listed in the PC 1E ‘S Pretreatment Performance SulTrnary,
(con’t) including: 1) sulziiission or reports: 2)inspections and sairq ling
events and 3) enforcement actions. The software should be available
in early 1988 in lxth a dBase III Plus® version (for those that
have this package and may wish to n dify the program) and a ccxpiled
version (which can be run without dBase III Plus® software). Copies
may be obtained, when available, by using the document request form
in the back of this bulletin.
PRF RENTMENT EPA has developed an autarated national pretreatment data tracking
PER’IITS AND system known as the Pretreatment Permits and Enforcement Tracking
E F0 iEI 7 System (Ppcrs). This system became operational in C tober 1987 and
TRACKING will provide EPA Regions and States with a valuable tool for oversight
SYSTEM of pretreatment program implementation by FOIWs. PPETS will be a
subpart of the Permit Cc* 1iance System (PCs), the existing mainframe
cariputer national database which tracks the car 1iance status of
direct discharging facilities. PPE S will consist of data obtained
by Regions and States fran POIWs by means of pretreatment audits,
pretreatment cciiipliance inspections, annual reports (including pre-
treatment performance surmaries), and other carpliance reports.
GUID .NCE FOR The Office of Water Enforcement and Permits has developed guidance for
EMALUATING AND EPA Regions and States to evaluate and report noncompliance by PCIIWs
REPORTING P(YIW that have failed to inpiement their approved pretreatment programs
NONC 4PLIANCE (a copy of the guidance will be mailed shortly to all EO1 , State,
and Regional pretreatment personnel). The criteria specified in
the guidance were developed by an EPA rkqroup and presented to
the States and EPA Regions at the National Pretreatment Coordinators
Meeting in December 1986. Draft guidance was developed and circulated
to the Regions, States and former Pretreatment Lrpleirentation
Task Force merr bers for carment in May 1987.
The guidance identifies criteria for evaluating the principal P0 1W
activities that are essential to fully iiiipl nt irost local programs.
If one or rtore of the following lettered irplemehtation criteria are
not met, PONs should be reported by EPA and approved States on the
o.iarterly Nonca liance Report (QNCR) for violations of their approved
pretreatment programs:
Issuance of industrial user (lu) control mechanisms
a) failed to issue, reissue, or ratify IU permits, contracts, or
other control mechanisms, where required, for “significant
IUs’ (SIUs) within six nonths after program approval. There-
after, each SIU control mechanism permit should be reissued
within 90 days after the date required in the approved program,
NPDES permit, or enforcement order*.
(continued on next page)

GUIDAN FOR P01W cczi pliance n riitoring and inspections
AND REPORI’ING b) failed to conduct at least eighty percent of the inspections
P 0 1W and sarrplings of SIUs required by the NPDES permit, the approved
NONCCMPLIANCE program, or enforcement order*.
c) failed to establish and enforce self—n nitcrthg requirements
that are necessary to assess SIUs canpliance as required by the
approved program, the NPDES permit, or enforcement order*.
P01W enforcement
d) failed to irr lement pretreatment standards (including categorical
standards and local limits) in an effective and timely menner
or as required by the approved program, the NPDES permit, or
enforcement order*.
e) failed to undertake effective enforcaient against the lU(s) for
instances of pass through or interference as defined in 40 CFR
*403.3 and required by §403.5.
P01W reporting to the Approval Authority
f) failed to su1 it a pretreatment report (e .g., annual report or
publication of the names of significant violators) to the
Apptoval Authority within thirty days of the due date specified
in the permit, enforcement order, or approved program.
Other P01W ii lementation violations
g) failed to ccz lete a pretreatment iirplerentation catpliance
schedule milestone within 90 days of the due date specified in
the permit, enforcement order*, or approved program.
h) any other violation or group of violations of local program
in 1ementation requirements based on the permit, approved
program or 40 CFR Part 403 which the State Director or EPA
Regional Administrator considers to be of substantial concern.
These criteria will be applied to violations of specific requir tents
in an NPDES permit, the approved program, or enforcement order*.
In sate cases, approved States and Regions may need to nodify the
approved local program and/or NPDES permit because the existing
requirements are inadequate or because conditions have changed. There-
fore, PCJIWs that lack specific program requirements for these inpie—
itentation activities may receive permit trodifications. In general,
PCYIWs that meet the definition of reportable nonccxnpliance should
be priorities for resolving the inadequacies in approved programs
or permits. EPA plans to incorporate specific criteria into the
NPDES Regulations for noncaipliance reporting of PO’IWs which fail
to adequately implement their pretreatment programs.
* the term enforcement order means an administrative canpliance
order, judicial order, or consent decree. (see 40 FR §123.45)

GUID .NCE FOR PCYIWs that accept hazardous wastes by truck, rail, or dedicated pipe
POfl within the boundary of the plant may be hazardous waste treatment,
RECEIVING storage, and disposal facilities (TSDFs) -and, if so, are subject to
HA2ARIX)US regulation under the Resource Conservation and Recovery Act (RCRA).
WASTE EPA has developed the Guidance Manual for the Identification of
Hazardous Wastes Delivered to Publicly O ned Treatment rks by Truck,
Rail, or Dedicated Pipe to offer adininstrative and technical recommend-
ations to PO’IWs seeking to preclude the receipt of hazardous wastes by
these transportation methods, and to discuss the responsibilities of
P(YIWs choosing to accept hazardous wastes by these transportation
methods. A copy of this manual was mailed to all pretreatment roIws
in late September/early October 1987.
In accomplishing the dual purposes mentioned above, the manual
provides the statutory and regulatory definitions of hazardous
wastes. It also describes the RCRA regulatory status of wastes that
P01W operators typically may encounter. The manual provides some
guideposts which will assist the operator in making these deter-
The manual also discusses the legal, administrative, and technical
methods to preclude the receipt of hazardous wastes, many of which are
already in use. A description of potential liabilities that POTWs
may incur as a result of accepting hazardous wastes is also provided.
The manual describes the responsibilities of POIWs that choose to
accept hazardous wastes by truck, rail, or dedicated pipeline, ex-
plaining the special regulatory provisions, kncwn as permit by rule
requirements, that the RCRA program imposes upon PO’IWs accepting
hazardous wastes by the aforementioned methods.
GUID .NCE FOR EPA is preparing the Guidance Manual for the Development of Industrial
DEVELOPING Pretreatment Permits to provide training in the development of waste—
INDUSTRIAL water discharge permits to Control Authorities required to implement
PRETREAThIENT a local pretreatment program. It is designed for new permit writers,
PERMITS but may also serve as a refresher for experienced permit writers.
The manual ass nes the Control Authority has selected to regulate its
industrial users (lUs) by means of a wastewater discharge permit system.
It focuses on elements of the permit process which are comron to any
Control Authority using this procedure, with particular emphasis on
the mare difficult steps. The guidance addresses establishment of a
permitting strategy, IU information collection and verification, draf t—
ing permit language (including determining discharge limits, n nitoring,
and reporting requirements).
The guidance manual will be mailed directly to all pretreatment PCYIWs,
States, and EPA Regions in the late 1987. Control Authorities should
not delay issuance of IU permits while this guidance is being developed .

P01W SLuG EPA is preparing a guidance manual to assist PCIIWs in controlling
DISC iA1 3E industrial user (iu) slug discharges, including both accidental
CONT L spills and intentional batch discharges. The guidance will draw
GUIDANCE upon and update current P01W control practices and guidance issued
by EPA on control of industrial discharges, and will assist in
iu 1ementation of pretreatment regulations currently being developed
in response to the Domestic Sewage Study (DSS).
The DSS documented discharges of large quantities of toxic pollutants
and hazardous constituents, sai portion of which are received at
PCT1 s as a result of slug discharges by lUs. In addition, a recent
survey undertaken by the Association of Metropolitan Sewerage
Agencies (AMSA ) indicated that nearly every respondent has received
hazardous wastes at its treatrrent plants. The rt st camon source
cited was spills into sewage systems. Sixty—six percent of AMSA
survey respondents have spill response plans, and 82% have prevention
and control plans. Given the large quantities of toxics and hazard-
ous constituents received at PCYIWs, it is apparent that not all of
these plans are effective and that improvement of the plans and
their inpiementation is warranted.
The manual will cover methods for improved control of batch discharges
via pretreatment permits and sewer use ordinances, as well as spill
control plans and measures for IU spill prevention and P01W spill
response. Protecting against such slug discharges will help prevent
IW interference and pass through including plant upsets or damage,
danger to rker safety or public health, irrpairment of water quality,
sludge contamination, or NPDES permit violations.
The anticipated final issuance date for the manual is Spring 1988.
The manual will be distributed to all pretreatnent POIWs, State, and
EPA Regional personnel, and will be available to other interested
PGNs arid lUs, as well.
RADIOACTIVE Sarc POIWs may be receiving radioactive waste frau industrial users
MATERIP L utilizing sanitary sewers for disposal. In addition to being reg-
DISPOSAL TO ulated try the general and specific prohibitions in the General Pre-
SANITA ( treatment Regulations, those entities using such materials are
Sfl ERS regulated by the Nuclear Regulatory Ca’rimission (NRC) and, very
likely, many States. NRC and States issue licenses and establish
disposal alternatives arid requirements. 10 CFR Part 20, ‘Standards
for Protection Against Radiation”, Section 20.303 establishes the
Federal requir i nt that no licensee shall discharge licensed
material into a sanitary sewerage system unless certain conditions
are met.
PCIIWs which receive radioactive waste fran licensees may wish to
consider periodic review and confirmation of self-nonitoring logs
kept by the users, and perform analysis of sludge and calpDst to
determine if there are any impacts. If impacts are detected,
tOrIWs may choose to develop radiological nonitoring program to
address the problem. -

EPA REGION IL/ The foll dng is a list of EPA Regional and Headquarters pretreatir nt
HEPJJQUARrEPS personnel. If, after first contacting the appropriate State pretreat-
PRE REAThENT ment office, PCflWs need further asistance with program developrent or
PERSONNEL in l ntation questions or probl s, please contact the EPA Regional
office responsible for your State. Should the need of assistance
persist, please contact the appropriate individual listed belo.q:
irrs cttn’ .cr irpcr
Joan Serra Lee Bo Wren Stenqer
EPA Region I EPA Region VI 6W-ED
JFK Federal Bldg. Allied Bank T r (6W—PM) (214) 655—6470
S B —2l09 1445 I ss Avenue
Boston, MA 02203 DeLlag, TX 75202
(617) 565—3490 (214) 655—7175
.ith ?de].nun Pat wrack Lee Devall sane
EPA Region II (212) 264—9826 EPA Region VII
26 Federal PLaza 726 Minnesota Avenue
New York, NY 10278 Fa.nsas City, KS 66101
(212) 264—2911 (919) 236—2817
C ar1ene Harrison Jdtn L ve1l Marshall Flsdter
EPA Region III (215) 597—6279 EPA Region vi i i
841 O estnut Street Cite Denver Place
3 152 999 18th Street
Philadelphia, PA 19107 Denver, aD 80202
(215) 597—9406 (303) 293—1592
Al Iierr at sane Keith Silva sane
EPA Region IV EPA Region IX
345 ( urtiaxxi Street, 215 Fr ront Street (W-5—1)
Atlanta, GA 30365 San Francisco, 94105
(404) 881—2211 (415) 974—8298
Dive Renkin sane Ribert bicJ,aed sane
EPA Region V EPA Region X
230 S th Dearbern Street Pezmits 8ran ± CM/S 521)
CDücago, U. 60604 1200 6th Avenue
(312) 353—Gill Seattle, 99101
(206) 442—1448
HEArC UARrE — all written requests shc*iid be addressed to:
Pertnits Division ( 4—336) or Enforc ient Division (E -338)
401 M Street, q —
% &u.ngta1, 20460
Pez its E force rent
Ed Ovserujc (202) 475-9529 Ricthard Kindt (202) 475—8319
aig Jacubo .iics (202) 475—9516 Edward Bender (202) 475—8331
Denise Scott (202) 475—9521 Salahiin Pbdul—Haqq (202) 382—4373
thuck Prorok (202) 475—7053 Andy H iock (202) 382—7745
George Utting (202) 475—7460 Divid S edroff (202) 475—8329

NATION L The EPA is considering holding a National Pretreatment Meeting in
MEETING the second half of l9 3 to include participation by P01W, State,
and EPA representatives. Such a neeting would last two to three
days, would address a broad range of pretreatment inp1 ntation,
cat liance, and enforcement topics, and would allow for substantial
participation by State and P01W representatives. EPA solicits
your ccm ents regarding the timing, location, format, and content
(including specific topics to be addressed) of such a meeting.
Please send your cai nts, and indicate your level of interest in
participating in such a meeting, by Dec er 15, 1987 to:
Thaitas Laverty, Cnief
Program Section
Permits Division/OWEP (EN—336)
401 M Street, SW
Washington, CC 20460

The docun nts listed on this
basis frcm EPA. To obtain a
please provide your nazie and
and return the information to:
request form are available on a limited
copy of any of the follc iing docunents,
address, check the requested docun nt Cs),
Cluck Pror
U.S. Environnental Protection Agency
401 M Street, SW (E —336)
shinqton, DC 20460
Pretreatirent. Bulletin No. 1 (Septather 30,
Pretreatt r t Bulletin No. 2 (Mar 6, 1987)
FiGuidance Manual for Electrcplatjng and Matal Finishing Pretreatment Standards
Guidance Manual for Iron and Steel Manufacturing Pretreatment Standards
Guidance Manual for Battery Manufacturing Pretreatment Standards
Guidance Manual for Nonferrons Metals, O.çç er, and A1txnintm Fbrrniog Pretreatment
Standards (piblication atheduled for late 1987)
* ( ) Guidance Manual for Inpl enting Total Toxic Organic (Tro) Pretreatiient Standards
* C ) Guidance Manual for the. Use of Production-Based Pretreatment Standards and the
thined Wastestream Fornula
* ( ) Metorand .nn: Local Limits Reguirai nts for P0Th ’ Pretreatment Programs (August 5,
* ( ) Guidance Manual on the Develqi ent of Local Distharge Limitations Under the
General Pretrea ent Regulations ( *thlication sd’ eduled for late 1987)
The National Pretreatment Program ( wiro ntai Regulations and Te&nology
doc .uient EPA/625/lO—86/oo5, 3Uly 1986)
* ( ) Guidance Manual for the Develcpt nt of Industrial User Permits (p.iblication
scheduled for late 1987)
* ( ) Guidance Manual for Preventing Interference at Y1S s
Pretreatment O pliance iitoring and Enfor Tent Guidance (PCIE)
* ( ) Guidance for Evaluating and Reporting iW Noncatpliance
RA Infornatjon on Hazardous Wastes for POIWs
Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly
O.Qned Treatment Works by Trudc, Rail, or Dedicated Pipe
PQ Software and User’ s Manual (delivery sdteduled for early 1988)
PR IM and User’s Manual (EPA ’s Tputer nodel for calculating local limits)
- fl c’ ,r.,rn ,. —- --
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