United States Environmental          Office of Water
                 Protection Agency                    Enforcement and Permits
                Office of Water                      Washington,  DC   20460
                               PRETREATMENT   BULLETIN

                Date; July 1, 1988	\	NO. 4	

                Pretreatment Bulletins,  this being the fourth to date, 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, implementation, and enforcement of local
                pretreatment programs.

                                         REGULATORY UPDATE

SLUDGE          The 1987 amendments to the Clean Water Act (CWA) require that permits
REGULATIONS     issued to treatment works contain sludge standards.  EPA expects to
                propose technical standards for pollutants of concern in sludge in the
                Fall of 1988, at 40 CFR Part 503.

                On March 9,  1988, EPA proposed regulations for incorporating sludge
                standards into NPDES permits and for developing approvable State
                sludge permitting programs (53 FR 7642).  These regulations are
                scheduled to be promulgated in the Spring of 1989.

                The 1987 CWA amendments also state that, prior to development of the
                Part 503 technical standards, the Administrator must put sludge
                conditions in permits issued to POTWs or take other appropriate action
                to protect public health and the environment.  To implement this
                requirement,  EPA has developed a "Strategy for Interim Implementation
                of Sludge Requirements in Permits Issued to POTWs".  Notice of
                availability of this document for public comment was published in the
                Federal Register on May 31, 1988 (53 FR 19817).  The comment period
                closes August 1, 1988.

                In addition,  EPA has prepared a second draft of guidance to permit
                writers on developing interim, "best professional judgment" permit
                conditions for sludge entitled "Guidance for Writing Case-by-Case
                Requirements for Municipal Sludge".  Anyone interested in obtaining a
                copy should contact Tom Wall at (202) 475-9515.


FDF VARIANCES The fundamentally different factors (FDF) variance provides for relief
FOR INDIREL’r fran the application of a nationally-applicable categorical pretreatment
DISCHPJ ERS standard as it applies to an existing industrial user if the facility
is fundamentally different from what EPA considered in establishing the
standard. FDF variances are available from pretreatment standards for
existing sources (PSES) for conventional, nonconventional, and toxic
pollutants. Alternative limitations are established to the extent of
the fundamental difference. EPA is aware of 53 FDF variance requests
fran indirect dischargers other than Organic Chemicals facilities; of
these requests, there have been no approvals, 45 denials or withdrawals,
and there are 8 pending requests.
The substantive and procedural criteria for evaluation of FDF variance
requests f ran indirect dischargers are contained in section 301(n) of
the Clean Water PkCt and, to the extent the regulations are not
inconsistent with the statute, in 40 CFR §403.13. The Regional
drninistrator has been delegated the decision raking authority in EPA
for FDF variances, subject to the concurrence of the Director, Office
of ter Enforceient and Permits for those requests determined to be
nationally significant.
The effluent guidelines and categorical pretreatment standards for the
organic chemicals, plastics and synthetic fibers (OCPSF) industrial
category re issued on Novei er 5, 1987. FDF variance requests for
OCPSF facilities n .ist have been submitted no later than May 3, 1988
(180 days from date of publication in the Federal Register ) or within
30 days after issuance of a categorical, determination (if that ..iould
result in a later deadline). EPA Regions should submit each OCPSF FDF
variance request to the Permits Division at EPA Headquarters for a
determination of national significance upon receipt of the request.
EPA is aware of 17 individual F’DF variance requests fran indirect
dischargers covered by the CXPSF standards. EPA has also received two
generic organic chemicals FDF variance requests sutinitted by PCIIWs
which cover 33 industrial users, including six industrial users who
also sutinittecl individual requests. For further information on FDF
variance requests, contact Gary Hudiburgh at (202) 475-9531.
PRE-1977 During the National Pretreatment Coordinators Meeting in Philadelphia,
CATEGORICAL PA in January 1988, concern was raised by a representative of one of
PR FREAThENT the States in attendance regarding the status of pre—1977 pretreatment
STANDARDS standards; These regulations (including Rubber Manufacturing, Asbestos,
etc.) contain requirements that: (1) reference 40 CFR Part 403 and/or
Part 128; (2) require zero discharge; (3) regulate conventional,
nonconventional, and toxic pollutants; or (4) state “no limitation”.
EPA is assessing all of these categories and will be issuing a n r —
randum on which, if any, standards EPA intends to revoke or rrcxUfy, and
what action is needed to guide lUs to achieve compliance with these
regulatory requirements. EPA intends to provide you with a detailed
up5ate on this activity by August 1988. For further information on
pre—1977 categorical pretreatment standards, contact Lee Okster at
(202) 475—9511.

0 March 21, 1988, EPA ax ended the Leather Tanning and Finishing
categorical pretreatrr nt standards (53 FR 9176). The air ndrrents
consisted of t’ changes to the pretreatxrent standards for existing
sources (PSES):
1) for Subpart C- Hair Save or Pulp 1 Non-Chrare Tan, Retan-Wet
Finish Subcategory, the pH limit was changed fran “7.0 to 10.0”
to “Not less than 7.0’.
2) the small tannery ex itption for chrciiuum in subparts:
A- Hair Pulp, thrare Tan, Petan-Wet Finish
C- Hair Save or Pulp, Non-thrare Tan, Retan-Wet Finish
I- Retan-Wet Finish- Splits
previaisly referenced a specified number of hides/splits per day,
a weight of hides/splits per year, as well as the number of rking
days per year underlying the specified hide and split exemption
criteria. EPA has no i deleted all reference to the annual weight
basis and number of &rking days per year —— the exemption is n
strictly based on the number of hides/splits per day.
EPA has taken several steps to insure the implerrentation of the OCPSF
categorical pretreat rent standard. EPA Regions were provided with a
listing of the 393 knci n OCPSF industrial users, the industrLal users
were provided with a copy of the regulations and a brief surm ry of
their requirements under the General Pretreatmant Regulations, and
instructed to contact their Control Authority. Please use the docurrent
request sheet at the bad of this bulletin if you need, but did r t
receive , a copy of the materials sent to the OCPSF industrial users.
Of mnrethate importance for Control Authorities is insuring that
Baseline Monitoring Reports for the OCPSF industry were submitted by
June 20, 1988. In addition, if you are addressing a relatively n
facility, you should be aware that an OCPSF industrial user is subject
to Pretreatnent Standards for Ne Sources if construction cormenced
after March 21, 1983. (Note, ne sources irust carply upon carrrencerrent
of discharge. ) As stated in the General Pretreatxrent Regulations, the
ne . i source definition is based on the proposal date of the categorical
pretreatrrent standard. For further information on the above referenced
materials, contact Karen Gray at (202) 382—4373.
Several categorical standards provide allo iances for pollutants in
isolated wastestreams:
Categorical Standard Pollutant(s )
For ccrLpliance ncnitoring, such wastestreams must be isolated and
rronitored separately. Alternatively, if they ccxrrbine with other waste—
streams (prior to rrcni.toring) these limits must be adjusted. For combined
wastestreams, the categorical a1bor iance is adjusted by multiplying the
categorical limit tines the category “isolated pollutant” bearing waste—
stream floe rate divided by the category flaw rate. After this adjustrrerrt,
the combined wastestreain formula or flo r weighted average (as appropriate)
can be used to address the category wastestream mixing with other regulated
unregulated, and dilution wastestreams. Where rn ss per day alloArances
are desired, concentrations are multiplied by the appropriate flog rate.
- Organic Chemicals, Plastics and
Synthetic Fibers
— Metal Finishing
- Pharmaceuticals Manufacturing
- Cyanide and Metals (Lead
and Zinc)
- Cyanide (or Cyanide A)
- Cyanide

- (4)
PRE FRE ThENT Under a grant frcn EPA’s Office of Water Enforc nt and Permits, the
FACILITY California State University, Sacranlento, School of Engineering, in
INSPEL’rIC cocperation with the Industrial and Hazardous Waste Car,nittee of the
FIELD-STUDY California Water Pollution Control Association, has deve1cç ed the
TRAINING Pretreat nt Facility Inspection Field-Study Training Program . This
P DGRZ M self—study training course allo. s the individual to progress at his or
her n pace and to study the material when and where they prefer.
Co uter answer sheets are sent to the University for grading and
remarks. The training program may also be used in the classroczn, and
for in—house or on—the—job training. Nine Continuing F ucation Units
and six University Serr ster Credits may be earned. The suppDrt staff
at the University is available to answer any questions regarding this
program. The course outline follo s:
Cows. OvtiIn
Pi ici , S Kwok, Depanins,u of WIW
Pofkjbon Conuol, City of San Joss
Eddis Estin , Sanitibon Dlstncts of LA County
Oil Garrrt. Sanitation OlaIncti of LA County
K b Sthott. Union Sanitary Dtsvict
Frsmoni, California
S tt Austin, Sanitation DisOicti of LA County
Phd Uarlyn, Lory E. RIslç. and Rotisti N Wionki
Indusv j Wuta Ssctlon
Sanitation OlsO,cts of LA County
Richard von 1ani j.n arid MaIw Talsbf
IndutVilJ Wait. Pvogrsrn
O . County Sanftadon OfsV ti
Douglas K. Ostitsad. MicItasi C La.. and
Rch&ti 0. W aon, n jsviaI Ssrvtc.s Grct .
Sdy/Jcnks/Citaton, I
0 1$ Qirro . Sanitation Dlstitti of LA County
Oft Gstrsti. Sardtat ion Olaatct, of LA Co.,t y
Jay krstnmr, b j th& Wait. S.cdcn
SaiUIati . Otasicts of LA County
A E U F Ezam
How ti SoNs Pvsfre nt Qot1jon
kta w
p .chon Wont. ( os.
The cxiirse will be available beginning July 1, 1988. Estimated
cost. for the manual is $30, plus an additional $30 to enroll in the
self—study course. Information regarding enrol].nent, cost, etc. may
be obtained by writing or phoning:
[ Yr. Kenneth Kern
Office of Water Prograns
California State University, Sacransnto
6000 J Street
Sacranento, California 95819—2694
(916) 278—6142

POIE TRAINING In January 1988, a copy of the Pretreatn nt CczTpliance Monitorir j
MATERIP LS AND and forc rent Training Course Instructor S Manual (PCME) was sent
flRKSHOPS to each EPA Regional Office. The training course features four major
topic areas or nodules, each of which stands alone:
- Overview of Significant Concepts of the 1 4E
- Ca liance Monitoring and Inspection Training
- Reporting Procedures
- Enforc nt Strategies
A workshop covering all four nodules can norir lly be conducted in
one thy. If all of the practical exercises accc panying the material
are utilized, a day and one—half is required. PO’IWs are encouraged
to contact their State or EPA Region if interested in P0€ training.
LOCAL LIMITS In April 1988, EPA began sponsoring workshops on the developiient and
ORKSHOPS irrplezrentation of local, discharge limitations under the pretreatmant
program. The one day workshops address:
- collection of data for local limits develo ent
- develo rent of maximum allo. iable headworks loath ngs
- allocation of rraximumn allowable headworks loadings
- local limits developrrent to address ol1ection system concerns
— application of local limits
PO1:Ws are encouraged to contact their State or EPA Region if interested
in local limits develoç nt and inplen ntation training.
GUIDANCE FOR In Pretreatn nt. Bulletin No. 3 (Nov nber 6, 1987), EPA indicated the
DEVELOPING Guidance Manual for Developing Industrial User Permits was scheduled
1N1)JSTRIAL Eor publication in late 1987. This guidance manual is currently
USER PERMITS scheduled for publication in the Fall of 1988, and will be sent to
all pretreatmant POIWs and States directly when available. In
addition, those individuals who requested copies of the guidance by
returning the docuirent request sheet in the back of Bulletin NO. 3
will be sent their copy when available.
SUPERFUND If you manage a PCYIW and you receive a request to accept waste from
WASTE AND a Superfund site, hci do you decide whether to accept the waste ?
PCY IWS What factors should you consider when you receive such a request ?
This article provides the P01W operator with saie general principles
to consider when deciding whether to accept Superfund waste.
waste received by the P01W must satisfy all Federal, State, and
local pretreatn nt requiremants. These pretreatr nt regu1r ents
apply to Superfund waste regardless of origin of the waste, regardless
of the contents of the waste, and regardless of the mathod for
receiving the waste. Therefore, a waste that is not treated as it
passes through the P01W and causes a violation of the PO’IWs NPDES
permit would vLolate the prohibition on pass through at 40 CFR 403.5.
Similarly, waste that. interferes with the treatn nt process at the P01W
causing a violation of the PGP?Js NPDES permit would violate the
prthibition on interference at 40 CFR 403.5.
(continued on next page)

SUPERFUND Tb determine whether a Superfund waste could cause violations of your
WASTE AND NPDES permit, you nn.ist kno. what pollutants are in the waste and the
Poiws (con’t) fate of the pollutants in the treatn nt process. A P(Yfl J should evaluate
the potential affects of a Superfund waste on the quality of sludge
generated at the P01W. The Superfund waste could foreclose a P0’IWs
options for marketing or disposing of its sludge. FurtheriTore, the
Superfund waste may cause the sludge to maet the definition of a
hazardous waste under RCRA. If the sludge is hazardous, then the
P01W would be required to find a qualified I RA facility to treat,
store, or dispose of the PO’IWs sludge. If the Superfund waste is also
a hazardous waste, and is delivered to the P01W by truck, rail, or
dedicated pipe, then the P01W rru.ist obtain a RCRA permit-by-rule. Waste
fran a Superfund site is not necessarily a hazardous waste. Only if the
waste rreets the definition of hazardous waste at 40 CFR 261.3 is the
waste hazardous. (If the waste is received via the sewer system, then
the da stic sewage exemption applies to the waste and the requirerrents
of PA do not apply, but pretreatnent. requirerrents do apply to waste
received via the sewer system.) A permit-by—rule is a streamlined RCRA
permit. but includes corrective action, a potentially costly and tirre—
consuming requirenent.
The decision whether to accept waste fran a Superfund site must be made
on a case—by-case basis. Only by knc ang the contents of the waste
and the requirenents that apply to the waste, can a P01W make a
technically sound and legally correct decision.
NEW NPDES In the past, a P01W seeking an NPDES permit to discharge wastewater fran
FORM 2a their facility would car lete a Standard Form A, a Short Form A, or the
State equivalent of these forms. The Standard Form A and the Short
Form A were originally designed in 1973. The Agency has nc begun
devekprent of NPDES application requirerrents for P0I’Ws and is revising
the Standard and Short Forms A into a new Form 2a.
The revised application form will be used by all municipal dischargers.
This form incorporates NPDES requirenents proposed under the municipal
sludge program at 40 CFR 122.21(c) (ii) and the proposed arrendnents to
irrpleirent the recczmendations under the E iestic Sewage Study at
40 CFR 122.21(i). No projected conpletion date has been defined for
the application requirezrents or the form.
Major changes to the form include the addition of new sections on
toxicity testing, and sludge managerrent and con osition. The pretreat-
trent section has been expanded to include nore information on industrial
users and local limits program evaluations. To reduce the burden on
the applicant, many questions fran the old forms have been deleted.
An effort is being made to eliminate duplication or reported and
unnecessary data. An examination of Discharge Moru.toring Reports,
Annual Reports, and other record keeping requirertents Of POThJs was
conducted to evaluate the usefulness of information contained in
these reports to the permit writer.
The forerrost Agency goal is to create application requirements and
a revised form that can be easily understood and car pleted by the
applicant while collecting sufficient information for the permit
writer to issue a technically sound and enforceable pernut. For rrore
information, contact Al ColLins at (202) 475—9517.

PP RENIMENT EPA Regions and States were required to begin entering pretreatment
PERMITS AND related data into the Pretreatment Permits and Enforcement Tracking
FO} .EME T System (PPETs) on January 4, 1988. This cci-tputerized data tracking
TRACKING system, developed as a sutpart of the Permit Ccmpliance System (FCS),
SYSTEM was created for the use of States, EPA Regions, and EPA Headquarters
as a tool to assist in the oversight of approved local pretreatment
programs. Pretreatment canpliance inspections, audits, and periodic
(annual or nore frequent) reports from control authorities (CA’s) are
the primary sources of the data in Pp rs.
PPETS will enable EPA Regions and States to nore easily: (1) track
the progress over time of individual CA’s in their efforts to
implement approved pretreatment programs; (2) allo , cc iparison
to related reportable noncarpliance (RNC) criteria for a CA’s failure
to implement its approved program; (3) identify prime CA candidates
for enforcement action; (4) identify specific program areas in which
additional guidance or resources are needed; and (5) allc better
oversight of CA’s. In addition, PP S will provide EPA Headquarters
with sunir ry statistics regarding pretreatment program irrplerrentation
based on the rtost recent information available. EPA will inform you
of these statistical suimnaries in the future.
PPETS consists of fifteen required data elements, plus another
fifty optional data elements. The PPETS required data elements
include counts of the numbers of significant industrial users (SIUs),
categorical industrial users, SIUs in significant nonccz 1iance (SNC),
and various enforc nt actions taken by CA’s against SIUs. Most of
the PPETS required data elements may be used as indicators fnich
relate directly to the specific RNC criteria against which CA’s are
evaluated for failure to impl nt. For further information on
PPETS, contact Andy Hudocic at (202) 382-7745.
S111MARI OF On January 24-26, 1988, EPA sponsored the 5th National Pretreatrr nt
ATI O NP L Coordinators Meeting. Held this year in Philadelphia, PA, the
PRETREAThIENT conference was attended by 109 individuals representing all ten EPA
MEETING FOR Regions, EPA Headquarters, 17 (of 25) delegated pretreatment States,
APP VAL and 15 non-delegated States. The 32 States in attendance met
AUTHORITIES separately for one—half day before the meeting began and presented
their vie is to the conference as part of the opening session.
Four major themes deve1c ed during the conference:
1) the need for consistent program urplementation from State to
State, and Region to Region
2) Regions, States, and Th ’Js should be kept informed with regard
to evolving issues, problems, and decisions
(continued on next page)

SIM’IARY OF 3) States and PCYIWs need n re guidance and training on the application
NATIONAL of categorical pretreatment standards, industrial user inspections,
PRErREAIME T local limits developrent. and application, industrial user permitting,
MEETING FOR and cczpliance nonitoring and enforc ient
AUTHORITIES 4) POIWs are under increasing pressure to accept RCRA, CERCLA, and
(con’t) underground storage tank wastes. Information and guidance regarding
waste characteristics, liabilities, permitting strategies, applic—
ability of local limits, etc., is needed to make decisions.
A number of potential nechanisms were discussed to address these areas,
as welL as a number of other issues raised at the conference, and EPA
will assess these reccnurendations in the caning rronths. EPA is already
involved in a number of activities that at least partially address partici-
pant concerns. First, in order to diss inate program information to all
pretreatment P(YIWs, EPA has issued and distributed four bulletins. EPA
plans to continue, and hopefully increase, this effort. Second, in the
Fall of this fiscal year, EPA will publish guidance to assist PCYIWs in
developing industrial user (IU) permits. This project has been delayed,
but the guidance will be distributed to all pretreatment PCIIWs when
available (see article on page 5 of this buLletin). Third, beginning
July 1988, the California State University, Sacramento, will be offering a
field-study training program for PO’lW and Approval Authority personnel in
conducting IU pretreatment facility inspections (see article on page 4 of
this bulletin for further information). Fourth, in April of this year,
EPA began sponsoring local limits development orkshops in a number of
States (see article on page 5 of this bulletin). EPA plans to conduct
these rkshops, which are based on the carprehensive technical guidance
scheduled for general distribution later this year, throughout the
remainder of 1988 and beyond. Fifth, EPA will continue to conduct
Pretreatment Caripliance Monitoring and Enforcement (PalE) rkshops (see
article on page 5 of this bulletin). These activities represent the major
EPA efforts in the short term. The discussions held in Philadelphia will
help direct future pretreatment program initiatives, which EPA will keep
pretreatment personnel informed of through this bulletin and other
rrechanisms. Page 10 of this bulletin provides pretreatment personnel the
opportunity for input regarding all aspects of the program .
EPA The following is a list of EPA Regional pretreatment coordinators. If,
PRETRENIMENT after first contacting the appropriate State pretreatment office, PCYTWs
ot rAcrs need further assistance with program developTent or iirplementation
questions or proble-as, please contact the EPA Regional office responsible
for your State.
Name Region Phone
Jack Stoecker I (617) 565—3492
Ruth Adelnen II (212) 264—2911
John Lovell III (215) 597—6279
Al Herndon IV (404) 347—3973
Dave Rankin V (312) 353—2105
Lee Bohne VI (214) 655—7175
Lee IXivall VII (913) 236—2817
Marshall Fischer VIII (303) 293—1592
Keith Silva IX (415) 974—8298
Bob Robichaud X (206) 442-1448

AVJLABLE The docuxt nts listed on this request form are available on a
XJC 14FNTS limited basis fran EPA. To obtain a copy of any of the foll 4ng
documents, please provide y i naire and address, check the requested
document(s), and return the inforrr tion to:
Chuck Prorok
U . S. E viroriinenta1 Protection Agencj
401 M Street., SW (E —336)
Washington, DC 20460
* ( ) Pretreatment Bulletin No. 1 (Septenber 30, 1985)
* ( ) Pretreatment Bulletin No. 2 (March 6, 1987)
* ( ) Pretreatment Bulletin No. 3 (Noveirber 6, 1987)
Guidance Manual for Electroplating and Metal Finishing Pretreatment Standards
Guidance Manual for Iron and Steel Manufacturing Pretreatment Standards
Guidance Manual for Battery Manufacturing Pretreatment Standards
Guidance Manual for Pulp, Paper, and Paperboard and Builders’ Paper and Board
Mills Pretreatment Standards
Guidance Manual for Leather Tanning and Finishing Pretreatment Standards
Merw randum: Irrplementation of the Organic Chemical Pretreatment Standards
(Decenber 30, 1987) and materials sent to OCPSF industrial users
* ( ) Guidance Manual for IlTplenenting Total Toxic Organic (Ti’O) Pretreatment Standards
* ( ) Guidance Manual for the Use of Production—Based Pretreatment Standards and the
Conbined stestream Forrr la
* ( ) Met orandum: Local Limits Requirements for P YIW Pretreatment Programe (August 5, 1985)
* ( ) Guidance Manual on the Development and Inplementation of Local Discharge Limitations
under the Pretreatment Program ( general distribution scheduled for Fall 1988 )
The National Pretreatment Program (Environmental Regulations and Technology document
EPA/625/10—86/005, July 1986)
* ( ) Guidance Manual for Preventing Interference at POTWs
Pretreatment Cc*Tpliance Monitoring and Enforcement Guidance (PO1E)
* ( ) Guidance for Evaluating and Reporting POTW Nonconpliance
R .A
* ( ) R(RA Informetion on Hazardous Wastes for I’vIa
* ( ) Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly
() ned Treatment Works by Truck, Rail, or Dedicated Pipe
PCME Software and user’s Manual
PRELIM and User’s Manual (EpA’s computer ntdel for calculating local limits)
* These documents have been, or shortly will be, trailed directly to all iw, state, and
EPA Regional pretreatment personnel. Due to the limited nunter available, please be
sure your office does not already have a copy before making a reguest.

PRgrREM? . F This page has been provided for your input on the aspects of the
FEEDBA ( Pretreatn nt Program that, in your view, are r t working well,
and those that are. We would appreciate hearing fran you. The
inforn tion you provide will be assessed ti j EPP for possible program
modification and/or increased assistance for local program irrplenen-
General Description of Issue:
Peaxtrrendation :
(Extra sheets n y be attached to identify nultiple issues.)
Please send your zm nts to the address listed on the docunent
request form on Page 9 of this billetin.