PRETREATMENT BULLETIN
JUNE 1989
BULLETIN #6
Contents
National Pretreatment Coordinators Meeting p. 1
Pretreatment Awards p. 1
Enforcement Update p. 2
Pretreatment Enforcement Initiative
Pretreatment Compliance Monitoring and
Enforcement Summary Report
Sludge Enforcement Initiative
Koppers Settlement
Ocean Spray Cranberries, Inc.
Pulp and Paper Mill Dioxin Discharges p. 3
Regulatory Update p. 4
Sludge Regulations
Storm Water Regulations
Guidance Update p. 5
Guidance Manual for Slug Loadings to POTWs
Enforcement Response Guide
Additional Local Limits Guidance
City Attorneys' Workshop
Upcoming Events p. 7
Index of Pretreatment Bulletins 1-6 p. 8
On April 14, 1989, Virginia became the 26th
state with an approved pretreatment
program.
U.S. Environmental Protection Agency
Office of Water Enforcement and Permits
EN-336
401 M St. SW
Washington, DC 20460
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PRETREATMENT BULLETIN #6
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1989 National Pretreatment Coordinators Meeting
Denver, CO was the site of the 1989 National Pretreatment Coordinators Meeting held by
EPA from April 11 through April 13. Over 100 participants including representatives from 35
states, 23 representatives from EPA Headquarters, and 35 representatives from all 10 EPA Regions
attended the meeting. For the first time, the meeting was international thanks to attendance by a Ca-
nadian representative from the Ontario Ministry of the Environment.
The objectives of the Pretreatment Coordinators Meeting were to exchange information
concerning the Pretreatment Program, provide EPA Headquarters with feedback on successes,
identify future challenges, and obtain recommendations from EPA Regions and States regarding
issues of importance.
The two and one half day meeting consisted of technical presentations, small group discus-
sions, and general meetings of all attendees. Just a few of the topics discussed were PIRT and DSS
requirements, enforcement issues in pretreatment, EPA’s Pollution Prevention Program, implementa-
tion of SNC and RNC for POTWs, regulation of lUs in non-pretreatment cities, and development of
a long-term pretreatment program strategy.
As in previous meetings, State coordinators met to discuss issues of particular concern.
Later the State coordinators presented their top five issues of concern:
1) Sludge technical standards, particularly with regard to the need for additional local
limits guidance and the time for POTWs to achieve compliance
2) Inadequate staff and staff turnover
3) Toxicity testing and the cost of Whole Effluent Toxicity testing for POTWs
4) The need for additional technical guidance regarding local limits development for
toxic organics
5) State Communications Network- an electronic bulletin board for the states
While state coordinators met, EPA Regional and Headquarters representatives met to discuss
the need for a revised National Pretreatment Strategy - the first pretreatment strategy was initially
developed in 1978 (see 38 Fed.Reg. 30982). EPA hopes that this revised strategy will allow the
Agency to better meet the changing needs of the Pretreatment Program.
The National Pretreatment Coordinators Meeting was an excellent opportunity for EPA and
the States to look back at program achievements. Attendees also looked forward to future challenges
which include increasing POTW effectiveness in implementation and enforcement of pretreatment
standards and requirements, continued improvement in the oversight process, development of more
comprehensive NPDES permits, and documentation of pretreatment successes. The 1989 National
Pretreatment Coordinators Meeting provided a chance for participants to assess current issues and
move toward future goals.
programs. These awards will be modeled after the
FYI... Operation and Maintenance Awards and the Bene-
ficial Sludge Use Awards given annually by the
Pretreatment Awards - This year the Office of Office of Water. The goal of the awards is two-
Water is adding a new approach acknowledging fold: to recognize POTWs for outstanding efforts
the efforts of POTWs to implement and enforce in the area of pretreatment, and to heighten overall
approved pretreatment program requirements. public awareness and support of local wastewater
EPA is developing Pretreatment Excellence treatment-related programs.
Awards to acknowledge exemplary pretreatment EPA Regions and States have been asked
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JUNE 1989
PRETREATMENT BULLETIN #6
to nominate POTWs they believe to be operating
exemplary pretreatment programs. After screen-
ing nominations at EPA Headquarters, EPA will
notify POTWs of their nomination and ask them to
submit an awards application which includes in-
formation that an Awards Committee (comprised
of pretreatment experts from EPA Headquarters,
EPA Regions, and States) will use to evaluate the
local programs.
The Awards Committee will choose win-
ning POTWs in four size categories based on
actual flow:
1) 0 to 2.00 million gallons per day (mgd)
2) 2.01 to 5.00 mgd
3) 5.01 to 20.00 mgd
4) Greater than 20.01 mgd
EPA will notify winning POTWs of their selec-
tionin August 1989 andpresent theawardsdunng
the Water Pollution Control Federation’s annual
national conference in October, 1989. One repre-
sentative from each of the first place POTWs will
be invited to attend the WPCF Conference in San
Francisco as a guest of EPA.
Pretreatment Enforcement Lnitiptive - EPA and the
States are now in the process of targeting POTW
candidates forenforcemerit actions to address fail-
ure to adequately implement approved local pre-
treatment programs. This national pretreatment
enforcement initiative began with a February 1989
memorandum signed by Edward Reich, Acting
Assistant Administrator for the Office of Enforce-
ment Compliance and Monitoring, and James
Elder, Director of the Office of Water Enforce-
ment and Permits. In this memorandum, Regions
were asked to identify potential enforcement can-
didates, to request state participation, and to begin
taking appropriate enforcement action (civil refer-
rals or administrative penalty actions) against each
of these POTWs.
EPA anticipates that this enforcement ini-
tiative will be larger in magnitude than those ini-
tiatives used in 1985 and 1986 to address failure to
develop approvable local pretreatment programs.
The initiative is part of a continuing effort
to ensure that appropriate enforcement action is
taken to address POTW failure to implement
approved local pretreatment programs. It is antici-
pated that a national press release providing addi-
tional details will be available in September 1989.
Pretreatment Compliance Monitoring and Enforce-
ment Summary Report- - The Enforcement Divi-
sion of the Office of Water Enforcement and Per-
mits is currently in the process of compiling a
Pretreatment Compliance Monitoring and Enforce-
ment Summary Report. This summary will pro-
vide analyses of pretreatment data on industrial
users, POTWs, States, and EPA. This data is
obtained primarily from the Pretreatment Permits
and Enforcement Tracking System (PPETS), the
national pretreatment data tracking system, which
contains information obtained by EPA Regions
and States during pretreatment audits, pretreat-
ment compliance inspections, review of annual
reports and other sources.
A draft version of this summary will be
transmitted to EPA Regions and certain States for
their review and comment in July 1989 . Public
release of the summary is planned for September
1989.
Sludge Enforcement Strategy - In response to the
statutory mandate in section 405(d) of the Clean
Water Act of 1987, EPA proposed technical regu-
lations outlining disposal/use practices and pollut-
ant standards for municipal sludge at 54 Fed. Reg.
5746,Feb 6,1989. EPA isin theprocessofevalu-
ating potential enforcement responses to the re-
quirements set forth in proposed Part 503 sludge
regulations, and gathering information on existing
sludge permits in order to identify and analyze en-
forcement issues related to sludge. This informa-
tion will be used by EPA to develop a sludge en-
ENFORCEMENT UPDATE
The summary will include graphs, tables,
and accompanying text related to such information
as issuance of control mechanisms, significant
noncompliance rates of significant industrial users
(SIUs), inspection of SIUs, enforcement actions
taken by POTWs against SIUs, publication of
significant violators, and technical analysis for
local limits.
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rKIl I KLA I lVIt,IN I I$ULLL I tIN #0
JUINt .. I9 S9
forcement strategy which will be in place by the
time the technical regulations are promulgated in
final form.
The enforcement strategy will cover the
following areas: assessing the effect of the sludge
regulations on EPA and State inspection proce
dures; developing a definition of SNC for sludge
violations; procedures for reporting SNC viola-
tions on the QNCR; and assessing compliance
with Best Professional Judgement and other exist-
ing sludge limits. This strategy is due to be
completed by the end of FY89.
Koppers Company Pays $950.000 to Settle Clean
Water Act Case Brought By U.S. EPA - On Octo-
ber 12, 1988, Koppers Company, Inc., a Fortune
500 company, agreed to pay a civil penalty of
$950,000 to the United States to settle a Clean
Water Act enforcement action brought against the
Company by U.S. EPA. The settlement order,
signed by U.S. District Court Judge Richard B.
McQuade, in Toledo, Ohio, represents the largest
penalty assessed for violations of the Clean Water
Act pretreatment standards at a single facility.
This penalty recovers more than the economic
benefit that Koppers Company may have obtained
from its noncompliance.
The complaint, filed in 1987, alleged that
Koppers Company, while the owner of an iron and
steel coke plant in Toledo, Ohio, violated pollutant
discharge limitations and reporting requirements
promulgated under the Clean Water Act. Specifi-
cally, U.S. EPA alleged that Koppers Company
discharged ammonia, phenol, and cyanide to the
local Toledo sewage treatment plant for almost
two years in violation of the categorical pretreat-
ment standards and requirements for iron and steel
manufacturing, cokemaking subcategory, 40
C.F.R. section 420.15(b). Koppers, by the terms
of the settlement, did not admit any of the viola-
tions alleged by U.S. EPA. Koppers sold its
Toledo coke plant in May 1987 to Toledo Coke
Corporation. The case against Toledo Coke is
pending.
Ocean Spray Cranberries. Inc. Fined - After dis-
charges with very low pH caused interference with
proper operations at the receiving POTW, Ocean
Spray Cranberries, Inc. was warned repeatedly of
the need to pretreat its wastes properly. As a result
of a criminal enforcement action for negligentl
willful violations, Ocean Spray Cranberries, Inc.
was fined $400,000 on December 20, 1988 after
pleading guilty to 20 misdemeanor counts for pre-
4
Regulation of Pulp and Paper Mill Dioxin Discharges
EPA and the States have been evaluating and regulating the discharge of dioxin from pulp
and paper mills that use chlorine to bleach chemical pulps. There are 104 of these mills in the
United States; eight are indirect dischargers.
Numerous data on the levels of dioxin in effluent, sludge and pulp from these mills have
been collected as part of an USEPA/Paper Industry Cooperative Dioxin Study. Data regarding
levels of dioxin in fish have been collected as part of the National Bioaccumuladon Study. In addi-
tion, various Regions and States have been conducting additional ambient water sampling around a
number of these mills.
On August 9, 1988, the Office of Water issued the Interim Dioxin Strategy for the Regulation
of Pulp and Paper Mill Dioxin Discharges to the Waters of the United States. Comments on the
strategy and its implementation are welcome. However, the strategy should be used now. The goal
of the interim strategy is to eliminate the presence of dioxin in discharges from pulp and paper mills
to the waters of the United States. The interim strategy calls for (1) aggressive standards for dioxin
applicable to all water bodies where mills using chlorine bleach processes are discharging; (2) col-
lection of data on each of the 104 affected mills, including dioxin levels in the puips, effluents,
sludges; (3) detailed technical evaluation of wastewater treatment technologies and/or in-process
changes to reduce or eliminate the presence of dioxin in wastewater discharges; and (4) issuance of
NPDES permits that regulate and require monitoring for dioxin, examine effluent toxicity and
provide for modification to tighten controls consistent with the final strategy and the requirements of
(continued on p. 4)
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JUNE 1989
PRETREATMENT BULLETIN #6
treatment violations and I misdemeanor count for
direct discharge to wetlands. In addition, Ocean
Spray was ordered to buy a sludge press for the
Town of Middleboro’s sewage treatment plant, as
restitution for damages caused to the POTW by
Ocean Spray’s violations.
REGULATORY UPDATE
Sludge Regulations - The 1987 amendments to the
Clean Water Act (CWA) require that permits
issued to treatment works contain sludge stan-
dards. EPA proposed technical standards for
pollutants of concern in sludge for five major use
or disposal methods (40 CFR Part 503) on Febru-
ary 6, 1989 (54 Fed.Reg. 5746).
The public comment period on the pro-
posed sludge standards will close August 7. 1989 .
EPA will hold public hearings and work-
shops to discuss the proposed standards as fol-
lows:
Workshops
May 23-24 Philadelphia, PA
May 31- June 1 Seattle, WA
Public Hearings
July 6 Washington, DC
July 13 Boston, MA
July 18 Chicago, IL
July 20 San Francisco, CA
Further information about the workshops and
public hearing may be obtained by calling EPA’s
Sludge Hotline at (617) 648-7898 or 7899 or Mark
Morris at (202) 475-7312.
On May 2, 1989, EPA published final
rules for incorporating sludge conditions in NPDES
permits and for approving State Sludge Manage-
ment programs (54 Fed.Reg. 18716). For further
information contact Debora Clovis, U.S. EPA,
Permits Division (EN-336), 401 M St. SW, Wash-
ington, DC 20460 Tel. (202) 475- 7052.
The 1987 CWA amendments also state
that, prior to development of the Part 503 technical
standards, the Administrator shall put sludge con-
the Clean Water Act. A final strategy should be issued after review of comments received and the
results of the EPA/Paper Industry Cooperative Study which is under way. The settlement and
agreement in the EDFINWF v. EPA dioxin lawsuit requires the strategy to be issued by April 1990.
On October 20, 1988, EPA issued data from a dioxin treatability study and provided sugges-
lions for interim control measures for regulating dioxin dischargers from pulp and paper mills.
On March 15, 1989, EPA issued Guidance for section 304(1) Listing and Permitting of Pulp
and Paper Mills which describes three lists used to organize information on dischargers: the ‘a” or
“long” list of all impaired waters, the “b’ or “short” list of impaired waters impacted by certain point
sources, and the “c list of facilities impacting waters on the “b’ list. This guidance indicated that re-
ceiving waters for every mill or associated POTW should be listed on the section 304(l)(1)(B) “short
list” if 2,3,7,8-TCDD is detected in fish (whole or fillet) (unless the State has adopted criterion for
the pollutant which establishes a risk level less stringent than 10.6 and the State’s criterion is not vio-
lated) or if the 2,3,7,8-TCDD data for the effluent indicate, after use of appropriate procedures
specified by the State regarding mixing zones and risk levels, that there will be a violation of water
quality standards. Chlorine bleaching pulp mills or associated POTWs should be identified on the
304(l)(1 )(c) list for each water identified on the (B) list. The Guidance goes on to indicate that the
Permits for those facilities on the (C) list should contain (I) a calculated water quality-based permit
limit for 2,3,7,8-TCDD, (2) a statement in the permit that the detection level is the threshold for
compliance/non-compliance determinations and (3) a statement in the permit citing the analytical
protocol set out in Appendix C of the USEPA/Paper Industry Cooperative Screening Study.
For more information on the permitting of these facilities, please contact Laura Phillips at
(202) 475-9532.
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ditions 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 Im-
plementation of Sludge Requirements in Permits
Issued to POTWs.” The draft strategy, which was
made available for public comment, is undergoing
revision in response to public comments and to
reflect new regulation. EPA expects to issue the
revised guidance this summer.
In addition, EPA has prepared two draft
guidance documents to help permit writers in
developing interim sludge conditions for POTW
permits. The first is the “Guidance for Writing
Case-by-Case Requirements for Municipal Sludge,
Sept. 1988.” This guidance is now being revised
in response to comments received and is sched-
uled for availability at the end of this fiscal year.
Limited quantities of the September 1988 draft are
still available by contacting Robert Goo at (202)
382-6961.
The second draft guidance is the “POTW
Sludge Sampling and Analysis Guidance Docu-
ment, June 1988,” which is also undergoing revi-
sion in response to comments and is expected to
be finalized this summer. For further information
or copies of the draft, contact Cristina Morrison at
(202) 475-7052.
Storm Water Regulations - On December 7,
1988,pursuant to the Water Quality Act of 1987,
EPA proposed regulations (53 Fed.Reg.49416),
for permit application requirements for Storm
water discharges from medium municipal sepa-
rate storm sewers serving a population of 100,000
or more, large municipal separate storm sewers
that serve a population of 250,000 or more, and
storm water discharges associated with industrial
activity.
A 90-day comment period ended on March
7, 1989. The proposal requested comments on
several issues including the appropriate definition
of municipality, sampling procedures, and spe-
cific industries covered by the regulation. EPA is
currently reviewing 450 comments submitted by a
variety of industries, municipalities, and state
agencies. EPA anticipates that final regulation
will be promulgated in early 1990.
Copies of the proposal can be obtained by
contacting Tom Seaton, Kevin Weiss, or Mike
Mitchell, Permits Division (EN-336), U.S. EPA,
401 M St. SW, Washington DC, 20460. Tel. (202)
475-9518.
GUIDANCE UPDATE = =
Guidance Manual for Control of Slug Loadings To
POTWs - Slug loadings are defined as any pollut-
ant discharges which violate the specific prohibi-
tions under40 CFR 403.5(b), including: (1) fire or
explosion, (2) corrosion, (3) obstruction, (4) inter-
ference, or (5) excessive heat. Under 40 CFR
403.12(f), all categorical and noncategorical in-
dustrial users are required to notify the POTW
immediately of slug loadings.
The Report to Congress on the Discharge
of Hazardous Wastes to Publicly Owned Treat-
ment Works (called the Domestic Sewage Study)
documented the problem of slug loadings of toxic
pollutants and hazardous constituents by indus-
trial users ( lOs) and recommended expansion of
pretreatment controls. The study acknowledged
that categorical industrial pretreatment standards,
locally -derived numerical limits, and reporting
requirements were not always effective in han-
dling accidental spills or irregular high strength
batch discharge which may be received at the
POTW as slug loadings.
This guidance manual was developed by
EPA to aid all POTWs (not just those that have
been required to establish federally-approved pre-
treatment programs) in developing and imple-
menting specific programs and measures to con-
trol JU slug loadings. Technical guidance is pro-
vided for imposing a range of slug loading control
measures on lUs and, where prevention fails,
engaging in remedial measures at the POTW.
By supplementing existing or future cate-
gorical standards and numerical local limits, slug
control measures will help reduce influent load-
ings overall, including loadings of toxic pollutants
and hazardous constituents. In addition, slug
controls can be useful to help POTWs comply with
NPDES effluent limitations on specific chemicals
or whole effluent toxicity.
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JUNE 1989
PRETREATMENT BULLETIN #6
A limited number of copies have been
distributed to EPA Regions and further distribu-
tion is planned.
Enforcement Response Guide - EPA is complet-
ingdevelopmentofan enforcementresponse guide.
The manual entitled, Guidance for Developing
POTW Pretreatment Enforcement Strategies. is
intended to supplement the Domestic Sewage
Study Proposed Rule (November 23, 1988) which
proposes to amend 40 CFR 403.8(f) to require all
POTWs with pretreatment programs to develop
enforcement response plans describing how
POTWs will investigate and respond to instances
of noncompliance, including time frames within
which the responses will take place.
The manual will provide municipal pre-
treatment personnel with guidance for developing
effective enforcement strategies. The guidance
will present the advantages, disadvantages and
proper use of enforcement remedies and responses
which in EPA’s experience, are typically available
to municipalities. The enforcement response
guide assists in the selection of both initial and
follow-up enforcement responses by identifying
appropriate enforcement response time frames for
carrying out these actions. To further guide Con-
trol Authority personnel, the manual includes a
model enforcement response guide illustrating
these concepts. Finally, the manual contains a
lengthy analysis of each of the common enforce-
ment remedies and responses with the advantages
and disadvantages of each tool described as well as
recommendations on how to use them. Sample
documents, which Control Authorities may use as
appropriate, are also included.
The Agency believes that the process of
developing these plans will be very valuable and
that such plans will make it easier for EPA to
determine whether a POTW is complying with its
pretreatment implementation requirements for
enforcement.
The guidance manual is anticipated to be
available in the Fall of this year. This manual will
complement an earlier document prepared by EPA
entitled, Pretreatment Compliance Monitoring and
Additional Local Limits Guidance - As a supple-
ment to the 1987 Guidance Manual on the Im-
plementation and Development of Discharge
Limitations Under the Pretreatment Program (the
Local Limits Manual) EPA is now preparing
additional local limits guidance which it expects to
be available later this year. The additional guid-
ance includes:
1) The Domestic/Commercial Loading Report-
This report examines sampling results based on
domestic and commercial background sources and
will serve as a source of additional data that can be
used as comparison data when developing local
limits. Although the Local Limits Manual pro-
vides literature data for domestic loadings, this re-
port identifies several additional types of dis-
charges as significant sources of loadings. Data
has been compiled on radiator shops, laundries,
septic haulers, landfill leachates, photo proces-
sors, hospitals and car washes.
2) Removal Efficiency Estimation for Local Limits
Development- The 1987 Local Limits Manual
presents the concept of the decile approach as an
alternative method for calculating removal effi-
ciencies. This guidance elaborates on the con-
cepts presented in the guidance manual and an-
swers questions not addressed there. The study
also provides a “worksheet” approach to decile
calculations which should allow POTV ’s to follow
step-by-step procedures in calculating removal ef-
ficiencies based on deciles.
City Attorneys’ Workshop - In a continuing effort
to improve the implementation of the National
Pretreatment Program, EPA is currently develop-
ing a workshop for local city attorneys. This
workshop is designed to: (1)facilitate and
enhance coordination between the POTW
personnel and municipal attorney; and (2) to
educate the local attorney in bringing adminis-
trative and civil enforcement cases against
noncompliant industrial users.
The substantive content of the workshop
will include: an overview of the federal pre-
treatment program; a review of a typical sewer
Enforcement Guidance (PCME (July 1986) .
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PRETREATMENT BULLETIN #6
JUNE 1989
use ordinance, including an analysis of common
obstacles to enforcement which occur in the
ordinance; administrative enforcement proce-
dures and techniques; civil enforcement issues
and procedures, including admissability of
evidence and procedures for bringing cases; and
model pleadings for civil and administrative
enforcement.
The overall goal of the workshop is to
promote institutional coordination between the
POTW and city attorney’s office and to encour-
age a more active role on the part of the city
attorney in the enforcement process.
a-
UPCOMING EVENTS
Workshops and Hearings regarding proposed
sludge technical regulations, see p. 4
Workshop on Toxic Air Pollutants and POTWs
Washington, D.C., July 10 & 11, 1989.
Contact: Atal Eraip, USEPA, (202)382-7369
Basic NPDES Permit Writers’ Course
Hartford, CT., August 7-11, 1989
Contact: Roxanne Gentry,
ERC Environmental, (703) 471-5550
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J UIN t . 1Y8Y A A 1L . I & ./% I AI.I A IJ .J — -
INDEX OF PRETREATMENT BULLETINS #1-6
Categorical standards (#1, attachment a)
Changes to.. .(#2, p.7)
Compliance dates (#3, p.3)
Implementation of.. .(#2, p.5)
Industries considered for. ..(#3, pA)
Industries subject to categorical standards, final regulations (#1, atiB)
Isolated wastestreams (#4, p.13)
Leather tanning and finishing (#4, p.3)
Metal finishing cyanide standards (#1, p.6)
Milestone dates (#2, p.6)
Organic chemicals, plastics, and synthetic fibers (OCPSF) (#2, p.8;#4, p.3)
Pesticides (#2, p.8)
Pre-1977 standards (#4, p.2)
Stand-alone R&D facilities (#3, p.5)
Clean Water Act Amendments-
Pretreatment effects (#3, p.1)
Definitions-
Final rules for new source, interference, and pass through definitions (#2, p.2)
Significant noncompliance (#2, p.2)
Domestic Sewage Study-
Federal register notice of public comments (#3, p.2)
Proposed ammendments to 40 CFR parts 122 and 403 (#5, p.3)
Public comments on the Advanced Notice of Proposed Rulemaking (ANPRM) (#2, p.13)
Enforcement Actions-
Kopper’s Settlement (#6,p. 3)
Ocean Spray Cranberries, Inc. (#6, p.3)
FDF variances (#3, p.2; #4, p.2)
General pretreatment regulations (#1, attachment a)
Domestic Sewage Study (#5, p.3)
Other changes (#2, p.1)
PIRT rule (see Pretreatment Implementation Review Task Force)
Revisions to appendix D (#2, p.2)
Technical Ammendments (#2, p.1)
Guidance Document Summaries-
Development of Industrial User Permits (#3, p.9; #4, p. 5 ; #6, p.7)
Enforcement Response Guide (#6, p.5)
Evaluating and reporting POTW noncompliance (#3, p.’7)
Identification of hazardous wastes delivered to POTWs by truck, rail, or dedicated pipe (#3, p.9)
Local limits
Technical Guidance (#2, p.12)
Additional Guidance (#6, p.6)
PCME guidance and training materials (#3, p.6; #6, p.5)
Preventing Interference at POTWs (#2, p. 1 3)
Slugs
Discharge Control (#3, p.10)
Loadings to POTWs (#6, p. 5)
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PRETREATMENT BULLETIN #6 JUNE 1989
National Pretreatment Coordinators Meeting
Summary #5 (#4, p. 7 )
Summary #6 (#6, p.1)
NPDES form 2a (#4, p.6)
Organic chemicals, plastics, and synthetic fibers (OCPSF) final regulations schedule (see
Categorical Standards)
Pesticides (see Categorical Standards)
Pretreatment Enforcement Initiative (#6, p.2)
Pretreatment Excellence Awards (#6, p.1)
Pretreatment Implementation Review Task Force (PIRT)-
Regulatory changes (#5, p.1)
EPA responses to PIRT-
Applicability of categorical standards to federal facilities (#1, p. 4 )
Compliance by industrial users after a change in ownership (#1, p.4)
Enforcement against interference (#1, p.3)
Enforcement against POTWs without program applications (#1, p.5)
Enforcement of pretreatment standards (#1, p.5)
Interaction between EPA, States, and POTWs (#1, p.4)
Local limits (#1, p.2)
Regulation of small industrial users (#1, p.3)
Tracking the development of State Water Quality Standards (#1, p.5)
Pulp and Paper Mill Dioxin Discharges Received by POTWs (#6, p.3)
Radioactive Waste (#3, p.10)
RCRA requirements for POTWs (#1, p.6)
Removal Credits (#3, p.3)
Third Circuit Court of Appeals ruling (#2, p.3)
Reportable noncompliance (#2, p.10)
Sludge regulations (#3, p.2; #4, p.1; #6, p.4)
Enforcement Strategy (#6, p.2)
Required limits in permits (#2, p.2)
Strategy forinterim implementation of sludge requirements in permits issued to POTWs (#4, p.1)
Software-
PCME (#3, p.6; #5, p.3)
PRELIM (#2, p.11)
PPETS (#3, p.7; #4, p.7)
Storm Water Regulations (#6, p. 5)
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PKEIKLAIMIM’ll DUJ_,L 111 WU
Superfund wastes and POTWs (#4, p.5)
Training-
City Attorneys’ Workshop (#6, p.6)
Local limits workshops (#4, p.5)
PCME instructor’s manual (#4, p.5)
Pretreatment facility inspection field-study
training program (#4, p.4)
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