Winners of Pretreatment Excellence Awards Announced     p. 1
    Pretreatment Enforcement Initiative                 p. 3
    Other Enforcement News                        p. 5
    Bulletin Board                              p. 5
    PIRT Deadline                              p. 6
    Sewage Sludge Sampling and Analysis Guidance          p. 6
    Pretreatment Enforcement Response Guidance           p. 6
    Pollution Prevention - How Does Pretreatment Fit In?       p. 7
    PRELIM Update                             p. 9
    Pretreatment Report to Congress                   p. 9
    Index                                    p. 10
   On September 22,1989, California became the 27th state
   with an approved state  pretreatment program.
 U.S. Environmental Protection Agency
 Office of Water Enforcement and Permits
 Washington, DC 20460
                                         Printed on Recycled Paper


Winners of Pretreatment Excellence
Awards Announced
The Awards Review Committee for the National Pretreatment Excellence Awards has an-
nounced its choices of recipients for the 1989 National Pretreatment Excellence Awards. EPA
received many fme applications from the 60 Publicly Owned Treatment Works (POTWs) originally
nominated by their States and Regions. After a thorough review of each POTW’s program, the
review committee chose eight POTWs to be honored at an EPA awards ceremony. This ceremony
took place on October 16, 1989, in San Francisco at the 1989 Water Pollution Control Federation
Art Saarinen, President of the Water Pollution Control Federation, welcomed the award
winners and their guests in his opening remarks to the group. With over 300 spectators in atten-
dance, representatives from each winning POTW received a plaque presented by James Elder,
Director of the Office of Water Enforcement and Permits at U.S. EPA. Rebecca Hanmer, Acting
Assistant Administrator for the Office of Water at U.S. EPA, described the highlights and innova-
tions of each POTW’s program. After the ceremony, a reception and photo session with Ms. Hanmer
was held for the winners and their guests.
The first place award winner for the smallest size category (0-2.00 million gallons per day
(mgd)) is the City of Three Rivers, Michigan. This POTW has had particular success in the areas of
influent, effluent, and stream quality improvements through implementation of the pretreatment
program. One example of this success is the removal of mercury from the system, through discovery
and removal of a mercury-containing biocide in an industrial user’s production process. This re-
moval may eventually lead to elimination of recommendations for the public to reduce fish con-
sumption from the local river.
The second place award winner for the smallest size category (0-2.00 mgd) is Contentnea
Metropolitan Sewerage District in Grif ton, North Carolina. As a small POTW with 4 significant
industrial users, Contenmea has used a system of communication and combined inspection and sam-
pling visits to accomplish their goals of reducing pollutant loadings at the POTW in order to ensure
consistent NPDES permit compliance.
The Searcy Board of j ublic Utilities in Searcy, Arkansas, is the first place award winner in
the 2.01-5.00 mgd size category. Through industrial user permits and an emphasis on communica-
tion with its industrial users through letters, memos, and inspections, and public relations projects
which build support for the pretreatment program through programs and tours for civic clubs and
schools, this POTW has reduced the threat of pass through and interference at its plant. They have
also encouraged the development of markets for industrial by-products, such as a local ice cream
producer’s whey and milk solids, which are sold to a local pig farmer.
(continued on p. 2 )

(Award Winners, continued)
The Northampton Wastewater Treatment Plant in Northampton, Massachusetts, is the recipi-
em of the second place Pretreatment Excellence Award in the 2.01-5.00 rngd size category. Through
a straightforward approach to program implementation, which includes an organized enforcement
plan and consistent financial support from the town, this POTW protects sludge quality, worker
health and safety, and the receiving waters of the Connecticut River.
In the 5.01-20.00 mgd size category, two POTWs tied for first place, so no second place
award was presented. -
The City of Tyler, Texas, is the first place co-recipient for the 5.0 1-20.00 mgd size cate-
gory. This POTW uses a rigorous monitoring program, plus a one-on-one approach with industrial
users including development of an industrial user sampling guide, to achieve environmental suc-
cesses. Through its pretreatment program, the City has experienced a 10-15% decrease in organic
and solids loading on each of its plants, as well as a reduction of heavy metals concentration in its
influent and sludge ranging up to 85% in some cases.
The second co-recipient of the first place award for the 5.01-20.00 mgd size category is the
City of La Crosse, Wisconsin. Along with a computerized system for permitting significant indus-
trial users, this POTW demonstrated innovation in its approach to non-permitted sources such as
restaurants and car washes. The POTW sent an informational letter to each restaurant and car wash
in the city, and followed up with a visit to answer any staff questions regarding grease and sand
traps. These steps helped to reduce the possibility of interference in the system. The improved
results of effluent toxicity testing are another of the positive results of this city’s pretreatment pro-
The East Bay Municipal Utility District in Oakland, California is the first place recipient in
the largest size category (>20.00 mgd). This POTW runs a large pretreatment program and main-
tains strong communication (i.e., direct mailings regarding regulatory changes and training pro-
grams, annual meetings for industrial customers, and tours of the treatment plant) with the regulated
community. Since institution of the authority to regulate industrial dischargers in 1972, the POTW
has achieved successes such as no treatment plant upsets caused by industrial discharges, 100%
compliance with NPDES limits for toxics, and successful sludge composting.
The second place recipient in the largest size category is Louisville and Jefferson County
Metropolitan Sewer District in Louisville, Kentucky. Through an active public education program
and an innovative spill response program supported by a Hazardous Material Ordinance, this POTW
has greatly improved its protection of the city’s sewer system against hazardous materials spills over
the past 5 years.

On October 4, 1989, EPA Administrator William K. Reilly and Attorney General Richard
Thomburgh announced that the U.S. EPA and the U.S. Department of Justice filed suit against
the cities of Detroit, MI, El Paso, TX, Phoenix, AZ, and San Antonio, TX, for failure to properly
implement and enforce their pretreatment programs. These four cities and 57 others are part of
the EPA’s Pretreatment Enforcement Initiative meant to draw attention to the poor implementa-
tion of pretreatment programs. “For health and safety reasons, as well as to protect the nation’s
investment in sewage treatment plants- estimated to range between $40 to $60 billion over the
last 20 years - these programs are essential,” Reilly said.
As of October 4, the ongoing enforcement initiative covered a total of 61 cities in 21
States. EPA is joined in the enforcement initiative by several States, including California, Michi-
gan, North Carolina, Ohio, and Tennessee. Each of the 61 cities has been issued administrative
penalty orders or has had civil judicial complaints filed against it for pretreatment violations.
Municipal treatment facilities in the 61 cities serve over 9 million people and regulate over 1,600
significant industries. In 1989, 29 settlements provided for over $2.3 million in penalties. In the
past few weeks, additional enforcement actions addressing pretreatment implementation prob-
lems have been taken by EPA and by States against the following cities: Conroe, TX, Easthamp-
ton, MA, Massillon, OH, and Springdale, AR. Additional enforcement actions are planned for
the near future.
Thornburgh stated that the initiative is meant to send a strong signal that “ [ plolluters,
public or private, cannot be permitted to ignore the law.” Reilly stated at a press conference that
•this action will help to prevent industries in some areas from gaining competitive advantage due
to uneven enforcement of environmental laws. The EPA Administrator said, “We are sending a
clear message-that no individual industry or municipality will be allowed to violate environ-
mental laws without risking economic sanctions and penalties.”
Reactions to the initiative from environmental groups such as the Natural Resources
Defense Council (NRDC) were generally favorable. The NRDC welcomed “this strong (and
long overdue) signal that the federal goverflment plans to increase enforcement of the pretreat-
ment laws. Pretreatment is a critical component of our national program to control toxic pollut-
ants in our waters and in sewage sludge.”
See the following page for a list of cities involved in the Pretreatment Enforcement
Initiative as of November 1989.

1989 Enforcement Actions for Failure to Imulement Pretreatment Programs
EPA Region 1
* Chicopee, MA
Easthampton, MA
Gloucester, MA
Greater Lawrence, MA
* Newburyport, MA
EPA Region 2
Rockaway Valley (Parsippany), NJ
Dunkirk, NY
* Haverstraw Regional Board, NY
Niagara County, NY
Watertown, NY
EPA Region 3
* Bellefonte, PA
Easton, PA
Lackawanna River Basin, PA
Lancaster Area, PA
Latrobe, PA
* Pottstown, PA
Punxsutawney, PA
EPA Region 4
* Escambia County (Pensacola), FL
* Titusville, FL
* Kings Mountain, NC
* Brownsville, TN
* Lawrenceburg, TN
* Lynchburg, TN
* McMinnville, TN
* Springfield, TN
EPA Region 5
Sauget, IL
Evansville, IN
Gaiy, IN
Speedway, IN
Detroit, Ml
* Jackson, MI
* Ashtabula, OH
* Bellefontaine, OH
* Cambridge, OH
* Girard, OH
* Massillon, OH
* Newark, OH
EPA Rethon 6
* Siloam Springs, AR
Springdale, AR
Monroe, LA
* Amarillo, TX
Beaumont, TX
Brownsville, TX
Conroe, TX
El Paso, TX
Galveston, TX
* McAllen, TX
Mineral Wells, TX
* Nacogdoches, TX
* San Antonio, TX
* Waxahachie, TX
EPA Region 7
Kansas City, KS
Salina, KS
Topeka, KS
Little Blue Valley (Independenče), MO
EPA Region 8
Delta, CO
* Denver (Metro), CO
* Great Falls, MT
EPA Region 9
Phoenix, AZ
‘ Chino Basin, CA
West Sacramento, CA
EPA Region 10
Clackamas County (Oregon City), OR
Kjamath Falls, OR
La Grande, OR
Portland, OR
* settled actions

POTWs, States, and EPA are continually taking enforcement action against industrial users
for failure to comply with pretreatment standards and requirements. A recent enforcement action
regarding Boijohn Optical Technology, Inc. is of particular interest. On October 2, 1989, a federal
grand jury returned a one hundred thirty-three count indictment, stemming from a joint investigation
by the Federal Bureau of Investigation and U.S. EPA. Borjohn Optical Technology, Inc., lo ated in
Burlington MA, and its president. John Borowski, were charged with knowingly discharging indus-
trial wastewater with an illegally low pH and illegally high concentrations of nickel in violation of
the Clean Water Act. The indictment also charged both parties with knowingly placing employees
of Borjohn Optical Technology, Inc. in imminent danger of death or serious bodily injury as a result
of the illegal wastewater discharges in violation of the Clean Water Act.
The indictment is the first in New England and the third in the U.S. to use the “knowing en-
dangerment” provision of the Clean Water Act. That provision was added to the Clean Water Act in
1987 and makes it a separate crime to knowingly place another person in imminent danger of death
or serious bodily injury.
U.S. Attorney Wayne A. Budd stated, “We have long known that environmental crime harms
not only our environment, but our health as well. The knowing endangerment provision of the Clean
Water Act now enables us to respond to both of these issues. This office’s enforcement of that provi-
sion underscores our determination to make use of every available tool in investigating and prosecut-
ing those who violate the environmental laws.”
Borowski faces a maximum penalty of 3 years in prison and a $50,000 fine on each of the 65
counts charging illegal discharge of pollutants and a maximum penalty of 15 years in prison and a
$250,000 fine on each of the 68 counts charging him with “knowing endangerment.” The company
faces a maximum fine of $50,000 on each of the 65 illegal discharge violations and a maximum fine
of $1 million on each of the 68 knowing endangerment counts. Arraignment was before a U.S. Mag-
istrate on October 17, 1989.
The Bulletin Board is a new section of the Pretreatment Bulletin meant to ptovide information exchange opportunities to
POTWs. If you have a r piesc for information from other POTWs please contaat Desiree Di Mauro at (202) 475-7017 or write
tO U.S. EPA. Permits Division (EN-336), 401 M St. SW, Washington DC 20460.
The Office of Water Enforcement and
Permits has recently become aware of
misleading advertisements for hazardous
waste training courses offered to POTWs.
Not all of these courses are taught or
sponsored by U.S. EPA and statements -
made in the brochures may be mislead-
ing. If you are interested in taking an
EPA course, we encourage you to verify
the authenticity of these courses with
your state or EPA regional office before
Passaic Valley Sewerage Commissioners
are attempting to design a portable sampler
for floatable oil and grease. If any other
POTW has already developed such a
device, Passaic Valley would appreciate
any information you could provide. Please
contact Phil Polios, Industrial Pretreatment
Section, CN-029, NJ Dept. of Environ-
mental Protection, Trenton, NJ 08625-

The deadline for one of the pretreatment pro-
gram changes resulting from the PIRT amend-
ments (53 FR, 40562, Oct. 17, 1988) was No-
vember 16, 1989. By that date all approved
POTW programs must have a minimum penalty
authority of $1,000 per day per violation for each
day that an industrial user is in violation of the
POTW’s pretreatment program (revised section
40 CFR 403.8(f)(1)(vi)(A)). Programs which
need a change in state law to implement this
change have until November 16, 1990, to com-
ply. For more information, see Federal Register
53, 40562, Oct. 17, 1988, or Pretreatment Bulle-
tin #5.
The POTW Sludge Samuling and Analysis
Guidance Document was finalized in August
1989, and is now available. The guidance, which
was distributed in draft in June 1988, was devel-
oped to assist POTW operators, and permit
writers in establishing and implementing a
sampling and analysis program, gathering infor-
mation on sludge quality, and developing and
determining compliance with permit conditions.
This guidance is based on current, state-of-the-
art field and laboratory practices and therefore is
recommended for all sludge sampling and
analysis programs. To obtain a copy of the final
guidance please contact Cristina Morrison at
(202) 475-9535 or you may write for a copy at
U.S. EPA, Permits Division (EN-336), 401 M St.
SW, Washington, DC 20460.
In November 1988, EPA proposed to promulgate
amendments to the General Pretreatment Regula-
tions requiring all POTWs with approved pre-
treatment programs to develop enforcement
response plans describing how the POTW will
investigate and respond to instances of noncom-
pliance. In conjunction with this rulemaking
and in recognition of POTW enforcement
difficulties, EPA has developed the Guidance
for Developing Control Authority Enforcement
Response Plans . This guidance is intended to
provide municipal pretreatment personnel with
recommendations for assessing enforcement
authorities, determining appropriate enforcement
roles for personnel, and deciding upon enforce-
ment remedies for specific violations. To further
assist Control Authorities in meeting the pro-
posed changes to the General Pretreatment
Regulations, the manual includes a model en-
forcement response guide and a detailed analysis
of each of the common enforcement remedies.
The Agency believes that the process of develop-
ing these plans will be very valuable in helping
POTWs decide what resources are needed to
enforce their pretreatment programs and how
they will actually deal with industrial user
violations. Such plans will also make it much
easier for the approval authority to determine
whether a POTW is complying with its pretreat-
ment implementation requirements for
enforcement.This manual complements an
earlier document prepared by EPA entitled,
Pretreatment Compliance Monitoring and
Enforcement Guidance (PCME) (September
The guidance was initially printed in early De-
cember and will be distributed to all POTWs
with approved pretreatment programs, approved
pretreatment states, and Regional pretreatment
coordinators. If you would like a copy of this
document and you are not jn this group of initial
recipients, please send a written request to: U.S.
EPA, Enforcement Division (EN-338), 401 M
St. SW, Washington, DC 20460.

As protection of the environment continues into the 1990s, environmental protection profes-
sionals must move beyond a singular focus on end-of-pipe clean-up methods. EPA ’s goal is to stop
pollution from occurring by promoting programs that recycle waste products and reduce sources of
pollution. Pollution prevention in the pretreatment program can be encouraged at the state, local,
and federal levels.
At the state level an example of pollution prevention in pretreatment is a program being de-
veloped in the State of New Jersey. New Jersey has proposed a statewide industrial hazardous sub-
stance source reduction and recycling program. Through legislative and administrative changes, the
Department of Environmental Protection (NJDEP) will implement the program both through exist-
ing program offices and through a new centralized pollution prevention office in the NJDEP.
The pollution prevention program in New Jersey involves two steps: facility self-identifica-
tion of pollution prevention opportunities and facility-wide permitting.
In developing the pollution prevention program, the NJDEP sponsored a study of the pre-
treatment program and the elements of the program which encourage or discourage pollution preven-
tion, primarily hazardous waste reduction. The writers of the study found that the pretreatment
program must be viewed as a vigorous program, rather than as a means of disposing of pollutants, if
it is to meet the goals of the pollution prevention program. The writers identified 4 elements of the
pretreatment program which have the potential to directly encourage pollution prevention among
industrial users.
The first of these elements is the use of NJPDES pretreatment permits to industrial users to
encourage them to explore methods of pollution prevention that could act as pretreatment tech-
The second element involves possible changes in pretreatment requirements in exchange for
use of pollution prevention techniques. For example, the control authority may choose to remove a
monitoring requirement for a certain pollutant if the industrial user can demonstrate that the pollut-
ant is no longer present in the waste stream due to pollution prevention technology.
The third element of the program involves education and technical assistance for indirect
dischargers. Through education, New Jersey hopes to demonstrate the benefits of pollution preven-
tion to industrial users.
The fourth element that indirectly encourages pollution prevention is the issuance of more
stringent local limits and new categorical standards. With newer, stricter standards, indirect dis-
chargers will seek Out new, more inventive methods to meet the new requirements.
Just as at the state level, pollution prevention can also be a goal of local pretreatment pro-
grams. Pretreatment staff at POTWs can encourage this practice through a number of techniques:
‘/ Through enforcement of stringent standards and local limits, pretreatment personnel can en-
courage new industries to seek the least polluting technology for their particular industries.
‘/ Pretreatment staff can encourage industries to prevent pollution by finding alternative mar-
kets for production by-products; this action turns pollutants back into production raw materials.
(continued on p. 8)

(Pollution Prevention, continued)
/ The writer of a pretreatment control
mechanism can further help EPA reach its goal
of pollution prevention through awareness of
cross-media effects of various methods of pollu-
tion control.
Pretreatment staff can help with technol-
ogy transfer by making pollution prevention
information available to their industrial users.
The benefits of pollution prevention for a
locality are numerous. With a pollution preven-
tion program in place, a local wastewater treat-
ment plant runs less risk of pass through and
interference, simply because the plant does not
receive as many hazardous pollutants and has
more of a safety zone regarding the amount of
pollutants it can handle. Equally important,
pollution prevention will result in better receiv-
ing stream water quality.
At the federal level, EPA encourages the
use of pretreatment control methods which,
rather than moving pollution between media,
prevent pollution from occurring. Training
courses are helpful in teaching permit writers to
write permits that are sensitive to these cross-
media effects.
EPA’s Pollution Prevention Information
Clearinghouse (PPIC) is a public outreach
project regarding pollution prevention. The
PPIC is part of EPA’s plan for reaching its goal
of pollution prevention by using technology
transfer, education, and public awareness. The
PPIC consists of four information exchange
sources for use by individuals interested in
pollution prevention:
1) Repository - a reference library con-
taining current information on pollution preven-
tion. Sources of information include case stud-
ies, educational materials, legislation review, and
fact sheets.
2) Electronic Information Exchange
System (ELES) - a computerized link to informa-
non. With this system, which is accessible by
any personal computer equipped with a modem,
the user can access data bases or order docu-
ments on pollution prevention. Information
found in this system includes a directory of
pollution prevention experts, case studies, and a
calendar of upcoming pollution prevention
3) Hotline - a free telephone service to
answer questions regarding pollution prevention
and provide a link with EIES for users without
access to a modem-equipped personal computer.
4) Outreach efforts - availability of
training sessions and packets containing general
and industry-specific pollution prevention
Individuals involved in the pretreatment
program can improve the prevention potential of
their programs by using the PPIC. For more
information on the PPIC, contact Myles E.
Morse, Office of Environmental Engineering and
Technology Demonstration at (202) 475-7161 or
Priscilla Flattery, Pollution Prevention Office at
(202) 245-3557, or by writing to her at the
Pollution Prevention Office, U.S. EPA, 401 M
St. SW, Washington, DC 20460. To have your
name included on the mailing list to receive
“Pollution Prevention News,” a monthly publica-
tion of the Pollution Prevention Office, contact
Priscilla flattery at the above address.
Pretreatment is a prime route by which
all levels of government can move closer to
EPA’s goal of pollution prevention. By using
tools such as pretreatment control mechanisms
(permits) and the PPIC, great strides can be
made at the federal, state, and local levels toward
preventing pollution.

The headworks analysis computer pro-
gram (PRELIM version 3) used in local limits
development has been upgraded and is now
undergoing testing. The new version, PRE-
LIM 4, is expected to be ready for release and
distribution to interested parties in the Spring
of 1990. Among the improvements included
are: changes that update the program to be
consistent with the 1987 Local Limits Guid-
ance, closer tracking of the data entry sheets,
the decile approach to calculate removal
efficiencies, unlimited number of industries
that can be entered, and pull-down menus.
EPA is now in the process of preparing a list
of users interested in receiving the new ver-
sion of PRELIM. if you want a copy of
PRELIM 4, please complete the form on the
next page and send it to John Hopkins (EN-
336), Permits Division , U.S. EPA, 401 M St.
SW, Washington, DC 20460.
In response to Section 519 of the Water
Quality Act of 1987, EPA has undertaken a com-
prehensive study of the pretreatment program. A
Report to Congress on the results of the study is
due in February 1991. Section 519 directs EPA
to address several aspects of the pretreatment
program in the Report to Congress:
* Adequacy of data on environmental
impacts of toxic discharges from POTWs
* Toxic pollutant removal efficiency of
secondary treatment
* POTWs’ capabilities to revise national
* Study of alternative regulatory strate-
gies, focussing on POTW ability to meet sludge
standards and adequacy of federal, state, and
local resources to establish, implement, and
enforce pretreatment limits
* Recommendations for improving
pretreatment requirements
The major objectives of the study are to
document and evaluate the environmental effec-
tiveness of the pretreatment program and to
identify and analyze improvements that would
enhance the program’s ability to achieve its
environmental objectives. The study will be
based principally on existing information and
involve a major effort to collect existing POTW-
specific data. Data collection efforts have begun
and are expected to continue into the summer of
The Office of Water Enforcement and
Permits is responsible for preparing the Report.
Contact Debora Clovis at (202) 475-7052 or
write to U.S. EPA, Permits Division (EN-336),
401 M St. SW, Washington, DC 20460 for
additional information.

(Please fold and staple to return)

John Hopkins (EN-336)
U.S. Environmental Protection Agency
401 M St. SW
Washington, DC 20460
•• • • S S.
• .
: m :
S. • • •

Categorical standards (#1, attachment A)
Changes to...(#2, p. 7 )
Compliance dates (#3, p.3)
Implementation of...(#2, p.5)
Industries considered for...(#3, p.4)
Industries subject to categorical standards, fmal regulations (#1, att.B)
Isolated wastestreams (#4, p.3)
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-
Impacts on pretreatment (#3, p.!)
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.3)
Enforcement Actions-
Borjohn Optical Technology, Inc. (#7, p.5)
Kopper’s Settlement (#6,p. 3)
Ocean Spray Cranberries, Inc. (#6, p.3)
Pretreatment Enforcement Initiative (#6, p.2; #7, p.2)
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 Amendments (#2, p.1)
Guidance Document Summaries-
Developing Control Authority Enforcement Response Plans (#7, p. 4)
Development of Industrial User Permits (#3, p.9; #4, p.5; #6, p.7)
Enforcement Response Guide (#6, p.5; #7, p.6)
Evaluating and reporting POTW noncompliance (#3, p7)
Identification of hazardous wastes delivered to POTWs by truck, rail, or dedicated pipe (#3, p.9)
Local limits, Technical Guidance (#2, p.12)
Local limits, Additional Guidance (#6, p.6)
PCME guidance and training materials (#3, p.6; #6, p.5)
Preventing Interference at POTWs (#2, p.13)
Sewage Sludge Sampling and Analysis Guidance (#7, p.6)

Slug Discharges
Discharge Control (#3, p.10)
Lo&lings to POTWs (#6, p. 5)
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)
Pollution Prevention (#7, p.7)
PRELIM 4 (#7,p.9)
Pretreatment Enforcement Initiative (#6, p.2; #7, p.3)
Pretreatment Excellence Awards (#6, p.1)
Winners announced (#7, p.1)
Pretreatment Implementation Review Task Force (PIRT)
Deadline for penalty authority changes (#7, p.6)
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)
Regulatory changes (#5, p.1)
Pretreatment Report to Congress (#7, p.2)
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 for interim implementation of sludge requirements in permits issued to POTWs (#4, p.1)

PCME (#3, p.6; #5, p.3)
PRELIM (#2, p.11)
PPETS (#3, p.7; #4, p.7)
Storm Water Regulations (#6, p. 5)
Superfund wastes and POTWs (#4, p.5)
City Attorneys’ Workshop, update on development of (#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)

u .S. Environmental Protection Agency Hi t-aass Mall
Office of Water Enforcement and Permits Paid
EN-336 Pen tNo.G-35
401 MSt.SW
Washington, DC 20460
Official Buslnesa
Penalty for Private Uao