U.S.Environmental Protection Agency • Washington, D.C.

Since the beginning of this
country, wastes from the nation's
industry and other activities were
dumped primarily into the coun-
try's waterways. It was thought that
these wastes would eventually de-
compose and disappear harm-
lessly and the water would purify
itself. It became clear as the coun-
try grew and industry and sewer
discharge increased, the waters'
ability to cleanse itself was being
In the 1800s and early 1900s, the
problem was addressed through
various legislative initiatives, such
as the Rivers and Harbors Act, the
Public Health Service Act, the Oil
Pollution Control Act, the Water
Pollution Control Act, the Water
Quality Act of 1965, and the Clean
Water Restoration Act of 1966.
These attempts at regulating the
pollution problem often were inef-
fective since water control require-
ments were established by the
states and were based primarily on
waterbody uses, such as drinking,
swimming, fishing, and navigation.
In 1972, the U.S. Congress
passed the Federal Water Pollution
Control Act that established clearly
that pollution of the nation's water-
ways by either industry or munici-
palities was unlawful. The act also
created a system of uniform control
for discharge of pollutants.
Also early in the 1970s, the Fed-
eral government established the
Environmental Protection Agency
to control toxic pollutants, regulate
industrial discharges, develop ef-
fluent guidelines, and develop
technical data. EPA was organized
into a headquarters group with five
offices and 10 regional offices to
carry out its assignment.

Office of Water,
OWRS, and
Within the Environmental Protection Agency,
the Office of Water is responsible for develop-
ing effluent guidelines and standards for indus-
trial dischargers. This task is delegated to the In-
dustrial Technology Division (ITD) of the Of-

l: iH


fice of Water Regulations and Standards. ITD
develops uniform technology-based effluent
limitations for industrial facilities discharging
directly into the nation's waters and for those
who discharge into municipal treatment facili-
ties . The overall objective is to eliminate pollut-
ant discharges by establishing uniform national
technology-based regulations.
Over the past 15 years, regulations for 50 in-
dustrial categories have been passed and 15
additional studies are in progress. These guide-
lines are technology based, that is, they are es-
tablished to achieve effluent pollutant reduc-
tion attainable by waste treatment technologies
actually employed within an industrial category.

ITD is a group of chemical engineers, chem-
ists, and environmental engineers dedicated to
the task of developing industrial water pollution
control regulations that will enhance the quality
of the nation's surface waters. This division is
are Involved
composed of some of the best technical experts
in the field who have had a profound influence
on the public policy of the United States con-
cerning the environment. The public interest is
served here through technical excellence, and
the work is being accomplished by a dedicated
cadre who take into consideration the nations
environmental and economic concerns in estab-
lishing water pollution control regulations.

ITD utilizes the Project Management con-
cept. Major projects are handled by a project
team headed by a project manager who coordi-
nates all aspects of the project.
As required by the Clean Water Act, effluent
guidelines must incorporate a number of fea-
tures to assure the equity as well as the enforcea-
EPA Employs
the Project
Concept with
All Task Re-
Resting with
the Project
bility of the regulations. Many of these features
are common to engineering feasibility studies in
general; however, other features, such as the
opportunity for public comment and the specific
internal review procedures by EPA are unique
to the guideline promulgation process.

Developing effluent guidelines and standards
is a process that is complex and professionally
challenging. Activities include engineering,
chemical and economic impact studies as well
as environmental impact studies.
ITD develops a detailed profile of the indus-
try; i.e., processes that generate waste and
amounts and types of pollutants discharged.
Pollutants of concern and technologies for
treating them or process modifications to re-
duce or eliminate them are then selected. A
determination to subcategorize or not is made
so that guidelines and standards apply to all
industrial processes within that industry. Full
consideration is given to recycle, reuse, and
waste prevention.

The Clean Water Act requires consideration
of costs and the economic effects of the regula-
tion upon the affected parties. ITD prepares an
estimate of the total investment and operation
and maintenance costs of complying with each
technology option. In some analyses these cost
estimates are provided on a model plant basis,
where the models may be defined by production
process, volume, size, etc. In other cases, cost
estimates are based upon upgrading existing
treatment on a plant-by-plant basis using a typi-
cal plant in a category or subcategory to be
regulated. The cost data are input to an eco-
nomic impact analysis that determines achieva-
bility of each treatment option. This analysis is
conducted by the economic staff at OWRS.
ITD Provides
Rulemaking for
Once the treatment options are identified
from a technical standpoint, another important
step is to evaluate economics and to select a
technology as the basis of the guideline. This
technology must take into consideration the
selection of individual pollutant parameters for
This selection process involves a thorough
analysis of literature and collected industry
data, plus detailed sampling, screening, and veri-
fication programs, e.g., analyzing raw and
treated wastewater streams from several opera-
tions. The analyses determine which pollutant is
present, the control technologies available, and
where the most effective removal can take place,
in the plant or at the end of the pipe.

There are three groups of industrial pollut-
ants for which effluent limitations, standards,
and guidelines are established: conventional,
toxic, and nonconventional. Conventional are
the most familiar group and include biochemical
oxygen demand, suspended solids, fecal coli-
forms, pH, and oil and grease. Toxic pollutants
include 65 priority pollutants and classes of pol-
lutants considered to be toxic. This classification
has been further refined to a list of 126 specific
toxic pollutants. Nonconventional pollutants in-
clude any pollutant not identified as either con-
ventional or "toxic". (In practice this classifica-
tion adds up to hundreds of pollutants.)
The effluent guideline generally limits the
mass of each individual pollutant that can be
discharged per unit of production at an indus-
trial facility. The production-based and concen-
tration-based concepts have been further used
to prevent the dilution of wastewater streams in
order to meet concentration limits and also as a
means of encouraging water reduction and recy-
ITD also determines the numerical limits of
the guidelines using the treatability data for the
selected technology. Only after these steps are
completed does ITD propose the guideline and
standard and the process is opened up to the
public for comment. After all issues are re-
solved, the guidelines and standards are pub-
lished in the Federal Register.
creates a
Database for

To implement the final effluent limitations
and standards, each direct discharger is required
to obtain a National Pollutant Discharge Elimi-
nation System permit. This NPDES permit
translates the limitations and standards into re-
quirements for each direct discharger's release
of treated wastewater. The pretreatment stan-
dards for indirect industrial dischargers are en-
forced by Publicly Owned Treatment
Works(POTW), which also hold NPDES per-
The scope of ITD's task requires highly
trained technical people whose primary interest
is improving the quality of the nation's water.
That is why ITD focuses on people with techni-
cal know-how in its hiring process.

Since 1972, ITD has had the lead responsibil-
ity with the Office of Water to develop effluent
limitations for 50 industries, including pulp and
paper, nonferrous metals forming, ore mining,
petroleum refining, pharmaceutical, plastics
molding, porcelain enameling, steam electric,
textiles, timber, organic chemicals and plastics,
and iron and steel.
In a little more than 10 years, many of the
bodies of water in this country have been re-
vived. A decade ago, science couldn't detect
some of these compounds. Today they are being
removed at the rate of over 800 million pounds
per year.	10 Years of
With its technical expertise, its emphasis on Cleaning up the
scientific know-how, its ability to develop and A/atfon s Wafers
implement new technology, ITD provides a
valuable service to meet the public's desire to
clean up the nation's rivers, streams, lakes and
coastal waterways.
ContaotMark Luttner
Deputy Director ITD
401 MSt. $.W> WH 552
Washington, &C. 20460

The Water Quality Act of 1987 strengthened
the Clean Water Act by adding Section 304(m)
which requires that the Agency publish plans to
revise existing effluent guidelines and promul-
gate new guidelines for dischargers of toxic and
nonconventional pollutants. Building on the ex-
isting national effluent guidelines program, a
Impact of strategy is evolving on how to identify and select
1987 Water potential industrial candidates for study and for
Quality Act regulatory action where necessary.
These new projects will emphasize pollution
prevention techniques which rely on reuse and/
or recycle of chemicals that would otherwise be-
come wastes. The program has identified 15
industrial categories for which new or revised
regulations may be developed in the 1990s in-
cluding: Hazardous Waste Treatment; Solvent
Recycling; Machinery Manufacturing and Re-
building; Transportation Cleaning; Paint Manu-
facture and Formulation; Industrial Laundries;
Hospitals; Waste Oil Reclamation and Refin-
ing; Drum Reconditioners; Oil and Gas (on-
shore and coastal subcategories); Copper Form-
ing; Timber Products Processing; Textile Manu-
facturing; Pharmaceutical Manufacturing; and
Organic Chemicals, Plastics, and Synthetic Fi-
bers (reserved priority pollutants and noncon-
ventional pollutants).

Office of Water
Industrial Technology Division
401 M St.S.W. Washington, D.C. 20460