DRAFT
DEVELOPMENT OF INDUSTRIAL USER PERMITS
UNDER THE PRETREATMENT PROGRAM
U.S. Environmental Protection Agency
Region VIII
August 1985
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
ONE DENVER PLACE — 999 18TH STREET - SUITE 1300
DENVER, COLORADO 3C202-2413
October 1, 1985
U.S [-.PA Region 8 Library
80C-L
999 I8!fi SI , Suilc 500
Denver, CO 80P02-2466
We are pleased to present the following draft guidance materials to
the Publicly Owned Treatment Works (POTW) on development of discharge
permits for industrial users of the sewer system. Effective implementa-
tion of the Pretreatment Program depends heavily on the quality of the
control mechanism (i.e., the permit or contract) used to establish the
Industrial User's discharge limitations and wastewater management
conditions. This document provides an outline of the procedures normally
followed in the environmental permitting process.
As the materials contained in this guidance are currently in draft
form and subject to Agency wide peer review, we invite and encourage your
comments on the manual. Questions and comments on this document should
be addressed to:
Pretreatment Program Coordinator
Compliance Branch
Water Management Division
U.S. Environmental Protection Agency
999 18th Street
Denver, Colorado 80202-2413
Telephone (303) 293-1589
Sincerely yours
Max H. Dodson
Director
Water Management Division
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ACKNOWLEDGMENT
This document was prepared by EPA Region VIII Water Management Division.
Assistance was provided by Science Applications International Corporation
under EPA Contract No. 68-01-7043.
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TABLE OF CONTENT
Paae
1. INTRODUCTION 1-1
2. THE PERMIT AS A CONTROL MECHANISM 2-1
3. PERMIT DEVELOPMENT PROCEDURES 3-1
3.1 EVALUATING INDUSTRIAL USER DATA 3-4
3.1.1 Review of Permit Application 3-4
3.1.2 Background Information Review 3-6
3.1.3 Facility Inspection 3-7
3.2 DEVELOPING DISCHARGE EFFLUENT STANDARDS 3-9
3.2.1 National Categorical Pretreatment Standards. . 3-10
3.2.2 Local Limits 3-12
3.2.3 Best Professional Judgment Provisions 3-14
3.3 DEVELOPING MONITORING/REPORTING REQUIREMENTS 3-15
3.3.1 Monitoring Requirements 3-16
3.3.1.1 Sampling Points 3-16
3.3.1.2 Frequency of Sampling 3-17
3.3.1.3 Sample Type 3-17
3.3.2 Reporting Requirements 3-13
3.4 ESTABLISHING SPECIAL CONDITIONS REQUIREMENTS 3-19
3.4.1 Best Management Practices 3-19
3.4.2 Compliance Schedules 3-20
3.5 ESTABLISHING GENERAL CONDITIONS 3-20
3.6 PREPARING FACT SHEET 3-22
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APPENDICES
APPENDIX A EXAMPLE PERMIT
APPENDIX B PERMIT FACT SHEET
APPENDIX C USE OF THE COMBINED WASTESTREAM FORMULA
APPENDIX D BEST MANAGEMENT PRACTICES
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1. INTRODUCTION
The General Pretreatment Program is a regulatory program for the control of
the discharges of pollutants to a Public Owned Treatment Works (POTWs) that
might interfere with plant operations, pass through the plant untreated, or
impair the quality of the plant's sludge (limiting reuse or disposal
options). Under the General Pretreatment Program regulations, the Control
Authority must be able to regulate the contribution to the POTW from each
Industrial user assuring compliance with pretreatment standards and
requirements. The issuance of wastewater discharge permits to indirect
dischargers (industries discharging to a POTW system) generally provides the
most effective control mechanism available for regulating industrial users.
In addition, it can effectively accommodate changes in environmental
regulations for Industrial processes. Since no two industrial users are the
same, a permit system provides an efficient means for varying limitations,
monitoring and reporting requirements.
Industrial discharge permits serve two essential functions. First, the
permit is a vehicle for establishing clear and explicit requirements
relevant to each Industrial user (IU). Through the permit, an IU will
better understand Its obligations for compliance with the Pretreatment
Program's requirements. Secondly, the POTW's ability to enforce the
standards becomes significantly enhanced through use of this strict
liability mechanism. In addition, the permit issuance process provides an
opportunity for the POTW and the IU to become more familiar with the kinds
of waste materials and potential waste materials that may be discharged from
the industrial facility.
This manual provides guidance to POTWs in developing wastewater discharge
permits. Chapter 2 provides an overview of the permit as the primary
enforcement and control mechanism. Chapter 3 details step-by-step permit
development procedures.
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2. THE PERMIT AS A CONTROL MECHANISM
A POTW's authority to control IU discharges through a permit system must
have a sound legal foundation. This authority 1s usually derrlved from the
POTW's sewer use ordinance and/or rules and regulations. The permit writer
should be familiar with the extent of the POTW's legal authority for Issuing
and enforcing permits. Once Issued, the permit becomes an enforceable
document. A violation of any permit condition then constitutes a violation
of the POTW's sewer use ordinance (or rules and regulations) and subjects
the permittee to enforcement actions and penalties authorized by the POTW's
sewer use ordinance.
To ensure Its enforceability, wastewater discharge permits must:
• Use specific language
t Contain concise and complete conditions and requirements
• Be clearly and simply written.
The POTW must be concerned that Its ability to enforce pretreatment program
requirements 1s not somehow compromised by weak, vague, or obtuse language
In the permit. For example, phrases such as:
It Is recommended that the permittee....
Results should not exceed....
The permittee may not....
Dally maximum violations ma^ be determined by....
The permittee is expected to....
Each contain a word (underscored) that undermines the enforceability of the
permit. These phrases should be written:
The permittee 1s required....
Results are not to exceed....
The permittee shall not....
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Dally maximum violations shall be determined by....
The permittee 1s required to....
In order to maintain the enforceability of the permit requirements.
It Is often necessary to take the complex pretreatment program requirements
and present them 1n a concise simplified manner. The permits must clearly
specify such Items as:
• Wastewater discharge requirements and limitations
• Dates (issuance date of permit, dates for compliance with discharge
limits, expiration date of permit)
• Self-monitoring requirements
a. The types of samples required (e.g., composite or grab)
b. The frequency of sampling, and
c. The location from where the sample 1s to be taken (e.g., final
control manhole prior to entering the POTW sewer main)
• Reporting requirements (e.g., how much data, how often, to whom it
1s to be sent, etc.)
• Analytical procedures to be followed In testing samples (e.g., all
samples must be performed in accordance with approved EPA procedures
published at Title 40, Part 136 of the Code of Federal Regulations)
• Special conditions where necessary (e.g., compliance schedules, best
management practices)
• General conditions and ordinance requirements
t Violation determination (e.g., any single sample, either grab or
composite, 1n excess of the daily maximum limitation shall be a
violation of this permit).
Because the permit will likely be used by the IU as the primary information
document explaining Its responsibilities for compliance, the permit require-
ments must be clear. An unclear presentation of the requirements could be a
cause for challenge of the permit by the IU.
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3. PERMIT DEVELOPMENT PROCEDURES
Formally documented permit issuance procedures will ensure that all aspects
of the permit development process are considered In the drafting of and IU's
permit. In addition, these procedures will help to establish fair and
consistent treatment by the POTW in the permit issuance process.
Usually the POTW's sewer use ordinance or rules and regulations require an
IU to complete and file a permit application to obtain a wastewater
discharge permit. Much of the permit application Information may have
already been gathered by the POTW using Industrial Wastewater Surveys during
pretreatment program development. The Baseline Monitoring Report (BMR),
required to be submitted by Industries subject to National Categorical
Pretreatment Standards also contains much of the relevant information. Thus
the POTW may wish to accept an IU's BMR or Industrial Wastewater Survey as
part of the application. Guidance on the development of permit application
or survey forms is provided in pretreatment guidance documents. A list of
these documents can be found 1n the bibliography at the end of this manual.
A POTW's sewer use ordinance or rules and regulations normally describe a
timeframe for issuance of a permit. Once the permit application has been
received, the POTW should complete the application review process, draft a
permit, send It to the Industrial user for review and comment, then Issue
the final permit. (There may be a need for the user and POTW staff to meet,
discuss and negotiate the conditions 1n the draft permit). Ideally, the
process should take no more than 60 days from review of permit to Issuance
of the final permit.
There are a number of general procedural steps that the POTW must follow in
developing the technical requirements of an IU's pretreatment program
permit. These steps are listed 1n brief form in Table 1. Each of these
steps Is further discussed In this chapter. Depending on the complexity of
the Industry being reviewed, various steps might be omitted for specific
permits. For Instance, if National Categorical Pretreatment Standards are
available, the POTW may not need to conduct an extensive toxic pollutant
assessment of the IU's process wastestreams. On the other hand, all IU
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TABLE 1
OUTLINE OF STEPS FOR THE DEVELOPMENT OF
INDUSTRIAL USER DISCHARGE PERMITS
I. EVALUATION INDUSTRIAL USER DATA
A. Permit Application Review
Is the application complete?
Does any supplemental Information need to be requested?
Are additional toxic pollutant information and/or data
required?
B. Background Information Review
Has all available file Information been compiled?
Is reference Information available?
Is the available information adequate?
Is it necessary to request supplemental information?
C. Facility Inspection
Will an onslte visit help the permit writer understand the
operation?
Is the facility a complex operation?
Is the available Information Inadequate or does it require
verification 1n order to prepare a permit?
Is there a history of compliance problems?
Are Best Management Practice (BMP) requirements needed?
(If there are significant surface runoff problems, a
history of spills and leaks, or onslte storage, treatment
or disposal of hazardous wastes, BMPs would appear
appropriate).
II. DEVELOPMENT WASTEWATER DISCHARGE EFFLUENT STANDARDS
Are National Categorical Standards applicable?
Are toxic substances used, produced, and/or present In the
effluent?
Do any toxic pollutants need to be limited?
Is the present treatment system adequate to treat toxi-
cants anticipated to be present?
What 1s the economic achievabillty of various technologies
available to treat the toxicants of concern?
Does the POTW need to develop specific limitations based
on its application of Best Professional Judgment (BPJ)?
Do the local limit requirements apply to any pollutants
anticipated to be in the effluent?
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TABLE 1
OUTLINE OF STEPS FOR THE DEVELOPMENT OF
INDUSTRIAL USER DISCHARGE PERMITS (CONTINUED)
II. DEYELOP WASTEWATER DISCHARGE EFFLUENT STANDARDS, continued
Does the IU have a known or potential to impact the POTW's
operating conditions?
Are POTW limits more stringent for any parameters?
Does the POTW have local limits or non-toxic and/or
conventional pollutants specified by ordinance or
regulation?
Are any guidelines on the regulation of non-toxic and/or
conventional pollutants available?
Is existing treatment adequate to control non-toxic and/or
conventional pollutants?
III. DEVELOP MONITORING/REPORTING REQUIREMENTS
IV. ESTABLISH SPECIAL CONDITIONS/REQUIREMENTS
A. Define Best Management Practices (BMPs)
Are toxic or hazardous substances handled?
Is there potential for discharge of toxic or hazardous
substances from ancillary activities?
Is it appropriate to require a BMP plan?
Is a plant inspection needed?
Can specific BMP requirements be defined?
V. ESTABLISH GENERAL CONDITIONS
VI. PREPARE A RATIONALE AND FACT SHEET
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pretreatment program pernrits require review of the application to determine
any necessary effluent limits and operating conditions.
A sample pretreatment permit 1s presented In Appendix A as an example of the
application of the permit development steps to actual permit cases. THe
sample is a hypothetical draft permit with ficticious names, places, and
associated data. Appendix B 1s the Fact Sheet Supporting the permit.
3.1 EVALUATING INDUSTRIAL USER DATA
The Initial step 1n the preparation of an IU's permit Includes review of
industrial user data contained in the permit application and other pertinent
background information, followed by a facility inspection.
3.1.1 Permit Application Review
A completed permit application should provide the following basic
Information:
1. Name, mailing address, location address, and telephone number of
the facility
2. Name of the responsible official at the facility and identification
of the facility contact
3. Nature of the facility's operations
4. A schematic diagram Indicating the process sequence and flow as
well as Identification of points of discharge to the POTW
5. Information providing an understanding of the representative
quality of the discharge
6. A brief discussion of the pretreatment system used by the facility
7. A brief discussion of the compliance program taken by the facility
to comply with applicable pretreatment standards
3. A brief discussion of the manner in which any residual solids are
disposed.
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The permit writer may find a review checklist to be helpful 1n evaluating
the completeness and adequacy of the completed permit application. Any
deficiencies or additional Information needed should be noted.
In reviewing the Industrial user's Information, particular attention should
be given to:
• Information on the use, production and discharge of toxic
substances, and
• Information on all wastestreams (schematic flow diagram, flows and
waste characterization of individual wastestreams).
Information on the use or production of toxic pollutants at a facility and
adequate sampling data on toxic pollutants in effluents are essential to the
preparation of adequate permit limits for toxic pollutants. Industrial
users should provide a comprehensive list of toxic substances used, produced
(as product, by-product, or Intermediary) stored, known or suspected to be
present 1n the wastestream. Specific organic constituents of trade name
products or compounds should be obtained from the manufacturers.
Schematic diagrams of facility operations and Internal water and wastewater
streams should be reviewed to Identify regulated, non-regulated and dilution
streams. Waste characterization (through sampling and analysis) of
Individual wastestreams may be necessary.
EPA experience 1n the National Pollutant Discharge Elimination System
(NPDES) program's regulation of surface water discharges has shown that
toxic pollutant data on the final effluent may not always be adequate for
complex facilities where Internal wastestreams can be diluted by large
volumes of cooling water prior to the sampling point. Further, any facility
subject to a National Categorical Pretreatment Standard is required to meet
the standard prior to mixing with any non-regulated and dilution waste-
waters. If sampling at the end of the regulation process or treatment of
the regulated process prior to being combined with dilution or non-regulated
wastewaters is not feasible, the POTW must utilize the combined wastestream
formula to adjust the allowable discharge standard. Further guidance on use
of the Combined Wastestream Formula is provided in Appendix C.
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In some cases, data on the waste characteristics of Internal wastestreams,
particularly treatment unit effluents, may be needed to assess the adequacy
of existing pollution controls and the feasibility of achieving greater
reductions 1n the discharge of toxic (priority) pollutants. A good example
of such a situation is the control of cyanide waste in the metal finishing
industry. Cyanides must be monitored directly after cyanide treatment
(generally a preliminary stage of treatment for some types of metal
finishing wastes) unless the standard Is adjusted using the combined
wastestream formula.
3.1.2 Background Information Review
In addition to the permit application and/or BMR, several items of
Information may be needed to adequately prepare a permit. Some Items which
might already be in the permit file or office Include:
a. Water use records (this information can be used to verify flow data)
b. Facility's BMR (this Information can assist Identifying any changes
1n production/operation procedures, wastestream characterization or
flows, pretreatment facilities)
c. A current permit
d. The fact sheet (rationale) for the current permit
e. Industrial self-monitoring reports
f. POTW compliance inspection/monitoring reports, and
g. Any correspondence concerning compliance problems, changes in plant
conditions and communications with other agencies.
Other information available to assist the POTW In the permit development
Include:
a. National Categorical Pretreatment Standards
b. Development documents supporting National standards
c. Reference textbooks on specific Industry categories
d. EPA's Treatability Manual
e. RCRA regulations.
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As needed, supplemental data may be available from the State Agency, the EPA
Regional Office, or a university or local library.
The POTW must assess the Impact of the pollutants (particularly toxic pollu-
tants) discharged by the III on treatment plant operations, receiving stream
water quality and sludge disposal practices. The POTW may have already
completed this assessment during pretreatment program development. However,
if an Industrial user discharges a toxic pollutant for which a local
analysis has not previously been determined, the POTW must examine that
pollutant's potential impact to the POTW as part of the permit development
process. In these cases, the POTW may also need information on State Water
Quality Standards, receiving water quality data, sludge disposal regulations
or criteria to conduct this assessment.
3.1.3 Facility Inspection
A facility Inspection Is a useful mechanism to verify application
Information and to gain an understanding of the IU's facilities. It 1s
Imperative that a site visit be made to the IU, particularly 1f:
• Significant pollution control or treatment Improvements will be
required
• Additional monitoring to characterize the wastewater Is needed
• Frequent problems with complying with the present permit have
occurred or potential or known problems with spills
• Leaks or contaminated surface runoff have been noted.
For an Inspection to be most useful, it must involve more than a general
discussion of plant activities and a quick tour of waste treatment
facilities and outfalls. A proper Inspection encompasses review of the
following:
1. Production processes. This will assist the permit writer In an
evaluation of:
a. Applicable categorical pretreatment standards
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b. What toxic or hazardous substances may be present 1n raw
materials and associated contaminants, 1n products and In
by-products
c. Water uses and resulting wastewater streams
d. Existing In-process pollution controls
e. Potential for spills and leaks
From this Information, the permit writer may wish to either select
toxic pollutants to be limited and/or require an evaluation of
possible In-process controls.
2. The sewer layout of the plant. If a sewer plan exists, the permit
writer needs to thoroughly review the plan to determine the course
and destination of each sewer lfne. The exact source and the point
at which each wastestream enters the sewer need also be
Identified. Existing monitoring or potential location for
monitoring should also be located
3. The wastewater treatment facilities, their performance and
operation and maintenance practices. This Information can be used
to evaluate the adequacy of existing treatment 1n assessing the
feasibility of improvements and In evaluating performance data.
4. The kinds of batch dischargers that occur at the facility.
5. The raw material and product storage and loading areas, sludge
storage and disposal areas, hazardous waste management facilities
Including onsite disposal areas and all process areas. This review
will help to Identify potential or known problems with spills,
leaks or contaminated surface runoff and determine the need for
additional controls through the establishment of specific Best
Management Practices (e.g., spill prevention plans, solvent
management programs, etc.).
6. Sampling methods and analytical techniques must be reviewed to
define any needed changes and to evaluate the quality of the
sampling data, both POTW and self-monitor1ng.
To conduct an adequate Inspection at a facility may require a full day.
Complex larger plants with several treatment systems, numerous outfalls and
extensive ancillary activities may require even more than one day to inspect.
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Time spent on plant Inspections during the development of the permit can
result In time savings during permit preparation. However, available
time/resources may not be adequate to allow as comprehensive an Inspection
as might be desired. In such cases, the permit writer should identify the
specific Information needed to complete permit development and conduct an
abbreviated Inspection to obtain this specific Information. Alternatively,
additional Information could be obtained from the next compliance monitoring
Inspection. This requires advance planning to review the permit application
and background information so that the compliance Inspector can be alerted
to specific information needs. Guidance on the performance of inspections
may be found in the following documents:
• USEPA Region VIII, Industrial Pretreatment Program Inspection
Manual - Draft, November 1984
• USEPA Office of Water Enforcement and Permits, NPDES Compliance
Inspection Manual, June 1934.
3.2 DEVELOPING DISCHARGE EFFLUENT STANDARDS
The primary purpose of the permit Is to convey specific wastewater discharge
limitations for each Industrial user discharging to the POTW. In determin-
ing which specific limits will apply to a particular industrial user the
permit writer must consider National Categorical Pretreatment Standards,
local limits (prohibited substances and numerical conventional, non-
conventional and toxic pollutant limits) and specific limits based on Best
Professional Judgment.' Each of these three types of wastewater discharge
limits 1s discussed further in this section.
In addition to containing the wastewater discharge limits that apply to a
particular IU, the permit should clearly Indicate where the limits will
apply. Generally, the IU Is required to be 1n compliance with the limits at
the point of connection to the sewer system. However, the IU may be
required to meet different limits at other points, such as National
Categorical Pretreatment Standards at the end of a regulated process or
after treatment, and local limits at the sewer connection point. In the
case where an IU has several connections the permits should identify each
connection and specify the limits which apply to each connection.
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The permit must also specify the date by which the III must be in compliance
with all permit conditions. This date may be the same as the issuance date
of the permit. Alternatively, the effective dates could be specified as 30
days from the date of the Issuance and lasting until a new permit Is
issued. In some cases, the permit might specify Interim milestones which
the III must comply with upon Issuance of the permit and final limits which
the IU must meet by a specified date.
3.2.1 National Categorical Pretreatment Standards
One of the primary responsibilities the POTW assumes In receiving approval
of Its Industrial Pretreatment Program 1s assuring IU compliance with all
applicable National Categorical Pretreatment Standards. These Standards are
published at 40 CFR 405 et seq. List of industries for which National
Standards were to have been developed appear in appendices published with
regulations and as notices 1n the Federal Register. It 1s important for the
POTW to realize that the list of industries that have been or are going to
be subjected to National Categorical Pretreatment Standards are likely to
change over time. Consequently, the POTW must periodically review various
sources of Information (e.g., EPA's regulatory agenda published each April
and October In the Federal Register, the quarterly and annual Federal
Register Index, Code of Federal Regulations) to determine:
1. If the IU has processes which might be subject to National
Categorical Pretreatment Standards. Sometimes the POTW will need
to refer to several possible categories of industry before 1t can
focus In on whether a specific process Is regulated. For example,
recovery of silver from photographic chemicals Is under Non-Ferrous
Metals Manufacturing.
2. If the National Categorical Pretreatment Standards have been either
proposed or promulgated for a process of that IU.
3. Where the National Categorical Pretreatment Standards have been
promulgated, what 1s the deadline for submission of the Industries
Baseline Monitoring Report (BMR) and the deadline for final
compliance with the National Categorical Pretreatment Standards.
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After making a preliminary determination as to the applicability of any
National Categorical Pretreatment Standards, the POTW must have sufficient
Information (either from the BMR, the permit application, onsite Inspection,
or other sources) to establish 1f the IU 1s currently in compliance with the
National Categorical Pretreatment Standards. Subsequently, the POTW will
apply the standards to the IU as follows:
a. If the IU1s BMR or permit application demonstrates compliance or
the compliance deadline for the National Categorical Pretreatment
Standards has passed, the permit must be written to require
immediate compliance with the National Categorical Pretreatment
Standards.
b. Alternatively, if the IU's BMR or permit application demonstrates
that compliance has not yet been achieved and the compliance
deadline for the National Categorical Pretreatment Standards has
not yet passed, the permit must establish interim limitations that
will be effective until such time as the National Categorical
Pretreatment Standards can be met. (Refer also to the Compliance
Schedule discussion section of this manual).
The permit must contain both the daily maximum and long-term average
standards specified 1n the Categorical Pretreatment Standards, (the
long-term average Is generally a 30-day average, but In some cases may be a
4-day average). In addition, where the regulated process wastewaters are
mixed with dilution water, non-regulated wastewaters or with wastewater
regulated by a different categorical pretreatment standard prior to
treatment, the permit writer must calculate alternative discharge limits
using the Combined Wastestream Formula (CWF). These alternatives discharge
limits then apply at the mixed effluent. Further guidance on the
application of the CWF Is found in Appendix C.
National Categorical Pretreatment Standards might be applied on either a
concentration and/or a mass basis. Generally, mass-based standards are
established relative to a production level of the Industry (i.e., so many
pounds of pollutant per 1000 units produced). Production-based mass
standards provide the IU the opportunity to apply water use conservation
techniques (e.g., recycle) to Its waste water system without penalizing the
IU In terms of the regulated concentration of pollutants. In some cases, it
may be desirable to convert concentration-based standards to mass
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limitations or visa versa. EPA Is developing a guidance manual to
specifically describe how to apply Categorical Pretreatment Standards.
The permit writer must also review the IU's discharge data to determine If
any toxic pollutants reportedly not used or produced are present In the
effluent at levels greater than allowed by the appropriate National
Categorical Pretreatment Standard. Such pollutants may originate as
contaminants 1n raw materials and products or .from ancillary non-process
operations.
3.2.2 Local Limits
Most POTWs have developed general prohibited standards and pollutant
specific local limits. These local limits normally apply to every IU of the
POTW. Consequently, local limits might be included with the general
conditions of the permit.
Local prohibited standards are generally established In a generic or
descriptive fashion in a POTW's sewer use ordinance or rules and
regulations. These prohibited standards are similar in nature to other
National prohibited standards 1n 40 CFR 403.5(b) of the General Pretreatment
Regulations.
Generally, pollutant specific local limits consist of heavy metal limits,
cyanide, BOD, TSS, and fats, oil and grease (FOG), and possibly a few toxic
organics. They are generally expressed as maximum limitations. However,
some POTWs have both average and maximum values. These limits are normally
contained in a POTW's sewer use ordinance or rules and regulations. Many
cities have had such limits in their ordinance for a number of years and
recently, as a requirement of developing Its own pretreatment program, have
refined existing limits or developed and enacted new limits for the first
time. The basic philosophy behind locally derived limits is prevention of:
• Interference
• Pass-through of pollutants that may affect water quality
t Sludge contamination.
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In Implementing Its pretreatment program, a POTW 1s required to enforce the
"applicable pretreatment standard" (i.e., 1ocal/State/Federal, whichever is
most stringent). Locally, derived numerical limits can, in some cases, be
more stringent that National Categorical Pretreatment Standards, since they
are based on local site-specific situations. Therefore, a permit may
contain a mixture of National Categorical Pretreatment Standards and local
limits. However, the determination of which limits are more stringent and
therefore which limits must be enforced may be a complicated task. In
contrast to the National Categorical Pretreatment Standards which apply at
the end of the regulated process, local limits are normally applied at the
point just prior to the Introduction of the Industrial wastewater to the
POTW (end-of-plpe). The POTW has a variety of options under which it might
address this apparent discrepancy. One way is to require the III to sample
at separate locations for compliance with the different standards.
Alternatively, the POTW might be able to Impose the more stringent (i.e.,
local limits v. National Categorical Pretreatment Standards) at every
monitoring location. Another alternative would be to impose the more
stringent at the end-of-p1pe.
The last two alternatives may require the use of the Combined Wastestream
Formula. In the situation where a plant sewer connected to the POTW's sewer
contains only wastewater from a process regulated under a particular
categorical standard, then the end-of-process is the same as the end-of-pipe
and the determination of which limits apply, local or Federal, is simply
which limit is more stringent.
However, In the situation where a plant discharge to the POTW'S sewer
contains other process wastewater (e.g., from a process regulated by another
category or not regulated by a categorical standard) or other wastewater
(e.g., non-contact cooling water or sanitary wastewater), then the POTW
using the combined wastestream formula must adjust the National Categorical
pretreatment standards to end-of-pipe. Guidance on use of the Combined
Wastestream Formula 1s contained In Appendix C. Alternatively, locally
derived effluent limits may be back-calculated to the regulated process
eliminating non-regulated and dilution streams.
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Although the industrial pretreatment program emphasizes the control of toxic
pollutants, both conventional and non-conventional pollutants can also be
controlled. Some facilities may require control of conventional and
non-conventional pollutants (e.g., limitations on BOD to protect capacity of
the treatment plant). If, for the pollutants to be limited, local limits or
Categorical Pretreatment Standards are not available, the BPJ procedures
discussed below can be used to develop any necessary effluent limits.
3.2.3 Best Professional Judgment Requirements
In the absence of an applicable National Categorical Pretreatment Standard
and an appropriate technology based local limit, or where the POTW feels
that significant toxic pollutants are contained 1n the IU's discharge,
establishment of limitations should be based on the application of Best
Professional Judgment (PBJ). The concept of BPJ 1s simply to conduct an
analysis of the technology available to treat toxic pollutants of concern.
Application of the following factors should result In the POTW establishing
appropriate technology-based pretreatment standards for the IU:
a. The age of the equipment and facilities involved
b. The Industrial processes used
c. The existing treatment techniques
d. The engineering aspects of available treatment technologies, pro-
cess changes, non-water quality environmental impacts (e.g., RCRA
Issues)
e. Process and procedure Innovations
f. Operation methods and alternatives for other categories of
facilities which might have similar waste characteristics
g. The cost of achieving such effluent reductions and,
h. Other factors which might be deemed appropriate.
An evaluation of the existing treatment system may often assist In the
selection of pollutants to be limited. If some pollutants are used in small
amounts, it may not be possible to directly limit that particular
3-14
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pollutant. In such cases, the evaluation might identify an indicator or
surrogate pollutant.
The usefulness of both indicator and surrogate pollutant 1s limited to the
Individual treatment technology employed. There must be a correlation
between indicator or surrogate pollutant and the underlying toxic pollutants
so that one can predict with some confidence that a particular treatment
technology which results 1n the discharge of a prescribed amount of the
Indicator or surrogate pollutant also achieves the appropriate level of
removal of the underlying toxic pollutant(s).
The treatment system evaluation Includes a determination of the adequacy of
present controls. Although the treatment system may be basically adequate
for overall control of process wastewater, 1n some cases additional control
of specific toxic substances will be needed. Such control 1s most often
achieved by 1n-process changes or by treatment units on selected small
process wastewater streams. To make such determinations requires a
combination of 1n-depth knowledge of the process, a detailed site
Inspection, and/or additional sampling data on the small wastestream.
Information on appropriate pretreatment controls on toxic pollutants can be
found in both the Treatability Manual and various development documents.
3.3 DEVELOPING MONITORING/REPORTING REQUIREMENTS
Monitoring of the discharge to determine compliance with the wastewater
discharge limits and periodic reporting of the results of this monitoring
are Important requirements which must be clearly specified In the permit.
Appropriate monitoring and reporting requirements must be determined based
on such factors as:
1. Applicability of categorical standards and use of the CWF
2. Effluent and process variability
3. Previous permit requirements, and
4. Local, State, and/or Regional policy and/or regulations.
3-15
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3.3.1 Monitoring Requirements
In establishing monitoring requirements for the sampling point, frequency of
sampling and type of sample are three major Items to be specified In the
permit. The factors to be considered in establishing each are discussed
below.
Sampling Point
The wastewater discharge permit should specify the location of the effluent
monitoring points within an IU's facility. Depending on how the effluent
conditions are established, the permit may specify that either the total
plant discharge flow is to be monitored and/or a specific discharge from a
certain operation must be monitored separately. The monitoring point should
coincide with the point where the limits apply.
The following factors apply for determining the representative sample point:
1. National Pretreatment Program Categorical Pretreatment Regulations
apply to the discharges from each regulated process wastestream.
Therefore, samples must be taken at representative sites of the
individual wastestreams. If two or more wastestreams are combined
prior to treatment, a combined wastestream formula can be used to
determine the effluent limitation and the discharge sampled after
the combined treatment. (The Combined Wastestream Formula is
discussed in Appendix C).
2. Samples must be taken at locations where flow can be measured or
estimated.
3. Sampling locations must be convenient, accessable, and practicable.
4. Above all other factors, the location must produce a sample that is
representative of the nature and volume of the discharge to the
POTW.
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Frequency of Sampling
To determine the appropriate frequency of sampling the IU's discharge, the
following factors need to be considered:
1. The regulatory requirements (I.e., the existing permit, ordinance,
POTW policy statements, or Federal regulation).
2. The frequency necessary to be representative of the discharge.
3. The nature of the waste generated and the reliability of the IU's
treatment system. For example, if the waste 1s highly variable,
more sampling is necessary to accurately characterize it.
Conversely, the more consistent the waste quantity and quality, the
less sampling needed.
4. The type and concentrations or loadings of pollutants. Discharges
with high concentrations or which contribute a significant load of
pollutant(s) to the POTW should be sampled more frequently because
of their greater potential to impact the POTW.
5. Any seasonal operations of the IU.
6. The length of the IU's operating day (e.g., the discharge occurs
only over an 8-hour shift).
7. Any special times during the day, week, or month set aside for
batch discharges or cleanup of production lines and the batch
and/or cleanup wastestream characteristics.
8. The IU's potential for upsets or spills.
9. The compliance history of the IU.
As a general rule, monitoring of IUs must be required during normal working
shifts In the season of productive operation. If appropriate, cleanup
periods and batch discharges must also be covered.
Type of Sample
The permit must also specify the type of sample (I.e., grab, or composite)
for effluent monitoring. Selection of the appropriate type of sample Is
done after careful analysis of the effluent and process variability and the
type of limit imposed. Time and flow proportional composite samples give a
better representation of the average amount of pollutant discharged and is
-------
the preferred method to determine compliance with 24-hour or dally average
limits and mass loading limits respectively. However, grab samples are
appropriate to determine compliance with "Instantaneous" limits. In
addition, grab samples might be collected 1f:
1. The IU employs a batch discharge
2. The flow 1s homogeneous and continuous with relatively constant
waste characteristics so a grab sample is representative of the
wastewater stream (e.g., there Is flow equalization prior to the
sewer discharge)
3. It Is necessary to characterize the extremes of flow and wastewater
quality
4. A sample is needed for a parameter requiring that the entire sample
container contents be used for analysis with no interior transfers
of containers, (e.g., oil and grease adherence to container walls
might impact the representativeness of a sample) or
5. When sampling for parameters which change character rapidly (e.g.,
dissolved gases) or those which cannot be held for a long length of
time before analyses (e.g., bacteria counts, chlorine, dissolved
oxygen, and sulfide.
Flow measurement techniques adopted must be in relation to the sampling
location, type of flow, and other similar characteristics.
3.3.2 Reporting Requirements
The permit should delineate the reporting requirements for the IU. These
should Include:
• Content of reports (flow, analytical data, time and place of sampl-
ing, analytical methods used, person conducting the monitoring)
t Dates when monitoring reports are to be submitted to the POTW
(frequency should be no longer than semi-annually for categorical
Industries)
t Who is to sign the reports (authorized representative)
• The POTW address (and department or person) where the reports are to
be sent
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3.4 DEFINING SPECIAL CONDITIONS
Special conditions are developed on a case-by-case basis to address any
specific situations or conditions at a particular IU facility. The
requirements for Best Management Practices or compliance schedules are two
examples that need to be tailored to the Individual IU facility.
3.4.1 Define Best Management Practices
Pretreatment permits can include best management practices (BMPs) conditions
to control or abate the discharge of pollutants. When numerical effluent
limitations are infeasible (such as in some types of hazardous waste/toxic
problems), BMPs become a practical means of carrying out the purposes and
intent of the Pretreatment Program. Through BMPs, marginally treatable and
untreatable materials can be kept out of the POTW. BMPs might also be
considered when evaluating the need to control conventional pollutants.
Currently, there are only a few promulgated National Categorical
Pretreatment Standards containing BMPs (e.g., Solvent Management Program to
control Total Toxic Organlcs). Therefore, BMP conditions will usually need
to be developed by the POTW. Appendix D provides some general guidelines on
the development of BMPs. Additional information Is contained In the 1980
draft technical support document "NPDES Best Management Practices Guidance
Document." Some recent development documents contain Information of
Industry type specific BMPs.
The Initial step in determining the applicability of BMPs is to identify if
the facility uses, produces (as an intermediate, product or by-product),
stores, handles or discharges toxic or hazardous substances. If a potential
for significant discharges of toxic or hazardous substances exists, the
permit may need to require the facility to develop a general BMP plan for
control of such discharges.
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In addition to a general BMP plan, it may be desirable for the POTW to
prescribe site-specific BMPs. This is especially true when there Is:
1. A known or probable surface runoff problem
2. A history of spills or leaks
3. Highly toxic substances used or generated, or
4. Onslte treatment, storage and/or disposal of hazardous wastes.
3.4.2 Develop Compliance Schedules
If treatment improvements, BMPs, or other changes are required, a compliance
schedule specifying a timeframe for completion of the change must be estab-
lished in the Ill's permit. These schedules must consider the complexity of
the improvements, seasonal factors, and statutory requirements.
The schedule must contain Increments of progress In the form of dates (not
to exceed nine months per event) for commencement and completion of major
actions (such as hiring an engineer, completing design and construction
plans, commencing construction, completing construction, etc.). In addi-
tion, the permit should specify that the IU 1s required to submit progress
reports to the POTW within 14 days following each date on the schedule. The
contents of these reports, which should also be delineated in the permit,
should include:
• A statement on the facility's status with respect to the compliance
schedule
• A statement on when the Industrial user expects to be back on
schedule 1f it Is falling behind. The reason for the delay and
steps being taken by the Industrial user to return to the
established schedule must also be reported.
3.5 ESTABLISHING GENERAL CONDITIONS
The general conditions section contains standard conditions for all
industrial users discharging to the POTW sewer system. Many conditions
Incorporate specific regulatory language by reference to the POTW
regulations rather than directly stating the requirement.
3-20
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Some Important general or standard conditions are:
Definition of Terms
Terms used In the permit which may be ambiguous should be defined.
Duty to Comply
By discharging to the POTW under this permit the IU has a duty to
comply with Its provisions
Duty to Mitigate
The IU must undertake all reasonable measures to mitigate the duration
and severity of any violation of this permit.
Right of Entry
This condition should firmly establish the POTW's right of access to
the permittee's property to inspect, monitor, examine and copy
records. Care should be taken so as not to restrict or limit the
POTW's ability to determine compliance with all permit conditions.
Permit Modification/Revision
The POTW's authority to modify or revise the permit during the life of
the permit should be stated.
SeverabU 1ty
A severability clause will allow the remaining part of the permit to
remain in force should a portion of the permit be found invalid and
suspended or revoked by a court of law.
Limitations of Permit Transfers
The discharge permit cannot be transferred to another party, and 1s
valid only for the company and facility to which it is Issued.
Duty to Reapply
The permittee's responsibility to reapply for a permit at a specified
time prior to permit expiration should be expressly stated 1n the
permit.
Permit Opener Clauses
In addition to the generic permit modification/revision clause,
specific conditions which would initiate the modification of the permit
could be stated.
3-21
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Notification of Spills, Slugs, Accidental Discharges
This condition should contain very specific procedures or Instructions
which the IU must follow to notify the POTW of any unusual discharges.
Prior Notification of Changes in Processes, Volume, or Characterization
of Wastewater
This 1s a key mechanism whereby the POTW can keep informed of
significant planned changes by the IU which could Impact the POTW.
Proper Disposal of Sludges, Hazardous Waste
This requirement can be beneficial In preventing the discharge of
pretreatment sludges and hazardous waste Into the sewer system.
Proper Operation and Maintenance of Pretreatment and Monitoring
Facilities
The IU is required to operate and maintain its facilities and
monitoring equipment with proper diligence.
Analytical Methods
The IUs analytical procedures must be In conformance with 40 CFR Part
136.
Signatory Requirements
This condition defines who will be recognized as the authorized
representative of the IU and requires this person to sign all reports
submitted by the IU.
Record Retention
The IU must maintain all plant records relevant to their discharge to
the sewer system for a minimum of three years.
3.6 PREPARE A RATIONALE AND FACT SHEET
The preparation of a permit 1s complex, and its content may be subject to
questions and legal challenges. To fully substantiate the basis for a
permit, a detailed rationale must be prepared. When properly done, this
will communicate clarifying information to the permittee and to the public
and will make defense of the permit conditions much simpler for the permit
writer.
3-22
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A sample rationale Is presented in Appendix B. The rationale gives a
detailed description of the facility (Its operations and wastewater flows
and characteristics) the Information needed In developing the permit (permit
application, BMR, Inspection/monitoring reports), the specific steps
followed 1n the development of the permit and the basis for the effluent
limits and permit conditions. The rationale presented here may be more
detailed than 1s generally necessary for most POTW issued permits.
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BIBLIOGRAPHY
1. Guidance Manual for POTW Pretreatment Program Development, USEPA,
October 1983 (Available from EPA, Office of Water Enforcement and
Permits).
2. Procedures Manual for Reviewing a POTW Pretreatment Program Submission,
USEPA, October 1983 (Available from EPA, Office of Water Enforcement and
Permits).
3. Federal Guidelines - State and Local Pretreatment Program, Vols I, II,
and III, EPA, 430/9-76-017 a, b, and c. January 1977.
4. Fate of Priority Pollutants in Publicly Owned Treatment Works, Vols I
and II, EPA, 440/1-82/303. September 1982.
5. EPA Treatability Manual, Vols I, II, III, IV and V. EPA, 600/8-80-042C,
July 1980.
6. Region VIII, Draft Industrial Pretreatment Inspection Manual.
7. PRELIM - The EPA Computer Program/Modul for Developing Local Limits -
User's Guide.
8. NPDES Best Management Practices Guidance Document Draft Technical
Support Document, 1980.
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APPENDIX A
EXAMPLE PERMIT
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Permit No.: IPP0000517
AUTHORIZATION TO DISCHARGE UNDER THE
INDUSTRIAL FALLS INDUSTRIAL PRETREATMENT PROGRAM
In compliance with the provisions of the Industrial Falls City Code at Chapter
35, Parts 35.001 et. seq. (hereinafter referred to as "the Code),
the Smith and Jones Corporation,
Is authorized by the City of Industrial Falls,
to discharge from its Metal Finishing Operations located at 1111 Industrial
Parkway, Industrial Falls,
to the City of Industrial Falls sanitary sewer system,
in accordance with effluent limitations, monitoring requirements and other
conditions set forth In Parts I, II, and III, hereof.
This permit shall become effective thirty (30) days after the date of
signature below.
This permit shall expire
Authorized Permitting Official Date
Alfred A. Adams
Director
Department of Utilities SEAL
A-l
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PART I
Page 2
Permit No.: IPP0000517
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
1. Description of Outfalls
Outfal1
Description
001
Discharge of the domestic wastewater
from all sources at the facility.
Point is prior to any mixing with the
discharge from the cooling tower system.
002
Discharge from the cooling tower system
prior to mixing with the discharge of
domestic wastewater.
003
The discharge of all process generated
wastewaters from the nickel-chrome
plating operations."
2. General Requirements Applicable to All Discharges
The permittee must comply with the City's Prohibitive discharge standards
at each of the specified outfall points. The City's Prohibitive Discharge
standards are specified at Chapter 35.101 of the Code and appear in Part III
of this permit.
3. Specific Effluent Limitations for Outfall 001, 002, and 003
Outfall 001
The discharge shall consist only of sanitary wastewater from domestic
sources.
Outfall 002
The discharge shall consist only of blowdown from the cooling tower
system.
No chemicals other than chlorine and Inorganic acids and bases (e.g.,
sulfuric acid, sodium hydroxide, etc.) shall be used In the cooling
tower system unless prior written approval has been granted by the
permit issuing authority. If approval Is granted, the use of the
chemical shall be 1n accordance with the conditions of approval. See
Part III for Information to be provided with request for permission
to use chemicals 1n the cooling tower system.
A-2
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PART I
Page 3
Permit No.: IPP0000517
3. Specific Effluent Limitations (continued)
Outfall 003
A. Effective Immediately and lasting through February 14, 1986, the
quality of effluent discharged by the facility shall, as a
minimum, meet the limitations as set forth below:
Effluent Concentration
Daily Maximum 4-Day 30-Day
Parameter Maximum a/ Average b/ Average c/
Total Cadmium (mg/L) 0.40 N/A N/A
Total Chromium (mg/L) 5.0 4.0 2.5
Total Copper (mg/L) 4.5 2.7 1.8
Total Lead (mg/L) 0.6 0.4 0.3
Total Nickel (mg/L) 4.1 2.6 1.8
Total Z1nc (mg/L) 4.2 2.6 1.8
Total Metals (mg/L) d/ 10.5 6.8 5.0
Total Cyanide (mg/L) 1.9 1.0 .55
TT0 (mg/L) e/ 4.57 N/A N/A
pH, units Shall remain between 6.5 and 10.0. a/
B. Effective no later than February 15, 1986, the quality of
effluent discharged by the facility shall, as a minimum, meet the
limitations as set forth below:
Outfall 003 (continued)
Effluent Concentration
Dally 30-Day
Parameter Maximum a/ Average b/
Total Cadmium (mg/L) 0.40 0.26
Total Chromium (mg/L) 2.77 1.71
Total Copper (mg/L) 3.38 1.8
Total Lead (mg/L) 0.69 0.3
Total Nickel (mg/L) 3.98 1.8
Total Zinc (mg/L) 2.61 1.48
Total Silver (mg/L) 0.43 0.24
Total Cyanide (mg/L) 1.20 0.55
TTO (mg/L)e/ 2.13 N/A
pH, units Shall remain between 6.5 and 10.0. a/
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PART I
Page 4
Permit No.: IPP0000517
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - (Continued)
3. Specific Effluent Limitations (continued)
a/ Any single analysis and/or measurement beyond this limitation
shall be considered a violation of the conditions of this permit.
b/ This limitation shall be determined by the arithmetic mean of a
the results of four (4) consecutive samples taken on separate
days. There Is no minimum period over which the samples must be
taken.
c/ This limitation shall be determined by the arithmetic mean of a
minimum of three (3) consecutive samples taken on separate weeks
In a 30-day period (minimum total of three (3) samples)
d/ Total metals shall be calculated by taking the summation of the
concentration of the total chrome, total copper, total nickel,
and total zinc.
e/ TTO's are defined at Title 40, Part 433 of the Code of Federal
Regulations.
4. Best Management Practices Plan
Within ninety (90) days of the effective date of this permit, the
permittee shall develop and Implement a Best Management Practices
(BMP) plan to minimize any potential for spills and/or slug
discharges to the POTW. Part III of the permit outlines the items to
be addressed by the BMP plan.
The BMP plan shall be submitted to the Department within thirty (30)
days of Its completion. Failure of the plan to prevent violations of
any other provisions of the permit and In no way relieves the
permittee from Its legal liability for noncompliance with the permit
conditions.
A-4
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PART I
Page 5
Permit No.:
IPP0000517
5. Schedule of Compliance
1
The permittee shall achieve compliance with the effluent limitations
specified at paragraph B. for Outfall 003 1n accordance with the
following schedule:
MILESTONE
Prepare an Engineering Evaluation
of treatment alternatives.
Award contracts for construction.
Commence Construction.
d. Complete Construction.
e. Attain Full Operational Status.
DEADLINE FOR COMPLETION
February 19, 1985
April 17, 1985
June 30, 1985
November 1, 1985
February 1, 1986
2. No later than fourteen (14) calendar days following a date Identified
1n the above schedule of compliance, the permittee shall submit
either a report of progress or, In the case of specific actions being
required by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the
cause of noncompliance, any remedial actions taken, and the
probability of meeting the next scheduled requirement.
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PART I
Page 6
Permit No.: IPP0000517
B. MONITORING AND REPORTING
1. Self-Monitoring Requirements
As a minimum, the following parameters shall be monitored at the
frequency and with the type of measurement Indicated; samples or
measurements shall be representative of the volume and nature of the
monitored discharge.
outraii ana
Parameter
Frequency
Sample Type
Outfall 001
Flow, mgd
Monthly
Instantaneous
Outfall 002
Flow, gpd
Weekly
Instantaneous
Temperature °C
Dai ly
Instantaneous
Outfall 003
Flow, mgd
Continuous
Recorder
Total Chromium (mg/L)
Monthly
Compos i te
Total Nickel (mg/L)
Monthly
Composi te
Total Lead (mg/L)
1 per 3 months
Composi te
Total Copper (mg/L)
1 per 3 months
Compos i te
Methyl Ethyl Ketone (mg/L)
1 per 3 months
Composi te
Tetrachloroethylene (mg/L)
1 per 3 months
Compos 1te
pH, units
Dally
Recorder
011 and Grease, v1sual
Meekly
Visual
Observation
** The discharge from Outfall 003 shall be visually examined for the
presence of a visible sheen and/or floating oil and the results
recorded. If a visible sheen and/or floating oil Is observed, the
appropriate corrective action shall be taken as soon as practical.
A-6
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PART I
Page 7
Permit No.: IPP0000517
Representative Sampling
Samples and measurements taken as required herein shall be
representative of the volume and nature of the monitored discharge.
All samples shall be taken at the monitoring points specified In this
permit and, unless otherwise specified, before the effluent joins or
Is diluted by any other wastestream, body of water, or substance.
Monitoring points shall not be changed without notification to and
approval by, the permit Issuing authority.
Reportlng
Monitoring results obtained during the previous 3 months shall be
summarized and reported on the IPP Discharge Report Form, postmarked
no later than the 28th day of the month following the completed
reporting period. The first report Is due on January 28, 1986. If
no discharge occurs during the reporting period, "no discharge" shall
be reported. Signed copies of these, and all other reports required
herein, shall be submitted to the permit Issuing authority at the
following address:
Industrial Pretreatment Program Unit
Department of Wastewater
City of Industrial Falls
19 POTW Plaza
Industrial Falls, New Colorado 80000
Definitions
a. A "composite" sample, for monitoring requirements, Is defined as
a minimum of four (4) grab samples collected at equally spaced
two (2) hour intervals and proportioned according to flow.
b. A "grab" sample, for monitoring requirements, Is defined as a
single "dip and take" sample collected at a representative point
In the discharge stream.
c. An "Instantaneous" measurement, for monitoring requirements, Is
defined as a single reading, observation, or measurement.
Test Procedures
Test procedures for the analysis of pollutants shall conform to
regulations published pursuant to Section 304(h) of the Federal Clean
Water Act, under which such procedures may be required.
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PART I
Page 8
Permit No.: IPP0000517
GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of the City Code and Is
grounds for possible enforcement action.
2. Duty to Mitigate - Prevention of Adverse Impact
The permittee shall take all reasonable steps to minimize or prevent
any discharge in violation of this permit which has a reasonable
likelihood of adversely affecting human health, the POTW, the waters
receiving the POTW's discharge, or the environment.
3. Facl11 ties Operation
The permittee shall at all times maintain In good working order and
operate as efficiently as possible, all control facilities or systems
Installed or used by the permittee to achieve compliance with the
terms and conditions of this permit. Bypass of treatment facilities
is prohibited except as provided for and In accordance with the
requirements set forth by this permit.
4. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the
course of treatment or control of waste waters shall be disposed of
in a manner such as to prevent any pollutant from such materials from
entering the sewer system. The permittee is responsible to assure
its compliance with any requirements regarding the generation,
treatment, storage, and/or disposal of "Hazardous waste" as defined
under the Federal Resource Conservation and Recovery Act.
A-8
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PART II
Permit No.: IPP0000517
Page 9
GENERAL CONDITIONS (Continued):
5. Upset Conditions
An "upset" means an exceptional Incident 1n which there 1s an
unintentional and temporary noncompliance with the effluent
limitations of the permit because of factors beyond the reasonable
control of the permittee. An upset does not Include noncompliance
to the extent caused by operational error, Improperly designed or
Inadequate treatment facilities, lack of preventative maintenance,
or careless or Improper operations.
An upset may constitute an affirmative defense for action brought
for the noncompliance. The permittee has the burden of proof to
provide evidence and demonstrate that none of the factors
specifically listed above were responsible for the noncompliance.
6. Right of Entry
The permittee shall allow the head of the State of New Colorado
Department of Water and Natural Resources, the Regional
Administrator of the Environmental Protection Agency, the City of
Industrial Falls, and/or their authorized representatives, upon the
presentation of credentials:
a. To enter upon the permittee's premises where a real or
potential discharge Is located or in which records are required
to be kept under the terms and conditions of this permit; and,
b. At reasonable times to have access to and copy records required
to be kept under the terms and conditions of this permit; to
Inspect any monitoring equipment or monitoring method required
in this permit; and to sample any discharge of pollutants.
7. Availability of Reports
Except for data determined to be confidential under the Code, all
reports prepared In accordance with terms of this permit shall be
available for public Inspection at the City of Industrial Falls. As
required by the Code, effluent data shall not be considered
confidential.
8. Duty to Provide Information
The permittee shall furnish to the Director of Wastewater or his
designee, within a reasonable time, any information which the
Director or his designee may request to determine whether cause
exists for modifying, revoking and reissuing, terminating this
permit or to determine compliance with this permit. The permittee
shall also furnish, upon request, copies of records required to be
kept by this permit.
A-Q
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PART II
Permit No.: IPP0000517
Page 10
GENERAL CONDITIONS (Continued):
9. Signatory Requirements
All reports or Information submitted pursuant to the requirements of
this permit must be signed and certified by a ranking official or
duly authorized agent of the permittee.
10. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule
of compliance specified in such effluent standard or prohibition) is
established under Section 307(a) of the Federal Clean Water Act for
a toxic pollutant which Is present In the discharge and such
standard or prohibition Is more stringent than any limitation for
such pollutant In this permit, this permit may be revised or
modified 1n accordance with the toxic effluent standard or
prohibition and the permittee so notified.
11. Civil and Criminal Liability
Nothing In this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncompliance.
12. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from any
responsibilities, liabilities, or penalties established pursuant to
any applicable Federal and/or State law or regulations.
13. Penalties for Violations of Permit Conditions
The Code provides that any person who violates a permit condition
Implementing is subject to a civil penalty not to exceed $1,000 per
day of such violation. Any person who willfully or negligently
violates permit conditions 1s subject to a fine of up to $5,000 per
day of violation, or by imprisonment for up to one (1) year, or both.
A-10
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PART II
Permit No.: IPP0000517
Page 11
GENERAL CONDITIONS (Continued):
14. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee In an enforcement action
that 1t would have been necessary to halt or reduce the permitted
activity to maintain compliance with the conditions of the permit.
15. Penalties for Falsification of Reports
The Code provides that any person who knowingly makes any false
statement, representation, or certification In any record or other
document submitted or required to be maintained under this permit,
Including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of up to
$5,000 per violation, or by imprisonment for not more than one (1)
year, or by both.
16. Property Rights
This permit does not convey any property rights 1n either real or
personal property, or any exclusive privileges, nor does it
authorize any injury to private property or any invasion of personal
rights, nor any infringement of Federal, State or local laws or
regulations.
17. Severability
The provisions of this permit are severable and, if any provision of
this permit or the application of any provision of this permit to
any circumstance Is held Invalid, the application of such provision
to other circumstances and the remainder of this permit shall not be
affected thereby.
18. Permit Modification, Revocation, Termination
This Permit may be modified, revoked and reissued, or terminated
with cause 1n accordance with the requirements of the City Code or
the Implementing regulations.
19. ReapplIcation for Permit Renewal
The permittee Is responsible for filing an application for
reissuance of the permit within 180 days of the expiration date of
the permit.
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PART III
Page 12
Permit No.: IPP0000517
OTHER REQUIREMENTS
The City of Industrial Falls' Prohibitive Discharge Standards
Prohibitive Standards at Chapter 35.101 of the Code require that under no
circumstances shall the permittee Introduce any of the following
pollutants Into the waste treatment system:
(1) Pollutants which could create a fire or explosion hazard In the
publicly owned treatment works (POTW).
(2) Pollutants which will cause corrosive structural damage to the POTW,
but 1n no case, discharges with a pH lower than 5.0, or greater than
(3) Solid or viscous pollutants In amounts which will cause obstruction
to the flow In sewers, or other Interference with the operation of
the POTW.
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.),
released In a discharge of such volume or strength as to cause
Interference in the POTW.
(5) Heat In amounts which will Inhibit biological activity in the POTW
resulting in interference, but in no case, heat In such quantities
that the temperature at the treatment works influent exceeds 40° C.
(104° F.) unless the POTW is designed to accommodate such heat.
(6) Wastewaters that exceed the maximum allowable concentrations for the
following specific pollutant parameters:
10.0.
Parameter
Maximum Concentration
(In any sample)
Total Cadmium
Total Chromium
0.40 mg/L
5.0 mg/L
5.0 mg/L
5.0 mg/L
5.0 mg/L
10.0 mg/L
Total Copper
Total Lead
Total Nickel
Total Z1nc
A-l 2
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PART III
Page 13
Permit No.: IPP0000517
OTHER REQUIREMENTS
Requesting Permission to Use Chemicals 1n the Cooling Tower System
No chemicals other than chlorine and inorganic acids and Inorganic bases
(e.g., sulfuric acid, sodium hydroxide, etc.) are to be used In the
cooling tower system without prior written approval from the permit
issuing authority. In requesting permission to use chemicals in the
cooling tower system, the permittee must provide as much of the
Information listed below as 1s practical:
1. Name of chemical compound (trade name and/or brand name);
2. Name and address of manufacturer;
3. Name and telephone number of any local manufacturers representative;
4. Chemical Abstract Registry Number;
5. EPA Registration Number (if applicable);
6. Copy of the Material Data Safety Sheet;
7. Chemical composition of the chemical compound and the percent of each
active ingredient to the total compound;
8. Proposed application rates of the chemical, resulting concentrations
(mg/L) In the cooling water, and frequency of application;
9. Summary of data on toxicity of chemical compounds (or active
Ingredients) to aquatic organisms;
Best Management Practices (BMP) Plan
As required in Part I of this permit, the permittee must develop and
implement a Best Management Practices (BMP) program. The BMP plan must
address the following:
1. Chemical Storage Areas
2. Chemical Loading and Unloading Areas
3. Process Tanks
4. Removing Process Tanks From Service
For each of the above categories, the BMP program must examine:
1. Proximity to the Sanitary Sewer system
2. Material Compatability (e.g., container v. solution, possible
reactivity with adjacent chemicals, etc.)
3. Transfer of Chemicals
4. Housekeeping/Inspections
5. Secondary Containment
6. Spill Contingency
7. Batch Treatment
8. Notification to the sewer authority.
A-13
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APPENDIX B
PERMIT FACT SHEET
-------
STATEMENT OF BASIS
INDUSTRIAL PRETREATMENT PERMIT
Smith and Jones Company, Inc.
Captive Electroplater and Metal Finisher
Mr. John J. Jones
President
Smith and Jones Company, Inc.
999 Corporate Circle
Corporatevl1le, New Colorado 81000
Telephone: (304) 666-1234
Mr. Sam S. Smith
General Manager
Smith and Jones Company, Inc.
1111 Industrial Parkway
Industrial Falls, New Colorado 80000
Telephone: (304) 555-1234
BACKGROUND INFORMATION:
The Smith and Jones Company, Inc. Is the largest manufacturer of sewing
thimbles In New Colorado producing approximately 10,000,000 thimble units a
year. The manufacturing process consists of stamping the metal pieces from
coiled steel, vapor degreaslng the fabricated pieces, and then processing the
thimbles though a nickel chrome plating line. The company employs 21
persons. Attachment A is a schematic diagram of the plating operation.
On August 1, 1981, Smith and Jones Company filed a Baseline Monitoring
Report with the Environmental Protection Agency's Region XIII. At that time,
Region XIII was the Pretreatment Control Authority as defined by the Federal
General Pretreatment Program Regulations at 40 CFR 403. The BMR report
contained information supporting the company's certification that It was In
full compliance with the National Categorical Pretreatment Standards at 40 CFR
413 for Electroplaters.
On July 7, 1984, the Company submitted another Baseline Monitoring Report
to the City of Industrial Falls, the Federal Pretreatment Control Authority
since 1t had officially been delegated the program on March 10, 1984. This
BMR addressed the revised TT0 requirements for Electroplating at 40 CFR 413
and the Metal Finishing requirements at 40 CFR 433 for Metal Finishing
activities. The company certified that It currently did not meet the final
effluent requirements set forth by either the TT0 regulations for
Electroplatlon or the heavy metals concentrations of the Metal Finishing
regulations. A compliance schedule, attachment B, was Included with the
company's BMR.
FACILITY:
INDUSTRIAL
CATEGORY:
CONTACTS:
B-I
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Page 2, Statement of Basis, Smith and Jones Company, Inc., Industrial
Pretreatment Program, Permit IPP00005T7
On September 23, 1984, pursuant to the requirements of the City Code,
Smith and Jones filed an application with the Department of Wastewater for a
Industrial Pretreatment Program Permit. The permit application contained some
additional information, but essentially cross-referenced the previously
submitted BMRs as being still accurate.
On October 16, 1984, the permit writer visited the Smith and Jones
facility to gain more familiarity with the operations at the site as well as
verify the accuracy of the information contained in the BMRs and permit
applIcatlon.
The company has three basic types of wastewaters which 1t is generating:
a. Sanitary:
100 X domestic from a small kitchen and toilets
Average Flow » 800 gpd
Typical Domestic strength
b. Cooling Tower Bleed-off Water:
Minimum Flow (winter) = 11,200 gpd
Maximum Flow (summer) » 17,800 gpd
Temperature: 95° F. to 75° F.
pH: 6-9
TSS: 24 mg/L
The blowdown (bleed-off) from the cooling tower system goes by pipe to
the outfall line directly into the city sewer. There currently is no
device to monitor the flow rate of the cooling tower blowdown. The flows
given are estimates. Their is no treatment of the cooling tower
blowdown. However, the company is contemplating chemical addition to the
cooling tower to prevent scaling and corrosion.
c. Process Generated Wastewaters
Smith and Jones' normal process generated wastewaters consist principally
of rinse tank overflows to the sewer system. In the past, the Company
has periodically batch discharged plating line tanks (both rinse tanks
and spent plating solutions) directly to the sewer without any treatment.
After their submission of their first BMR In 1981, Smith and Jones
Installed a treatment unit to neutralize and filter the process generated
wastewaters from the rinse tank overflows. The company, however, did not
sample Its treatment units until the submission of the Metal Finishing
BMR in 1984. The results of the BMR sampling of the treatment system
were as follows:
B-2
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Page 3, Statement of Basis, Smith and Jones Company, Inc., Industrial
Pretreatment Program, Permit IPP0000517
PARAMETER
RESULTS
Total Cadmium (mg/L)
Total Chromium (mg/L>
Total Copper (mg/L)
Total Lead
-------
Page 4, Statement of Basis, Smith and Jones Company, Inc., Industrial
Pretreatment Program, Permit IPP0000517
Outfall 003
Because Smith and Jones Is a captive shop electroplater, the company's
process generated wastewaters are required to meet both the National
Categorical Pretreatment Standards for Electroplating and for Metal
Finishing at 40 CFR 413 and 40 CFR 433 respectively. A Captive Shop owns
more than 50X (on an area basis) of the materials undergoing metal
finishing. The Electroplating Standards must be met Immediately and the
Metal Finishing Standards by no later than February 15, 1986.
In addition to the National Categorical Standards, the Company must also
meet the City's prohibitive requirements at each of the outfalls. The
Company's requirements are thus affected as follows:
1. Requirements prior to February 15, 1986
Smith and Jones discharges approximately 18,000 gallons per day of
regulated process wastewater. Consequently, the company must meet
the requirements for all regulated metals under the Electroplating
standards for common metal plating and the Interim TT0 requirements
for Metal Finishing.
The City's Prohibitive Standards result 1n more restrictive
requirements for total cadmium and total chromium than would be
required under the National Categorical Pretreatment Standards for
Electroplating (40 CFR 413).
2. Requirements after February 15, 1986
The City's Prohibitive Standards result in a more restrictive
requirements for total cadmium than would be required under the
National Categorical Pretreatment Standards for Metal Finishing at
40 CFR 433.
The Company has had a history of batch discharges and spills, Including
spills of solvents. Nonetheless, the company currently Is classified
only as a Small Quanlty Generator under the Resource Conservation and
Recovery Act and has not been given much attention regarding Its solid
waste handling.
To assure that the POTW Is not adversely Impacted by any spills from the
company and that batch discharges are adequately treated, the Permit
requires the Company to develop and Implement a Best Management Practices
Program. This program will encompass the requirements for a Toxic
Organics Management Plan under the Electroplating and Metal Finishing
Regulations.
B-4
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Page 5, Statement of Basis, Smith and Jones Company, Inc., Industrial
Pretreatment Program, Permit IPP0000517
The three outfalls
Outfall and
Parameter
are to be monitored, at a minimum, as specified below:
Frequency Sample Type Comments
Outfall 001
Flow
Monthly
Instant.
Flow to be monitored
for spill prevention
Outfall 002
Flow,
Weekly
Instant.
Temperature
Dai ly
Instant.
Outfall 003
Flow
Daily
Recorder
Total Chromium
Monthly
Comp.
Total Nickel
Monthly
Comp.
Total Zinc
1? 3 months
Comp.
Incidental presence
Total Copper
10 3 months
Comp.
Incidental presence
Methyl Ethyl Ketone
10 3 months
Comp.
BMP plan should reduce
Tetrachloroethylene
10 3 months
Comp.
presence of these TTOs
pH, units
Dai ly
Recorder
Assure process control
011 and Grease
Weekly
Visual
Spill prevention
Observe
* *
** The discharge from Outfall 003 shall be visually examined for the presence
of a visible sheen and/or floating oil and the results recorded. If a
visible sheen and/or floating oil is observed, the appropriate corrective
action shall be taken as soon as practical.
The reporting frequency will be quarterly.
January 28, 1986.
The first report will be due
Oscar 011ver, P.E.
Pretreatment Program Administrator
-------
ATTACHMENT B.
Schedule of Compliance
Following Is the schedule of compliance by which the Smith and Jones
Company, Incorporated will achieve compliance with all applicable Metal
Finishing Category and local pretreatment standards which become effective no
later than February 16, 1986:
MILESTONE DATE FOR COMPLETION
1. Prepare an Engineering Evaluation
of treatment alternatives. February 19, 1985
2. Award contracts for construction. April 17, 1985
3. Commence Construction. June 30, 1985
4. Complete Construction. November 1, 1985
5. Attain Full Operational Status. February 1, 1986
B-6
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Chromium waste
(gal/min. lb Cr**]
Heavy metals wastes
(gal/min, lb metal'l
Solids generation factors
Legend:
Reduction (NaHSOj. H2S04)
3 lb NsHSO,/lb Cr+a
2 lb H2S04/lb Cr+*
0.3 lb NaHSOj/1,000 gal
0.2 lb HjSCVI.OOO gal
Neutralization [Ca(0H)2]b
1.2 lb CalOHyi.OOOgal
Neutralization (Ca(OH)2]b
0.1 lb dry solids generated
lb Ca(OH)2 consumed
Process step (treatment reagent)
Consumption (actor
Neutralization |Ca(OH)2|
1.7 lb CafOHIj/I.OOO gal
3
-U-
Precipitation (Ca(0H)2)
2.6 lb CafOH^b Cr
2.2 lb Ca(0H)2/lb metal
Precipitation
lb dry solids generated
lb metal precipitated
Cr
Ni
Cu
Cd
Fe+a
Zn
Al
2.24
1.80
1.75
1.52
1.83
1.74
3.11
PRFn?£#7 A# F*lT
0
Flocculation
0.02 lb/1.000 gal
*lb metals expressed ss lb metal iona.
^Alkalinity consumes lime and adds to solids generation rate.
-------
APPENDIX C
USE OF THE COMBINED WASTESTREAM FORMULA
-------
USE OF THE COMPILED WASTESTREAN FORMULA
TURrOSE OF THE combined wastestream formula
Federal categorical pretreatment standards regulate the indirect dis-
charge of certain pollutants from a particular industry or industrial
process. An important consideration for Control Authorities as well as
industrial users (Ills), when applying or complying with categorical
standards, is that the pollutant limitations specified in the standards
apply to the discharge of wastewater from the regulated process only, prior
to mixing with any other wastestreams. As such, determination of an IU's
compliance status should be performed by collecting and analyzing a sample
of wastewater representing only the discharge from the regulated process.
However, it is often difficult or impossible to collect and analyze a
sample of only the wastewater from the regulated process. The IU may
combine some or all of their wastestreams and treat them in a single waste-
water treatment facility. Some of the wastestreams may be regulated by one
categorical pretreatment standard, while others are regulated by a different
categorical standard or not regulated at all.
The combined wastestream formula (CWF), as described in Section
403.6(e) of the General Tretreatment Regulations, is a mechanism for
adjusting categorical pretreatment standards (either concentration or
production-based) when a regulated process wastestream is combined with
another wastestream (either regulated by categorical standards or not)
resulting in a mixed discharge to the TOTW system. The CWF 1s applied to
the mixed discharge to account for the presence of those flows from other
wastestreams combined with the regulated process discharge.
A regulated process wastestream is an industrial process wastestream
regulated by rederai categorical standards (I.e., metal finishing and
electroplating). An unregulated process wastestream is an industrial waste-
stream that is not regulated by Federal categorical standards and not consi-
dered a dilution stream as defined below. A dilute wastestream is defined
in 40 CrR Tart 403 to include:
• Boiler blowdown (except in certain cases as described below)
• Non-contact cooling water (except in certain cases as described
below)
• Sanitary wastewater
• Trocess wastestreams shown in Appendix D of 40 CFR, Tart 403 that
ErA has exempted from regulation by categorical standards due to
several conditions related to insignificant or untreatable pollutant
levels as described below.
To further assist the Control Authority and industrial user in deter-
mining whether a boiler blowdown or a non-contact cooling water discharge is
an unregulated or dilute wastestream, the ErA has proposed and
-------
promulgated amendments to the Ceneral FYetreatment Regulations (40 CrR
Tart 403). In the N'ay 17, 19C4 rederal Register, Sections 403.6(e)(1)(f)
and Hi) were amended to revise the definition of a dilute wastestrean
(referred to as the variable Fq in the CWr). This amendment states that:
"rn ® the average daily flow (at least a 30-day average) from
(a) boiler blowdown streams and non-contact cooling streams;
provided, however, that where such streams contain a significant
amount of a pollutant, and the combination of such streams, prior
to treatment, with an Industrial Users regulated process
wastestream(s) will result in a substantial reduction of that
pollutant, the Control Authority, upon application of the
Industrial User, may exercise its discretion to determine whether
such stream(s) should be classified as diluted or unregulated. In
its application to the Control Authority, the Industrial User must
provide engineering, production, sampling and analysis and such
other information so that the Control Authority can make its
determination, or (b) sanitary wastestreams where such streams are
not regulated by a categorical Tretreatment Standard, or (c) from
any process wastestreams which were or could have been entirely
exempted from categorical Oetreatment Standards pursuant to
paragraph C of the NRDC v. Costle Consent Decree (12 ERC 1G33) for
one or more of the following reasons (see Appendix D):
(1) the pollutants of concern are not detectable in the
effluent from the Industrial User (paragraph (C)(a)(iii);
(2) the pollutants of concern are present only in trace
amounts and are neither causing nor likely to cause toxic
effects (paragraph (C)(a)(11i);
(3) the pollutants of concern are present in amounts too small
to be effectively reduced by technologies known to the
Administrator (paragraph (C)(a)(11i); or
(4) the wastestream contains only pollutants which are
compatible with the rOTW (paragraph (0(b)(1).N
Consequently, if the IU combines boiler blowdown and/or non-contact cooling
process water with a regulated wastestream, the Control Authority must
determine (supported by required engineering, production, sampling and
analysis data, etc., from the IU) whether the boiler blowdown and/or non-
contact cooling process waters should be classified as diluted or unregu-
lated for each pollutant for which an alternative limit is calculated.
The definition of regulated and unregulated, and 1n some cases dilute
wastestreams (boiler blowdown and non-contact cooling waters) are pollutant
specific. For example, the Aluminum rorming category limits the discharge
of chromium (Cr), cyanide (CN), zinc (Zn), and total toxic organics (TTO)
from Aluminum Forming process discharges. If the Aluminum Forming process
discharges were combined with other wastewaters, the aluminum forming
wastestreams would be considered regulated for Cr, CN, Zn and TTO pollutant
parameters. However the Aluminum Forming process wastestreams would be
r_9
-------
considered unregulated for copper if the aluminum forming wastestream were
to be combined with an Electroplating process wastestream.
AITLICATION AND IMPLEMENTATION OF THE CVF
Combined Wastestream rormulas
Section 403.6(e) of the Ceneral Tretreatment Regulations provides two
formulas to develop alternative categorical limits. One formula is used to
develop an alternative concentration limit for standards that are
concentration based. The other formula is used to develop an alternative
mass limit for those categorical standards that are production based.
Alternative Concentration Limit Formula
Cj = Alternative concentration limit for the pollutant in the
combined wastestream
Ci - Concentration-based categorical pretreatment standard for the
pollutant in regulated stream i
F-j = Average daily flow (at least 30 day average) of regulated
stream 1
rD = Average daily flow (at least 30 day average) of dilute
wastestream(s) (see previous complete definition, page 3-2)
Fx « Average daily flow (at least 30 day average) through the
combined treatment facility (including regulated, unregulated
and dilute wastestreams)
N ¦ Total number of regulated streams.
The CWF develops an alternative concentration limit for each pollutant by
multiplying the categorical standard for each pollutant of each regulated
stream (C-f) by the flow of the regulated stream (F^) and then adding the
resultant product for all the regulated wastestreams that are combined.
This amount is then divided by the sum of the flows (F-j) of all the
wastestreams in which that pollutant is regulated. If no dilution
C-3
-------
wastestreams for a pollutant are being combined, only the first part of the
formula would be needed to compute an alternative concentration limit. If
dilute wastestreams are combined with the regulated and unregulated process
wastestreams, the number resulting from the first part of the formula is
multiplied by a fraction. This fraction 1s derived by taking the total flow
through the wastewater treatment system (rj) minus the total flow from all
dilute wastestreams (Fp) combined with the regulated process wastewater
treatment system (ry).
It should be noted that when the formula Is applied properly, it has the
effect of allowing the unregulated streams that are combined with the
regulated streams to be discharged at the same pollutant concentrations as
the standards for the regulated streams.
Alternat"'—
My = Alternative mass limit for the pollutant in the combined
wastestream (mass per day)
= Troduction-based categorical pretreatment standard for the
pollutant in regulated stream i (or the standard multiplied by
the appropriate measure of production if the standards being
combined contain different units of measurement)
Fj * Average daily flow (at least 30 day average) of regulated
Fp = Average dally flow (at least 30 day average) of dilute
wastestream(s)
Fj = Average daily flow (at least 30 day average) through the
combined treatment facility (including regulated, unregulated
and dilute wastestreams)
N * Total number of regulated streams.
Alternative mass limits are developed by adding together the calculated mass
values from production-based categorical a standard for a pollutant (M-f)
in each regulated process wastestream that is combined. If the units of
mass 1n the production-based standards being combined were different, then
each of the production-based standards would have to be multiplied by the
appropriate daily production basis for each regulated process, before the
standards are added together. If only regulated process wastestreams were
combined, only this sum of the production-based categorical standards is
needed to establish an alternative mass limit (Mj). In the case of the
stream i
C-4
-------
addition of dilute or unregulated wastewaters, the sum of production-based
categorical standards mass values would need to be multiplied by a
fraction. This fraction is calculated by taking the total flow through the
wastewater treatment system (Fj) minus the total of dilute wastestreams
(rp) combined with the regulated process wastestreams and dividing by the
total flow of regulated process wastestreams (F-f).
As with the concentration limit formula, when applied properly the mass
limit formula has the effect of allowing the unregulated streams that are
combined with the regulated streams to be discharging to the same pollutant
concentrations as allowed by the standards for the regulated streams.
C-5
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EXAMTLE I
CALCULATION OF" ALTERNATIVE DISCHARGE LIMIT
FOR AN INTEGRATED ELECTROrLATER TRIOR
TO THE METAL FINISHING COMrLIANCrETIT
Industrial Category
(Subcategory)
Electroplating
(connon metals)
Metal Finishing
(painting)
Waste stream How
type MGP
Regulated 0.4
Unregulated 0.1
Dally Max.
Zn Limit (mg/1)
4.2
N/A
Electroplating
(common metals)
Metal r1nishing
(Tainting)
C = 0.4 MGD
Zn = 4.2 mg/1
C = 0.1 MGD
Zn = N/A
Zncwf 3 4-2 m9/l
This limit applies to integrated electroplaters from June 30, 19C4 to Feb.
15, 19C6. After reb. 15, 19C6, integrated electroplaters are covered by the
single Industrial category - Metal Finishing. The daily maximum zinc limit
for Metal Finishing is 2.61 mg/1. Therefore, this example facility must
meet a zinc limit of 4.2 mg/1 until reb. 15, 19C6 and 2.61 mg/1 after Feb.
15, 19C6.
-------
CALCULATION Oc ALTERNATIVE DISCHARGE LIMIT
rOR AN IMTECRATED ELECTROrLATER AFTER THE METAL
FIMISMINC COMPLIANCE DATE (EOTTTtS 2-5)
Industrial Category
Subcategory)
Metal Finishing
(Electroplatlng)'
(Tainting)'
Torcelain Enameling
(Steel - coating only)
Photographic processing
Sanitary Waste
Wastestream How
Type MCD
Regulated 0.5
Regulated 0.3
Unregulated 0.2
Dilution 0.05
Daily Max.
Zn Limit (mg/1)
2.6
1.332
N/A
N/A
^These are not subcategories; they are metal finishing processes.
^Alternate production based limit = 0.C5 mg/m? coated.
C-7
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EXAMINE 2A
CALCULATION Or ALTERNATIVE DISCIIARCE LIMIT
(ZnCwf) WHEN TWO REGULATED WASTESTREAMS ARE COMBINED
(MO DILUTE WASTESTREAMS)
Metal r1nish1ng
(Electroplating)
(Tainting)
C = 0.5 MGD
Zn » 2.61 mg/1
Torcelaln
Enameling (Steel)
C = 0.3 MGD
Zn = 1.33 mg/1
Zncwf = 2*61 mg/1 (0*5 MCD) + 1-33 mg/1 (0.3 MGD) = 2 13 mg/1
(0.5 MCD + 0.3 WD)
[Alternate limit is proportioned by flow to regulated wastestream]
EXAMINE 2E
CALCULATION 0r ALTERNATIVE DISCHARCE LIMIT
(Zncwf) WI'EN TWO REGULATED WASTESTREAMS ARE
COMBINED WITH A DILUTE WASTESTREAM
ZnCwf "2.13 mg/1
(0.5 MCD +0.3 MCD + 0.05 MCP - 0.05 MGD)
0.C5 MCD
2.0 mg/1
[Alternate limit of 2.13 mg/1 derived in Example 2A 1s further reduced
because of dilution]
C-8
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EXAMTLE 3A
CALCULATION OF ALTERNATIVE DISCHARCE LIMIT
(Zncwf) WHEN ONE REGULATED WASTESTREAM AND ONE
UNREGULATED WASTESTREAM ARE COMBINED
(NO DILUTE WASTESTREAM)
Metal rinishing
(Electroplating)
(Tainting)
Thotographic
Processing
c = 0.5 MCD
Zn = 2.61 mg/1
Q » 0.2 MGD
Zn = (N/A)
Zncwf =2.16 mg/1
[Alternate limit is not changed by addition of unregulated wastestream]
EXAMTLE 3B
CALCULATION OF ALTERNATIVE DISCHARGE LIMIT
(Zncwf) WHEN ONE REGULATED WASTESTREAM AND
ONE UNREGULATED WASTESTREAM ARE
COMBINED WITH A DILUTE WASTESTREAM
Zrvwf = 2.61 m,/l <0-5 WD + 0"2 TOD + °-05 reD ' °-05 HCD) - 2.44 .g/1
0.71 RED
[Alternate limit of 2.61 mg/1 derived in Example 3A is reduced because of
dilution]
C-9
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EXAMPLE 4A
CALCULATION OF ALTERNATIVE DISCHARGE LIMIT
(Zncwf) WHEN TWO REGULATED WASTESTREAMS AND
ONE UNREGULATED WASTESTREAM ARE COMBINED
(NO DILUTE WASTESTREAM)
Zncwf 3 (2>61 m9/1 + (0,5 MCD) + 1,33 m9/1 (0,3 ^GD) =2 13 mg/1
CW {U.b MCP + 0.3 MCD)
[Alternate limit 1s proportioned by flow to regulated wastestream and not
changed by addition of unregulated wastestream]
EXAMPLE 4E
CALCULATION OF ALTERNATIVE DISCHARGE LIMIT
(Zncwf) WHEN TWO REGULATED WASTESTREAMS AND ONE UNREGULATED WASTESTREAM
ARE COMBINED WITH A DILUTE WASTESTREAM
Zn f a 2.13 mg/1 (0.5 MGD + 0.3 MCD + 0.2 MGD + 0.05 MCD - 0.05 MCD) = 2 Q3 mg/]
1.05 MGD
[Alternate limit of 2.13 mg/1 derived in Example 4A is reduced because of
dilution]
C-10
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EXAMPLE 5
COWVERSION Oc PRODUCTION BASED CATEGORICAL STANDARDS TO
CONCENTRATION-EASED: TWO RECULATED WASTESTREAMS
WITHOUT DILUTION WATER
The rorcelain Enameling categorical standards can be Implemented as
concentration limits or production-based limitations. The example below
converts production-based limits to concentration limits. These equivalent
concentration limits can be used as the standard for porcelain enameling in
the previous examples. The same wastestreams used in Example 2A are given
below.
rorcelain Enameling (Steel) Daily
Maximum Limit (Zinc)
Average Daily Production During
Last 12 months
Average Daily Water Usage in
rorcelain Enameling Coating
During Last 12 months
= 0.C5 mg/m2 coated
= 2 x 106 m2 coated/day
= 300,000 gpd
Zn „ 0.C5 mg/m2 (2 x 106 m2 coated/day) = 1<5Q mg/1
(equivalent) 300,000 gpd (3.7C5 liters/gal Ion)
Once the concentration-based equivalent is determined, then the alternate
limit can be calculated as in Example 2A.
Metal r1nishing
rorcelain
(El ectroplating
Enameling
(Tainting)
(Steel)
C « 0.5 MCP
C -
0.3 MGD
Zn = 2.61 mg/1
Zn *
1.50 mq/1
Zn
cwf
2.61 mg/1
(0.5 MCD) +
(0.5 MCD
1.50 mg/1 (0.3 MGD)
+ 0.3 MGD)
2.19 mg/1
C-ll
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APPENDIX D
BEST MANAGEMENT PRACTICES
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BEST MANACEMEMT PRACTICES
Introduction
Traditionally, discharge requirements for Industrial Users (IUs) of
TubUcly Owned Treatment Works (rOTVJs) have been based on numeric standards
for specific chemical compounds. Unfortunately, for many chemicals, it is
difficult to quantify the input level the P0TW can tolerate safely, or to
determine that level which can consistently and economically be achieved by
an IU's wastewater pretreatment facilities.
As an alternative to end-of-pipe pretreatment facilities, establishing
wastewater management practices (e.g., improved housekeeping, reduced water
usage, etc.) can often result 1n substantial reductions in the quantity of
waste discharged by an IU. In addition, implementation of proper management
practices will minimize the potential for catastrophic discharge incidents
or spills into the rOTW. These management practices are referred to as Best
Management Practices (Bf>Ts).
Section 304(e) of the Federal Clean Water Act provides EPA with the
authority to establish BMrs:
(e) The Administrator, after consultation with appropriate
Federal and State agencies and other interested persons, may
publish regulations, supplemental to any effluent limitations
specified under subsections (b) and (c) of this section for a
class or category of point sources, for any specific pollutant
which the administrator 1s charged with a duty to regulate as a
toxic or hazardous pollutant under Section 307(a)(1) or 311 of
this Act, to control plant site runoff, spillage or leaks, sludge
or waste disposal, and drainage from raw material storage which
the Administrator determines are associated with or ancillary to
the Industrial manufacturing or treatment process....
Under this authority, ErA has specifically established BMr requirements
1n some of its National Categorical Tretreatment Standards,. cor example,
the standards at 40 CFR 413 and 40 CFR 433 for Electoplaters and Metal
rin1shers, respectively, currently may require certain Installations to
develop and Implement a written "Solvent Management Program" to control the
introduction of solvents to the wastewater discharged to the POTW.
Together, rOTVJs and IUs can often identify plant specific BMrs which
would Improve the IU's performance and the overall quality of wastewater
discharge to the POTW. This paper outlines the steps Involved 1n Identi-
fying the need for BMrs and some of the criteria used to establish specific
BMrs. These Items Include:
Risk Identification and Assessment
Good Housekeeping
Preventative Maintenance
Material Compatability
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Inspections and Records
Security
Employee Training
Reporting of BHr Incidents
Risk Identification and Assessment
Risk identification and assessment begins with a review of the facility
layout with focus on the areas with a potential for discharge Into the
TOTW. These areas should be clearly indicated on a plant plot plan or
drawing. A simplified materials flowsheet showing major process operations
can be used to indicate the direction and quantity of flow of materials from
one area to another. Dry chemicals which are on the toxic or hazardous
lists need to be evaluated 1f they have the potential to reach the roTV!.
The following are examples of areas with the potential for discharges
to the rOTW:
Storage facilities
Transfer pipelines
Loading and unloading areas
Tipes, pumps, valves, tank drain valves, and fittings
Tank corrosion (internal and external)
Windblowing of dry chemicals
Deterioration of chemical storage primary or secondary containment
Housekeeping
Damaged shipping containers
conveying systems for dry chemicals
Stormwater collection system cross connections
Leaks, seepage, and overflows from sludge and various waste
disposal sites
A hazardous substance and toxic chemical (material) Inventory 1s
essential to conduct an adequate risk identification and assessment. The
Inventory will provide Information on the quantity of hazardous substances
used and/or stored on site and the potential for these substances to reach
the TOTW. Determining the potential for Incidents reaching a TOTW as well
as the detail needed for the materials inventory requires sound engineering
judgment.
Examples of material Inventories Include:
(1) Materials stored in bulk quantities at a facility's tank farm have
a direct access to a TOTW drain in the event of structural failure
or overfill of any tanks. Therefore, the materials Inventory for
the tank farm must be detailed, and should provide the Identity,
quantities, and locations of each material.
(2) Only small quantities of materials are stored in the research
laboratory at an IU facility. The proximity of the storage area
is away from any sewer drain and, consequently, there 1s a low
potential that any spilled materials would reach the TOTW drain.
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Therefore, the materials inventory for the laboratory requires very minimal
detail, (e.g., only an estimate of the total quantity of toxic and hazardous
materials stored).
(3) An IU manufacturing process involves operations with a high
potential that any spill will reach the roTVJ drain. The plant
supplies a variety of products through the batch operation process
to accomodate fluctuations in public demand. Consequently, the
materials used for the batch process vary from week to week,
oftentimes unexpectedly. Therefore, the inventory should include
the identification of each material expected for use, and the
maximum quantity of material that the batch process can handle.
The materials inventory needs to be updated frequently to include
any material substitutions unanticipated at the time of the
original inventory.
The materials inventory and other useful technical information must be
available to the TOTV.' but can require separate filing from any permit
application so as to protect confidentiality or trade secrets specifically
claimed by an IU. This data may include physical, chemical, toxicological
and health information (e.g., technical bulletins or safety data sheets on
the toxic and hazardous substances handled, the quantities involved in
various operations or ancillary sources, etc.)
Materials planned for future use in the plant should be evaluated for
their potential to be discharge to the rOTW. Where the potential 1s high,
the same type of technical data described above should be obtained.
In summary, the steps involved with Risk Identification and Assessment
are:
Identification of areas of the facility which appear to require
BMr conditions.
Examination of identified areas for potential risks for discharge
of uncontrolled materials Into the TOTW.
Identification of any existing site-specific or pollutant-specific
containment measures or need for such measures.
riant plot plans or drawings that clearly label the Identified
areas.
Simplified flowsheet(s) of the major process operations.
Estimation of the direction of flow of potential discharges
towards various TOTW and storm sewer drains.
Evaluation of the potential for materials planned for future use
to be discharged to the TOTW 1n significant amounts.
Materials Inventory system of the facility.
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rhysical, chemical, toxlcological, and health information of the
toxic and hazardous chemicals on-site.
Best Management fYactices
1. Material Compatibility
Incompatibility of materials can cause equipment failure resulting from
corrosion, fire or explosion. Equipment failure can be prevented by
ensuring that the materials of construction for containers handling
hazardous substances and toxic pollutants are compatible with containers'
contents and surrounding environment (e.g., wet or dry).
The fundamental concepts 1n BMrs for Materials Compatibility include:
Evaluation of process changes/ revisions for materials
compatibllIty.
Incorporation of existing engineering practices with regard to
materials of construction, corrosion, and other aspects of
materials compatibility.
Evaluation of procedures for mixing of chemicals and of possible
incompatibility with other chemicals present.
Cleansing of vessels and transfer lines before they are used for
another chemical.
2. Cood Housekeeping
Good housekeeping 1s essentially the maintenance of a clean, orderly
work environment and contributes to the overall facility pollution control
effort. Periodic training of employees on housekeeping techniques for those
plant areas where the potential exists for spills reduces the possibility of
accidental Incidents caused by mishandling of chemicals or equipment. Good
Housekeeping BWs address:
Neat and orderly storage of chemicals.
FYompt removal of spillage (e.g., dry vs. wet washdown).
Maintenance of dry and clean floors by use of brooms, vacuum
cleaners, etc.
Troper pathways and walkways and no containers and drums that
protrude onto walkways.
Minimum accumulation of liquid or solid chemicals on the ground or
floor.
Stimulation of employee interest in good housekeeping.
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3. Preventive Maintenance
An effective preventive maintenance program is important to prevent
equipment breakdowns and/or failures with resultant significant discharges
of chemicals to the rOTW. The program Includes Inspection and testing of
plant equipment and systems to uncover conditions requiring corrective
action. To a large the degree, the program will be designed to assure
proper equipment adjustment, repair or replacement occurs before such
breakdowns and/or failures occur. Steps 1n a preventative maintenance
program are:
Identification of equipment and systems to which the Preventive
Maintenance program should apply.
Periodic Inspections of identified equipment and systems.
Teriodic testing of such equipment and systems.
Appropriate adjustment, repair, or replacement of parts.
Maintenance of complete preventive maintenance records on the
applicable equipment and systems.
4. Inspections and Records
The inspection and records system must include those equipment and
plant areas identified in the risk Identification process as having the
potential for significant discharges. To determine the inspection frequency
and inspection procedures, competent environmental personnel should evaluate
the causes of previous incidents, and assess the probable risks for incident
occurrence. Furthermore, the nature of chemicals handled, materials of
construction, and site-specific factors including age, inspection techniques
and cost effectiveness should be considered.
Ill inspections of plant areas and equipment must be recorded. In
addition, an IU should develop and formally document procedures to assure
adequate response and corrective action have been taken when inspections
reveal deficiencies.
5. Security
riant security is sometimes necessary to prevent discharge Incidents
resulting from malicious mischief and/or unauthorized personnel working
around critical areas. Examples of security measures Include:
Routine patrols of plant by security personnel
Cenc1ng
Cood lighting
Controlled access at guardhouse or main entrance gate
Locks on certain drain valves and pump starters
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6. Employee Training
Employee training programs should instill in personnel, at all levels
of responsibility, a complete understanding of the rOTW discharge
requirements. Training should include Instruction on the processes and
materials with which they are working, the safety hazards, the practices for
preventing discharges, and the procedures for responding properly and
rapidly to toxic and hazardous material incidents.
Employee Training must, as a minimum, entail:
Meetings held at least annually to assure adequate understanding
of program goals and objectives.
Environmental Incident (Spill) drills used at least semiannually.
Periodic input from management.
Adequate training in particular job and process operation and the
effect on other operations.
Transmission of knowledge of past incidents and causes.
Making employees aware of BMr plan and incident reporting
procedures.
Training in the use of sorbents, gelling agents, foams, and
neutralizing agents for cleanup or mitigation of incidents.
Maintaining operating manuals and standard operating procedures.
Making employees aware of health risks of the chemicals handled
and promoting safety.
Motivating employees concerning incident prevention and control.
Records of the personnel who were trained, and of the dates,
Instructors, subject matter, and lesson plans of the training
sessions.
Training and supervisions of contractors and temporary personnel.
7. Reporting of Spill/Upset Incidents
A spill/upset Incident reporting system Is necessary to minimize
recurrence of future incidents, expedite any mitigation and/or cleanup
activities, and to assure compliance with applicable legal requirements.
Reporting procedures include:
Maintenance of records of incidents and provide for formal
internal review of each reported incident.
D-6
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Notification of the appropriate plant personnel, and taking
preventive or mitigating actions.
Notification to the appropriate governmental and environmental
agencies.
A cormunications system for reporting incidents 1n-plant (i.e.,
telephone, alarms, radio, etc.)
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