United States            Office of Water       EPA821-B-01-003
              Environmental Protection        (4303)          June 2001
              Agency	Version 3.0	
4>EPA       SMALL ENTITY COMPLIANCE GUIDE

              Centralized Waste Treatment
              Effluent Limitations Guidelines
              and Pretreatment Standards
              (40 CFR 437)

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DISCLAIMER
   j  i he Engineering and Analysis Division of EPA's Office of Water prepared this guide pursuant
   j  to section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA),
   -  Public Law 104-121. EPA intends this guide to aid small regulated entities that are direct or
indirect industrial dischargers in complying with recently published national regulations, "Effluent
Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards for the
Centralized Waste Treatment Industry Point Source Category" (Federal Register, Vol.  65, No. 247,
pages 81242 - 81313, December 22, 2000).

       The discussion in this document is intended solely as guidance.  This guide is not a
regulation itself nor does not it substitute for any requirements under Clean Water Act or EPA's
regulations. Thus, it does not impose legally-binding requirements on EPA, States, or the regulated
community, and the general description provided here may not apply to a particular situation
based upon the circumstances. This guide does not confer legal rights or impose legal obligations
upon any member of the public.

       Among other things, in the course of the guide, the document describes new and existing
requirements with  respect to industrial dischargers under the Clean  Water Act  and its
implementing regulations at 40 CFR §§ 122, 123, 124 403 and chapter 1, subchapter N.  A
discharger's legal duty requires it to comply with the CWA and its implementing regulations.
While EPA has made every effort to ensure the accuracy of the discussion in this guide,  a
discharger's obligations are determined, in the case  of direct dischargers by the terms of their
NPDES permit and EPA's regulations or in the case of indirect dischargers by permits or equivalent
control mechanisms issued to POTW industrial users or by regulatory requirements.  Nothing in
this guide, of course, changes any statutory or regulatory  requirement. In the event of a conflict
between the discussion in this guide and any permit or regulation, the guide would  not be
controlling. EPA and local decision makers retain the discretion to adopt approaches on a case-by-
case basis that differ from those described in this guidance where appropriate. However, in any
civil or  administrative action  against  a small business for  violation  of the effluent limitations
guidelines, pretreatment standards or new source performance standards for the centralized waste
treatment industry under 40 CFR Part 437, the content of this guide may be considered as evidence
of the reasonableness or appropriateness of proposed fines,  penalties or damages.

       Mention of trade names or commercial products does not constitute endorsement or
recommendation for their use.

       EPA may decide to revise this guide without public notice to reflect changes in the Agency's
approach to implementing effluent limitations guidelines, pretreatment standards, and new source
performance standards for the centralized waste treatment industry, or to clarify and update text.
To determine whether the Agency has revised this guide and/or to obtain copies, contact EPA's
Small Business Ombudsman Office at (202)260-0490.  You can also determine whether EPA has
revised  or supplemented the information  in this guide by accessing the document at:
www.epa.gov/ost/guide/cwti.html.

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               1

     INTRODUCTION
     -"""--;"'- ihis document is published by the U.S. Environmental Protection Agency (EPA) as our official
       |  compliance guide for small entities, as required by the Small Business Regulatory
         Enforcement Fairness Act of 1996. Before you begin using this guide you should know that
     the rule for which EPA has prepared this guide was published on December 22, 2000.  EPA is
     continually improving and upgrading its rules, policies, compliance programs and outreach efforts.
     You can determine whether EPA has revised or supplemented any of the rules or information
     provided in this guide by visiting www.epa.gov/ost/guide/cwti.html.

           EPA published the regulation titled " Effluent Limitations Guidelines and Pretreatment
     Standards for the Centralized Waste Treatment Industry" (Federal Register, Volume 65, No. 247,
     pages 81242 - 81313) on December 22, 2000 under the authority of the Clean Water Act (CWA).
     EPA has prepared this small entity compliance guide because Section 212 of the Small Business
     Regulatory Enforcement Fairness Act of 1996, Public Law No. 104-121, requires EPA to prepare and
     publish such guides for any rule for which it has prepared a regulatory flexibility analysis under
     the Regulatory Flexibility Act, 5 U.S.C. § 601, et seq. EPA prepared a regulatory flexibility analysis
     of this rule and consequently also has developed this guide.

            EPA designed this guide to help owners and operators of centralized waste treatment
     (CWT) facilities that are small entities - whether they are small businesses, small government
     jurisdictions or small non-profit organizations — understand and comply with the CWT effluent
     guidelines  limitations and pretreatment standards ("the rule"). EPA has focused this guide on
     what a small entity will need to know to comply with the regulation. Small entity is defined as (1)
     a small business with gross revenue under $6 million (based on Small Business Administration size
     standards); (2)  a small governmental jurisdiction that is  a government of a city, county, town,
     school district or special district with a population less than 50,000; and (3) a small organization
     that is any not-for-profit enterprise which is independently owned and operated and is not
     dominant in its field.

1.1   Why is Proper Implementation Important?
           Implementation of a regulation is obviously a critical component in achieving the desired
     objectives of the regulation.  If this regulation is not effectively implemented, then expected
     reductions  in pollutant discharges and the environmental benefits expected to be obtained from
     the  reduced discharges may not occur.   Furthermore, CWT facilities that do not properly
     implement the rule may not be able to comply with it and consequently may violate the CWA.
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     INTRODUCTION                                               CWT SMALL ENTITY COMPLIANCE GUIDE
            Effective implementation of this regulation will require the cooperation of the CWT
     facilities that are discharging their wastewater and the Federal, State and local authority that
     regulate discharges from these facilities. In discussions with permitting control authorities, many
     stressed the need for close communication with CWT facilities. Federal, State and local permit and
     control authorities need to have a thorough understanding of a CWT facility's operations to
     implement this rule properly. Likewise, CWT facilities must maintain close communication with
     the generators and sources of the wastes and wastewater treated at the CWT facility in order to
     accurately characterize and treat the incoming waste streams.

1.2  Who Should Use This Guide?
            EPA developed this guide to aid small entities that are CWT facilities. CWT facilities treat
     or recover hazardous or non-hazardous industrial waste, wastewater, or used material from off-
     site.   The entities that are subject to this rule include small  entities that are CWT facilities that
     either discharge wastewater directly into surface water or that introduce wastewater into publicly
     owned treatment works.

            Because the regulation establishes the same requirements for all affected facilities, this guide
     is helpful for both small and large businesses that are CWT facilities.

1.3  What Does This Guide Cover?
            EPA designed this information to provide guidance on implementing effluent limitations
     guidelines and standards for the CWT industry. As part of this guidance, EPA included general
     information on effluent limitations guidelines and pretreatment standards (that is, what are they?)
     and specific information on those promulgated for the CWT industry.  This guidance also enables
     the reader to determine whether a facility is a CWT and, thus, affected by this rule, what CWT
     wastewater discharges are subject to this rule, and what requirements a CWT facility may have to
     meet to comply with this rule.

1.4  How to Use  this Guide
            This guide contains 11 chapters and 1 appendix:

     Chapter 2     provides basic information on effluent guidelines and pretreatment standards. EPA
                  developed this chapter  primarily for  readers with little or no experience with
                  effluent limitations or pretreatment standards.

     Chapter 3     provides a general overview of the CWT industry and summarizes the CWT rule.
                  This summary includes  a description of the requirements of the CWT rule along
                  with a compliance timetable.

     Chapter 4     provides guidance on what type of facilities and operations  must comply with this
                  rule.

     Chapter 5     provides information on determining what  subcategories apply  to a facility's
                  operations.
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INTRODUCTION
CWT SMALL ENTITY COMPLIANCE GUIDE
Chapter 6    provides information on implementing the rule for facilities complying with a
             single subcategory only.

Chapter 7    provides information on implementing the rule for facilities complying with more
             than one CWT subcategory.

Chapter 8    provides information on establishing equivalent treatment for facilities complying
             with the multiple wastestream subcategory.

Chapter 9    includes information on the compliance assurance process. This chapter describes
             how EPA determines compliance and how violations may be corrected.

Chapter 10   presents questions frequently asked during the development of this rule and EPA's
             responses to those questions.

Chapter 11   provides a list of resources for additional help in complying with the regulation.

Appendix A  presents the final limitations and standards for the CWT regulation.

How Do I Obtain a Complete Copy of the Rule?
       You may obtain a complete copy of this rule at 65 Fed. Reg. 81242 (December 22,2000) or by
visiting www.epa.gov/ost/guide/cwti.html.
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               2
     OVERVIEW OF EFFLUENT  LIMITATIONS  GUIDELINES  AND
     PRETREATMENT STANDARDS
      -- •., PA is providing basic information in this chapter on effluent limitations guidelines and
     |: -:> pretreatment standards (ELGs). EPA has simplified the information presented so as to make
         it useful to individuals with little or no  experience with ELGs.  You will find addition
    information on ELGs in the preamble of the CWT rule.

2.1  What Are Effluent Limitations Guidelines and Pretreatment Standards?
           Effluent limitations guidelines and pretreatment standards are restrictions which may apply to
    wastewater discharges from CWT facilities.  The Clean Water Act (CWA) prohibits the discharge
    of pollutants into navigable waters except as otherwise authorized by the statute. It establishes
    restrictions on  the types and  amounts  of pollutants  discharged from  various industrial,
    commercial, and public  sources of wastewater.  Among these are restrictions on the direct
    discharge of effluent, i.e. wastewater, into navigable waters ("effluent limitations") and restrictions
    on the indirect discharge of pollutants to navigable waters ("pretreatment standards") through
    their introduction publicly owned treatment works (which, in turn, discharge to navigable waters).

           These effluent limitations and pretreatment standards do not prevent CWT facilities from
    discharging wastewater.  However, they impose a  requirement, or limit, on the concentration of
    pollutants a CWT may discharge, regardless of its location in the United States or the condition of
    the receiving water. ELGs are not water quality or health based requirements. Rather, as required
    by the CWA, EPA bases ELGs on the performance of wastewater treatment technologies applied
    to CWT wastestreams. ELGs represent the greatest pollutant reductions economically achievable
    for the CWT industry.

           CWT facilities are not the only facilities  that may be subject to effluent limitations
    guidelines and pretreatment standards. EPA develops ELGs on an industry-by-industry basis and
    has developed effluent guidelines limitations and pretreatment standards for over 55 categories
    of industries. Therefore, a facility which is required to meet the restrictions established by this rule
    may also be required to meet the restrictions for another rule if it also performs industrial
    operations in another regulated industrial category.

           Effluent limitations and pretreament standards represent different sets of restrictions. As
    noted above, effluent limitations apply to direct dischargers and pretreatment standards apply to
    indirect dischargers. Finally, as mentioned above, ELGs are minimum requirements. The permit
    writer or control authority may establish additional or tighter restrictions (based  on site-specific
    local POTW pretreatment ordinance limits, water  quality standards, and other authority) than

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     OVERVIEW OF ELGs
                                                               CWT SMALL ENTITY COMPLIANCE GUIDE
     those established by this rule. Therefore, discharge requirements may be more restrictive than the
     ELGs, but not less restrictive than the ELGs.
                                                   A CWT facility discharging wastewater
                                                   directly to waters of the U.S., the
                                                   construction of which commenced after
                                                   August 28,2000 is considered a new source.
2.2   Direct Dischargers and Effluent Guidelines
           A direct  discharger  is  a facility  that
     discharges  pollutants directly to waters of the
     U.S. such as a river or stream. If a CWT facility
     is a direct discharger, it is required to have a
     permit to discharge wastewater — an NPDES
     permit.   NPDES permits  are drafted  by
     "Permitting Authorities" and contain effluent limitations.
            For CWT direct discharging facilities, EPA has established four overall sets of limits which
     may apply.  These are referred to as BPT, BCT, BAT, or NSPS.  These acronyms stand for Best
     Practicable  Control Technology  Currently  Available,  Best  Conventional  Pollutant Control
                                                      Technology,  Best Available  Technology
                                                      Economically Achievable, and New Source
                                                      Performance   Standards,   respectively.
                                                      Existing direct  discharging CWT facilities
                                                      are required to  comply  with BPT  for
                                                      conventional pollutants1 (BOD5, TSS, oil and
                                                      grease, pH) and BAT for all other regulated
                                                      pollutants.   New  source direct dischargers
                                                      must comply with NSPS for all regulated
                                                      pollutants.  The BPT, BCT, BAT, and NSPS
                                                      limits are listed  in Appendix A.
       BPT-
       Best Practicable Control Technology,
       Economically Achievable.
       Best Available Control Technology,
       Economically Achievable.
       Best Conventional Control Technology,
       Economically Achieveable.
NSPS - New Source Performance Standards.
PSNS - Pretreatment Standards for New Sources.
PSES -  Pretreatment Standards for Existing Sources.
       BAT-
       BCT-
2.3  Indirect Dischargers and Pretreatment Standards
            An indirect discharger is a facility that discharges
                                                              In this guide and the CWT rule
                                                              and preamble, EPA refers to the
                                                              POTW or the state collectively
                                                              as the "control authority."
     pollutants to  surface  water indirectly by introducing
     pollutants into  a publically  owned  treatment works
     (POTW).  POTWs  are often  referred to  as  municipal
     wastewater treatment plants. If a CWT facility discharges
     wastewater to a sewer, then it is an indirect discharger. It is
     also  an  indirect discharger if  it  trucks  or  sends  its
     wastewater to a POTW by barge or rail. Permits for indirect dischargers are drafted by "Control
     Authorities" and contain pretreatment standards.
              Conventional pollutants also include fecal coliform, but EPA has not regulated
       fecal coliform in the CWT rule.
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OVERVIEW OF ELGs
                                                              CWT SMALL ENTITY COMPLIANCE GUIDE
 A CWT facility discharging wastewater
 to a POTW, the construction of which
 commenced after August 28, 2000 is
 considered a new source.
                                                      For CWT indirect discharging facilities, EPA
                                               has established two overall sets of pretreatment
                                               standards which may apply. These are referred to
                                               as PSES and PSNS.  These acronyms stand for
                                               Pretreatment Standards for Existing Sources and
                                               Pretreatment Standards for New Sources. Existing
     indirect dischargers must comply with PSES.   New sources that are indirect dischargers must
     comply with PSNS. PSES and PSNS do not contain restrictions for conventional pollutants because
     POTWs are generally designed to treat these parameters effectively. PSES and PSNS are listed in
     Appendix B.

2.4   Zero or Alternative Dischargers and ELGs
            Some CWT facilities do not discharge process wastewater into waters of the U.S. or a POTW.
     These facilities are referred to as zero or alternative dischargers. Zero or alternative discharging CWT
     facilities dispose of their process wastewater  through   ^^^^^^^^^^^^^^^^^^^_^
     evaporation, land application, deep well injection, or off-
     site transfer to  a facility other  than a POTW. These
     facilities do not have to meet the restrictions established
     by this  rule (these facilities may have to meet restrictions
     established under other acts or rules, such as the Clean
     Air Act or RCRA).  However,  if a CWT transfers its
     process wastewater off-site directly to a POTW, then the
     CWT standards would continue to apply to that wastewater (this would not be true if the CWT
     wastewater is sent off-site to another CWT). If a zero or alternative discharging CWT facility alters
     its disposal method and becomes a direct  or indirect discharger, then it will be required to comply
     with the applicable CWT restrictions. A CWT facility which is currently a direct or indirect
     discharging facility and alters its wastewater disposal method to become a zero or alternative
     discharger would no longer be regulated  under this rule.
                                                       In the remainder of this
                                                       document, EPA refers to control
                                                       mechanism or permit to
                                                       discharge to a POTW collectively
                                                       as the "control mechanism."
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               3
     THE  CWT INDUSTRY AND THE  CWT  RULE
     i  i f  -:his chapter provides a general overview of the CWT industry and the CWT rule.  It also
       i   includes general information on the requirements of the CWT rule. EPA developed this
       ! i  chapter primarily for readers unfamiliar with this industry or this rule. Interested parties
          may obtain additional information from the preamble or the  technical  development
     document for the rule.
3.1  What Is A CWT Facility?
           A CWT facility is one that accepts for treatment and/or recovery used industrial materials
    generated off-site (at another location). These used materials may be hazardous, non-hazardous,
    solid, or liquid.  A CWT facility may be a stand alone operation (i.e., centralized waste treatment
    is the only operation at that site) or it may be operated in conjunction with other industrial
    operations (such as production of chemicals).
           CWT  facilities do not fall into a single
    description. Some treat used materials or wastes
    from a few generating facilities while others treat
    wastes from hundreds of generators. Some treat
    non-hazardous  wastes  exclusively while others
    treat hazardous and non-hazardous wastes. Some
    primarily treat concentrated wastes while others
    primarily treat  dilute wastes.  Some primarily
    perform   wastewater   treatment  or materials
    recovery and recycling, while others perform both.
           EPA estimates there are 223 centralized
    waste treatment facilities in 38 states. The major concentration of centralized waste treatment
    facilities is in EPA Region 4, 5 and 6 due to the proximity of the industries generating the wastes
                                               undergoing treatment. The vast majority of CWT
                                               facilities are indirect dischargers.  Fewer than
                                               10% are direct dischargers.  The average volume
                                               of wastewater discharged on an annual basis by
                                               an indirect discharging CWT facility is 9.3 million
                                               gallons while a direct discharging CWT facility
                                               averages 38 million gallons/year.  EPA estimates
                                               that   sixty-three  small   companies  own
                                               discharging  facilities that  are subject to the
                                               requirements of this rule.
                                             Treatment means any method, technique,
                                             or process designed to change the
                                             physical, chemical or biological character
                                             or composition of  any metal-bearing,
                                             oily, or organic waste so as to neutralize
                                             such wastes, to render such wastes
                                             amenable to discharge or to recover
                                             energy or recover metal, oil, or organic
                                             content from the wastes.
In this document, wastes are defined as
aqueous, non-aqueous, and solid waste,
wastewater, and/or used material.
Waste receipts are those wastes that CWT
facilties receive from off-site for the
purpose of treatment. Waste receipts do
not include those wastes generated at the
CWT as part of its regular operation.
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     THE CWT INDUSTRY AND THE CWT RULE
                                      CWT SMALL ENTITY COMPLIANCE GUIDE
                                       Figure 3-1EPA Regions

3.2   What is the CWT Rule and What Does It Require?
            The CWT rule contains effluent limitations guidelines and standards for the CWT industry.
     These are numerical restrictions that may be applied to the discharge of wastewaters from CWT
     facilities to waters of the U.S. or the introduction of wastewater from a CWT facility into a POTW.
     The CWT rule requires facilities that are subject to this rule to meet these discharge requirements.
            EPA  developed different  effluent limitations  and
     standards for the  CWT operations depending on the type of
     waste  received by the CWT.   There are four types,  or
     subcategories, of waste (oily, metals, and organics wastes and
     a fourth, a mixture of any of the three previously listed waste
     types). The subcategories are as follows :
                                       Chapter 5 provides
                                       guidance on determining
                                       the applicable subcategories.
        Subcategory A:

        Subcategory B:

        Subcategory C:

        Subcategory D:
Facilities that treat or recover metal from metal-bearing waste, wastewater,
or used material received from off-site;
Facilities that treat or recover oil from oily waste, wastewater, or used
material received from off-site;
Facilities that treat or recover organics from organic waste, wastewater, or
used material received from off-site; and
Facilities that treat or recover some combination of metal-bearing, oily, or
organic waste, wastewater, or used material received from off-site.
      Chapter 8 provides
      more information on
      demonstrating
      equivalent treatment.
     CWT facilities that fall within multiple subcategories (A, B, or C) may
     elect to  comply with each set  of restrictions  separately or those
     established for Subcategory D.  If a facility elects to comply with the
     Subcategory D limitations, the CWT  rule requires the facility to
     demonstrate equivalent treatment.
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     THE CWT INDUSTRY AND THE CWT RULE
                                                      CWT SMALL ENTITY COMPLIANCE GUIDE
3.3  What Treatment Technologies Were Used to Establish the CWT Limitations and
     Pretreatment Standards?
         EPA based the effluent limitations for existing CWT facilities on the following technologies:

     Table 3-1 Technology Basis for the Final CWT Limitations for Existing Facilities
       Subpart   Name of Subcategory
                                 Technology Basis
                 Metal-Bearing Waste
                 Treatment and Recovery
                 (metals)
A      Metal-Bearing Waste        Batch Precipitation, Liquid-Solid Separation, Secondary
                                 Precipitation, Clarification, and Sand Filtration

                                 For Metal-Bearing Waste Which Includes Concentrated
                                 Cyanide Streams:

                                 Alkaline Chlorination in a two step process

B      Used/Waste Oil Treatment  Emulsion Breaking/Gravity Separation, Secondary
       and Recovery              Gravity Separation and Dissolved Air Flotation
       (oils)

C      Organic Waste Treatment    Equalization and Biological Treatment
       (organic)
         EPA based the pretreatment standards for the metals1 and organics subcategories on the same
     technologies as those listed in Table 3-1.  For the oils subcategory, however, the technology basis
     for the pretreatment standards is emulsion breaking/ gravity separation and dissolved air flotation.
         The technology basis for the effluent limitations and standards for new CWT facilities for the
     oils and organics subcategories are the same as those listed in Table 1.  For new CWT metals
     facilities, however, the technology basis for the limitations is selective metals precipitation, liquid-
     solid separation, secondary precipitation, liquid-solid separation, tertiary precipitation, and liquid-
     solid separation.
         The CWT rule only establishes numerical restrictions on a CWT
     facility's discharge. It does not establish monitoring frequencies nor
     does it require that a particular technology be used. A CWT facility
     may use  any technology it deems  appropriate  as  long as its
     discharges are not in excess of those established in the rule.
                                                             The CWT rule does not
                                                             require a specific
                                                             treatment technology.
              lrThe treatment technology basis for PSES for the metals subcategory does not include sand
       filtration
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     THE CWT INDUSTRY AND THE CWT RULE
                                                        CWT SMALL ENTITY COMPLIANCE GUIDE
3.4   What CWT Discharges Are Subject to This Rule?
        The wastewater discharges covered by this
     rule include some or all discharges  related to
     materials received from off-site (waste receipts)
     and on-site  CWT  wastewater generated  as  a
     result of CWT operations. Examples of off-site
     waste  receipts include metal finishing rinse
                                             Discharges of non-contaminated
                                             stormwater are not subject to this rule
                                             and should not be mixed with discharges
                                             subject to this rule prior to complete
                                             treatment of covered wastewaters.
     waters and sludges, used oils, and  leachate or
      ^^^^^^^^^^_^^^^^^^^^^^   groundwater cleanup.  On-site CWT wastewater include:
                                        solubilization wastewater,  emulsion breaking/gravity
                                        separation wastewater, used oil processing wastewater,
                                        treatment equipment washes, transport washes (tanker
                                        truck,  drum, and roll-off boxes),  laboratory-derived
                                        wastewater,  air pollution  control wastewater,  landfill
                                        wastewater from on-site landfills, and contaminated storm
                                        water.
See Chapter 14 of the technical
development document for a
detailed description of
stormwater (contaminated and
non-contaminated) and
wastewaters subject to this rule.
     Compliance Timetable
        As described above, the CWT rule requires facilities subject to the rule to comply with the
     applicable set(s) of effluent limitations or standards.  The following table summarizes these
     requirements and the required compliance dates.
     Table 3-2 Compliance Times for CWT Facilities
      Type of CWT Facility1
                           Requirement
Deadline
      Existing Direct Discharger
      New Direct Discharger
                           Comply with BPT (conventional
                           pollutants) and BAT (other regulated
                           pollutants)

                           Comply with NSPS
      Existing Indirect Discharger    Comply with PSES
      New Indirect Discharger
                           Comply with PSNS
when your federal or
state NPDES permit is re-
issued

when you begin
discharging

December 22, 2003

when you begin
discharging
      A new discharger is a CWT facility that commences construction after August 28, 2000
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     THE CWT INDUSTRY AND THE CWT RULE                            CWT SMALL ENTITY COMPLIANCE GUIDE
3.6   How Does This Regulation Relate to Other Federal, State, and Local Requirements?
        Effluent limitations and standards act as a primary mechanism to control the concentration of
     pollutants discharged into waters of the United States. These effluent limitations and standards
     are applied to individual facilities through NPDES permits or control mechanisms developed by
     POTWs or authorized States under Section 402 of the CWA and local pretreatment programs under
     Section 307 of the CWA.
        A CWT facility may be required to comply with more stringent limits than those contained in
     the CWT rule, pursuant to (1) federal or state statutes or rules or (2) local ordinances. For example,
     certain POTWs are required by federal regulations to develop local limits to protect against pass-
     through and interference. This means the control authority must develop local limits that protect
     the treatment plant from pollutants that may upset the plant, pass-through the plant untreated (or
     inadequately  treated), may endanger  the well being of workers, or would inhibit sludge
     management practices. These local limits may be more stringent than the CWT pretreatment
     standards.
        In addition to  CWT requirements, other federal, state, or local requirements may also apply
     to a CWT facility.  These may include, but are not limited to, other NPDES program and general
     pretreatment  requirements (CWA), waste tracking requirements  (RCRA,  EPCRA), waste
     management planning requirements (RCRA), spill prevention, reporting and emergency response
     requirements (SPCC, EPCRA), and maximum achievable control technology (MACT) requirements
     (CAA). In general, the CWT rule will not impact these other requirements.

3.7   What Steps Do I Need to Take to Comply With This Rule?
     1.  A CWT facility should determine if its operations are subject to the CWT rule. Chapter 4
        describes the applicability of the CWT rule to various CWT operations.

     2.  If a facility is subject  to the CWT rule, it should determine what subcategory its wastes may
        be classified into. Chapter 5 provides guidance on classifying wastes.

     3.  If a CWT facility accepts wastes in more than one subcategory, it must decide to comply with
        each applicable set of limitations or  standards separately or to comply with the applicable set
        of multiple wastestream subcategory effluent limitations or standards. If the facility chooses
        the later, it will be required to demonstrate equivalent treatment (See Chapter 8).

     4.  A CWT facility must determine if  its treatment system will  allow it to meet the required
        discharge restrictions. If not, it will be required to alter its operation or treatment system prior
        to the compliance date to achieve the discharge restrictions.
     5.  If a CWT facility is an indirect discharger, it must also   _  ~AT1TT  ,  ,
                    ,   ,          ,                           The CWT rule does not require a
        comply with the  general  pretreatment reporting   BMR; the general pretreatment
        requirements which includes submission of a baseline
                            monitoring  report  within  180
                            days of the effective date of the
                            CWT rule, or July 21, 2001. This
                            baseline  monitoring  report
The effective date
of the CWT rule is
January 22, 2000.
regulations do.  BMRs for
existing indirect discharging
CWTs are due on July 21,2001.
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     THE CWT INDUSTRY AND THE CWT RULE                            CWT SMALL ENTITY COMPLIANCE GUIDE
     (BMR) must include results of sampling and analysis identifying   ,,        ,  , ,   ,„ „„„ c
     v     '                          r   &         3         3  &   You can obtain 40 CFR §
     the  concentration of all regulated pollutants in its discharges.
     Additional information on this requirement can be found in 40 CFR
     § 403.12(b).
403.12 through EPA's
web site: www.epa.gov
3.8   What Compliance Monitoring Is Required by the CWT Rule?
        The CWT rule does not establish monitoring frequency requirements. Monitoring frequencies
     are found in other sections of the CWA regulations.  For example, §403.12(e) requires industrial
     users (lUs) subject to categorical pretreatment standards, such as the CWT regulations, to self-
     monitor and report at least twice per year.  Additionally, pursuant to 40 CFR 403, POTWs, or
     control authorities, have developed industrial pretreatment programs (IPPs). IPPs generally
     contain guidelines for determining monitoring frequencies. Permitting and control authorities look
     towards these rules, IPPs, and guidelines to determine monitoring frequencies. They also consider
     the individual characteristics of a site, such as compliance history of the facility and other relevant
     factors.
                                               3-6

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               4
     APPLICABILITY
          -:his chapter provides guidance on the types of facilities and CWT operations that must
           comply with this rule.  It is only a summary.  The preamble to the rule contains detailed
           information on many of these operations.
4.1   Regulated and Non-Regulated CWT Activities
           The CWT rule applies to all wastewater discharges to
                                                              See also Section V of the
                                                              preamble and Chapter 3 of the
                                                              Development Document.
a receiving stream or to a POTW from a facility defined by the
rule as a CWT  facility unless  specifically excluded.   As
previously noted, the rule does  not establish  different
requirements for CWT that are small entities. The rule defines
a CWT facility as "any facility that treats and/or  recovers or recycles any hazardous or non-
hazardous industrial waste, hazardous or non-hazardous industrial wastewater, and/or used
material from off-site." The following table provides a general summary of regulated and non-
regulated CWT activities.
     Table 4-1  Examples of Regulated and Non-Regulated CWT Operations
       Centralized Waste
       Treatment Activity
                               Regulated by this rule
Not Regulated by this rule
Those performed at
federally owned
facilities
POTWs
Thermal drying of
POTW biosolids
Sanitary wastes or
toilet wastes
Food processing
all federally owned CWT operations
none
none
none
none
none
all
all
all
all
     wastes
                                              4-1

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APPLICABILITY
                                                              CWT SMALL ENTITY COMPLIANCE GUIDE
Table 4-1  Examples of Regulated and Non-Regulated CWT Operations
  Centralized Waste
  Treatment Activity
                                  Regulated by this rule
 Not Regulated by this rule
Manufacturing
facilities
                     those that accept off-site wastes for treatment
                     and/or recovery that are not generated in a
                     manufacturing process subject to the same
                     limitations/standards as on-site generated waste
                     and that the permit writer determines are not
                     similar to, and compatible with treatment of, the
                     on-site waste

                     those that accept waste materials from use of
„   ,   ,  ,     , , .    their products that are not similar to, and
Product stewardship       r ,.    ..•,..    .   c    ^        ^ A
                     compatible with, treatment of waste generated
Pipeline materials


Recycle/recovery
activities

Traditional solvent
recovery

Fuel blenders

Scrap metals
recyclers


Silver recovery


Used oil filters & oily
absorbent recycling

High Temperature
Metals Recovery
(HTMR)

Used glycol recovery

Re-refining

Solids, soils, and
sludges

Stabilization/ Solidifi
cation

Transfer stations and
recycling centers
                     on-site

                     materials received via pipeline from waste
                     consolidators or commingled with other covered
                     CWT wastewaters

                     all unless specifically excluded elsewhere


                     none

                     those that generate a wastewater

                     none

                     only included where wastewater generated from
                     these activities is commingled with other
                     covered wastes

                     those that generate a wastewater
                     those that generate a wastewater


                     all

                     all

                     those activities which generate a wastewater
                     unless specifically excluded

                     those that generate a wastewater


                     none
all others
those that accept back their
unused products, shipping
and storage containers with
product residues, and off-
specification products

all other piped materials and
POTWs
aU

"Dry" operations

aU


all others


"Dry" operations


"Dry" operations


none

none

"dry" operations


"Dry" operations


aU
                                              4-2

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APPLICABILITY
                                         CWT SMALL ENTITY COMPLIANCE GUIDE
Table 4-1  Examples of Regulated and Non-Regulated CWT Operations
  Centralized Waste
  Treatment Activity
            Regulated by this rule
 Not Regulated by this rule
                      only included when the wastewater generated
Incineration activities  from these activities is received from off-site and  all others
                      commingled with other covered wastewater

   ,.                 only included where wastewater generated from
        ,  ,.           these activities is commingled with other         all others
transportation               ,   .             °
          . i    .      covered waters
equipment cleaning
Landfills
Grease
trap/interceptor
wastes

Marine generated
wastes
only included where wastewater generated from
these activities is commingled with other         all others
covered waters
those which contain petroleum based oils
off-loaded and subsequently sent to a CWT
facility at a separate location and commingled
with other covered wastewater
Waste, wastewater or  those activities not listed in the next column or
used material re-use   excluded elsewhere
Treatability, research
and development, or
analytical activities
only included where wastewater generated from
these activities is commingled with other
covered waters
those which contain animal
or vegetable fats/oils
all others
                                              not covered if the
                                              wastewater is accepted for
                                              use in place of potable water
                                              or if materials are accepted
                                              in place of virgin treatment
                                              chemicals.
all others
                                              4-3

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Le".

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          5
DETERMINING  THE APPLICABLE SUBCATEGORIES
                                                    CWT facilities accept a wide variety
                                                    of materials, such as oils and acids.
                                                    Although many of these materials
                                                    are processed and reused, for
                                                    purposes of this guidance and the
                                                    rule, the material is collectively
                                                    referred to as 'waste/
     P :,  ;his chapter provides guidance on determining the
       j   applicable CWT subcategories for wastes accepted
       ij  at a CWT facility. EPA developed this chapter to
          provide guidance to CWT facilities. EPA is aware
     that many CWT facilities may classify  their wastes
     differently.   The CWT  rule does not require CWT
     facilities, control authorities, or permitting authorities to
     use this subcategorization process. EPA has provided it
     only as guidance.

5.1   Waste Acceptance Procedures
           In absence of the CWT rule, CWT facilities have already established waste acceptance
     procedures. The CWT rule does not establish waste acceptance procedures. However, in EPA's
     view, these procedures are critical in determining the applicable CWT subcategories and in
     conducting adequate treatment or recovery, and in ensuring the wastes accepted conform to a
     faciliy's discharge permit or control mechanism.   Certainly, all CWT facilities should,  at a
     minimum, collect adequate information from the generator on the type of waste received since this
     is the minimum information required by CWT facilities to effectively treat off-site wastes.
     Consequently, EPA has included information on waste acceptance procedures as the first step in
     its guidance for determining subcategories.  The following paragraphs  describe the waste
     acceptance procedures generally performed at most CWT facilities.
           Before a CWT facility accepts a wastestream for treatment, the CWT facility typically
     performs a pre-approval review of the proposed wastestream. This pre-approval process may
     include screening the waste for treatability and compatibility with both other wastes being treated
     and the treatment system. The waste generator initially furnishes the CWT facility information
     concerning the level of pollutants in the wastestream. Bench-scale treatability tests are typically
     performed to determine what treatment is necessary for effective removal. At this point, the CWT
     facility decides whether to approve  the wastestream for acceptance.  If the wastestream is
     approved, each load received by the CWT facility is typically sampled to ensure that it is consistent
     with the initially approved wastestream. If the sample is similar, the shipment of waste is accepted
     for treatment. If the sample is dissimilar, but falls within an allowable range as determined by the
     CWT facility, the CWT  facility will  reevaluate acceptance.   This reevaluation may include
     additional testing.  Once the reevaluation is completed, the generator is contacted to discuss the
     discrepancy and reach a resolution. Please note that the level of screening is based on the source
     of the waste and the processes used.  Figure 5-1 below is an example of a waste profile form.
                                         5-1

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DETERMINING THE APPLICABLE SUBCATEGORIES
CWT SMALL ENTITY COMPLIANCE GUIDE

ANYFIRM GENERATOR'S
ANYTOWN, USA MATERIAL PROFI
(555)555-1212 _ N£W
	 AMENDMENT
GENERATOR
Name
Address
Technical Contact Phone
Shipping Contact Phone
Business Contact Phone
EPA ID #

WASTE DESCRIPTION
WASTE PROFILE NUMBER
LE SHEET

BROKER OR SALESPERSON
Name
Address
Contact | Phone
TRANSPORTER
Name
Address
Contact I Phone
EPA ID #

Applicable Manufacturing Category (if any):
CHEMICAL & PHYSICAL STATE
Liquid Multilayered
Semi-liquid Bilayered
	 Solid 	 Single Phase
PH
• 2 8-10
2-4 10-12
4-6 -12
_ 6-8 _ N/A
Odor
TSS
Color
Flash Point
% Bottoms Sediment
% Debris
% Ash
Specific Gravity
PROCESS DESCRIPTION
(Describe process generating waste stream. Include a list of virgin materials and their Material Safety Data Sheets.)
CHEMICAL CONSTITUENTS
Petroleum Phase Aqueous Phase




OTHER CONSTITUENTS
% Oil (or ppm Oil)


METALS (PPM)
Arsenic Magnesium
Cadmium Mercury
Chromium Nickel
Copper Tin
Lead Zinc
SHIPPING INFORMATION
RCRA Code
Shipping Method
Volume (gallons)

                           Figure 5-1  Sample Waste Acceptance Form
                                            5-2

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     DETERMINING THE APPLICABLE SUBCATEGORIES
                   CWT SMALL ENTITY COMPLIANCE GUIDE
            Furthermore,  CWT facilities and  waste generators complete extensive amounts of
     paperwork during the waste acceptance process.  The amount of paperwork  necessary for
     accepting a waste stream emphasizes the difficulty of operating CWT facilities.
            Finally, EPA emphasizes that while the CWT rule does
     not require waste segregation, CWT facilities should encourage
     their waste generators to segregate their wastestreams (i.e.,
     keep metal  bearing  wastes separate from organic-bearing
     wastes).  This will help CWT facilities comply with the CWT
     rule and more effectively utilize their treatment technologies.
                           The CWT rule does not
                           require waste segregation.
                           EPA recognizes that
                           commingling wastes can be
                           beneficial in certain cases.
5.2  Initial Subcategory Determination for Existing CWT Facilities
            Based on information provided by CWT facilities during the development of the CWT rule,
     EPA has developed guidance for determining subcategorization. This guidance, which consists
     of three basic steps, is illustrated in Figure 5-2 below. For many CWT facilities, however, steps 1
     and 2 will be sufficient to determine into which subcategory the wastes treated at its facility should
     be classified.  Step 3 would only be necessary if the first two steps are inconclusive. This guidance
     will help facilities classify their incoming wastes into the metals, oils, or organics subcategory. A
     facility that accepts waste in more than one of these subcategories may also be  classified as
     "mixed". This is detailed in Chapter 7.
      Incoming Waste
      Receipt Data Collection
      - collected when each
      shipment is received at
      the facility.
Compare Waste
Receipt Information
to Waste Receipt
Classification Table,
>=>
For waste receipts that are
unknown or not listed in the
waste receipt classification
table, the facility should
consult the numerical criteria.
                            Figure 5-2 Subcategory Determination Procedure


     Step 1: Waste Receipt Data Collection
            The first step in EPA's recommended subcategory determination procedure is to collect
     information on the incoming waste receipts.  This data is usually collected at the point where the
     shipment is received by the CWT facility. Most (if not all) CWT facilities are already performing
     this step. EPA believes that the paperwork and analyses currently performed at CWT facilities as
     part of their waste acceptance procedures provide CWT facilities with sufficient information to
     complete this step. Figure 5-1 shows an example of a waste acceptance form typical of those used
     at existing CWT facilities.

     Step 2: Compare Waste Receipt Information to Waste Receipt Classification Table
            In Step 2, the CWT facility should review data collected from its waste receipts for a period
     of one year. The CWT facility should use common sense to determine which subcategory the waste
     falls into. To assist the CWT facility, it may use the waste classification table (Table 5-1) to classify
                                                5-3

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 DETERMINING THE APPLICABLE SUBCATEGORIES
                               CWT SMALL ENTITY COMPLIANCE GUIDE
each of its waste receipts for that one year period into Subcategory A (Metals), B (Oils), or C
(Organics).
        If the CWT  facility receives the wastes listed in the  waste classification table, the
subcategory determination may be made solely from this information. For purposes of this rule,
the CWT facility need not determine the percentage of each type of waste within a subcategory or
between subcategories. The CWT facility only need to determine what subcategory the wastes fall
into: one or multiple subcategories. When subcategory determination is complete, the facility may
refer to Chapter 6 for implementing the rule if only one subcategory applies or Chapter 7 if more
than one subcategory applies.
Table 5-1  Waste Receipt Classification
  Metals Subcategory
• spent electroplating baths and/or sludges
• metal finishing rinse water and sludges
• chromate wastes
• air pollution control blow down water and sludges
• spent anodizing solutions
• incineration wastewaters
• waste liquid mercury
• cyanide-containing wastes
• waste acids and bases with or without metals
• cleaning, rinsing, and surface preparation solutions from
  electroplating or phosphating operations
• vibratory deburring wastewater
• alkaline and acid solutions used to clean metal parts or equipment
  Oils Subcategory
• used oils
• oil-water emulsions or mixtures
• lubricants
• coolants
• contaminated groundwater clean-up from petroleum sources
• used petroleum products
• oil spill clean-up
• bilge water
• rinse/wash waters from petroleum sources
• interceptor wastes
• off-specification fuels
• underground storage remediation waste
• tank clean-out from petroleum or oily sources
• non-contact used glycols
• aqueous and oil mixtures from parts cleaning operations
• wastewater from oil bearing paint washes
  Organics
  Subcategory
- landfill leachate
- contaminated groundwater clean-up from non-petroleum sources
- solvent-bearing wastes
- off-specification organic product
- still bottoms
- byproduct waste glycol
- wastewater from paint washes
- wastewater from adhesives and/or epoxies formulation
- wastewater from organic chemical product operations
- tank clean-out from organic, non-petroleum sources
                                            5-4

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     DETERMINING THE APPLICABLE SUBCATEGORIES                  CWT SMALL ENTITY COMPLIANCE GUIDE
           This classification is not inclusive of all possible wastestreams.  It is simply a guidance of
    the typical wastestreams in each subcategory.

    Step 3: Waste Characterization Using Numerical Criteria
           For wastestreams that are from non-specific sources or not listed in the waste receipt
    classification table, the facility should additionally complete Step 3. In Step 3, the facility should
    use data collected during the waste acceptance procedures to classify the waste into the appropriate
    subcategory. EPA recommends the CWT facility apply the following hierarchy:

    1).     If the waste receipt contains oil and grease at or in excess of 100 mg/L, the waste
           receipt should be classified in the oils subcategory;

    2).     If the waste receipt contains oil and  grease  <100 mg/L, and has any of the
           pollutants listed below in concentrations in excess of the values listed below, the
           waste receipt should be classified in the metals subcategory.
cadmium
chromium
copper
nickel
0.2 mg/L
8.9 mg/L
4.9 mg/L
37.5 mg/L
    3).     If the waste receipt contains oil and grease  < 100 mg/L  and does not have
           concentrations of cadmium, chromium, copper, or nickel above any of the values
           listed above, the waste receipt should be classified in the organics subcategory.

           At this point, the CWT facility has determined the applicable subcategories and should refer
    to Chapter 6 for implementing the rule if only one subcategory applies or Chapter 7 if more than
    one subcategory applies.

5.3 Follow-Up Subcategory Determination Procedures
           Once the CWT facility's initial subcategory determination (oils, metals, organics, or mixed)
    has been made,  the facility  will not need to repeat this  determination process where its
    wastestreams remain consistent.  This includes accepting a new wastestream that is within the
    CWT facility's current subcategory. However, if a CWT facility alters its operation to accept wastes
    from a subcategory outside its permit (or to no longer accept waste from a subcategory), the facility
    should notify the appropriate permitting or control authority and the subcategory determination
    should be re-visited.  EPA notes that current permit and  pretreatment regulations require
    notification to  the permitting or  control authority when significant changes occur.  EPA also
    recommends that a facility revisit its subcategory determination whenever the permit or control
    mechanism is re-issued, though this would not necessarily require complete characterization of a
    subsequent year's waste receipts if there is no indication that the make-up of the CWT facility's
    receipts had significantly changed.
                                               5-5

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     DETERMINING THE APPLICABLE SUBCATEGORIES                  CWT SMALL ENTITY COMPLIANCE GUIDE


5.4   Subcategory Determination Procedures for New CWT Facilities
           New CWT facilities  should estimate the percentage of waste receipts expected in each
     subcategory. Alternatively, the facility could compare the treatment technologies being installed
     to the treatment technologies selected  as the basis for the limitations or standards for each
     subcategory. After the initial year of operation, the permit writer or control authority should
     reassess the facility's subcategory determination and follow the procedure outlined for the initial
     determination for existing facilities. Because of the variable nature of waste receipts at CWT
     facilities, EPA recommends issuance of short-term permits or control mechanisms for new CWT
     facilities.

5.5   On-Site Wastewater Subcategory Determination
           The  sections  above explain how  an entity might  approach classifying its  off-site
     wastestreams. For other on-site generated wastewater sources such as those described in Chapter
     4  (for  example, contaminated stormwater,  emulsion  breaking  wastewater,  solubilization
     wastewater), wastewater generated in support of, or as the result of, activities associated with each
     subcategory should be classified in that subcategory. For facilities that are classified in a single
     subcategory, this step is unnecessary as the facilities should generally classify on-site wastewater
     in that subcategory.
           For facilities that are classified in more than one subcategory, and do not elect to comply
     with the multiple wastestream subcategory limits, the facilities should apportion the on-site
     generated wastewater to the appropriate subcategory. Certain waste streams may be associated
     with more than one subcategory such as stormwater, equipment/area washdown, air pollution
     control wastewater,  etc.   For these  wastewater sources, the volume generated should be
     apportioned to each  associated subcategory.  For example, for contaminated stormwater, the
     volume can be apportioned based on the proportion of the surface area associated with operations
     in each subcategory.  Equipment/area washdown may be assigned to a subcategory based on the
     volume of waste treated in each subcategory. Alternatively, permitting or control authorities may
     assign the on-site wastestreams to a subcategory based on the appropriateness of the selected
     subcategory treatment technologies.    EPA  notes that this is  only necessary for multiple
     subcategory facilities which elect not to comply with the Multiple Wastestream Subcategory
     limitations  or standards.
                                               5-6

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     DETERMINING THE APPLICABLE SUBCATEGORIES                  CWT SMALL ENTITY COMPLIANCE GUIDE
5.6  Examples
     Example 1
     A CWT facility has been operating for ten years and services 30 customers. This facility is located around
     auto manufacturers and mainly accepts metal finishing rinsewaters. Over the past two years the facility has
     also accepted used oils for recovery. It also accepts wastewaters from some customers that are unknown in
     origin, but which usually have oil and grease levels about 100 mg/L.  This facility generates emulsion
     breaking/gravity separation wastewater and equipment cleaning wastewater. It also collects and discharges
     rainwater collected on its property, but all of the CWT facility's activities occur inside a building.
           This facility may wish to review first all of its incoming waste receipts from the past year
     to ensure that the wastes listed above are the only wastes accepted for treatment. It may then
     compare its wastestreams to the waste receipt classification table. The waste classification table
     indicates that the metal finishing rinsewaters are classified in the metals subcategory and the used
     oils are classified in the oils subcategory. The wastes of non-specific origin can not be classified
     using the waste classification table, so this facility should utilize Step 3 for these wastes.  The
     facility notes that these wastes usually have oil and grease levels in excess of 100 mg/L. Therefore,
     based on the hierarchy established for Step 3, these non-specific wastes are also classified in the oils
     subcategory.  Therefore, this facility is both a metals and an oils subcategory facility.
           This facility also discharges on-site generated wastewaters - emulsion breaking wastewater
     and stormwater. The facility must determine if the discharge of these on-site wastewaters is subject
     to the CWT rule (that is, defined  as "CWT process wastewaters").  As described in Chapter 3,
     emulsion breaking wastewaters are subject to this rule. Stormwater, however, may or may not be
     subject to this rule. Based on the information provided, since the stormwater is collected outside
     the building, and there are no operations whatsoever outside, this stormwater is most likely non-
     contact stormwater and not a CWT process wastewater subject to this rule. Necessarily, if the non-
     contact stormwater is introduced  prior to the monitoring location, the limits would be adjusted
     using the combined  wastestream formula  or  building  block approach to account for the
     stormwater.  If the facility  maintains a waste handling area  outside the building  and this
     stormwater comes in contact with this waste handling area, it is contact stormwater and is CWT
     process wastewater subject to this rule.
           If this facility elects to comply with the mixed waste
     subcategory, it does not need to classify these on-site CWT
                           j,-  ,          .,   c  .,..    i  .   .      Non-contact stormwater is not
     process  wastewaters.  If, however, the facility  elects to    ^1TrT,
                                                                CWT process wastewater and
                                                                does not need to be classified
                                                                into a subcategory.
comply with the limitations or standards for the metals and
oils subcategory separately, it will be additionally required
to classify the on-site CWT  process wastewaters into the
metals or oils subcategory. Clearly,  the emulsion breaking
wastewater  and any wastewater associated with cleaning the treatment equipment for these
wastewaters will be classified in the  oils subcategory. Likewise, any wastewater associated with
cleaning the treatment equipment for the metals subcategory wastes will be classified in the metals
subcategory.  If the stormwater is contact stormwater and the  facility collects the contact
stormwater from dedicated areas of the facility for each subcategory, then these wastewaters would
be classified accordingly. If these contact stormwaters are not collected from dedicated areas, the
                                                5-7

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 DETERMINING THE APPLICABLE SUBCATEGORIES
CWT SMALL ENTITY COMPLIANCE GUIDE
facility could sample the wastewater to determine the level of oil and grease. If these levels exceed
100 mg/L, then these wastewaters will be classified in the oils subcategory. The facility may use
other methods as long as they can demonstrate to the permitting or control authority that these on-
site wastewaters receive adequate treatment.

Example 2:
The following is a waste receipt log for a single day for a CWT facility:

Table 5-2  Sample Waste Receipt Log
Customer
1
2
3
4
5
6
7
Waste Type
used oil
lubricants
oily wastewater
leachate
metal finishing waste
bilge water
electroplating waste
oil and grease
(mg/L)
40,000
50,000
250
20
15
99
150
Chromium
(mg/L)
10
2
non-detect
12
200
5
100
nickel
(mg/L)
15
50
non-
detect
39
1500
7
3000
Volatile Organic
Compounds
(VOCs)
(ug/L)
40
non-detect
20
100
non-detect
25
non-detect
       This facility  would only need to complete  Step  2 to determine  the  waste receipt
classification for this day's waste receipts.  All of the waste types are listed in the waste
classification table.  Used oils, lubricants, oily wastewater, and bilge water are all in the oils
subcategory. Leachate is in the organics subcategory, and metal finishing and electroplating wastes
are in the metals subcategory. This facility would not complete Step 3 since the waste receipt table
generally takes precedence  over the numerical criteria hierarchy.  Notice, however, that if the
wastewater from customer 6 was an unknown waste type, this facility would need to complete Step
3. Using this step, the wastewater from customer 6 would be classified in the organics subcategory.
This is a different subcategory than was established using Step 2.
                                           5-8

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               8

     SINGLE SUBCATEGORY FACILITIES
           hapter 6 provides guidance to aid small entities in determining what CWT subcategories
     i \     may apply to their CWT discharges. Many CWT facilities are subject to discharge limits
        -   for a single subcategory only. This chapter describes how CWT facilities that accept waste
     in only one CWT subcategory may comply with the CWT rule.

6.1   How Will the Permitting or Control Authority Establish My Limitations or Standards?
           An adequate waste management program is an important ingredient of a successful
     wastewater treatment system at CWT facilities. The permitting or control authority should confirm
     the CWT facility's single subcategory determination by looking at a sampling of the waste receipts
     at the  CWT facility. The  permitting or control  authority will then establish the appropriate
     discharge limitations or standards.  Available  guidance in calculating NPDES  categorical
     limitations for direct discharge facilities can be found in the U.S.  EPA NPDES Permit Writers'
     Manual (December 1996, EPA-833-B-96-003). Sources of information used for calculating Federal
     pretreatment standards for indirect discharge facilities include 40 CFR Part 403.6, the Guidance
     Manual for the Use of Production-Based Pretreatment Standards and the Combined Waste Stream
     Formula (September 1985) (CWF Guidance), and EPA's Industrial User Permitting Guidance
     Manual (September 1989).

6.2   What Compliance Options Do Facilities That Accept Wastes in a Single Subcategory Have?
           CWT facilities that are subject to effluent limitations and standards for more than one
     subcategory have a choice of either complying with limitations or standards determined for each
     applicable subcategory or complying with a single set of limitations and standards for multiple
     wastestreams. A single subcategory facility does not have a similar option and must comply with
     the limitations or pretreatment standards for the applicable subcategory (i.e. a metals subcategory
     must comply with the limitations (or standards) for the metals subcategory, etc.)

6.3   How Will the Permitting or Control Authority Incorporate the Cyanide Limit in the Metals
     Subcategory?
           Whenever a CWT facility accepts a waste stream that contains more than 136 mg/L of total
     cyanide, the CWT regulation requires that the  CWT facility monitor for cyanide when the
     wastewater exits the cyanide destruction process rather than after mixing with other process
     wastewater. Alternatively, under the regulations, the facility may monitor for compliance after
     mixing if the permitting or control authority adjusts the cyanide limitations (or standards) using
     the "building block approach" or  "combined waste stream formula," assuming the cyanide

                                             6-1

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limitations do not fall below the minimum analytical detection limit. For further information on
the "building block approach"  or "combined waste  stream formula",  see Section  14 of
Development Document for Effluent Limitations Guidelines and Standards for the Centralized
Waste Treatment Industry - Final, (EPA 821-R-00-020, referred to herein as TDD) and the CWF
Guidance referred to in 6.1 above.
                                         6-2

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                7

     MULTIPLE SUBCATEGORY FACILITIES
          ; PA estimates that many facilities in the CWT industry accept wastes in two or more
          ! subcategories (a combination of wastes in Subcategory A, B or C).  This chapter describes
          ohow CWT facilities that accept
     wastes in more than one subcategory
     may comply with the CWT rule.

7.1   What Steps Should I Take To Help
     Ensure  Compliance  with  My
     Limitations or Standards?
A multiple subcategory facility accepts wastes in
more than one CWT subcategory. It is different from
the case in which metal-bearing waste streams may
include low-level organic pollutants or that oily
wastes may include low level metal pollutants due to
the origin of the waste stream accepted for treatment.
            An adequate waste management program is an important ingredient of a successful
     wastewater treatment system at CWT facilities. The first step in such a system is identification and
     segregation  of wastestreams.   By identifying and  segregating waste  streams in different
     subcategories to the extent possible, a CWT facility is more likely to ensure obtaining optimal mass
     removals of pollutants from industrial wastes. Next, the CWT facility should employ treatment
     technologies designed and operated to optimally treat all off-site wastes received, as appropriate.
     For example, biological treatment is inefficient for treating concentrated metals waste streams like
     those found  in the metals subcategory or wastestreams with oil and grease compositions and
     concentrations like those found in the oils subcategory. In fact, concentrated metals streams and
     high levels of oil and grease compromise the ability of biological treatment systems to function.
     Likewise, emulsion breaking/gravity  separation, and/or dissolved air  flotation is typically
     insufficient for treating  concentrated metals wastewaters or wastewaters  containing organic
     pollutants which solubilize readily in water.  Finally, chemical precipitation is insufficient for
     treating organic wastes and waste streams with high oil and grease concentrations. This step is
     only required for facilities that elect to make an equivalent treatment determination.
            Once the  CWT facility is segregating its wastestreams and has appropriate treatment
     technologies in place for all off-site wastes received, as appropriate, the CWT facility should make
     sure it is operating its treatment technologies optimally.
            Finally, simply employing appropriate technologies may not ensure compliance with the
     regulations.  It is equally important that the CWT facility  operate these treatment technologies
     effectively.
                                              7-1

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       MULTIPLE SUBCATEGORY FACILITIES                                CWT SMALL ENTITY COMPLIANCE GUIDE
7.2    What Compliance Options Do Facilities Have if they Accept Wastes from More Than One
      Subcategory?
             Multiple subcategory facilities may comply with this rule in one of two ways. Facilities
      may:

      1.     elect to comply with the effluent limitations or standards for each applicable subcategory
             directly following treatment (before commingling with different subcategory wastes); or
      2.     certify equivalent  treatment and comply with one of the four sets of limitations or
             standards for the mixed waste subcategory (Subcategory D).  Each of these options is
             discussed further below.

      The choice of compliance is up to the CWT facility.  The percentage of waste  in a particular
      subcategory is irrelevant to the compliance method selected by the CWT facility.

7,2.1  Comply with Limitations or Standards for Subcategory A,B or C
             If a multi-subcategory CWT facility elects to comply with each applicable subcategories
      limitations or standards individually, the CWT facility must monitor for compliance with each
      subcategory's effluent limitations or standards prior to commingling wastestreams from different
      subcategories. For example, a CWT facility may accept metal finishing rinsewaters and used oils
      for treatment and recovery. In this case, the CWT facility must treat/recover the metal finishing
      rinsewaters and monitor for compliance with the metals subcategory limitations (or standards) and
      treat/recovery the used oil and monitor for compliance with the oils subcategory limitations (or
      standards). In other words, the example facility must monitor in two separate locations for the two
      different sets of subcategory limitations (or standards).
             This option can be beneficial in the case of CWT facilities that have separate treatment
      systems for their incoming waste receipts, for facilities that only accept a small amount of waste
      in one subcategory, or facilities that do not want to
      complete  the paperwork required to demonstrate
      equivalent  treatment.     However,  compliance
      monitoring costs  for  this  option will be  more
      expensive since it requires monitoring at more than
      one sample point.
Multiple subcategory CWT facilities
that comply with each subcategory's
limitations separately do not have to
demonstrate equivalent treatment.
      Figure 7-1 and the example 7-1 below illustrate this option.
                                                7-2

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 MULTIPLE SUBCATEGORY FACILITIES
                     CWT SMALL ENTITY COMPLIANCE GUIDE
Example 7-1
       Facility A accepts wastes in all three CWT subcategories with separate subcategory
       treatment systems and has elected to comply with each set of pretreatment standards
       separately. This facility treats 20,000 L/day of metal-bearing wastes, 10,000 L/day of oily
       wastes, and 45,000, L/day of organic wastes and discharges to its local POTW.
              Metals Waste
              20,000 L/day
 Oils Waste
10,000 L/day
Organics Waste
 45,000 L/day
                 Metals
                Treatment
    Oils
 Treatment
   Qrganics
  Treatment
              Sample Point 1            Sample Point 2             Sample Point 3

       Figure 7-1  Facility Accepting Waste in All Three Subcategories With Treatment in Each

       For this example,  the control authority establishes monitoring points 1, 2, and 3.  The
       control authority requires that the facility comply with the metals subcategory pretreatment
       standards at Sample Point 1, the oils subcategory pretreatment standards at Sample Point
       2, and the organics subcategory pretreatment standards at Sample Point 3. Note that the
       specific analytes requiring compliance monitoring vary at each sampling point since the
       pollutants regulated vary among subcategories.

Comply with Limitations or Standards for Subcategory D
       If a multi-subcategory CWT facility elects to comply with the limitations or standards for
Subcategory D, then the permitting or control authority will establish a single monitoring point
prior to discharge and apply the appropriate set of limitations or standards from Subcategory D.
This option can be beneficial in the case of existing CWT facilities that have sequential treatment
systems  or to facilities that want to monitor at a single point.  For example,  if a CWT facility
accepts wastes  in both  the metals and oils subcategory,  the permitting or control authority
establishes  limits or  standards  for  Subcategory D  facilities that commingle wastes from
Subcategories A and B. Examples 6-2 and 6-3 illustrate this approach. EPA notes that under this
approach, the permitting or control authority must allow a multi-subcategory facility to commingle
wastestreams prior to discharge. Also, facilities that select this compliance method must first
establish equivalent treatment as detailed in Chapter 8.
                                            7-3

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 MULTIPLE SUBCATEGORY FACILITIES
                      CWT SMALL ENTITY COMPLIANCE GUIDE
Example 7-2
       Facility B accepts wastes in all  three CWT subcategories with separate subcategory
       treatment systems and has elected to comply with Subcategory D pretreatment standards
       at a combined outfall. This facility treats 20,000 L/day of metal-bearing wastes, 10,000
       L/day of oily wastes, and 45,000 L/day of organic wastes and discharges to its local POTW.
              Metals Waste
              20,000 L/day
                   1
                  Metals
                Treatment
 Oils Waste
10,000 L/day
    i
     Oils
  Treatment
                                           Monitoring
                                             Point
Organics Waste
 45,000 L/day
    Organics
   Treatment
                                           Discharge
                                          75,000 L/day

       Figure 7-2  Facility Accepting Waste in All Three Subcategories With Treatment in Each and
       Combined Outfall
       First, the CWT facility must demonstrate equivalent treatment for
       all three subcategories.   The control authority then establishes a
       single monitoring point. The control authority  requires the facility
       to comply with Subcategory D pretreatment standards for facilities
       which commingle wastes from Subcategory A, B, and C.
                               Facilities may only
                               use this approach if
                               they establish
                               equivalent treatment.
                                              7-4

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      MULTIPLE SUBCATEGORY FACILITIES
CWT SMALL ENTITY COMPLIANCE GUIDE
      Example 7-3
             Facility C accepts waste in the oils and metals subcategory. The total volume ofwastewater
             discharged to the local POTWis 100,000 liters per day.  The facility segregates oils and
             metals  waste receipts and first  treats the oils waste receipts using two stage emulsion
             breaking/gravity separation and dissolved air flotation. The facility then commingles this
             wastewater with metal subcategory waste receipts and treats the combined wastestreams
             using primary and secondary chemical precipitation and solid/liquid separation followed by
             multimedia filtration.
                                   Metals Waste


Oils
Treatment
h- A
\


r S
Metals
Treatment
h- A

U*
r 1
Monitoring
Point
i. j
L/iscnarge

              Figure 7-3  Facility Accepting Wastes in Multiple Subcategories and Treating Separately

             First, the CWT facility must demonstrate equivalent treatment for the metals and the oils
             subcategory. Like example 7-2, the control authority then establishes a single monitoring
             point. This monitoring point follows the metals treatment. The control authority requires
             the facility  to comply with Subcategory D pretreatment standards for facilities which
             commingle wastes from Subcategories A and B.
7.3   How Will the Permitting or Control Authority Incorporate the Cyanide Limit in the Metals
      Subcategory?
             Whenever a CWT facility that is a small entity accepts a waste receipt that contains more
      than 136 mg/L of total cyanide, the CWT facility must monitor for cyanide when the wastewater
      exits the cyanide destruction process rather than after mixing with other process wastewater.
      Alternatively, the facility may monitor  for compliance after mixing if permitting  or control
      authority adjusts the cyanide limitations using the "building block approach" or "combined waste
      stream formula/' assuming the cyanide  limitations do not fall below the minimum analytical
      detection limit.  For further information on the "building block approach" or "combined waste
      stream formula", see Section 14 of the TDD.  Example 7-4 illustrates this approach.
                                                  7-5

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 MULTIPLE SUBCATEGORY FACILITIES
CWT SMALL ENTITY COMPLIANCE GUIDE
Example 7-4
       Facility C in example 7-3 also accepts concentrated cyanide baths.
Metals Wa
with Cyaru

ste
de
' ^
Cyanide
Pretreat
k. _j



Cyanide
Monitoring
Point
k. A
>ois waste

r -^
Oils
Treatment
k, ^

vr

r 1
Metals
Treatment
i j



Efecharge
Monitoring
Point
K. ^
L^iscnargt

       Figure 7-4 Facility Accepting Multiple Subcategory Wastes (including Cyanide) and Treating
       Separately

       In  addition to monitoring for compliance with the multiple wastestream subcategory
       pretreatment standards for a combination of metals and oils wastes, this facility would be
       required to monitor for compliance with cyanide pretreatment standards. Alternatively, the
       control authority may  allow  the facility to  monitor for compliance with the cyanide
       pretreatment standards at the monitoring point at the point of discharge if the control
       authority adjusts the limit appropriately and  that limit does not fall below the minimum
       analytical detection limit.
                                              7-6

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                o

      EQUIVALENT  TREATMENT DETERMINATION
             s described in Chapter 7, a CWT facility that accepts wastes in more than one CWT
             subcategory may elect to comply with the appropriate set of limitations or standards for
       A   ;  Subcategory D. A facility, however, may only elect to comply with the Subcategory D
             limitations or standards if it has established that it is providing "equivalent treatment."
      Providing equivalent treatment  means that the facility is providing treatment  for its mixed
      wastewater that is designed to ensure pollutant removal that are essentially the same as would be
      obtained from separate treatment of the different subcategory wastestreams.  If a facility cannot
      establish equivalent treatment then it must comply with each applicable subcategory's limitations
      or standards individually. This chapter provides guidance to CWT facilities on how to establish
      equivalent treatment.

8.1    Introduction
             Before a multi-subcategory CWT facility may elect to comply with effluent limitations or
      standards from Subcategory D, it must first demonstrate equivalent treatment for each applicable
      subcategory. The CWT rule defines equivalent treatment as "a wastewater treatment system that
      achieves comparable pollutant removals  to the applicable treatment technology selected as the
      basis for the limits and standards."  The permitting or control authority makes the equivalent
      treatment determination. The CWT facility needs to provide its permitting or control authority
      with the information and data needed to make this determination.  The CWT rule defines three
      things a CWT facility must do to demonstrate equivalent treatment. The  facility must:

      1.      submit an initial certification statement;
      2.      submit periodic certification statements; and
      3.      maintain on-site compliance paperwork.

      Each of these requirements are discussed in more detail below.

8.2    Initial Certification Statement
8,2.1  What is an Initial Certification Statement?
             The initial  certification  statement  is a written
      submission from a  CWT  facility to the  appropriate
      permitting  authority certifying that its treatment train
      includes all applicable equivalent treatment systems.  It
The initial certification
statement should be signed by
the same person who signs the
          . ,   .    j ,    .,          .-.,             ,,.          compliance status reports.
      must be signed by  the responsible corporate officer as       r              r

                                               8-1

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       EQUIVALENT TREATMENT DETERMINATION                             CWT SMALL ENTITY COMPLIANCE GUIDE
       defined in 40 CFR 403.12(1) or 40 CFR 122.22. It should also be kept on file at the CWT facility as
       part of the required on-site compliance paperwork.

3,2.2   When Does the Facility Have to Submit the Initial Certification Statement?
              The CWT facility must notify its permitting or control authority of its desire to be subject
       to  Subcategory  D  limitations  or
       standards  by  submitting an initial
       certification  statement.    Table  8-1
       outlines  when  CWT  facilities  must
       submit an initial certification statement.
EPA suggests that an indirect CWT facility planning to
comply with the multiple wastestream subcategory
standards notify its control authority of this intent and
also state, based on its BMR submission, whether it can
                                                or cannot comply with the standards currently.
                                               ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^

       Table 8-1 Initial Certification Dates

        „     ..„..._              _,   .      ... i^  L-C:  ^   ct t     IT^ t     Submission Must Be
        Type of CWT Faculty         Required Initial Certification Statement Date    ,, ,
         yv	y	^	Made to:	

        Existing Direct Discharger     at the time of permit renewal or modification   NPDES permit writer

        Existing Indirect Discharger   prior to December 22, 20031                   control authority

        New Direct Discharger       at the time of submitting its application for     NPDES permit writer
                                   permit

        New Indirect Discharger      at the time of submitting its application for an   control authority
                                   individual control mechanism
8.2,3   What Does a CWT Facility Have to Include in an Initial Certification Statement?
              The CWT rule requires the initial certification to include three items:
       1.      A list and description of the subcategories of wastes accepted for treatment at the CWT
              facility;
       2.      A list and description of the treatment systems at the CWT facility and the conditions under
              which the treatment systems  are operated for the subcategories of wastes accepted for
              treatment; and
       3.      Information and supporting data establishing that these treatment systems will achieve
              equivalent treatment.

              The following sections provide guidance to small entities that are CWT facilities on how
       EPA envisions these materials should be submitted.
                facilities need to submit the initial certification to their control authorities well in
         advance of this date to ensure multiple wastestream pretreatment standards are in effect by
         this date.

                                                   8-2

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EQUIVALENT TREATMENT DETERMINATION                            CWT SMALL ENTITY COMPLIANCE GUIDE
     1: List and description of the subcategories of wastes accepted for treatment at the facility
       While not required, CWT facilities may use the guidance provided in Chapter 5 to aid in
determining what subcategories of wastes are accepted for treatment/recovery at the facility. The
list of wastes accepted for treatment at the facility may be general (i.e., landfill leachate, used oil,
metal finishing wastewater) or may be more specific (i.e., broken down by RCRA codes or waste
codes).  Based on information collected by EPA during development of this rule, CWT facilities
already collect this type of information as part of their waste acceptance procedures. Table 8-2 is
an example of the type of information EPA envisions facilities submitting to document the wastes
accepted for treatment at the facility.

Table 8-2  Types of Wastes Accepted at Acme CWT

 oils subcategory                               metals subcategory
 used oil                                      spent electroplating sludges
 lubricants                                    metal finishing rinse waters
 coolants                                      waste acids or bases with metals
 oil-water emulsions
 non-contact used glycols
     2: A list and description of the treatment systems at the facility and the conditions under which the
treatment systems are operated for the subcategories of wastes accepted for treatment
       The facility should provide information on the treatment systems for each subcategory
identified in Step 1 above.  This should include a listing of each treatment technology step that will
be used (not which is present at the facility) to treat the wastestreams. In EPA's view, this should
include a flow diagram of each treatment system as well as a written discussion.  This written
discussion should include pertinent information on the operation of each treatment step such as
the type of treatment chemicals included in a chemical precipitation step.  Figure 8-1 is an example
of the level of detail envisioned by EPA.
                                           8-3

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EQUIVALENT TREATMENT DETERMINATION
                                                        CWT SMALL ENTITY COMPLIANCE GUIDE
   M  EMORANDUM
                                                                                          July 1, 20XX

   FROM:          Jane Doe, Plant Supervisor, Acme CWT
   TO:             Pretreatment Coordinator, City POTW
   SUBJECT:       Equivalent Treatment Determination for CWT Regulation

           The Acme CWT facility treats both oils and metals subcategory wastes. As illustrated below,
   some oily wastewater is sent directly to oil/water separation tanks where gravity oil/water separation
   occurs. Others do not separate efficiently using gravity alone and are transferred to the emulsion breaking
   tank where heat and/or treatment chemicals may be added to break the emulsions. The temperature and
   treatment chemicals vary depending on the emulsion being treated.  Treatment chemicals may include
   polymer, sulfuric acid, and/or alum. The resulting wastewater from the oil/water separation phase is
   then treated by dissolved air flotation. The DAF system consists of a 3,000 gallon slow-mix tank, a DAF
   unit, chemical mix tanks, metering pumps for each chemical, and in-line mixers. The treatment chemicals
   added to the DAF vary depending on the wastewater being treated and may include polymer or caustic.
   The total detention time of the DAF system is 50 to 100 minutes. Wastewater from the DAF is then
   commingled with treated metals subcategory wastewater for final discharge.

           Metals subcategory wastewaters are treated in a system which consists of primary and secondary
   metals precipitation.  Primary precipitation treatment occurs in the primary treatment tanks where lime is
   added. The precipitation is carried out at ambient temperatures with pH ranging from 8 to 9.5. Caustic or
   waste sulfuric acid may also be added to maintain pH.  Other chemicals such as sodium sulfide or
   potassium permanganate may also be added. The resulting wastewater is then sent to a clarifier.
   Following clarification, the wastewater is processed through a second precipitation step.  Once again the
   precipitation is carried out at ambient temperatures and the pH varies depending on the specific metals
   being removed from the wastewater. Treatment chemicals may include caustic, sulfuric acid, lime, or
   ferric chloride. The resulting wastewater is then clarified and commingled with treated oils subcategory
   wastewater.

                      Non-Emulsified
                      Oils Waste
      Emulsified
      Oils Waste
                      Emulsion
                      Breaking
                                  Gravity
                                  Separation
                  Dissolved
                  Air Flotation
    Metals
    Waste
Primary
Chemical
Precipitation
                                   Clarification
Secondary
Chemical
Precipitation
                                                                            Clarification
              Figure 8-1  Sample Memorandum for Equivalent Treatment Determinations

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EQUIVALENT TREATMENT DETERMINATION
     CWT SMALL ENTITY COMPLIANCE GUIDE
     3: Information and supporting data establishing that these treatment systems will achieve equivalent
treatment.
       The CWT rule defines equivalent treatment as a "wastewater treatment system that
achieves comparable pollutant removals to the applicable technology selected as the basis for the
limitations and pretreatment standards.  Comparable removals may be demonstrated through
references in technical and engineering treatises, journals or other literature, treatability tests, or
self-monitoring data." The most common measurement of pollutant removals is percent removal
which measures the amount of contaminant removed from the wastestream. Calculation of percent
removals is discussed in more detail in Chapter 7 of the technical development document and is:
(MASS^^t - MASSeffluent)/MASStafluent.  EPA calculated
the percent removals for each regulated pollutant using
the data included for developing the  limitations and
standards in each subcategory. Tables 8-3 and 8-4 show
these pollutant removals.  CWT facilities can use the
information in these tables to compare  the pollutant
removals achieved  by their selected technologies to
EPA's technology basis.
The treatment technologies selected
as the basis for the limitations and
pretreatment standards are listed in
Table 3-1 in Chapter 3.
Table 8-3  Removal Efficiencies for Indirect Discharging CWT Treatment Systems
Oils Subcategory
Pollutant Parameter
CLASSICALS
Total Cyanide

METALS
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Silicon
Oils Subcat.
Existing
Source
Removal (%)

64.38


87.99
57.64
91.91
88.07
80.54
52.20
91.09
92.64
77.43
53.73
41.24
36.94
54.16
Oils Subcat.
New
Source
Removal (%)
64.38

87.99
57.64
91.91
88.07
86.24
52.20
90.02
88.26
77.43
53.73
41.24
36.94
54.16
Metals Subcategory
Pollutant Parameter
CLASSICALS
Hexavalent Chromium
Total Cyanide
METALS
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Iridium
Lead
Lithium
Mercury
Molybdenum
Nickel
Selenium
Metals Subcat.
Existing & New
Source
Removal (%)
98.01
99.30
94.30
91.74
99.97
99.91
98.47
99.91
99.69
99.95
66.83
98.38
26.40
99.59
57.54
Organics Subcategory
Pollutant Parameter
CLASSICALS
Total Cyanide

METALS
Antimony
Cobalt
Copper
Molybdenum
Silicon
Strontium
Zinc

ORGANICS
2-butanone
2-propanone
2,3-dichloroaniline
2,4,6-trichlorophenol
Organics Subcat.
Existing &
New Source
Removal (%)
33.46

33.27
17.31
38.04
57.10
4.71
59.51
60.51

69.20
68.57
80.45
45.16
                                          8-5

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EQUIVALENT TREATMENT DETERMINATION
CWT SMALL ENTITY COMPLIANCE GUIDE
Table 8-3  Removal Efficiencies for Indirect Discharging CWT Treatment Systems
Oils Subcategory
Pollutant Parameter
Strontium
Tin
Titanium
Zinc


ORGANICS
2-Butanone
4-chloro-3-methylphenol*
Acenapthene
Alpha-terpineol
Anthracene
Benzo (a) anthracene
Benzole acid
Bis(2-
Butyl benzyl phthalate

Carbazole
Chrysene
Diethyl phthalate
Fluoranthene
Fluorene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o-cresol*
p-cresol*
Phenol
Pyrene
Pyridine
Oils Subcat.
Existing
Source
Removal (%)
50.68
90.77
89.99
80.33



15.41
-
96.75
94.77
97.07
94.38
6.54
93.22
92.19

81.09
96.93
77.01
96.24
95.32
97.36
97.25
94.14
95.88
97.38
97.32
97.26
-
-
53.68
97.10
21.45
Oils Subcat.
New
Source
Removal (%)
50.68
90.77
89.99
83.48



15.41
27.48
96.75
94.77
96.67
95.69
19.32
93.66
92.19

81.09
97.22
63.97
95.21
92.86
94.98
96.87
96.50
95.54
96.53
97.20
96.85
21.08
34.88
14.88
97.63
21.45
Metals Subcategory
Pollutant Parameter
Silicon
Silver
Strontium
Tin

Titanium
Vanadium
Yttrium
Zinc
Zirconium

ORGANICS
2-Butanone
2-Propanone
Benzole Acid
n,n-
Dimethylformamide
Pyridine
















Metals Subcat.
Existing & New
Source
Removal (%)
98.58
99.62
95.89
99.94

99.84
99.46
95.39
99.93
42.13


74.72
65.62
82.99
54.81

48.49
















Organics Subcategory Organics Subcat.
Pollutant Parameter Existing &
New Source
Removal (%)
Acetophenone 92.44
Aniline 92.88
Benzole Acid 94.29
n,n- 89.26
Dimethylformamide
o-Cresol 98.39
p-Cresol 85.38
Pentachlorophenol 23.19
Phenol 87.08
Pyridine 61.69
























' Not applicable for Existing Sources
                                            8-6

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EQUIVALENT TREATMENT DETERMINATION
CWT SMALL ENTITY COMPLIANCE GUIDE
Table 8-4  Removal Efficiencies for Direct Discharging CWT Treatment Systems
Oils Subcategory
Pollutant Parameter
CLASSICALS
Total Cyanide

METALS
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Silicon
Strontium
Tin
Titanium
Zinc


ORGANICS
2-Butanone
4-chloro-3-
metnylpnenol*
Acenapthene
Alpha-terpineol
Anthracene
Benzo (a) anthracene
Benzole acid
Bis(2-ethylhexyl)
phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Diethyl phthalate
Fluoranthene
Fluorene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o-cresol*
Oils Subcat.
Existing &
New Source
Removal (%)
64.38

87.99
57.64
91.91
88.07
86.24
52.20
90.02
88.26
77.43
53.73
41.24
36.94
54.16
50.68
90.77
89.99
83.48


15.41
27.48

96.75
94.77
96.67
95.69
19.32
93.66
92.19
81.09
97.22
63.97
95.21
92.86
94.98
96.87
96.50
95.54
96.53
97.20
96.85
21.08
Metals Subcategory
Pollutant Parameter
CLASSICALS
Hexavalent Chromium
Total Cyanide
METALS
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Iridium
Lead
Lithium
Mercury
Molybdenum
Nickel
Selenium
Silicon
Silver
Strontium
Tin

Titanium
Vanadium
Yttrium
Zinc

Zirconium

ORGANICS
2-Butanone
2-Propanone
Benzole Acid
n,n-Dimethylformamide
Pyridine












Metals Subcat.
Existing Source
Removal (%)
98.01
99.30
94.30
91.74
99.97
99.91
98.47
99.91
99.69
99.95
66.83
98.38
26.40
99.59
57.54
98.58
99.62
95.89
99.94

99.84
99.46
95.39
99.93

42.13

74.72
65.62
82.99
54.81
48.49












Metals Subcategory
Pollutant Parameter
CLASSICALS
TSS

METALS
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Tin
Titanium
Vanadium
Zinc


























Metals Subcat.
New Source
Removal (%)
99.97

99.76
99.87
99.98
99.98
99.76
100.00
99.79
99.89
40.11
99.86
94.33
99.61
99.89
99.78
98.95
99.99


























Organics
Subcategory
Pollutant Parameter
CLASSICALS
Total Cyanide

METALS
Antimony
Cobalt
Copper
Molybdenum
Silicon
Strontium
Zinc

ORGANICS
2-butanone
2-propanone
2,3-dichloroaniline
2,4,6-trichlorophenol
Acetophenone
Aniline
Benzole Acid
n,n-
Dimethylform amide
o-Cresol
p-Cresol
Pentachlorophenol
Phenol

Pyridine


















Organics Subcat.
Existing &
New Source
Removal (%)
33.46

33.27
17.31
38.04
57.10
4.71
59.51
60.51

69.20
68.57
80.45
45.16
92.44
92.88
94.29
89.26

98.39
85.38
23.19
87.08

61.69


















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EQUIVALENT TREATMENT DETERMINATION
                                                         CWT SMALL ENTITY COMPLIANCE GUIDE
Table 8-4  Removal Efficiencies for Direct Discharging CWT Treatment Systems
OilsSubcategory OilsSubcat.
Pollutant Parameter Existing &
New Source
Removal (%)
p-cresol* 34.88
Phenol 14.88
Pyrene 97.63
Pyridine 21 .45
Metals Subcategory Metals Subcat.
Pollutant Parameter Existing Source
Removal (%)

Metals Subcategory Metals Subcat.
Pollutant Parameter New Source
Removal (%)

Organics Organics Subcat.
Subcategory Existing &
Pollutant Parameter New Source
Removal (%)

       For the Acme CWT facility described in Figure 8-
1 above, the facility could simply state that it uses the
same treatment technologies selected as the basis for the
limitations and  standards for the oils  and  metals
subcategory, and has therefore demonstrated equivalent
treatment.  However, a CWT facility does not need to
use the treatment systems selected as the basis of the
                                  limitations  and
                                                     An evaluation of equivalent
                                                     treatment should focus on
                                                     effective treatment of each
                                                     subcategory's wastes in the
                                                     treatment train. The goal is not to
                                                     evaluate combined wastestreams
                                                     from different subcategories.
  EPA included this
  requirement so that pollutant
  reductions would be through
  treatment rather than dilution.
                                  standards to demonstrate equivalent treatment. As defined,
                                  equivalent  treatment  may  be  demonstrated  through
                                  literature studies, treatability tests, or self-monitoring data,
                                  or  a combination of these. Each of these are discussed
                                  further below.
                                                   The National Risk Management
                                                   Research Laboratory's (NRMRL)
                                                   Treatability Database can be accessed
                                                   on-line:  www.epa.gov/tdbnrmrl
Demonstrate equivalent treatment through literature
       Effective treatment  technologies  can  be
identified through a variety of sources  including
technical  literature,  treatability  databases,  and
treatment vendors.  Treatability testing on similar
wastewaters may provide clues on how to effectively
treat a particular wastewater. Treatment technology
vendors should have information on the capabilities of their treatment systems. A CWT facility
may use information from any of these sources, if available, to demonstrate that a particular
treatment system will achieve comparable removals to EPA's model technologies. This option may
be particularly useful if a facility has actual removal data for a particular technology for some
regulated pollutants and not others, but  can demonstrate through literature sources that the
pollutants should be treated in a similar manner.
Demonstrate equivalent treatment through treatability tests
       Literature sources are a good method for evaluating various treatment technologies, but
treatability tests may also be required to demonstrate that a particular technology has comparable
removals to the model technologies selected as the basis for the rule. For example, a facility may
have literature information that carbon adsorption is effective for the removal of n-dodecane, but

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EQUIVALENT TREATMENT DETERMINATION                           CWT SMALL ENTITY COMPLIANCE GUIDE
does not have information on n-decane. Because these chemicals have similar structures, one
would expect them to behave similarly. However, a treatability test would provide the CWT
facility with the additional data which confirm the equivalent treatment demonstration.
       Many CWT facilities already perform  treatability tests to  obtain optimum pollutant
removals and identify alternative treatment schemes. A treatability test may also allow a facility
to identify surrogate parameters that may be used on an on-going basis to demonstrate equivalent
treatment.
       When conducting a treatability test, facilities may only test the individual treatment unit
operations. However, if a facility intends to implement an entire treatment train, testing the entire
train may reveal important information about how the wastewater characteristics change with each
treatment step. Testing the wastewater through the entire treatment train can help troubleshoot
the system and determine whether pretreatment steps are adequate to prevent malfunctioning of
other unit operations in the treatment train.
       It is not always  necessary to treat a large volume of wastewater in treatability tests, and
often valuable information can be acquired from smaller scale tests. Treatability tests are typically
categorized based on size as bench-, pilot- and full-scale test. A bench scale test is typically used
to screen treatment technologies or determine  initial design  and operating parameters,  and is
typically conducted  on one gallon  or  less of  wastewater.  Bench  scale  tests  use laboratory
equipment (for example, beakers, hot plates, and stirring rods) and may be conducted on synthetic
wastewater (that is, distilled water spiked with a known concentration of contaminants). A bench
scale test requires less cost and effort because of the smaller volume of wastewater tested and the
basic equipment used.  In addition, a bench scale treatability test may involve less sophisticated
sampling and analysis,  and may use indicator parameters or visual appearance of the wastewater
instead of laboratory analysis to gauge test results.
       A pilot scale test is conducted on actual wastewater,  and is typically  used to optimize
design and operating parameters and to troubleshoot treatment problems before constructing a
full-scale treatment system. Actual wastewater may contain surfactants, chelates, or impurities that
may interfere with treatment. The test is generally intermediate in size. Pilot scale tests typically
use smaller and simpler equipment than would be found in a full scale system, such as buckets and
drums instead of treatment tanks. These systems may also use temporary equipment that can be
disposed of after the test instead of permanently installed.
       A full scale treatability test is conducted on actual wastewater using the actual size and type
of equipment to be used for routine treatment.
       If a CWT facility elects to demonstrate equivalent treatment through treatability tests, it
needs to submit a detailed description of its treatability tests as well  as the results.  The detailed
description should include the type of treatability test and the parameters used for evaluation.
Operating parameters and information on the wastes treated should also be submitted. Figure 8-2
is an example of a treatment test summary that may be  submitted as part of an equivalent
treatment demonstration. The example  shows treatability tests using oils subcategory wastes.
                                          8-9

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EQUIVALENT TREATMENT DETERMINATION
CWT SMALL ENTITY COMPLIANCE GUIDE
Facility:
Date:
Location:
Prepared by:
Insert your optimal treatment train and operating parameters in the space provided below:
Sulfuric
1 and Poly
Addition
V K
' 	 IX*
Oils Waste
Technology
Acid Caustic and
mer |"| Lime Addition
II
Emulsion ^7

T = 60 deg C
24 hour settling time
Chemical
& Settling
PI pH adju
— 	 rx,
	 \^
pH=9
T = 25 deg C
1 hour detention time
stment
Carbon
i ^
pH=7
T = 25 deg C
flow rate = 87 mL/i
empty lied residenc
Pollutant pH Temp, Treat Constituent
deg. C Time Concentration
Influent Effluent
(mg/L) (mg/L)
Emulsion
breaking
Single stage
precipitation
Carbon
n-decane
carbazole
fluoranthene
chromium
chromium
n-decane
carbazole
fluoranthene
2 60 24 hr. 1,000 700
2 60 24 hr. 2500 2000
2 60 24 hr. 3,000 2,000
2 60 24 hr. 230 150
9 25 Ihour 150 1
7 25 15min 700 10
7 25 15min 2000 20
7 25 15min 2000 40

Treated
Effluent
nin
° time = 15 min
Test CWT
% BAT
Rem %
Rem
30.0
20.0
33.3
34.8
99.3
98.6
99.0
98.6
                        Figure 8-2 Sample Treatment Test Summary
       For the parameters listed, this information indicates that the treatment systems evaluated
achieve comparable removals to the treatment systems selected as the basis for the CWT limitations
and pretreatment standards. Alternatively, if a treatment technology only removes 30 percent of
a parameter, but that parameter is removed to below its detection limit or to the required discharge
limits or standards, this would also demonstrate comparable removals.
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       EQUIVALENT TREATMENT DETERMINATION                           CWT SMALL ENTITY COMPLIANCE GUIDE
      Self Monitoring Data
             The CWT facility may also provide the permitting or control authority with self-monitoring
      data to establish equivalent treatment.  This is essentially the same as conducting a full-scale
      treatability test discussed above. It is important to remember that this self-monitoring data must
      demonstrate equivalent treatment for each individual subcategory and should not include
      commingled wastewater from different subcategories or non-CWT wastewater such as stormwater.
       The information submitted should be similar to that submitted for treatability tests and should
      include a summary table similar to Table 8-3. Self-monitoring data from the treatment system as
      employed on actual waste receipts is the most  fool-proof method for demonstrating equivalent
      treatment.

8.3    Periodic Certification Statement
      What Is a Periodic Certification Statement?
             The periodic certification statement is a written submission to the permitting or control
      authority  that  certifies the facility is operating its treatment systems to provide equivalent
      treatment as set forth in its initial certification.  In the event that the  facility has modified its
      treatment systems, it must also include a justification to allow modification of the practices listed
      in its initial certification. The rule provides that the statement must be signed by the appropriate
      manager in charge of overall operations at the site to ensure that information provided is true,
      accurate, and complete to the best of his/her knowledge. Again, this manager should be the same
      person who signs compliance status reports required by 40 CFR 403.12(1) or 40 CFR 122.22. The
      periodic certification statements should also be kept on file at the facility as part of the required on-
      site compliance paperwork.

8,3.2  When Does  a CWT Facility Have to File the Periodic Certification Statement?
             The CWT rule requires the CWT facility to submit a periodic certification statement once
      per year.   The permit writer or  control authority should determine the required month of
      submission of the periodic certification statement and include this in the facility's discharge permit
      or control mechanism.

      What Information Should Be Included in the Periodic Certification Statement?
             If the information contained in the initial certification statement is still applicable, including
      information on the subcategory type for wastes accepted for treatment, a facility shall simply state
      that in a letter to the permit writer or control authority, and the letter shall constitute the periodic
      statement. However, if the facility has modified its treatment system or the subcategories of wastes
      accepted for treatment, it shall submit the revised information in a manner similar to the  initial
      certification. In EPA's view, a modification is a change in treatment technology or a major change
      in operation. A CWT facility accepting different types of wastes within the same subcategory
      previously identified is not a major modification. EPA understands that CWT facilities may change
      operating parameters as needed depending on the waste being treated.  In EPA's view, a  major
      change in operating parameters (such as pH, temperature, etc.) is one that is not listed  in the
      original certification that may reduce the effectiveness of the treatment. Similarly, a change in the
      treatment technology is any significant technology change that may reduce the effectiveness of the
      overall treatment system. For example, it would not include the addition of a mixer to an existing

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EQUIVALENT TREATMENT DETERMINATION
CWT SMALL ENTITY COMPLIANCE GUIDE
technology, but would include removing/changing an entire treatment step in a treatment train.
An example of a periodic certification statement in shown in Figure 8-3.
                                                                      ACME CWT
                                                                      1234 Main Street
                                                                      Anytown, VA 12345

                                                                      March 1, 20XX
          Anytown POTW
          1 Main Street
          Anytown, VA 12345

          Dear Sir/Madam:

                  Please be advised that our facility located at 1234 Main Street still accepts wastes in
          both the CWT oils and metals subcategories.  The information in our original certification
          remains the same except that we now occasionally add a polymer to the DAF system.  This
          has not reduced the effectiveness of the system.

                  Please feel free to contact me at (703) 555-5555 if you have any questions or
          comments about this additional treatment chemical.
                                                       Sincerely,
                                                       John Doe
                                                       President
                         Figure 8-3 Sample Periodic Certification Statement
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       EQUIVALENT TREATMENT DETERMINATION                           CWT SMALL ENTITY COMPLIANCE GUIDE
8.4    On-Site Compliance Paperwork:
      What Materials Must Be Included with the On-site Paperwork?
             The CWT rule requires the following materials be included as part of the on-site paperwork:
      1.      A  general list  and  description  of  the subcategory wastes  being  accepted for
             treatment/recovery at the facility;
      2.      A list and description of the treatment systems at the facility and the conditions under
             which the treatment systems are operated for the subcategories of wastes accepted for
             treatment;
      3.      Information and supporting data establishing that these treatment systems will achieve
             equivalent treatment.
      4.      A description of the procedures it follows to  ensure that its treatment systems are well
             operated and maintained; and
      5.      An explanation of why the procedures it has adopted will ensure its treatment system are
             well-operated and maintained.

             The first three items are included in the initial certification  and periodic certification
      statements. Therefore, the CWT facility should keep these certifications on file.  Items 4 and 5 are
      discussed in more detail below.

      Treatment System Operation and Maintenance
             CWT facilities that comply with Subcategory D limitations or standards must also choose
      a method to demonstrate that their treatment system(s) are well operated and maintained. This
      method should be stated and the rationale for choosing it should be discussed in the on-site
      compliance paperwork, such as an environmental management system (EMS).
             Proper operation and maintenance of a system includes a qualified person to operate the
      system, use of correct treatment chemicals in appropriate quantities, and operation of the system
      within stated design parameters (for example, temperature and  pressure).  Basically, the CWT
      facility should keep  records of its operating parameters for  its  treatment systems.  Based on
      information EPA collected during the development of this rule, most CWT  facilities already
      maintain these records on-site. For example, the CWT facility should keep records on the amount
      and type of chemicals added to each step of its treatment systems. The facility should also
      document flow rates and recycle rates on a regular basis (or whenever possible).  Additionally,
      facilities operating systems that require periodic maintenance (such as multimedia filters or carbon
      adsorption systems) should keep records  on this aspect  of treatment system  operation.
      Alternatively, a facility could also monitor for specific parameters or a surrogate parameter. For
      example, a facility may operate dissolved air flotation. The method for demonstrating that the
      dissolved air flotation system is well operated can be as simple as maintaining records on the
      temperature and pH, the chemicals added (including quantity), the duration of treatment, recycle
      ratio,  and physical characteristics  of the wastewater before  and after dissolved air flotation.
      Conversely, the facility could monitor for selected parameters for the  purpose of demonstrating
      effective treatment. This could include any pollutant or a combination of pollutants.  A CWT

                                               8-13

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       EQUIVALENT TREATMENT DETERMINATION                           CWT SMALL ENTITY COMPLIANCE GUIDE
      facility should work with its permitting or control authority to determine whether its current EMS
      or alternative method for demonstrating that its treatment system(s) are well operated and
      maintained
             EPA notes that permitting or control authorities may inspect the CWT facility at any time
      to confirm that the listed practices are being employed, that the treatment system is well operated
      and maintained,  and that the necessary paperwork provides sufficient justification for any
      modifications.

8.5    Additional Considerations  Permitting and  Control Authorities May Use in Confirming
      Equivalent Treatment Determinations
             Permitting and control authorities will evaluate and review certification statements and
      on-site compliance paperwork from CWT facilities for conformity with the rule requirements.
      Factors that may influence their decisions include previous experience with the CWT facility, the
      CWT facility management's commitment to program implementation, and the thoroughness and
      accuracy of the supporting documentation.
             One area subject to interpretation is the determination of treatment system equivalency.
      When reviewing treatment system performance data, the permitting or control authority will likely
      review the source of data, the time period during which it was collected, and the type of data
      collected.
                                               8-14

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                9
      COMPLIANCE ASSURANCE PROCESS
           .his chapter explains how EPA will determine compliance with the CWT rule, what happens
           if you or EPA discovers noncompliance, and the legal status of this guide.
9.1   How Will EPA Determine Compliance With the CWT Rule
            EPA uses several approaches to monitor compliance with its environmental regulations,
     including methods initiated by EPA and by facilities.
     A.
Compliance
Monitoring -
     B.     Reporting -
Each  discharge permit  or  individual  control mechanism includes
compliance monitoring requirements. These requirements typically specify
the frequency of monitoring required as well as the individual parameters
to be monitored and their respective discharge limits. Most permits (or
control mechanisms) include limits for the daily maximum and the monthly
average. The compliance monitoring must demonstrate that the discharge
complies with both.

The permitting or control authority will monitor reports submitted by the
facility including discharge monitoring reports and periodic certification
statements. These are the key means by which your compliance will be
evaluated.
     C.
Inspections -  Permitting authorities, control authorities, or EPA may conduct periodic
             inspections at facilities subject to this regulation.  Inspections may be
             initiated by disclosures, random selection, or a variety of other targeting
             methods. Inspections may be used to evaluate operations, records, or other
             information at the facility. This will be an important component in assuring
             equivalent treatment at facilities which have elected this option.
     D.
Self
Disclosure -
                         The CWT  facility has  the primary responsibility for ensuring that its
                         wastewater discharge complies continuously with its numerical discharge
                         requirements and, if applicable, its equivalent treatment demonstration.
                         EPA encourages CWT facilities to take advantage of EPA's self disclosure
                         policies or small business policy.
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       COMPLIANCE ASSURANCE PROCESS                                 CWT SMALL ENTITY COMPLIANCE GUIDE
9.2    If I Discover a Violation, How Can I Work with EPA to Correct It?
             EPA encourages self-disclosure of violations and has implemented two policies to meet this
      goal.   These policies meet the  objectives of Section 223 of the Small  Business Regulatory
      Enforcement Fairness Act of 1996 (SBREFA), which provides for the reduction, and, under some
      appropriate circumstances, the complete waiver  of  civil penalties for certain environmental
      violations.  The policies are:

      !  Small
        Business Policy -  The "Policy on Compliance Incentives for Small Businesses"  applies to
                          companies with 100 or fewer employees and provides penalty waivers or
                          penalty reductions as incentives to participate  in an on-site compliance
                          assistance  program  and to  conduct self-audits to discover and correct
                          violations.

      !  Audit Policy -      The "Incentives for Self-Policing: Disclosure, Correction, and Prevention of
                          Violations" policy  applies  to businesses of  all sizes  that  meet  the
                          applicability criteria and promptly disclose and  correct violations.

9.3    If EPA Discovers a Violation, What Might EPA's Response Be?
             To maximize compliance, EPA implements a balanced program of compliance assistance,
      compliance incentives, and traditional law enforcement.  EPA knows that CWT facilities owned
      by small businesses that must comply with complicated new statutes or rules often want to do the
      right thing, but may lack the requisite resources. Compliance assistance information and technical
      advise helps small  businesses  to understand and meet  their environmental obligations.
      Compliance incentives, such as  our Small Business  Policy,  encourage persons to voluntarily
      discover, disclose, and correct violations before they're identified by the government. EPA's strong
      law enforcement program protects all of us by targeting persons who neither comply nor cooperate
      to address their problems.
             EPA uses a variety of methods to determine whether businesses are complying, including
      inspecting facilities, reviewing records and reports, and responding to citizen complaints. If we
      learn  a person  is violating the law, EPA  (or State, if the program is delegated) may file  an
      enforcement action seeking penalties of up to $27,500 per violation, per day. The proposed penalty
      in a given case will depend on many factors, including the number, length, and severity of the
      violations, the economic benefit obtained by the violator, and its ability to pay. EPA has policies
      in place to ensure penalties are calculated  fairly. These  policies are available to the public.  In
      addition, any company with a violation has the right to contest EPA's  allegations and proposed
      penalty before an impartial judge or jury.
             In summary, EPA recognizes that  we can achieve the  greatest possible protection by
      encouraging small businesses to work with us to discover, disclose, and correct violations. That's
      why we've issued self-disclosure, small business, and small community policies to eliminate or
      reduce penalties for small and large entities which cooperate with EPA to address compliance
      problems.  In addition, we've established compliance assistance centers to serve over a million

                                                 9-2

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      COMPLIANCE ASSURANCE PROCESS                                CWT SMALL ENTITY COMPLIANCE GUIDE
      small businesses.  For more information on these and other EPA programs for small business,
      please contact EPA's Small Business Ombudsman, Karen Brown, at (202) 260-1390 or e-mail at
      brown.karen@epa.gov.

9.4    What is the Legal Status of This Guide?
             A judge may review a compliance or implementation guide in determining what penalty
      is appropriate and reasonable, although the content of the guide cannot otherwise by reviewed by
      the court.
             In this Compliance Guide, we have tried to make clear what you must do to comply with
      the applicable law and regulation. This is the minimum required by SBREFA.  You'll notice,
      however, that here and there we have also included suggestions for alternative approaches that
      may make compliance easier and possibly even reduce costs. We hope you find this presentation
      of regulatory requirements useful and the additional information helpful  in reaching and
      maintaining compliance.
                                               9-3

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Le".

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                 1 0

      QUESTIONS AND ANSWERS
      I  rI  -j'his chapter provides questions commonly asked during development of this rule and EPA's
        j    responses This information may serve to answer many questions which small entities may
        .v! -„  have about the CWT rule.

10.1   General
      Ql.    How many facilities are covered under the scope of this rule?  How many discharge
             wastewater?
      Al.    EPA estimates there are 223 centralized waste treatment facilities in the U.S., 165 of which
             discharge wastewater.

      Q2.    My facility is a CWT, but it does not discharge wastewater.  All wastewaters are shipped
             off-site to another CWT.  Do I need to meet the CWT discharge requirements prior to
             shipping the wastewater off-site?
      A2.    The CWT rule applies to CWT facilities that discharge wastewater to surface waters or to
             POTWs.   This facility  does  neither and is not required to  meet the CWT discharge
             requirements before shipping the wastewater to another CWT.

      Q3.    Does the CWT rule include a de minimis exemption?
      A3.    No,  the CWT rule does not include a de minimis exemption.

10.2   Applicability
      Ql.    My facility accepts wastes from off-site, but we are not a treatment facility. RCRA classifies
             us as a recycling facility. Are we subject to the CWT rule?
      Al.    The CWT rule is not  limited to  facilities that perform treatment only.  In  general,
             wastewater discharges  from facilities that accept wastes from off-site for recycling are
             subject to the CWT  rule. However, wastewater discharges from some specific recycling
             activities (such as solvent recovery) are not subject to the rule. Therefore, a recycler should
             consult the applicability section of the rule for more information on its specific recycling
             activity. If information is not included on its specific recycling activity, then its discharges
             associated with these acetifies are subject to this rule.

                                               10-1

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       QUESTIONS AND ANSWERS                                       CWT SMALL ENTITY COMPLIANCE GUIDE
      Q2.    My facility only treats and discharges non-hazardous wastes. Is it subject to the CWT rule?
      A2.    The CWT rule applies to both hazardous and non-hazardous wastes.  It  does not
             differentiate based on the RCRA status of the wastes accepted for treatment.

      Q3.    My facility discharges wastewaters generated in the treatment of solid wastes received from
             off-site. Since the off-site wastes are not liquid, is the wastewater generated subject to the
             CWT rule?
      A3.    The CWT rule applies to wastewater discharges associated with the treatment and/or
             recovery of solid wastes, wastewater and used materials received from off-site.

      Q4.    My local POTW is my biggest competitor. Are POTWs subject to the CWT rule?
      A4.    POTWs are not CWT facilities and are not subject to the CWT rule. However, wastes that
             are hauled, piped or shipped by rail to POTWs must comply with applicable pretreatment
             standards and requirements, including categorical standards.

      Q5.    I only accept non-industrial wastes (that is, sanitary wastes) from off-site.  Am I a CWT
             facility?
      A5.    No, the CWT rule only applies to discharges of industrial wastewaters.  EPA does not
             consider sanitary wastewater to be industrial.

      Q6.    Are scrap metal yards and municipal waste transfer stations considered CWT facilities?
      A6.    No, scrap metal yards and municipal waste transfer stations are not subject to the CWT
             rule.

      Q7.    Is there a SIC Code which identifies the CWT industry?
      A7.    There is no SIC Code for the CWT industry. However, many CWT facilities have identified
             themselves with the SIC code for "Refuse systems," 4953.

10.3  Pollutants Selected for Regulation
      Ql.    My facility's permit does not currently limit all of the pollutants regulated in this rule.
             How did you select the regulated pollutants?
      Al.    EPA did not restrict its list of pollutants considered for regulation to the list of pollutants
             limited in current permits. EPA examined data from influent wastewater samples collected
             at many CWT facilities to determine the list of pollutants considered for regulation. Chapter
             6 of the technical development document provides information on the methodology EPA
             used to establish the pollutants considered for regulation and Chapter 7 of the technical

                                                10-2

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QUESTIONS AND ANSWERS                                      CWT SMALL ENTITY COMPLIANCE GUIDE
       development document details EPA's decisions on which of these pollutants were selected
       for regulation.

Q2.    I discharge to a POTW and the regulated pollutants do not cause problems with my POTW.
       Why do I have to monitor for these pollutants?
A2.    The objective of the Clean Water Act is to "restore and maintain the chemical, physical, and
       biological integrity of the Nation's waters."  In order to achieve this objective, the CWA
       establishes as a  national goal  the elimination of the discharge of all pollutants into the
       nation's waters. Congress mandated EPA to establish pretreatment standards that are
       equivalent to standards for direct dischargers. These limitations for direct dischargers are
       based on effluent reductions that can  be achieved  by  best available  technology
       economically achievable (BAT)). However, Congress further mandated that EPA consider
       and recognize the treatment  capability and performance of the POTW in controlling
       discharges for indirect dischargers. Consequently, EPA evaluated which pollutants to
       regulate for indirect dischargers by comparing removals of the pollutants regulated for
       direct dischargers with POTW removals to determine whether they "pass through" the
       POTW to surface waters. All pollutants regulated for indirect dischargers were determined
       to pass-through  in EPA's assessment. This pass-through assessment is detailed further in
       Chapter 7 of the final technical development document and in the preamble to the final
       rule.

Subcategorization Procedure
Ql.    Who is responsible for determining the proper subcategories? The CWT facility or the
       permit writer or control authority?
Al.    EPA believes the CWT facility is in the best position to classify waste receipts into the
       proper subcategory.   For indirect dischargers,  this responsibility is even clearer, as
       categorical standards are self-implementing and do not depend necessarily on issuance of
       a permit.

Q2.    My facility mainly accepts used oils. Occasionally, we also accept landfill leachate.  The
       leachate represents no more than 5% of the volume of waste discharged when present.
       Based on your recommended Subcategorization procedure, our facility would be classified
       as an oils and organics facility. However, since the leachate is only periodic and such a
       small percent of the wastewater discharged, can we simply classify ourselves as an oils
       facility?
A2.    No, your facility is both an oils and an organics facility. During development of this rule,
       EPA considered an option for facilities that accept waste from different subcategories to
       round to the nearest five percent.  The final rule did not include this option.  EPA clearly

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QUESTIONS AND ANSWERS                                       CWT SMALL ENTITY COMPLIANCE GUIDE
       intends that the facility accurately account for all off-site wastes accepted - even if these off-
       site wastes are small in volume or represent a small percent of the wastewater discharged.

Q3.    Are we required to use the subcategorization procedure outlined by EPA? For example,
       our facility accepts a waste that has high levels of zinc, low levels of other metals, and low
       levels of oil and grease.  Using EPA's hierarchy, it would fall into the organics subcategory,
       but we believe it clearly belongs in the metals subcategory. Why do I have to  classify it in
       the organics subcategory?
A3.    First, EPA stresses that the criteria and  information on subcategory determination are
       provided as guidance to permit writers, control authorities, and CWT facilities in properly
       classifying their wastes by subcategory. EPA expects that facilities will also apply common
       sense when using our suggested guides.   Clearly, the waste described  is a metals
       subcategory waste and should be classified as such. If it is not explicitly listed  in the waste
       receipt classification table in Chapter 5, and the numerical hierarchy would otherwise
       classify this unusual waste as an organics waste, despite the high concentration of zinc,
       then the facility's judgment could override the classification procedure's output and classify
       this particular waste as needed.

Q4.    We accept lubricants that sometimes contain nickel in concentrations in excess of the 37.5
       mg/L listed in the waste hierarchy.   Should this be classified as an oils waste, a metals
       waste or both?
A4.    Using EPA's recommended subcategorization procedure, this waste would be classified in
       the oils subcategory. Lubricants are included in the waste receipt classification table as an
       oils subcategory waste. The subcategorization hierarchy (numerical criteria)  should only
       be consulted if the waste is not listed in the waste receipt classification table in Chapter 5.

Q5.    Does the CWT rule require documentation for determining the proper classification of
       wastes?
A5.    The CWT rule does not require any documentation for determining the proper classification
       of wastes. However, permitting or control authorities may require such documentation.
       In EPA's view, however, most CWT facilities already collect and maintain sufficient
       information during their waste acceptance procedures to classify their waste receipts
       properly. In EPA's view, permitting or control authorities should only request additional
       documentation if a facility's waste acceptance procedures are inadequate.  Inadequate
       support for classification could conceivably prevent a permitting or control authority from
       confirming which subcategories apply, at which point the permitting or control authority
       could choose to not issue a discharge permit.
                                          10-4

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       QUESTIONS AND ANSWERS                                       CWT SMALL ENTITY COMPLIANCE GUIDE
      Q6.    I have been accepting used oils and coolants. I am now accepting bilge water. Do I need
             to repeat the determination?
      A6.    No, since bilge water is classified as an oils subcategory waste (see Table 5-1, Waste Receipt
             Classification), a new round of subcategorization is unnecessary.

U£    Treatment
      Ql.    Does the CWT rule require facilities to use the model technologies?
      Al.    No, CWT facilities are not required to use the model technologies.

      Q2.    I installed the model technologies and still can't meet the required limits? What am I doing
             wrong?
      A2.    Installation of the model technology does not guarantee that you will be able to meet the
             discharge requirements. You must also optimize the operation of your system. In addition,
             many facilities improperly target the design and operation of their treatment systems to
             actual numerical limits. This does not ensure that the facility will be in compliance. Rather,
             a facility should target the design and operation of its system to the long-term averages.
             The long-term average for each limit is included in Appendix A.  Unless there is a major
             upset of the system, this should ensure compliance with the discharge requirements.

      Q3.    How does this rule prevent the commingling of different types of wastestreams prior to
             receipt at the CWT. For example, waste is represented as oily waste, but metals have been
             mixed in during transport.

      A3.    As discussed in Chapter 5, waste generators initially furnish a CWT facility with a sample
             of the wastestream to be treated. The CWT analyzes this sample to characterize the level
             of pollutants in the sample and to determine what treatment is necessary. Then, generally,
             for each truck load of waste received for treatment from the generator, the CWT facility
             collects a sample and conducts "fingerprint" analysis to confirm it is similar to the initial
             sample tested.  In this manner, the CWT facility should be aware if the waste generator is
             misrepresenting the wastestream characteristics. In the case of the example provided, the
             facility could decline to accept the wastestream (if it is unable to treat it effectively or if the
             wastestream is from a subcategory which would violate the facility's discharge permit).

      Monitoring for Compliance
      Ql.    What monitoring frequency is required by the CWT rule?
      Al.    The CWT rule does not establish nationally-applicable monitoring frequency requirements,
             but rather, leaves the decision up to the permitting authority. The permitting or control
             authority is in the best position to gauge the facilities potential for violations and establish

                                                10-5

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QUESTIONS AND ANSWERS                                      CWT SMALL ENTITY COMPLIANCE GUIDE
       monitoring frequencies accordingly.  Permitting and control authorities generally use
       factors such as raw waste variability, wastewater flow volume, type of treatment, and
       compliance history, as well as self-developed IPPs to determine appropriate monitoring
       frequencies. Section 403.12(e) of the pretreatment regulations requires Ills  subject to
       categorical pretreatment standards such as the CWT regulations to self-monitor and report
       at least twice per year.

Q2.    Can a permitting or control authority reduce or waive sampling requirements for a
       particular pollutant after a history of sampling shows the pollutant to be absent?
A2.    EPA has not established methods to waive sampling requirements for particular pollutants
       under the CWT rule. In general, EPA does not believe sampling requirements for specific
       pollutants should be waived entirely for the CWT industry because this industry accepts
       a wide variety of wastestreams that can vary considerably from one batch to the next.
       However, direct dischargers (those with NPDES permits) that demonstrate their
       discharge is continually well within the limitations may have their monitoring
       frequency reduced.  The requirements and procedures for this are described in
       detail in the EPA publication "Interim Guidance for Performance-Based Reduction
       of NPDES Permit Monitoring Frequencies" (EPA-833-B-96-001, April, 1996).  In
       general, at least two years of monitoring data are needed and the modifications are
       made during the re-issuance of the permit. The modifications are made on a
       pollutant-by-pollutant basis.
       For indirect dischargers, EPA has proposed regulatory and administrative changes
       that may reduce the burden on entities regulated under the National Pretreatment
       Program. These proposed changes are referred to as the Pretreatment Streamlining
       Proposal. One of the proposed changes is to allow control authorities to waive
       industrial user (IU) sampling for pollutants that have been determined not to be
       present.

Q3.    Does a CWT facility (electing to comply with the multiple wastestream limitations or
       standards) that accepts cyanide have to monitor for cyanide immediately following cyanide
       pretreatment?
A3.    The CWT rule requires a facility that accepts wastes containing cyanide in excess of 136
       mg/L to monitor for cyanide after cyanide treatment and before commingling with other
       waste streams.  However, the permitting or control authority may allow the facility to
       monitor after commingling with other waste streams if the permitting or control authority
       adjusts the  limit (or standard) using the building block approach (or  combined waste
       stream formula) and the adjusted limit (or standard) does not fall below the analytical
       minimum level.
                                         10-6

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QUESTIONS AND ANSWERS                                       CWT SMALL ENTITY COMPLIANCE GUIDE
Q4.    What if a wastewater matrix causes interference with the analytical method (and therefore
       the detection limit is higher than the discharge limit)?
A4.    The procedures outlined in EPA's Guidance on Evaluation, Resolution, and Documentation
       of Analytical Problems  Associated with Compliance Monitoring (EPA 821-B-93-001)
       explain how to eliminate matrix or other interference with analysis.

Multiple Wastestream Subcategory
Ql.    Can permitting or pretreatment authorities use the building block approach or combined
       waste stream formula to determine the discharge requirements for a facility in lieu of the
       multiple wastestream subcategory pretreatment standards?
Al.    No, the building block approach and combined waste stream formula cannot be used to
       establish discharge requirements for facilities subject to more than one CWT subcategory.
       The facility must comply with each applicable subcategory's limitations or standards
       separately or with the applicable set of multiple wastestream subcategory limitations or
       standards.

Q2.    Does a CWT facility need to know the percentage of wastes that would be in each of the
       subcategories if it elects to comply with the multiple wastestream subcategory limitations?
A2.    No, the CWT facility need not know the percentage of wastes that would fall into each of
       the subcategories if it chooses to comply with the multiple wastestream subcategory
       limitations. The multiple wastestream subcategory limitations consist of the most stringent
       of the limitations from each subcategory for each pollutant.

Initial Certification Paperwork for Equivalent Treatment
Ql.    Who receives the initial certification?
Al.    The permitting or control authority receives the certification from CWT facilities that wish
       to comply with multiple wastestream limitations or standards.

Q2.    Does a CWT facility have to use the model technology to establish equivalent treatment?
A2.    No, facilities electing to comply with the multiple wastestream subcategory limitations or
       standards may use the model technology or any technology they can demonstrate will
       achieve comparable removals.

Q3.    What data requirements are necessary to establish equivalent treatment? For example, to
       establish that my system achieves zinc removals equivalent to the model technology, how
       many samples must I collect?
A3.    The final CWT rule defines equivalent treatment, but gives CWT facilities the latitude to

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QUESTIONS AND ANSWERS                                       CWT SMALL ENTITY COMPLIANCE GUIDE
       determine the appropriate manner in which to establish it. The rule does not specify a
       particular "number" of samples that must be collected and submitted. In fact, the final rule
       does not require CWT facilities to collect any samples.  CWT facilities should work with
       their respective permit writer or control  authority to determine an appropriate and
       reasonable manner to establish equivalent treatment for their particular circumstances.

Q4.    When does the initial certification paperwork have to be completed?
A4.    For existing indirect dischargers, the initial certification paperwork must be completed by
       or before the compliance deadline. For existing direct dischargers, new direct dischargers
       and new indirect dischargers, the initial certification must be completed by the time of
       permit or control mechanism issuance, re-issuance or renewal.   EPA suggests that an
       indirect discharging CWT facility that plans to comply with the multiple wastestream
       subcategory pretreatment standards notify its control authority of this intent and also state,
       in their BMR submission, whether it can or cannot comply with theses standards currently.

Q5.    Does the system have to be fully tested and operational at the time of the initial certific ation
       statement is submitted?
A5.    No, the treatment system may be tested after the initial certification statement is submitted,
       but the system must be fully operational by the required date of compliance.

Q6.    Do treatability tests require elaborate QA/QC procedures?
A6.    No, the level of QA/QC  conducted during EPA sampling is not necessary for facility
       treatability testing.

Periodic Certification Statement for Equivalent Treatment Certification
Ql.    When is the periodic certification required?
Al.    The periodic  certification requirement begins  after the facility has submitted  its initial
       certification and is required once per year. The timing of submittal can be coordinated with
       the submittal of compliance paperwork required by the General Pretreatment Regulations
       or the NPDES regulations.

Q2.    Does a facility need to monitor for the regulated pollutants when developing a relationship
       for surrogate parameters used to demonstrate that a treatment system is well -operated and
       maintained?
A2.    The CWT rule does not require monitoring or the establishment of a surrogate parameter
       to demonstrate  that a system is well-operated and maintained.  However, if a facility
       chooses to use  a surrogate parameter to demonstrate that a treatment system is well
                                          10-8

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QUESTIONS AND ANSWERS                                       CWT SMALL ENTITY COMPLIANCE GUIDE
       operated and maintained, it should monitor for the specific regulated pollutant(s) to
       establish the relationship between the surrogate and the regulated pollutants.

Q3.    In the periodic certification statement, the CWT  rule requires  the facility to provide
       information if it has modified its treatment system. What does EPA mean?
A3.    In EPA's view, a modification is any significant  change in the equipment,  treatment
       chemicals, or operating procedures that could negatively affect the demonstrated removals.
       For example, if a facility has demonstrated equivalent treatment with a system that includes
       chemical precipitation and dissolved air flotation, and decides to eliminate the chemical
       precipitation step, this would be a modification that would require a re-demonstration
       assuming the applicable subcategories have not changed. However, switching chemical
       companies is an insignificant change.

Q4.    Are CWT facilities required to submit monitoring data to the permitting or control
       authority that they collect to demonstrate that a treatment system is well-operated and
       maintained?
A4.    No, such data should be kept with the facility's on-site compliance paperwork and must
       be available to the permitting or control authority as well as enforcement officials.

On-Site Compliance Paperwork for Equivalent Treatment Certification
Ql.    For on-site compliance paperwork, may a facility cross-reference other records at the
       facility, or does a separate copy of those records need to exist in its CWT compliance file?
Al.    Facilities may cross-reference records in other parts of the facility, but must be able to
       produce those records when requested by their permitting or control authority.

Q2.    How is confidential business information (CBI) that is included as part of compliance
       paperwork (either initial or periodic certification or other on-site compliance paperwork)
       handled? What can a facility claim as CBI?
A2.    The permitting or control  authority  is authorized to view CBI,  but they must have
       procedures in place to protect CBI from unauthorized public access. Permitting and control
       authorities have to allow  access to  the  public at  least to  the extent that the EPA
       confidentiality regulations allow public access. A facility cannot claim any effluent data
       or data associated with the "point of compliance" as confidential.

Costs
Ql.    Is there any guidance  on how much CWT facilities should spend on treatment of CWT
       wastewater?
                                          10-9

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QUESTIONS AND ANSWERS                                      CWT SMALL ENTITY COMPLIANCE GUIDE
Al.    There is no guidance on the amount of money a facility should spend on wastewater
       treatment; it depends on a number of factors that the facility should consider in making a
       final compliance decision.  These factors include the amount of wastewater treated, the
       characteristics of the wastewater being treated, treatment in place currently at the facility,
       the financial stability of the facility, and the market for waste treatment. For example, a
       facility may be able to treat a wastewater adequately using  available technologies.
       However, if the amount of wastewater treated is very small, it may not be profitable for a
       facility to treat and discharge this wastewater to comply with this rule.

Q2.    My  facility  cannot currently afford the upgrades to our treatment system  that will be
       required to comply with this rule. Can we get a waiver of the requirements or an extension
       on the date  of compliance?
A2.    No,  a CWT  facility can not obtain a waiver (or PDF) based on financial constraints. If the
       facility is unable to comply with the regulation by the required date due to financial
       considerations, it should cease discharge by the compliance date.

Q3.    Can EPA make any recommendations on financing additional wastewater  treatment
       technologies for small businesses to comply with this rule?
A3.    PPA has compiled a variety of sources to assist small businesses in applying for loans for
       pollution control.  See http://www.epa.gov/smallbusiness/money.htm.

Baseline Monitoring Report
Ql.    When is the baseline monitoring report due and to whom must it be submitted?
Al.    For existing indirect dischargers, the baseline monitoring report is due on July 21, 2001. It
       is submitted to the control authority.

Q2.    How many  samples are required for the BMR?
A2.    40 CFR 403.12(b)(5)(iv)  states, "The  User  shall take a minimum of one representative
       sample to compile the data necessary to comply with the requirements of this paragraph."
       The type of sample will depend on the nature of the pollutant  as described  in 40 CFR
       403.12(b)(5)(iii), which states "a minimum of four(4) grab samples must be used for pH,
       cyanide,  total  phenols, oil and grease, sulfide, and volatile organics.  For all other
       pollutants,  24-hour composite samples must  be obtained  through flow-proportional
       composite sampling techniques where feasible. The Control Authority may waive flow-
       proportional composite sampling for any  Industrial User that demonstrates  that flow-
       proportional sampling is infeasible. In such cases, samples may be obtained through time-
       proportional composite sampling techniques or through a minimum of four(4) grab
       samples where the User demonstrates that this will provide a representative sample of the

                                         10-10

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QUESTIONS AND ANSWERS                                     CWT SMALL ENTITY COMPLIANCE GUIDE
      effluent being discharged."  If the process produces a discharge that is a homogeneous
      batch, one grab sample may be taken.

RCRA Permits
Ql.   Our facility has a Federal RCRA permit because we accept hazardous wastes. We cannot
      obtain a RCRA permit modification to alter our treatment system to meet the required
      pretreatment standards by the required date of compliance. How can we get an extension?
Al.   Many CWT facilities with Federal RCRA permits are under the impression that if they
      modify their existing treatment system to comply with this regulation they will have to
      obtain a RCRA permit modification.  This is incorrect.  RCRA contains a wastewater
      treatment unit exemption from RCRA permit modification requirements for wastewater
      treatment units that are subject to NPDES or pretreatment requirements established under
      the CWA. Thus, CWT facilities with RCRA permits will not need to modify their RCRA
      permits as a result of this rule.
                                        10-11

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                11

     WHERE TO GET ADDITIONAL HELP
      i  i < T;his chapter presents additional sources of information, as well as EPA contacts, that may
        i   help small entities obtain additional information related to implementation of the CWT
       l.i  effluent guidelines limitations and standards for new and existing sources. Specifically, this
           chapter presents a list of selected federal programs. These lists also include information on
      how to reach EPA program personnel and how to access periodicals and directories.
11.1  Where Can I Get Copies of Document Related to the CWT Rule?
            Copies of documents directly related to the CWT effluent guidelines and standards, such
     as the Technical Development Document (EPA-821-R-00-020), the Economic Analysis (EPA-821-R-
     00-024), the Cost Effectiveness Analysis (EPA-821-R-00-023), the Detailed Costing Document (EPA-
     821-R-00-021), and the Environmental Assessment Document (EPA-821-R-00-022) may be obtained
     from our web site at: www.epa.gov/ost/guide/cwti.html. You may also obtain copies of these
     documents by contacting the Office of Water Resource Center at (202) 260-7786 or by e-mail at:
     waterpubs@epamail.epa.gov or fax: (202) 260-0386.

11.2  Who Can Help Me at EPA with Specific Questions About the CWT Rule?
            Questions specifically related to the effluent limitations guidelines and standards for the
     CWT industry should be directed to:

     A.     Ms. Jan Matuszko (technical questions)
            Engineering and Analysis Division
            Washington, DC
            Tel: (202) 260-9126
            Fax: (202) 260-7185
            e-mail: matuszko.jan@epa.gov

     B.     Mr. Timothy Connor (technical questions)
            Engineering and Analysis Division

            Washington, DC
            Tel: (202) 260-3164
            Fax: (202) 260-7185

                                             11-1

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WHERE TO GET ADDITIONAL HELP
                              CWT SMALL ENTITY COMPLIANCE GUIDE
       e-mail: connor.timothy@epa.gov
C.     Dr. William Wheeler (economic questions)
       Engineering and Analysis Division

       Washington, DC
       Tel: (202) 260-7905
       Fax: (202) 260-7185
       e-mail: wheeler.william@epa.gov

General Information
       There are a number of web site resources for obtaining general information about the CWT
rule, related programs, and general EPA policies. The following table identifies some of the main
resources you may  find helpful.


 Table 11-1 General Resources Information
 Resource
Web Address
Description
 EPA web site
 Engineering and Analysis
 Division website
 Federal Register Online via
 GPO Access
 EPA Small Business
 Assistance Program (SBAP)

 EPA Office of Enforcement
 and Compliance Assurance:
 Policy on Compliance
 Incentives for Small Business
                             www.epa.gov
www.epa.gov/ ost/ guide
www.access.gpo.gov/
su_docs/aces/
acesl40.html
www.epa. gov/ ttn/ sbap
es.epa.gov/oeca/
smbusLhtml
EPA's web site includes press releases,
proposed and final EPA rules and
regulations, and updates to this manual.
Federal Register notices of proposed and
final effluent limitations guidelines and
standard rules, supplemental notices,
pre-proposal documents, background
information, draft industry
questionnaires, public meeting notices,
development documents and other
supporting documents, updates to this
manual, and related documents.
Official Federal Register documents,
including the published CWT regulation
(December 22, 2000)
State and local SBAP contacts, SBAP
materials, related web sites, meetings and
conferences
Applicability of EPA's policy to promote
environmental compliance among small
businesses.  Criteria for civil penalty
mitigation.
                                           11-2

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WHERE TO GET ADDITIONAL HELP
                                CWT SMALL ENTITY COMPLIANCE GUIDE
 Table 11-1  General Resources Information
 Resource
Web Address
Description
 EPA Office of Enforcement
 and Compliance Assurance:
 Audit Policy: Incentives for
 Self-Policing
es.epa.gov/oeca/
auditpol.html
Applicability of EPA's policy to enhance
protection of human health and the
environment by encouraging regulated
entities to voluntarily discover, and
disclose and correct, violations of
environmental requirements.
                                            11-3

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FINAL EFFLUENT LIMITATIONS AND STANDARDS FOR
THE CWT INDUSTRY
p i < T;his appendix presents the final effluent limitations and standards for the CWT industry. The
  j   limitations and standards are presented in tables starting on the next page. The limits are
 • 1 -:-  accompanied by the long-term averages that CWT facilities ought to use as the basis for
design of their treatment systems. Note that the metals, oils, organics, and multiple wastestream
subcategories are labeled Subcategories A, B, Q and D, respectively. Note also that the multiple
wastestream effluent limitations and standards are presented for all possible subcategory
combinations.
                               Appendix A -1

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Table Appendix A-l. CWT design targets and BPT limitations by subcategory (mg/L)
Pollutant Parameters
CONVENTIONAL PARAMETERS*
BODs
Oil & Grease
TSS
METAL ANALYTES
Antimony
Arsenic
Barium
Cadium
Chromium
Cobalt
Copper
Cyanide (in-plant)
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Tin
Titanium
Vanadium
Zinc
ORGANIC ANALYTES
Acetone
Acetophenone
Aniline
Bis(2-ethylhexyl) phthalate
Butanone
Butylbenzyl phthalate
Carbazole
o-Cresol
p-Cresol
n-Decane
2,3-Dichloroaniline
Fluoranthene
n-Octadecane
Phenol
Pyridine
2.4.6-Trichloroohenol
CAS
Registry
Number
C-003
C-007
C-009
7440-36-0
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7439-92-1
7439-97-6
7439-98-7
7440-02-0
7782-49-2
7440-22-4
7440-31-5
7440-32-6
7440-62-2
7440-66-6
67-64-1
98-86-2
62-53-3
117-81-7
78-93-3
85-68-7
86-74-8
95-48-7
106-44-5
124-18-5
608-27-5
206-44-0
593-45-3
108-95-2
110-86-1
88-06-2
Metals - Subcategory A
Long-Term Limitations
Avera9e .. ğu,
_ _ ., Monthly
Design Daily . '
T . .. • Average
Targets Maximum „, . °
Maximum

34.3
16.8
0.170
0.0839

0.0580
1.67
0.115
0.744
136
0.177
0.000560
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413












205.
60.0
0.249
0.162

0.474
15.5
0.192
4.14
500
1.32
0.00234
3.95
1.64
0.120
0.409
0.0947
0.218
2.87












50.2
31.0
0.206
0.104

0.0962
3.07
0.124
1.06
178
0.283
0.000739
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641











Long-Term
Average
Design
Targets

28.3
25.5
0.103
0.789
0.221
0.00746
0.183
7.42
0.157
0.0986
0.00309
1.54


0.107
0.0217

3.14


0.0629
0.0550
0.151

0.238

0.0173
0.203


Oils - Subcategory B
Limitations
Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

127.
74.1
0.237
2.95
0.427
0.0172
0.746
56.4
0.500
0.350
0.0172
3.50


0.335
0.0510

8.26


0.215
0.188
0.598

0.948

0.0537
0.589



38.0
30.6
0.141
1.33
0.281
0.0102
0.323
18.8
0.242
0.160
0.00647
2.09


0.165
0.0299

4.50


0.101
0.0887
0.276

0.437

0.0268
0.302


Organics - Subcategory C
Long-Term Limitations
Average Monthly
Design Daily . y
T . .. • Average
Targets Maximum „, . °
Maximum
41.0

45.0
0.569




0.704
0.943





0.382
2.06
0.0359
0.0105
0.878

0.185
0.0682
0.0230


0.362
0.116
0.0858
163.

216.
0.928




0.865
1.01





0.497
30.2
0.114
0.0333
4.81

1.92
0.698
0.0731


3.65
0.370
0.155
53.0

61.3
0.679




0.757
0.965





0.420
7.97
0.0562
0.0164
1.85

0.561
0.205
0.0361


1.08
0.182
0.106
* - The promulgated performance bounds for pH are 6-9 in standard units.
                                                               Appendix A - 2

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Table Appendix A-2. CWT design targets and BPT limitations for Subcategory D mixed wastestream combinations (mg/L)
Metals,
CAS Long-Term
Pollutant Parameters Registry Average
Number Design
Targets
CONVENTIONAL PARAMETERS*
BODs C-003 41.0
Oil & Grease C-007 28.3
TSS C-009 25.5
METAL ANALYTES
Antimony 7440-36-0 0.103
Arsenic 7440-38-2 0.0839
Barium 7440-39-3 0.221
Cadium 7440-43-9 0.00746
Chromium 7440-47-3 0.183
Cobalt 7440-48-4 0.115
Copper 7440-50-8 0.157
Cyanide (in-plant) 136
Lead 7439-92-1 0.0986
Mercury 7439-97-6 0.000560
Molybdenum 7439-98-7 0.943
Nickel 7440-02-0 1.16
Selenium 7782-49-2 0.280
Silver 7440-22-4 0.0264
Tin 7440-31-5 0.0898
Titanium 7440-32-6 0.0217
Vanadium 7440-62-2 0.0500
Zinc 7440-66-6 0.382
ORGANIC ANALYTES
Acetone 67-64-1 2.06
Acetophenone 98-86-2 0.0359
Aniline 62-53-3 0.0105
Bis(2-ethylhexyl) phthalate 117-81-7 0.0629
Butanone 78-93-3 0.878
Butylbenzyl phthalate 85-68-7 0.0550
Carbazole 86-74-8 0.151
o-Cresol 95-48-7 0.185
p-Cresol 106-44-5 0.0682
n-Decane 124-18-5 0.238
2,3-Dichloroaniline 608-27-5 0.0230
Fluoranthene 206-44-0 0.0173
n-Octadecane 593-45-3 0.203
Phenol 108-95-2 0.362
Pyridine 110-86-1 0.116
2.4.6-Trichloroohenol 88-06-2 0.0858
Oils, Organics (A, B, & C)
Limitations
Daily "f°"thlv
.. . Average
Maximum .. .
Maximum

163.
127.
74.1

0.237
0.162
0.427
0.0172
0.746
0.192
0.500
500
0.350
0.00234
1.01
3.95
1.64
0.120
0.409
0.0510
0.218
0.497

30.2
0.114
0.0333
0.215
4.81
0.188
0.598
1.92
0.698
0.948
0.0731
0.0537
0.589
3.65
0.370
0.155

53.0
38.0
30.6

0.141
0.104
0.281
0.0102
0.323
0.124
0.242
178
0.160
0.000739
0.965
1.45
0.408
0.0351
0.120
0.0299
0.0662
0.420

7.97
0.0562
0.0164
0.101
1.85
0.0887
0.276
0.561
0.205
0.437
0.0361
0.0268
0.302
1.08
0.182
0.106
Long-Term
Average
Design
Targets


28.3
25.5

0.103
0.0839
0.221
0.00746
0.183
0.115
0.157
136
0.0986
0.000560
1.54
1.16
0.280
0.0264
0.0898
0.0217
0.0500
0.413




0.0629

0.0550
0.151


0.238

0.0173
0.203



Metals, Oils (A & B)
Limitations
Daily "f°"thlv
.. . Average
Maximum .. .
Maximum


127.
74.1

0.237
0.162
0.427
0.0172
0.746
0.192
0.500
500
0.350
0.00234
3.50
3.95
1.64
0.120
0.409
0.0510
0.218
2.87




0.215

0.188
0.598


0.948

0.0537
0.589





38.0
30.6

0.141
0.104
0.281
0.0102
0.323
0.124
0.242
178
0.160
0.000739
2.09
1.45
0.408
0.0351
0.120
0.0299
0.0662
0.641




0.101

0.0887
0.276


0.437

0.0268
0.302



Metals, Organics (A & C)
Long-Term Limitations
nV8rage n -, Monthly
Design Daily *
Targets Maximum Average
Maximum

41.0
34.3
16.8

0.170
0.0839

0.0580
1.67
0.115
0.704
136
0.177
0.000560
0.943
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.382

2.06
0.0359
0.0105

0.878


0.185
0.0682

0.0230


0.362
0.116
0.0858

163.
205.
60.0

0.249
0.162

0.474
15.5
0.192
0.865
500
1.32
0.00234
1.01
3.95
1.64
0.120
0.409
0.0947
0.218
0.497

30.2
0.114
0.0333

4.81


1.92
0.698

0.0731


3.65
0.370
0.155

53.0
50.2
31.0

0.206
0.104

0.0962
3.07
0.124
0.757
178
0.283
0.000739
0.965
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.420

7.97
0.0562
0.0164

1.85


0.561
0.205

0.0361


1.08
0.182
0.106
Long-Term
Average
Design
Targets

41.0
28.3
25.5

0.103
0.789
0.221
0.00746
0.183
7.42
0.157

0.0986
0.00309
0.943



0.107
0.0217

0.382

2.06
0.0359
0.0105
0.0629
0.878
0.0550
0.151
0.185
0.0682
0.238
0.0230
0.0173
0.203
0.362
0.116
0.0858
Oils, Organics (B & C)
Limitations
„ .. Monthly
Daily 3
.. . Average
Maximum „ .
Maximum

163.
127.
74.1

0.237
2.95
0.427
0.0172
0.746
56.4
0.500

0.350
0.0172
1.01



0.335
0.0510

0.497

30.2
0.114
0.0333
0.215
4.81
0.188
0.598
1.92
0.698
0.948
0.0731
0.0537
0.589
3.65
0.370
0.155

53.0
38.0
30.6

0.141
1.33
0.281
0.0102
0.323
18.8
0.242

0.160
0.00647
0.965



0.165
0.0299

0.420

7.97
0.0562
0.0164
0.101
1.85
0.0887
0.276
0.561
0.205
0.437
0.0361
0.0268
0.302
1.08
0.182
0.106
' - The promulgated performance bounds for pH are 6-9 in standard units.
                                                                    Appendix A - 3

-------
Table Appendix A-3. CWT design targets and NSPS standards by subcategory (mg/L)
Pollutant Parameters
CONVENTIONAL PARAMETERS*
BODs
Oil & Grease
TSS
METAL ANALYTES
Antimony
Arsenic
Barium
Cadium
Chromium
Cobalt
Copper
Cyanide (in-plant)
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Tin
Titanium
Vanadium
Zinc
ORGANIC ANALYTES
Acetone
Acetophenone
Aniline
Bis(2-ethylhexyl) phthalate
Butanone
Butylbenzyl phthalate
Carbazole
o-Cresol
p-Cresol
n-Decane
2,3-Dichloroaniline
Fluoranthene
n-Octadecane
Phenol
Pyridine
2,4,6-Trichlorophenol
CAS
Registry
Number
C-003
C-007
C-009
7440-36-0
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7439-92-1
7439-97-6
7439-98-7
7440-02-0
7782-49-2
7440-22-4
7440-31-5
7440-32-6
7440-62-2
7440-66-6
67-64-1
98-86-2
62-53-3
117-81-7
78-93-3
85-68-7
86-74-8
95-48-7
106-44-5
124-18-5
608-27-5
206-44-0
593-45-3
108-95-2
110-86-1
88-06-2
Metals
Long-Term
Average
Design
Targets

34.3
9.25
0.0213
0.0112

0.0819
0.0398
0.0574
0.169
136
0.177
0.000201
0.255
0.0563
0.0100
0.0300
0.00500
0.0500
0.206











- Subcategory A
Standards
Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

205.
29.6
0.111
0.0993

0.782
0.167
0.182
0.659
500
1.32
0.000641
0.794
0.176
0.0318
0.0955
0.0159
0.0628
0.657












50.2
11.3
0.0312
0.0199

0.163
0.0522
0.0703
0.216
178
0.283
0.000246
0.309
0.0698
0.0122
0.0367
0.00612
0.0518
0.252











Long-Term
Average
Design
Targets

28.3
25.5
0.103
0.789
0.221
0.00746
0.183
7.42
0.157
0.0986
0.00309
1.54


0.107
0.0217

3.14


0.0629
0.0550
0.151

0.238

0.0173
0.203


Oils - Subcategory B
Standards
Daily ^hly
„ . Average
Maximum „, . °
Maximum

127.
74.1
0.237
2.95
0.427
0.0172
0.746
56.4
0.500
0.350
0.0172
3.50


0.335
0.0510

8.26


0.215
0.188
0.598

0.948

0.0537
0.589



38.0
30.6
0.141
1.33
0.281
0.0102
0.323
18.8
0.242
0.160
0.00647
2.09


0.165
0.0299

4.50


0.101
0.0887
0.276

0.437

0.0268
0.302


Long-Term
Average
Design
Targets
41.0

45.0
0.569




0.704
0.943





0.382
2.06
0.0359
0.0105
0.878

0.185
0.0682
0.0230


0.362
0.116
0.0858
Organics - Subcategory C
Standards
Daily ^hly
„ . Average
Maximum „, . °
Maximum
163.

216.
0.928




0.865
1.01





0.497
30.2
0.114
0.0333
4.81

1.92
0.698
0.0731


3.65
0.370
0.155
53.0

61.3
0.679




0.757
0.965





0.420
7.97
0.0562
0.0164
1.85

0.561
0.205
0.0361


1.08
0.182
0.106
' - The promulgated performance bounds for pH are 6-9 in standard units.
                                                                  Appendix A - 4

-------
Table Appendix A-4. CWT design targets and NSPS standards for Subcategory D mixed wastestream combinations (mg/L)
CAS
Pollutant Parameters Registry
Number
CONVENTIONALS PARAMETERS*
BODs C-003
Oil & Grease C-007
TSS C-009
METAL ANALYTES
Antimony 7440-36-0
Arsenic 7440-38-2
Barium 7440-39-3
Cadium 7440-43-9
Chromium 7440-47-3
Cobalt 7440-48-4
Copper 7440-50-8
Cyanide (in-plant)
Lead 7439-92-1
Mercury 7439-97-6
Molybdenum 7439-98-7
Nickel 7440-02-0
Selenium 7782-49-2
Silver 7440-22-4
Tin 7440-31-5
Titanium 7440-32-6
Vanadium 7440-62-2
Zinc 7440-66-6
ORGANIC ANALYTES
Acetone 67-64-1
Acetophenone 98-86-2
Aniline 62-53-3
Bis(2-ethylhexyl) phthalate 117-81-7
Butanone 78-93-3
Butylbenzyl phthalate 85-68-7
Carbazole 86-74-8
o-Cresol 95-48-7
p-Cresol 106-44-5
n-Decane 124-18-5
2,3-Dichloroaniline 608-27-5
Fluoranthene 206-44-0
n-Octadecane 593-45-3
Phenol 108-95-2
Pyridine 110-86-1
2,4,6-Trichlorophenol 88-06-2
Metals,
Long-Term
Average
Design
Targets
41.0
28.3
9.25
0.0213
0.0112
0.221
0.00746
0.0398
0.0574
0.169
136
0.0986
0.000201
0.943
0.255
0.0563
0.0100
0.0300
0.00500
0.0500
0.206
2.06
0.0359
0.0105
0.0629
0.878
0.0550
0.151
0.185
0.0682
0.238
0.0230
0.0173
0.203
0.362
0.116
0.0858
Oils, Organics (A, B, & C)
Standards
Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
163.
127.
29.6
0.111
0.0993
0.427
0.0172
0.167
0.182
0.659
500
0.350
0.000641
1.01
0.794
0.176
0.0318
0.0955
0.0159
0.0628
0.657
30.2
0.114
0.0333
0.215
4.81
0.188
0.598
1.92
0.698
0.948
0.0731
0.0537
0.589
3.65
0.370
0.155
53.0
38.0
11.3
0.0312
0.0199
0.281
0.0102
0.0522
0.0703
0.216
178
0.160
0.000246
0.965
0.309
0.0698
0.0122
0.0367
0.00612
0.0518
0.252
7.97
0.0562
0.0164
0.101
1.85
0.0887
0.276
0.561
0.205
0.437
0.0361
0.0268
0.302
1.08
0.182
0.106
Long-Term
Average
Design
Targets

28.3
9.25
0.0213
0.0112
0.221
0.00746
0.0398
0.0574
0.169
0.0986
0.000201
1.54
0.255
0.0563
0.0100
0.0300
0.00500
0.0500
0.206


0.0629
0.0550
0.151

0.238

0.0173
0.203


Metals, Oils (A &B)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

127.
29.6
0.111
0.0993
0.427
0.0172
0.167
0.182
0.659
500
0.350
0.000641
3.50
0.794
0.176
0.0318
0.0955
0.0159
0.0628
0.657


0.215
0.188
0.598

0.948

0.0537
0.589



38.0
11.3
0.0312
0.0199
0.281
0.0102
0.0522
0.0703
0.216
178
0.160
0.000246
2.09
0.309
0.0698
0.0122
0.0367
0.00612
0.0518
0.252


0.101
0.0887
0.276

0.437

0.0268
0.302


Metals, Organics (A &C)
Long-Term Standards
Average Monthly
Design Daily . y
T . .. • Average
Targets Maximum „, . °
Maximum
41.0
34.3
9.25
0.0213
0.0112

0.0819
0.0398
0.0574
0.169
0.177
0.000201
0.943
0.255
0.0563
0.0100
0.0300
0.00500
0.0500
0.206
2.06
0.0359
0.0105
0.878

0.185
0.0682
0.0230


0.362
0.116
0.0858
163.
205.
29.6
0.111
0.0993

0.782
0.167
0.182
0.659
500
1.32
0.000641
1.01
0.794
0.176
0.0318
0.0955
0.0159
0.0628
0.657
30.2
0.114
0.0333
4.81

1.92
0.698
0.0731


3.65
0.370
0.155
53.0
50.2
11.3
0.0312
0.0199

0.163
0.0522
0.0703
0.216
178
0.283
0.000246
0.965
0.309
0.0698
0.0122
0.0367
0.00612
0.0518
0.252
7.97
0.0562
0.0164
1.85

0.561
0.205
0.0361


1.08
0.182
0.106
Oils,
Long-Term
Average
Design
Targets
41.0
28.3
25.5
0.103
0.789
0.221
0.00746
0.183
7.42
0.157
0.0986
0.00309
0.943


0.107
0.0217

0.382
2.06
0.0359
0.0105
0.0629
0.878
0.0550
0.151
0.185
0.0682
0.238
0.0230
0.0173
0.203
0.362
0.116
0.0858
Organics (B & C)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
163. 53.0
127. 38.0
74.1 30.6
0.237 0.141
2.95 1.33
0.427 0.281
0.0172 0.0102
0.746 0.323
56.4 18.8
0.500 0.242
0.350 0.160
0.0172 0.00647
1.01 0.965


0.335 0.165
0.0510 0.0299

0.497 0.420
30.2 7.97
0.114 0.0562
0.0333 0.0164
0.215 0.101
4.81 1.85
0.188 0.0887
0.598 0.276
1.92 0.561
0.698 0.205
0.948 0.437
0.0731 0.0361
0.0537 0.0268
0.589 0.302
3.65 1.08
0.370 0.182
0.155 0.106
' - The promulgated performance bounds for pH are 6-9 in standard units.
                                                                   Appendix A - 5

-------
Table Appendix A-5. CWT design targets and PSES standards by subcategory (mg/L)
Pollutant Parameters
METAL ANALYTES
Antimony
Arsenic
Barium
Cadium
Chromium
Cobalt
Copper
Cyanide (in-plant)
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Tin
Titanium
Vanadium
Zinc
ORGANIC ANALYTES
Bis(2-ethylhexyl) phthalate
Carbazole
o-Cresol
p-Cresol
n-Decane
2,3-Dichloroaniline
Fluoranthene
n-Octadecane
2,4,6-Trichlorophenol
CAS
Registry
Number
7440-36-0
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7439-92-1
7439-97-6
7439-98-7
7440-02-0
7782-49-2
7440-22-4
7440-31-5
7440-32-6
7440-62-2
7440-66-6
117-81-7
86-74-8
95-48-7
106-44-5
124-18-5
608-27-5
206-44-0
593-45-3
88-06-2
Long-Term
Average
Design
Targets
0.170
0.0839

0.0580
1.67
0.115
0.744
136
0.177
0.000560
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413







Metals - Subcategory A
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
0.249
0.162

0.474
15.5
0.192
4.14
500
1.32
0.00234
3.95
1.64
0.120
0.409
0.0947
0.218
2.87







0.206
0.104

0.0962
3.07
0.124
1.06
178
0.283
0.000739
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641







Long-Term
Average
Design
Targets
0.103
0.221

0.323
7.42
0.257
0.149
1.54


0.107


3.45
0.116
0.151

2.37

0.253
0.793

Oils - Subcategory B
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
0.237
0.427

0.947
56.4
0.405
0.222
3.50


0.249


6.95
0.267
0.392

5.79

0.787
1.22

0.141
0.281

0.487
18.8
0.301
0.172
2.09


0.146


4.46
0.158
0.233

3.31

0.393
0.925

Organics - Subcategory C
Long-Term Standards
Avera9e .. ğu,
_ _ ., Monthly
Design Daily . '
T . .. • Average
Targets Maximum „, . °
Maximum






0943 1.01 0.965







0185 1.92 0.561
00682 0.698 0.205
00230 0.0731 0.0361


00858 0.155 0.106
                                                                 Appendix A - 6

-------
Table Appendix A-6. CWT design targets and PSES standards for Subcategory D mixed wastestream combinations (mg/L)
CAS
Pollutant Parameters Registry
Number
METAL ANALYTES
Antimony 7440-36-0
Arsenic 7440-38-2
Barium 7440-39-3
Cadium 7440-43-9
Chromium 7440-47-3
Cobalt 7440-48-4
Copper 7440-50-8
Cyanide (in-plant)
Lead 7439-92-1
Mercury 7439-97-6
Molybdenum 7439-98-7
Nickel 7440-02-0
Selenium 7782-49-2
Silver 7440-22-4
Tin 7440-31-5
Titanium 7440-32-6
Vanadium 7440-62-2
Zinc 7440-66-6
ORGANIC ANALYTES
Bis(2-ethylhexyl)phthalate 117-81-7
Carbazole 86-74-8
o-Cresol 95-48-7
p-Cresol 106-44-5
n-Decane 124-18-5
2,3-Dichloroaniline 608-27-5
Fluoranthene 206-44-0
n-Octadecane 593-45-3
2,4,6-Trichlorophenol 88-06-2
Metals,
Long-Term
Average
Design
Targets
0.103
0.0839
0.221
0.0580
0.323
0.115
0.257
136
0.149
0.000560
0.943
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413
0.116
0.151
0.185
0.0682
2.37
0.0230
0.253
0.793
0.0858
Oils, Organics (A, B, & C)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
0.237
0.162
0.427
0.474
0.947
0.192
0.405
500
0.222
0.00234
1.01
3.95
1.64
0.120
0.409
0.0947
0.218
2.87
0.267
0.392
1.92
0.698
5.79
0.0731
0.787
1.22
0.155
0.141
0.104
0.281
0.0962
0.487
0.124
0.301
178
0.172
0.000739
0.965
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641
0.158
0.233
0.561
0.205
3.31
0.0361
0.393
0.925
0.106
Long-Term
Average
Design
Targets
0.103
0.0839
0.221
0.0580
0.323
0.115
0.257
136
0.149
0.000560
1.54
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413
0.116
0.151


2.37

0.253
0.793

Metals, Oils (A &B)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
0.237
0.162
0.427
0.474
0.947
0.192
0.405
500
0.222
0.00234
3.50
3.95
1.64
0.120
0.409
0.0947
0.218
2.87
0.267
0.392


5.79

0.787
1.22

0.141
0.104
0.281
0.0962
0.487
0.124
0.301
178
0.172
0.000739
2.09
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641
0.158
0.233


3.31

0.393
0.925

Metals, Organics (A &C)
Long-Term Standards
Avera9e .. ğu,
_ _ ., Monthly
Design Daily . '
T . .. • Average
Targets Maximum „, . °
Maximum
0.170
0.0839

0.0580
1.67
0.115
0.744
136
0.177
0.000560
0.943
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413


0.185
0.0682

0.0230


0.0858
0.249
0.162

0.474
15.5
0.192
4.14
500
1.32
0.00234
1.01
3.95
1.64
0.120
0.409
0.0947
0.218
2.87


1.92
0.698

0.0731


0.155
0.206
0.104

0.0962
3.07
0.124
1.06
178
0.283
0.000739
0.965
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641


0.561
0.205

0.0361


0.106
Oils,
Long-Term
Average
Design
Targets
0.103

0.221

0.323
7.42
0.257

0.149

0.943



0.107


3.45
0.116
0.151
0.185
0.0682
2.37
0.0230
0.253
0.793
0.0858
Organics (B & C)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum
0.237 0.141

0.427 0.281

0.947 0.487
56.4 18.8
0.405 0.301

0.222 0.172

1.01 0.965



0.249 0.146


6.95 4.46
0.267 0.158
0.392 0.233
1.92 0.561
0.698 0.205
5.79 3.31
0.0731 0.0361
0.787 0.393
1.22 0.925
0.155 0.106
                                                                   Appendix A - 7

-------
Table Appendix A-7. CWT design targets and PSNS standards by subcategory (mg/L)
Pollutant Parameters
METAL ANALYTES
Antimony
Arsenic
Barium
Cadium
Chromium
Cobalt
Copper
Cyanide (in-plant)
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Tin
Titanium
Vanadium
Zinc
ORGANIC ANALYTES
Bis(2-ethylhexyl)phthalate
Carbazole
o-Cresol
p-Cresol
n-Decane
2,3-Dichloroaniline
Fluoranthene
n-Octadecane
2,4,6-Trichlorophenol
CAS
Registry
Number

7440-36-0
7440-38-2
7440-39-3
7440-43-9
7440-47-3
7440-48-4
7440-50-8

7439-92-1
7439-97-6
7439-98-7
7440-02-0
7782-49-2
7440-22-4
7440-31-5
7440-32-6
7440-62-2
7440-66-6

117-81-7
86-74-8
95-48-7
106-44-5
124-18-5
608-27-5
206-44-0
593-45-3
88-06-2
Long-Term
Average
Design
Targets

0.170
0.0839

0.0580
1.67
0.115
0.744
136
0.177
0.000560

1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413










Metals - Subcategory A
Standards
Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

0.249
0.162

0.474
15.5
0.192
4.14
500
1.32
0.00234

3.95
1.64
0.120
0.409
0.0947
0.218
2.87











0.206
0.104

0.0962
3.07
0.124
1.06
178
0.283
0.000739

1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641










Long-Term
Average
Design
Targets

0.103

0.221

0.183
7.42
0.157

0.0986

1.54



0.107


3.14

0.0629
0.151


0.238

0.0173
0.203

Oils - Subcategory B
Standards
Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

0.237

0.427

0.746
56.4
0.500

0.350

3.50



0.335


8.26

0.215
0.598


0.948

0.0537
0.589


0.141

0.281

0.323
18.8
0.242

0.160

2.09



0.165


4.50

0.101
0.276


0.437

0.0268
0.302

Organics - Subcategory C
Long-Term Standards
Avera9e .. ğu,
_ _ ., Monthly
Design Daily . '
T . .. • Average
Targets Maximum „, . °
Maximum











0943 1.01 0.965










0185 1.92 0.561
00682 0.698 0.205

00230 0.0731 0.0361


00858 0.155 0.106
                                                                 Appendix A - 8

-------
Table Appendix A-8. CWT design targets and PSNS standards for Subcategory D mixed wastestream combinations (mg/L)
CAS
Pollutant Parameters Registry
Number
METAL ANALYTES
Antimony 7440-36-0
Arsenic 7440-38-2
Barium 7440-39-3
Cadium 7440-43-9
Chromium 7440-47-3
Cobalt 7440-48-4
Copper 7440-50-8
Cyanide (in-plant)
Lead 7439-92-1
Mercury 7439-97-6
Molybdenum 7439-98-7
Nickel 7440-02-0
Selenium 7782-49-2
Silver 7440-22-4
Tin 7440-31-5
Titanium 7440-32-6
Vanadium 7440-62-2
Zinc 7440-66-6
ORGANIC ANALYTES
Bis(2-ethylhexyl)phthalate 117-81-7
Carbazole 86-74-8
o-Cresol 95-48-7
p-Cresol 106-44-5
n-Decane 124-18-5
2,3-Dichloroaniline 608-27-5
Fluoranthene 206-44-0
n-Octadecane 593-45-3
2,4,6-Trichlorophenol 88-06-2
Metals,
Long-Term
Average
Design
Targets

0.103
0.0839
0.221
0.0580
0.183
0.115
0.157
136
0.0986
Oils, Organics (A, B, & C)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

0.237
0.162
0.427
0.474
0.746
0.192
0.500
500
0.350
0.000560 0.00234
0.943
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413

0.0629
0.151
0.185
0.0682
0.238
0.0230
0.0173
0.203
0.0858
1.01
3.95
1.64
0.120
0.409
0.0947
0.218
2.87

0.215
0.598
1.92
0.698
0.948
0.0731
0.0537
0.589
0.155

0.141
0.104
0.281
0.0962
0.323
0.124
0.242
178
0.160
0.000739
0.965
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641

0.101
0.276
0.561
0.205
0.437
0.0361
0.0268
0.302
0.106
Long-Term
Average
Design
Targets

0.103
0.0839
0.221
0.0580
0.183
0.115
0.157
136
0.0986
Metals, Oils (A &B)
Standards
_ ., Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

0.237
0.162
0.427
0.474
0.746
0.192
0.500
500
0.350
0.000560 0.00234
1.54
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413

0.0629
0.151


0.238

0.0173
0.203

3.50
3.95
1.64
0.120
0.409
0.0947
0.218
2.87

0.215
0.598


0.948

0.0537
0.589


0.141
0.104
0.281
0.0962
0.323
0.124
0.242
178
0.160
0.000739
2.09
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641

0.101
0.276


0.437

0.0268
0.302

Metals, Organics (A &C)
Long-Term Standards
Avera9e .. ğu,
_ _ ., Monthly
Design Daily . '
T . .. • Average
Targets Maximum „, . °
Maximum

0.170
0.0839

0.0580
1.67
0.115
0.744
136
0.177
0.000560
0.943
1.16
0.280
0.0264
0.0898
0.0569
0.0500
0.413



0.185
0.0682

0.0230


0.0858

0.249
0.162

0.474
15.5
0.192
4.14
500
1.32
0.00234
1.01
3.95
1.64
0.120
0.409
0.0947
0.218
2.87



1.92
0.698

0.0731


0.155

0.206
0.104

0.0962
3.07
0.124
1.06
178
0.283
0.000739
0.965
1.45
0.408
0.0351
0.120
0.0618
0.0662
0.641



0.561
0.205

0.0361


0.106
Oils
Long-Term
Average
Design
Targets

0.103

0.221

0.183
7.42
0.157

0.0986

0.943



0.107


3.14

0.0629
0.151
0.185
0.0682
0.238
0.0230
0.0173
0.203
0.0858
Organics (B & C)
Standards
Monthly
Daily . *
„ . Average
Maximum „, . °
Maximum

0.237 0.141

0.427 0.281

0.746 0.323
56.4 18.8
0.500 0.242

0.350 0.160

1.01 0.965



0.335 0.165


8.26 4.50

0.215 0.101
0.598 0.276
1.92 0.561
0.698 0.205
0.948 0.437
0.0731 0.0361
0.0537 0.0268
0.589 0.302
0.155 0.106
                                                                   Appendix A - 9

-------