EPA Update
David Phillips
Industrial Pretreatment Program Coordinator
U.S. EPA Region 4
FIPA Spring Workshop + Silver Springs, Florida + March 25, 2011
New Categorical Standards
Being Considered
 Healthcare Industry
 Unused Pharmaceuticals
 Hospitals
 Long-term Care Facilities
 Hospices
 Clinics (school, prison, community)
 Doctor’s offices
 Veterinary Clinics and Hospitals
New Categorical Standards
Being Considered
 Healthcare Industry
 Unused Pharmaceuticals
 Hospitals
 Long-term Care Facilities
 Hospices
 Clinics (school, prison, community)
 Doctor’s offices
 Veterinary Clinics and Hospitals
New Categorical Standards
Being Considered
 Healthcare Industry
 Unused Pharmaceuticals
 “Best practices” (i.e., BMPs) being
developed for Hospitals and Long Term Care
Facilities
 Details to be released with
Final 2010 ELG Plan
http://www.smarxtdisposal.net
http://www.disposemymeds.org
New Categorical Standards
Being Considered
 Airport Deicing Operations
 EPA proposed standards in 2009
 High Ammonia wastewaters
 Dental Amalgam
 Voluntary BMP Program Underway (ADA)
 EPA-proposed Standards expected 2011
 EPA final Standards expected 2012
New Categorical Standards
Being Considered
 Dental Amalgam
 ADA-funded study indicated 50% of mercury
entering POTWs can originate from dental.
 Well-maintained amalgam separators
capture/recycle 95-99% of dental mercury.
 Use reduces free mercury in influent and
biosolids (reports of 30-50% biosolids reduction).
 Use may have limited impact on reducing
mercury elevated in POTW effluent.
Amalgam Separators
New Categorical Standards
Being Considered
 Dental Amalgam
 Is anyone mandating use/maintenance of
amalgam separators?
 (2008) 11 States and 20 local jurisdictions.
 Can I use local limits? (Yes)
 MWRA (Massachusetts, 350 MGD, 250+ SIU)




Local limit established is 1 ppb (mg/L)
Mercury sources: dentists 18%, industry 3%, Other 84%
Reduction from medical sources in 5 years: 91%
Annual penalties collected: ~$400k-100k
Revisions to Existing Standards
Being Considered
 OCPSF/Inorganics/Pharma Mfg –
Parts 414/415/439
 Chlorine and Chlorinated Hydrocarbons
(CCH) Manufacturing
 Dioxins…forming from manufacture of :
ethylene dichloride (EDC)
vinyl chloride monomer (VCM)
polyvinyl chloride (PVC)
Revisions to Existing Standards
Being Considered
 OCPSF/Inorganics/Pharma Mfg –
Parts 414/415/439
 Chlorine and Chlorinated Hydrocarbons
(CCH) Manufacturing
 Mercury…increases due to new air pollution
controls in mercury-cell process to manufacture :
Chlorine
Caustics
Revisions to Existing Standards
Being Considered
 Steam Electric Power – Part 423
 EPA-proposed rule expected 2012
 EPA-final rule expected 2014
 www.epa.gov/guide/steam
Pending Guidance
 IU Permitting Guidance Manual
 Updates 1989 guidance
 Will be released with a Webcast
 www.epa.gov/npdes/pretreatment
 Publications (right-side box)
Pending Guidance
 Introduction to the National
Pretreatment Program
 Updates 1999 manual
 Will be released with a Webcast
 www.epa.gov/npdes/pretreatment
 Publications (right-side box)
Guidance in Development
 Guidance for POTW Pretreatment
Program Development
 Updates 1983 guidance
 Procedures for Reviewing POTW
Pretreatment Program Submissions
 Updates 1983 guidance
Webcasts
 www.epa.gov/npdes/pretreatment
 Trainings and Meetings (right-side box)
 Register for upcoming casts and/or
scroll to Pretreatment listings
 Posted:




Compliance Monitoring 101
Compliance Inspections 101
Industrial Waste Surveys 101
Other topics
POTW Pretreatment
Programs in SNC
 Region 4 closely reviewing State reports
Elevated response from EPA where:
 POTW’s SNC continues despite State actions
 POTW’s SNC unresolved for two quarters or more
 State requests EPA action
FOG Programs and
Pretreatment:
Regulatory Basis
FOG Programs and Pretreatment:
Regulatory Basis

What is an Industrial User?

40 CFR 403.3(j)
• An industrial user is a source of indirect discharge.

What is an Indirect Discharge?

40 CFR 403.3(i)
• Introduction of pollutants into a POTW from any nondomestic source regulated under section 307(b), (c), (d) of
the Clean Water Act.
All non-domestic sources regulated by
Pretreatment Standards require a control
mechanism. 40 CFR 403.8(f)
FOG Programs and Pretreatment:
Regulatory Basis
 What
is a Pretreatment Standard?
40 CFR 403.3(l)
• Any categorical standards applicable to IUs
• Any prohibitions in 40 CFR 403.5
40 CFR 403.5(d)
• Local limits
FOG Programs and Pretreatment:
Regulatory Basis
 Specific

Prohibitions - 403.5(b)
The following pollutants shall not be introduced into a
POTW:

403.5(b)(3)
• Solid or viscous pollutants in amounts which will
cause obstruction to the flow in the POTW
resulting in Interference.

403.5(b)(4)
• Any pollutant at a flow rate or concentration that
will cause Interference with the POTW.
FOG Programs and Pretreatment:
Regulatory Basis

What is a POTW?

40 CFR 403.3(q)
• A treatment works owned by a municipality. This definition
includes any devices or systems used in the storage,
treatment, recycling, and reclamation of municipal sewage or
liquid industrial wastes. It also includes sewers, pipes, and
other conveyances that convey wastewater to a municipal
treatment plant.

What is Interference?

40 CFR 403.3(k)
• A discharge, either alone or in combination with discharges
from other sources, which both:


(1) Inhibits or disrupts the POTW (see above); it’s treatment or
operations, or sludge management
(2) Causes a violation of any POTW permit requirement
FOG Programs and Pretreatment:
Regulatory Basis
 POTW


permit requirements:
…shall at all times properly operate and
maintain…
…shall implement approved pretreatment
program and Part 403…
The receiving sewer serves a commercial fast-food area.
Is the source of this pollutant an industrial user?
Can this pollutant cause Interference with the POTW, and
therefore a violation of Pretreatment Standards?
Do the industrial users that supply this pollutant require a
control mechanism by the POTW Pretreatment Program?
FOG Programs and Pretreatment:
Regulatory Basis

What about residential sources?
They are domestic sources…

Control also necessary to meet
common goals:



Meet proper O&M condition of
NPDES permit
Prevent sewer overflow violations
Authorities for controlling domestic
FOG sources are local
Questions
Phillips.David@epa.gov
(404) 562-9773