CENTRALIZED WASTE
TREATMENT
40 CFR 437
Lessons Learned
LESSONS LEARNED:
The goal of this presentation is to
share our CWT compliance
strategies with you based on our
experiences.
THE MESSAGE IS:
 Understand the CWT treatment process
as it relates to your process and
compliance requirements.
 Confirm that Dilution of Wastestreams
at the CWT is NOT occurring.
WHO IS GULF COAST WASTE
DISPOSAL AUTHORITY (GCA)?
GCA has an approved Pretreatment
Program in the Houston, Texas area.
GCA operates several industrial
wastewater treatment plants and
receives wastewater from Centralized
Waste Treatment Facilities.
WHAT IS A CENTRALIZED WASTE TREATMENT FACILITY?
A CWT Facility is one that accepts for treatment and/or
recovery used industrial materials generated off-site (at
another location).
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 amendable to discharge or to recover energy or
recover metal, oil or organic content from the wastes.
Application to Discharge
Affluent Permit to CWT Facility
Reviewing CWT Incoming Wastestreams
Inspecting the CWT Facility
Continuous Evaluation of Analytical Data
Lessons Learned:
Application to Discharge
Determine what subcategories your POTW can treat and still be in compliance with your
POTW’s permits and applicable regulations. The CWT Subcategories are facilities that treat
or recover from off-site:
 Subcategory A: metal-bearing waste, wastewater, or used material
received from off-site - GCA does not accept this subcategory. POTWs
are not really designed to treat metals.
 Subcategory B: oil from oily waste, wastewater, or used material
 Subcategory C: organics from organic waste, wastewater, or used material
 Subcategory D: combination of above - GCA does not accept this
subcategory because it is too difficult to verify compliance with our
customers.
Lessons Learned:
Application to Discharge
Key Questions:
 Do you agree that the Facility is actually subject to CWT and their Subcategory
Determination?
 Do they describe a treatment process appropriate to the subcategory being treated?
Lessons Learned:
Application to Discharge
Key Questions:
Review the pollutant loadings and evaluate if your POTW:
 has the capacity to treat the wastewater and
 will still be in compliance with your POTW permits and
other regulations.
Lessons Learned:
Affluent Permit to CWT Facility
CONTROL WHAT COMES INTO YOUR POTW
Under Specific Prohibitions in the Affluent Permit make sure to describe in detail
the type of incoming wastestreams that the CWT Facility can accept for
subsequent transfer into your POTW.
Lessons Learned:
Affluent Permit to CWT Facility
To accurately evaluate compliance with each
Subcategory Have:
 Separate sampling points for each subcategory,
 Sampling points strategically located within the process,
and
 Carefully review the analytical results for compliance.
Lessons Learned:
Affluent Permit to CWT Facility
Fact Sheet for Each Affluent Permit that documents
items such as:
 Permit Action Summary,
 Pass Through and Interference Evaluations and
 Special Conditions and Rationale.
Lessons Learned:
Reviewing CWT Incoming Wastestreams
CONTROL WHAT COMES INTO YOUR
POTW
Insert into your permit specific elements such as Documentation of
Authorizations:
In the event the Permittee intends to accept for treatment,
storage and/or recovery any wastes that are hazardous,
prior to Permittee’s acceptance of such waste,
Permittee’s shall provide to the Authority this
information in writing.
Lessons Learned:
Reviewing CWT Incoming Wastestreams
CONTROL WHAT COMES INTO YOUR POTW
Insert into your permit specific elements such as:
 Customer / Generator / Transporter Information and
Regulatory Identification Numbers
 Identification of organic, oily and metal-bearing wastes and
waste codes
 General description of waste and process generating waste,
and
 A description of the treatment that the Permittee conducts on
the waste.
Lessons Learned:
Reviewing CWT Incoming Wastestreams
CONTROL WHAT COMES INTO YOUR POTW
Insert into your permit specific elements such as
Additional CWT Monthly Reporting Requirements. If
Permittee accepts wastes that are regulated under 40
CFR 437 whose compliance is not expressly described
in the Permittee’s Application to Discharge the CWT
Monthly Report shall describe specific information.
Lessons Learned:
Affluent Permit to CWT Facility
CONTROL WHAT COMES INTO YOUR POTW
Insert into your permit specific elements such as:
Prior to the Permittee’s acceptance of a new or changed
waste from an existing or new customer or generator,
the Permittee must provide to the Authority:
 Waste profiles;
 All the informational details referenced in the CWT Monthly
Report; and
 GCA must approve the acceptance, in writing, prior to
Permittee’s receipt of said waste.
Lessons Learned:
Inspecting the CWT Facility
Check On-Site Records to Confirm:
 Consistency with Application to Discharge
 Consistency with Approved Wastestreams
 Future Wastestreams Being Considered
Lessons Learned:
Inspecting the CWT Facility
Walk the Site:
 Follow Pipelines to Ensure Treatment is Actually Being
Undertaken
 Confirm the Treatment being Implemented is
Appropriate for the Subcategory
 Make sure that Dilution of the Wastestream is NOT
Occurring (i.e., Evaluate Boiler Blowdown Pipelines)
Lessons Learned:
Inspecting the CWT Facility
Inspect the On-Site Laboratory to Ensure that:
 Appropriate Testing is Being Undertaken to Ensure
Incoming Wastestreams are Accurately Being Identified,
 Compliance with any Affluent Permit Limits are Being
Evaluated and
 Analytical Documentation is Acceptable.
Lessons Learned:
Continuous Evaluation of Analytical Data
It is an Ongoing Process to:
 Confirm Compliance
 Check Data and Compare with Wastestream Profiles
 Cross Reference Process Events that Might Be Occurring
at the POTW with Wastestream Profiles at the CWT
(i.e., Metals at POTW Outfall or Sludge)
 Adjust Approval Process to Accommodate Outcome
TO SUMMARIZE LESSONS
LEARNED:
 Understand the CWT treatment process
as it relates to your process and
compliance requirements.
 Confirm that Dilution of Wastestreams
at the CWT is NOT occurring.
Thank You