Memorandum
From:
Carey
A.
Johnston,
P.
E.
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
Final
Rule:
Streamlining
the
General
Pretreatment
Regulations
for
Existing
and
New
Sources
of
Pollution
EPA
Docket
Number
OW­
2002­
0007
(
www.
epa.
gov/
edockets/)

Date:
June
6,
2005
Re:
Example
Types
of
Pretreatment
Standards
EPA
may
promulgate
pretreatment
standards
(
and
other
effluent
guidelines)
in
a
number
of
ways
including:
(
1)
production­
normalized
mass­
based
(
mass­
pollutant/
production
unit);
(
2)
flow­
normalized
mass­
based
(
mass­
pollutant/
time
unit);
and
(
3)
concentration­
based
standards
(
mass­
pollutant/
volume
of
wastewater).
These
three
types
of
pretreatment
standards
can
be
converted
to
a
mass­
based
permit
limit
by
using
a
reasonable
measure
of
the
Industrial
User's
actual
long­
term
daily
production
(
for
production­
normalized
mass­
based
standards)
or
the
Industrial
User's
actual
long­
term
average
daily
flow
rate
(
for
flow­
normalized
mass­
based
and
concentration­
based
standards).

EPA
prefers
setting
production­
normalized
mass­
based
standards,
where
feasible,
since
production
normalized
limitations
can
require
flow
reduction
and
reduces
any
potential
for
the
substitution
of
dilution
for
treatment.
Specifically,
production­
normalized
mass­
based
standards
are
calculated
from
production
normalized
flows
(
volume
of
wastewater/
production
unit)
and
incorporate
wastewater
flow
reductions
representing
BAT
(
technology
basis
for
PSES)
or
BADT
(
technology
basis
for
PSNS).
Flow­
normalized
mass­
based
and
concentration­
based
standards
may
include
flow
reduction
when
estimating
the
PSES
and
PSNS
incremental
compliance
costs,
however,
the
standards
themselves
do
not
specifically
require
flow
reductions
to
maintain
compliance.

EPA
reviewed
effluent
guidelines
regulations
with
concentration­
based
pretreatment
standards
and
identified
the
rationales
for
why
EPA
established
concentration­
based
standards
for
certain
categories
or
subcategories
instead
of
production­
normalized
mass­
based
standards.


POTWs
and/
or
the
affected
industry
submitted
comments
favoring
concentration­
based
standards,
because
they
are
easier
to
implement
and
enforce.


Due
to
the
complexity
and
variation
among
facilities
to
be
covered
by
categorical
standards,
EPA
did
not
have
enough
data,
could
not
adequately
measure
production,
or
could
not
find
a
consistent
production
normalizing
relationship
in
order
to
establish
production­
normalized
mass­
based
standards
on
a
nationwide
basis.


Because
the
industry
covered
by
the
categorical
standards
does
not
make
a
product
and
existing
best
professional
judgment­
based
permits
were
concentration­
based,
EPA
chose
concentration
standards
over
mass­
based.


For
concentration­
based
oil
and
grease
standards,
EPA
based
its
decision
on
a
literature
review
which
indicated
at
what
concentration
oil
and
grease
can
interfere
with
a
POTW's
operations.


EPA
could
not
identify
any
additional
water
reduction
technologies
at
the
time
of
promulgation
which
would
necessitate
setting
production­
normalized
mass­
based
standards.

A
summary
of
how
these
three
example
types
of
pretreatment
standards
are
incorporated
into
permits
is
presented
in
Table
1.
Finally,
Table
2
presents
a
current
summary
of
pretreatment
standards
including
whether
the
industrial
point
source
category
is
regulated
by
mass­
based
or
concentration
based
pretreatment
standards.
Table
1:
Summary
Examples
of
Permit
Limits
and
Use
of
Effluent
Guidelines
Permit
Limit
Description
and
units
What's
Needed
to
Establish
the
Permit
Limit?
What's
Needed
to
Demonstrate
Compliance
Concentration­
based
(
mass­
pollutant)/

vol.
discharged)
­
Identify
applicable
concentration­
based
ELGs
(
mass­
pollutant)/
vol.
discharged).

­
Identify
sample
point.

­
Identify
average
daily
flows
regulated
by
ELGs.

­
Identify
average
daily
flows
NOT
regulated
by
ELGs.

­
Concentration­
based
permit
limit
is
calculated
for
the
sample
point
with
an
accounting
for
dilution
with
non­
regulated
flows.

Direct
Discharges:
This
type
of
limit
is
generally
not
available
to
direct
dischargers
unless
mass­
based
(
flow)
limits
are
infeasible
because
pollutant
discharges
can't
be
correlated
with
production
(
e.
g.,
certain
mining
operations).

Indirect
Discharges:
This
type
of
limit
is
often
available
to
indirect
dischargers
(
e.
g.,

metal
finishers)
but
is
not
available
when
mass­
based
(
flow)
or
mass­
based
(
production)

limits
are
required.
­
Grab
sample
of
wastewater
at
the
sample
point
to
determine
pollutant
concentrations
and
compare
against
the
permit
limits.

­
Inspection
to
ensure
no
dilution
is
occurring.

Mass­
based
(
flow)

(
mass­
pollutant)/

time)
­
Identify
applicable
concentration­
based
ELGs
(
mass­
pollutant)/
vol.
discharged).

­
Identify
sample
point.

­
Identify
average
daily
flows
regulated
by
ELGs.

­
Identify
average
daily
flows
NOT
regulated
by
ELGs.

­
Use
the
concentration­
based
ELG
and
flow
information
to
calculate
an
adjusted
concentration
at
the
sample
point
to
account
for
dilution.

­
Calculate
permit
limit
as:

adjusted
concentration
(
mass­
pollutant)/
vol.
discharged)
x
average
daily
flow
at
sample
point
(
vol.
discharged/
time)

Direct
Discharges:
This
type
of
limit
is
most
often
required
when
ELGs
are
expressed
in
units
of
concentration
unless
mass­
based
(
flow)
limits
are
infeasible
because
pollutant
discharges
can't
be
correlated
with
production
(
e.
g.,
certain
mining
operations).

Indirect
Discharges:
This
type
of
limit
is
only
required
for
indirect
dischargers
in
a
few
industrial
categories
(
e.
g.,
OCPSF,
Petroleum
Refining,
Pesticide
Manufacturing).
­
Grab
sample
of
wastewater
at
the
sample
point
to
determine
pollutant
concentrations.

­
Wastewater
flow
at
sample
point.

­
Multiply
measured
grab
sample
pollutant
concentrations
and
sample
point
flow
to
calculate
the
measured
mass
of
pollutants
discharged.
Compare
these
measured
pollutant
mass
discharges
against
the
permit
limits.

­
Inspection
to
ensure
no
dilution
is
occurring.
Table
1:
Summary
Examples
of
Permit
Limits
and
Use
of
Effluent
Guidelines
(
cont.)

Permit
Limit
Description
and
units
What's
Needed
to
Establish
the
Permit
Limit?
What's
Needed
to
Demonstrate
Compliance
Mass­
based
(
production)

(
mass­
pollutant)/

time)
­
Identify
applicable
production­
based
ELGs
(
mass­
pollutant)/
production).

­
Identify
sample
point.

­
Identify
reasonable
measure
of
the
facility's
regulated
actual
long­
term
daily
production
­
Perform
the
following
calculation:

production­
based
ELGs
(
mass­
pollutant)/
production)
x
facility's
regulated
actual
long­
term
daily
production
(
production/
time)

­
Identify
average
daily
flows
regulated
by
ELGs.

­
Identify
average
daily
flows
NOT
regulated
by
ELGs.

­
Use
the
above
calculation
and
flow
information
to
calculate
an
adjusted
mass­
based
limit
at
the
sample
point
to
account
for
dilution.

Direct
Discharges/
Indirect
Discharges:
This
type
of
limit
is
required
when
ELGs
are
based
on
production
(
e.
g.,
Iron
and
Steel
Manufacturing).
­
Grab
sample
of
wastewater
at
the
sample
point
to
determine
pollutant
concentrations.

­
Wastewater
flow
at
sample
point.

­
Multiply
measured
grab
sample
pollutant
concentrations
and
sample
point
flow
to
calculate
the
measured
mass
of
pollutants
discharged.
Compare
these
measured
pollutant
mass
discharges
against
the
permit
limits.

­
Inspection
to
ensure
no
dilution
is
occurring.
Table
2:
Summary
of
Categorical
Pretreatment
Standards
No.
Category
40
CFR
Part
Subparts
Type
of
Standard
Overview
of
Pretreatment
Standards
1
Aluminum
Forming
467
A­
F
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
monthly
averages.
Subpart
C
prohibits
discharges
from
certain
operations.

2
Battery
Manufacturing
461
A­
G
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
monthly
averages.
No
discharge
is
allowed
from
any
process
not
specifically
identified
in
the
regulations.

3
Carbon
Black
Manufacturing
458
A­
D
PSNS
Limits
are
for
Oil
&
Grease
only
(
no
duration
specified).

4
Centralized
Waste
Treatment
437
A­
D
PSES
PSNS
Limits
are
concentration­
based,
daily
maximums
and
monthly
averages.

5
Coil
Coating
465
A­
D
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
monthly
averages.

6
Concentrated
Animal
Feeding
Operations
(
CAFO)
412
B
PSNS
Discharge
of
process
wastewater
is
prohibited,
except
when
there
is
an
overflow
resulting
from
a
chronic
or
catastrophic
rainfall
event.

7
Copper
Forming
468
A
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
monthly
averages.

8
Electrical
and
Electronic
Components
469
A­
D
PSES
PSNS
Limits
are
concentration­
based,
daily
maximums
and
30
day
averages
or
monthly
averages
(
varies
per
subpart
and
pollutant
parameter).
Certification
is
allowed
in
lieu
of
monitoring
for
certain
pollutants
when
a
management
plan
is
approved
and
implemented.

9
Electroplating
413
A,
B,
D
­
H
PSES
Limits
are
concentration­
based
(
or
alternative
mass­
based
equivalents),
daily
maximums
and
four
consecutive
monitoring
days
averages.
Two
sets
of
limits
exist,
depending
on
if
facility
discharging
more
or
less
than
10,000
gallons
per
day
of
process
wastewater.
Certification
is
allowed
in
lieu
of
monitoring
for
certain
pollutants
when
a
management
plan
is
approved
and
implemented.

10
Fertilizer
Manufacturing
418
A­
G
PSNS
Limits
may
specify
zero
discharge
of
wastewater
pollutants
(
Subpart
A),

production­
based
daily
maximums
and
30­
day
averages
(
Subparts
B­
E),
or
concentration­
based
(
Subparts
F­
G),
with
no
duration
of
limit
specified.

11
Glass
Manufacturing
426
H
K­
M
PSNS
Limits
are
either
concentration­
or
production­
based,
daily
maximums
and
monthly
averages.

12
Grain
Mills
406
A
PSNS
Discharge
of
process
wastewater
is
prohibited
at
a
flow
rate
or
mass
loading
rate(
BOD
5
and
TSS)
that
is
excessive
during
periods
when
a
POTW
is
receiving
peak
loads.

13
Ink
Formulating
447
A
PSNS
Regulations
specify
no
discharge
of
process
wastewater
pollutants
to
a
POTW.
Table
2:
Summary
of
Categorical
Pretreatment
Standards
No.
Category
40
CFR
Part
Subparts
Type
of
Standard
Overview
of
Pretreatment
Standards
14
Inorganic
Chemicals
Manufacturing
415
A,
B,
F,
L,

AH,
AJ,
AL,
AR,
AU,
BC,

BL,
BM,
BO
B
­
F,
H,

K
­
N,
P,
Q,

T,
V,
AA,

AC,
AE,
AH
AI,
AJ,
AL,

AN,
AP,
AQ
AR,
AU,
AX
BB,
BC,

BH,

BK
­
BO
PSES
PSNS
Limits
vary
for
each
subpart
with
a
majority
of
the
limits
concentration­
based,

daily
maximums
and
30­
day
averages,
or
may
specify
no
discharge
of
wastewater
pollutants.

15
Iron
and
Steel
Manufacturing
420
A­
F,
H­
J,
L
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
30
day
averages.

16
Leather
Tanning
and
Finishing
425
A­
I
PSES
PSNS
Limits
are
concentration­
based,
daily
maximums
and
monthly
averages.
In
certain
instances,
applicability
of
pretreatment
standards
is
dictated
by
volume
of
production.

17
Metal
Finishing
433
A
PSES
PSNS
Limits
are
concentration­
based,
daily
maximums
and
monthly
averages.

Certification
is
allowed
for
certain
pollutants
where
a
management
plan
is
approved
and
implemented.

18
Metal
Molding
and
Casting
464
A­
D
PSES
PSNS
Limits
are
primarily
production­
based,
daily
maximums
and
monthly
averages.

Discharges
from
certain
processes
are
prohibited
(
Subparts
A­
C).

19
Nonferrous
Metals
Forming
and
Metal
Powders
471
A­
J
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
monthly
averages.
In
some
instances,
the
discharge
of
wastewater
pollutants
is
prohibited.

20
Nonferrous
Metals
Manufacturing
421
C,
F
­
M,
P,
Q,
V,
X,
Y,

AA
­
AC
B
­
Z,

AA
­
AE
PSES
PSNS
Limits
are
production­
based,
daily
maximums
and
monthly
averages.

21
Oil
and
Gas
Extraction
435
D
PSES
PSNS
Regulations
specify
no
discharge
of
wastes
(
e.
g.,
produced
water,
drill
cuttings)
to
a
POTW.

22
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
414
B­
H,
K
PSES
PSNS
Limits
are
mass­
based
(
concentration­
based
standards
multiplied
by
process
flow),

daily
maximums
and
monthly
averages.
Standards
for
metals
and
cyanide
apply
only
to
metal­
or
cyanide­
bearing
wastestreams.

23
Paint
Formulating
446
A
PSNS
Regulations
specify
no
discharge
of
process
wastewater
pollutants
to
the
POTW.
Table
2:
Summary
of
Categorical
Pretreatment
Standards
No.
Category
40
CFR
Part
Subparts
Type
of
Standard
Overview
of
Pretreatment
Standards
24
Paving
and
Roofing
Materials
(
Tars
and
Asphalt)
443
A­
D
PSNS
Limits
are
for
Oil
&
Grease
only
(
no
limit
duration
specified).

25
Pesticide
Chemicals
455
A,
C,
E
PSES
PSNS
Limits
are
mass­
based
(
concentration­
based
standards
multiplied
by
process
flow),

daily
maximums
and
monthly
averages.
Subpart
C
specifies
no
discharge
of
process
wastewater
pollutants,
but
provides
for
pollution
prevention
alternatives.

Subpart
E
specifies
no
discharge
of
process
wastewater
pollutants.

26
Petroleum
Refining
419
A­
E
PSES
PSNS
Limits
are
concentration­
based
(
or
mass
based
equivalent),
daily
maximums.

27
Pharmaceutical
Manufacturing
439
A­
D
PSES
PSNS
Limits
are
concentration­
based,
daily
maximums
and
monthly
averages.
These
facilities
may
certify
they
do
not
use
or
generate
cyanide
in
lieu
of
performing
monitoring
to
demonstrate
compliance.

28
Porcelain
Enameling
466
A­
D
PSES
PSNS
Limits
are
concentration­
based
(
or
alternative
production­
based),
daily
maximums
and
monthly
averages.
Subpart
B
prohibits
discharges
from
certain
operations.

29
Pulp,
Paper,
and
Paperboard
430
A­
G,
I­
L
PSES
PSNS
Limits
are
production­
based
daily
maximums
and
monthly
averages.
These
facilities
may
certify
they
do
not
use
certain
compounds
in
lieu
of
performing
monitoring
to
demonstrate
compliance.
Facilities
subject
to
Subparts
B
and
E
must
also
implement
Best
Management
Practices
as
identified.

30
Rubber
Manufacturing
428
E
­
K
PSNS
Limits
are
concentration­
or
production­
based,
daily
maximums
and
monthly
averages.

31
Soap
and
Detergent
Manufacturing
417
O
­
R
PSNS
Regulations
specify
no
discharge
of
process
wastewater
pollutants
to
a
POTW
when
the
wastewater
COD/
BOD
7
ratio
exceeds
10.0
and
the
COD
concentrations
exceed
subcategory
specific
concentrations.

32
Steam
Electric
Power
Generating
423
 
PSES
PSNS
Limits
are
either
concentration­
based,
daily
maximums,
or
"
maximums
for
any
time,"
or
compliance
can
be
demonstrated
through
engineering
calculations.

33
Timber
Products
Processing
429
F
­
H
PSES
PSNS
All
PSNS
(
and
PSES
for
Subpart
F)
prohibit
the
discharge
of
wastewater
pollutants.
PSES
for
Subparts
G
and
H
are
concentration­
based,
daily
maximums
(
with
production­
based
alternatives).

34
Transportation
Equipment
Cleaning
442
A­
C
PSES
PSNS
Operators
subject
to
effluent
guidelines
in
subparts
A­
B
must
either
meet
concentration­
based,
daily
maximum
standards
or
develop
a
Pollutant
Management
Plan.
Operators
subject
to
effluent
guidelines
in
subpart
C
must
meet
concentration­
based,
daily
maximum
standards.

35
Waste
Combustors
444
A
PSES
PSNS
Limits
are
concentration­
based,
daily
maximums
and
monthly
averages.
