
Page
1
of
10
Previous
Recommendations
for
the
Effluent
Guidelines
Planning
Process
November,
2003
Through
an
informal
and
ongoing
information
collection
process,
the
Agency
has
collected
numerous
recommendations
from
the
States,
Regions,
and
EPA
headquarters
that
fall
under
Factor
4,
"
Implementation
and
Efficiency."

Background:
Historically,
part
of
EPA's
planning
process
for
selecting
effluent
guidelines
for
development
or
revision
has
been
the
consideration
of
information
provided
by
stakeholders
and
EPA
experts
both
through
the
formal
comment
process
and
through
informal
discussions
with
headquarters,
regional,
and
state
staff
charged
with
the
task
of
implementing
effluent
guidelines.
Traditional
sources
of
this
information
include
management,
NPDES
permit
writers,
and
TMDL
coordinators
in
the
Regions;
state
and
local
governments
and
associations
including
AMSA
and
ASIWPCA;
and
headquarters
employees
in
the
Office
of
Wastewater
Management
(
OWM).
In
the
fall
of
1999
and
again
in
the
spring
of
2001,
the
EPA
talked
with
some
of
these
stakeholders
and
EPA
experts
to
follow
up
on
concerns
and
to
gather
recommendations
regarding
the
effluent
guidelines
that
the
Agency
might
develop
or
revise.
Their
recommendations
were
aggregated
and
ranked
by
the
frequency
they
were
mentioned.
Where
an
equal
number
of
recommendations
were
gathered,
subjects
with
more
recent
comments
were
given
precedence.
The
results
are
summarized
below
for
discharge
categories
that
were
recommended
by
two
or
more
responders.

POTWs/
Municipal
Treatment
Plants
Wastewater
treatment
facilities
was
one
of
the
two
the
most
frequently
recommended
subjects
for
an
effluent
guideline,
with
a
total
of
nine
recommendations.
Many
of
those
recommending
this
subject
cited
the
need
for
a
new
guideline
that
would
set
technology­
based
controls
for
nutrients,
including
ammonia,
nitrate­
nitrite,
and
phosphorus.
Metals
were
also
identified
as
a
concern.
Treatment
of
sanitary
wastewater
was
identified
as
an
overlooked
source
of
nutrients
and
resulting
BOD.
Improving
secondary
treatment
regulations
were
discussed
by
almost
half
of
those
listing
this
concern;
while
a
few
others
requested
tertiary
treatment
requirements.
At
issue
is
the
legal
authority
to
promulgate
an
effluent
guideline,
as
well
as
ongoing
efforts
within
EPA's
municipal
program.

Petroleum
Refining
(
CFR
419)
Concerns
about
discharges
from
petroleum
refining
facilities
was
the
second
of
the
two
the
most
frequently
recommended
subjects
for
an
effluent
guideline,
with
a
total
of
nine
recommendations.
Respondents
identified
the
need
to
revise
this
guideline
expand
the
list
of
pollutants
regulated
to
include:
1)
priority
pollutants
to
make
it
consistent
with
OCPSF;
2)
metals
especially
selenium;
and
3)
nutrients
(
ammonia),
BOD,
and
COD.
The
age
of
the
guideline
(
promulgated
in
1982)
was
also
cited
as
a
cause
for
concern.
Respondents
suggested
a
review
of
BPT/
BCT/
BAT
for
accuracy.

Steam
Electric
Power
Plants
(
CFR
423)
Concerns
about
discharges
from
power
plants,
most
specifically
steam
electric
power
plants,
was
the
second
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
eight
recommendations.
Respondents
noted
applicability
Page
2
of
10
concerns
for
cogeneration
units,
concerns
over
toxic
pollutants
in
coal
pile
runoff
(
including
mercury
and
selenium);
and
concerns
about
the
growing
use
of
POTW
effluent
as
cooling
water.
In
addition,
respondents
suggested
revising
the
guideline
to
expand
the
scope,
citing
exempt
facilities
that
should
not
be
exempt
and
many
newer
facilities
that
are
not
covered.
Permits
for
these
must
rely
on
BPJ.
About
1,300
new
power
plants
are
expected,
and
such
changes
could
ease
the
permit
writing
process.

Food
Processing
(
CFRs
405,
406,
407,
408)
Concerns
about
discharges
from
food
processing
facilities
was
the
third
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
seven.
In
general,
respondents
were
concerned
with
nutrients
as
well
as
overloading
of
POTWs
and
small
streams
(
for
direct
dischargers)
by
conventional
pollutants
such
as
BOD.
Respondents
identified
several
specific
industries
as
producing
such
problems,
including
seafood
processing,
dairies,
cheese
manufacturing,
vegetables
processing.
A
concern
for
copper
was
also
mentioned
in
relation
to
dairies.
A
respondent
identified
the
"
protein
technologies"
industry
as
a
category
without
an
effluent
guideline
which
could
use
one.
Another
respondent
expressed
concerns
about
non­
approved
pretreatment
processes,
and
mentioned
juice
manufacturing
as
an
example.

Drinking
Water
Treatment
(
Public
Water
Supply)
Concerns
about
discharges
from
drinking
water
treatment
facilities
was
the
fourth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
five.
Responders
noted
the
need
for
minimum
technology
based
guidelines,
especially
for
TDS,
TSS,
pH.
The
chemicals
used
by
these
facilities
also
need
to
be
controlled.
Concerns
were
also
raised
for
disposal
of
treatment
sludges
and
backwash
waters,
especially
when
those
discharges
are
sent
to
surface
water
reaches
already
impaired
for
sediment.
An
issue
is
the
legal
authority
to
promulgate
an
effluent
guideline
for
this
source
category?

Meat
Products
(
CFR
432)
Concerns
about
discharges
from
meat
products
facilities
was
the
fifth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
five.
Responders
mentioned
the
need
to
revise
this
guideline
to
address
concerns
for
nutrients,
specifically
the
need
for
limits
for
nitrogen
and
ammonia.
Additional
concerns
raised
were
POTWs
overloaded
by
conventional
pollutants
and
unregulated
discharges
of
copper.
This
guideline
is
already
in
the
process
of
revision,
with
a
proposal
published
in
February
of
2002,
and
a
final
guideline
due
in
December
of
2003.

Coal
Bed
Methane
Extraction
(
CFR
435)
Concerns
about
discharges
from
coal
bed
methane
extraction
was
the
sixth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
four.
Responders
suggested
revising
the
oil
and
gas
effluent
guidelines
to
address
issues
arising
from
the
extraction
procedure.
Although
the
bulk
of
the
discharge
from
this
activity
is
water,
responders
identified
concerns
for
depleting
aquifers,
erosion,
sedimentation,
barium
concentrations
exceeded,
salinization
of
land,
adverse
impact
on
farmers
through
plugging
of
soils
which
decreases
infiltration,
and
the
loss
of
the
water's
return
to
groundwater.
Several
states
are
affected
by
these
activities:
WY,
CO,
NM,
AL,
MT,
and
UT.
Page
3
of
10
Ore
Mining
and
Dressing
(
CFR
440)
Concerns
about
discharges
from
ore
mining
activities
(
also
referred
to
as
hard
rock
mining)
was
the
seventh
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
four.
A
comment
suggested
revising
the
guideline
since
available
treatment
technology
is
much
advanced
compared
to
that
considered
in
the
guideline.
In
addition,
the
guideline
could
be
revised
to
include
discharges
from
waste
rock,
spent
ore,
and
leach
material.
Issues
not
addressed
include
closure/
financial
assurance
plans,
remediation,
and
a
definition
of
active
vs.
inactive
mine.
A
commenter
suggested
revising
the
hard
rock
mining
guidelines
using
the
National
Mining
Team
argument;
which
includes
consideration
of
water
budgets
and
closure
plans.

Pulp
and
Paper
Subcategories
(
CFR
430)
Concerns
about
discharges
from
pulp
and
paper
subcategories
tied
with
ore
mining
as
the
seventh
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
four.
Responders
raised
concerns
about
discharges
into
smaller
water
bodies,
and
difficulties
with
establishing
WET
limits.
Additional
concerns
were
dyes
and
dioxin
from
bleaching
at
secondary
mills
and
problems
regulating
chip
mills
since
the
stormwater
regulations
are
not
stringent
enough.
Phase
3
of
a
series
of
revisions
to
this
guideline
is
already
underway,
with
a
final
guideline
due
in
September
of
2004.

Stormwater/
Urban
Runoff
Concerns
about
stormwater
and
urban
runoff
discharges
ranked
as
the
eighth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
four.
Pollutants
that
needed
limits
include
oil
and
grease,
pesticides,
pathogens,
metals,
and
sediment.
The
concern
is
that
stormwater
regulators
cannot
use
WQBELs,
just
BMPs.
Two
respondents
recommended
defining
MEP
to
the
maximum
extent
possible.
An
issue
is
the
legal
authority
to
promulgate
an
effluent
guideline
for
this
source
category?

Metal
Molding
and
Casting
(
CFR
464)
Concerns
about
discharges
from
metal
molding
and
casting
ranked
as
the
ninth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
three.
Two
of
these
recommendations
were
second
hand,
by
Regional
staff
reporting
issues
in
specific
states
(
Arkansas
and
Washington).
Specific
activities
of
concern
including
fastener
manufacturing,
job
shop
galvanizers,
and
jewelry
manufacturing,
phenol
was
identified
as
a
pollutant
of
concern.

Aquaculture
Concerns
about
discharges
from
aquaculture
(
including
fish
farming)
ranked
as
the
tenth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
three.
Pollutants
of
concern
include
nutrients
(
including
ammonia),
medicinals,
and
formaldehyde.
There
is
a
new
guideline
already
being
developed
for
this
discharge
category,
with
a
proposal
published
in
September
of
2002
and
a
final
guideline
due
in
June
of
2004.

Ballast
and
Bilge
Water
Concerns
about
discharges
of
pollutants
carried
in
the
ballast
and
bilge
waters
of
ships
ranked
as
the
eleventh
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
three.
Pollutants
generating
this
concern
were
oil
and
grease,
metals,
and
invasive
species.
Page
4
of
10
Coal
Mining
(
CFR
434)
Concerns
about
discharges
from
coal
mining
ranked
as
the
twelfth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
two.
No
specific
concerns
were
noted.
This
guideline
was
recently
revised,
with
revisions
promulgated
in
January
of
2002.

Petroleum
Bulk
Storage
Terminals
Concerns
about
discharges
from
petroleum
bulk
storage
terminals
tied
with
coal
mining
as
the
twelfth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
two.
Responders
identified
concerns
that
due
to
the
number
of
facilities
and
the
absence
of
an
effluent
guideline,
permit
writers
must
depend
on
BPJ,
which
raises
consistency
issues
as
well
as
being
time
consuming.
Discharges
may
be
primarily
from
collected
stormwater.

Metal
Finishing
(
CFR
433)
Concerns
about
discharges
from
metal
finishing
ranked
as
the
thirteenth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
two.
One
responder
suggested
that
the
guideline
be
revised
to
remove
phosphaters
of
mild
steel
from
the
scope.
The
other
responder
identified
activities
of
concern,
including
fastener
manufacturing,
job
shop
galvanizers,
jewelry
manufacturing.
As
part
of
the
recently
completed
Metal
Products
and
Machinery
rulemaking
project
(
February,
2003),
EPA
did
a
full
review
of
the
Electroplating
and
Metal
Finishing
guidelines
and
determined
that
revised
effluent
limitations
guidelines
and
pretreatment
standards
were
not
warranted
(
due
to
economic
achievability
concerns
or
the
small
toxic
pollutant
removals
as
compared
to
the
costs).

Mineral
Mining
and
Processing
(
CFR
436)
Concerns
about
discharges
from
mineral
mining
tied
with
metal
finishing
as
the
thirteenth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
two.
Concerns
about
the
mineral
mining
and
processing
guideline
suggested
the
need
for
more
complete
guidelines,
including
the
addition
of
TSS
limits
and
also
that
the
existing
guidelines
were
inconsistently
applied.

Airports
Deicing
Concerns
about
discharges
from
airport
deicing
activities
ranked
fourteenth
most
frequently
recommended
subject
for
an
effluent
guideline,
with
a
total
of
two.
Responders
suggested
that
a
new
guideline
be
developed
as
a
way
to
level
the
playing
field
as
well
as
to
ease
the
burden
on
permit
writers,
since
modeling
oxygen
demand
is
very
time
consuming.
A
study
on
this
discharge
category
was
completed
in
1999.
At
that
time,
the
industry
was
initiating
activities
to
reduce
the
toxicity
of
deicing
fluids,
and
many
airports
were
still
in
the
process
of
upgrading
their
strategies
for
managing
deicing
runoff
to
meet
their
permit
requirements
for
the
year
2000.
Page
5
of
10
RECOMMENDED
BY
EPA/
STATES/
PUBLIC
RECOMMENDATIONS
Rank
Industry
1999
2001
Total
1
(
TIE)
MUNICIPAL/
SANITARY
WASTEWATER;
SECONDARY/
TERTIARY
TREATMENT
AT
POTWS
SIC
4952
3
6
9
1
(
TIE)
PETROLEUM
REFINING
(
CFR
419)
SIC
2911
3
6
9
2
STEAM
ELECTRIC
POWER
PLANTS
(
CFR
423)
SIC
4911
1
7
8
3
FOOD
PROCESSING
(
CFR
405,
406,
407,
408)
INCLU.
SICS
2091,
2092
1
6
7
4
DRINKING
WATER
FACILITIES
(
PUBLIC
WATER
SUPPLY)
0
5
5
5
MEAT
PRODUCTS
(
CFR432)
3
2
5
6
COAL
BED
METHANE
(
CFR
435)
INCLUDES
SIC
1311
0
4
4
7
(
TIE)
ORE
MINING
AND
DRESSING
(
HARD
ROCK
MINING)
(
CFR
440)
1
3
4
7
(
TIE)
PULP
&
PAPER
SUBCATEGORIES
(
CFR
430)
INCLUDES
SICS
2611,
2621,
2631
1
3
4
8
STORMWATER
/
URBAN
RUNOFF
2
2
4
9
METAL
MOLDING
&
CASTING
(
464)
1
2
3
10
AQUACULTURE
2
1
3
11
BALLAST
AND
BILGE
WATER
3
0
3
12
(
TIE)
COAL
MINING
(
CFR
434)
0
2
2
12
(
TIE)
PETROLEUM
BULK
STORAGE
0
2
2
13
(
TIE)
METAL
FINISHING
(
CFR
433)
1
1
2
13
(
TIE)
MINERAL
MINING
(
CFR
436)
1
1
2
14
AIRPORTS/
DEICING
2
0
2
Page
6
of
10
1999
and
2001
RECOMMENDATIONS
SORTED
BY
CATEGORY
RECOMMENDED
BY
EPA/
STATES/
PUBLIC
RECOMMENDATIONS
Rank
Industry
1999
2001
Total
1
(
tie)
Municipal/
sanitary
wastewater;
secondary/
tertiary
treatment
at
POTWs
SIC
4952
3
6
9
State:
Louisiana
Gary
Aydell
sanitary
wastewater
(
kitchen
and
bathroom
contributions
to
wastewater)
for
nutrients,
BOD;
secondary
treatment
of
sanitary
effluent
for
dischargers
to
smaller
rivers,
need
effluent
limits
for
ammonia,
nitrate­
nitrite,
and
phosphorus
(
not
double
counted)
Region:
I
William
Beckwith
secondary
treatment
requirements
for
POTWs
nutrients
Region:
III
Allison
Wiedeman
municipal
treatment
plants
nutrients
and
toxic
persistent
metals
Region:
III
Thomas
Maslany
POTWs
nutrient
effluent
standards
Region:
III
Brian
Trulear
secondary
water
treatment
part
133,
problems
with
85%
removal
rate
Region:
IX
Douglas
Liden
tertiary
treatment
to
POTWs
nutrient,
TSS
removal;
BAT
for
metals
and
BCC
Region:
IX
Robyn
Stuber
tertiary
guidelines
for
POTWs
EPA
HQ:
OWM
Rob
Wood
secondary
treatment
regulations
EPA
HQ:
OWM
Rob
Wood
municipal
waste
treatment
facilities
tech
based
controls
for
nutrients
1
(
tie)
Petroleum
Refining
(
CFR
419)
SIC
2911
3
6
9
State:
Louisiana
Gary
Aydell
petroleum
refineries
specifically
to
include
priority
pollutants
like
OCPSF
and
lower
BOD/
COD
limits
State:
Oklahoma
Kendra
Foyil
petroleum
refineries
ammonia
concerns
Region:
III
Allison
Wiedeman
petroleum
refining
per
Pennsylvania
contact
Region:
VI
Jack
Ferguson
oil
refineries
­
these
guidelines
are
old,
and
do
not
cover
some
pollutants
Region:
VI
Ed
McHam
petroleum
refining
review
BPT/
BCT/
BAT
accuracy,
need
controls
on
priority
pollutants
Region:
IX
Keith
Silva
oil
refineries
metals,
especially
selenium
Region:
X
Sharon
Wilson
petroleum
refining
large
facilities
discharging
into
small
POTWs,
problems
in
Alaska
with
sulfolane
(
ask
CA,
also!)
EPA
HQ:
OWM
Benita
Best­
Wong
petroleum
refining
VP's
initiative
RECOMMENDED
BY
EPA/
STATES/
PUBLIC
RECOMMENDATIONS
Rank
Industry
1999
2001
Total
Page
7
of
10
2
Steam
Electric
Power
Plants
(
CFR
423)
SIC
4911
1
7
8
State:
Louisiana
Gary
Aydell
steam
electric
cogeneration
units
(
applicability)
State:
Michigan
Brenda
Sayles
steam
electric
power
plants
toxics
in
coal
pile
runoff:
Hg,
Se
State:
Oklahoma
Kendra
Foyil
steam
electric
chlorine,
combined
cycle
&
cooling
tower
blowdown,
using
POTW
effluent
for
cooling
waters
Region:
IV
Marshall
Hyatt,
Connie
Kagey,
Karrie­
Joe
Shell
power
plants
Region:
VI
Jack
Ferguson
steam
electric
­
some
facilities
are
exempt
that
shouldn't
be
Region:
VI
Phillip
Jennings
power
plants
using
POTW
effluent
as
cooling
water
Region:
VI
Ed
McHam
electrical
services
many
newer
facilities
not
covered,
permits
must
rely
on
BPJ
EPA
HQ:
OWM
Benita
Best­
Wong
steam
electric
power
plants
VP's
initiative;
1,300
new
power
plants
expected;
need
to
ease
permits
process
3
Food
Processing
inclu.
2091,
2092
1
6
7
State:
Louisiana
Gary
Aydell
seafood
processing
facilities
­
high
BOD
loads
into
low
DO
waters;
discharging
to
smaller
rivers
State:
Oklahoma
Kendra
Foyil
protein
technologies
not
covered
in
food­
related
ELGs
Region:
III
Thomas
Maslany
food
mfr
nutrient
effluent
standards
Region:
III
Brian
Trulear
food
industry
e.
g.
Wise
Potato
Chips;
expressed
as
concentrations,
consistent
with
biological
treatment
systems,
instead
of
lb/
1000
lb;
technology
better
than
limits,
but
industry
uses
ELG
limits
to
avoid
BPJ
Region:
V
Carol
Staniec
food
processing
POTWs
overloaded
by
conventionals
(
specifically
dairies,
cheese,
vegetables)
Region:
VIII
Curt
McCormick
food
processing
concerns
about
non­
approved
pretreatment
processes;
includes
juice
mfr.,
cheese
factories,
copper
in
the
dairy
lagoons
Region:
X
Sharon
Wilson
food
processing
small
POTWs
overloaded
by
conventional
pollutants,
specifically
dairies
RECOMMENDED
BY
EPA/
STATES/
PUBLIC
RECOMMENDATIONS
Rank
Industry
1999
2001
Total
Page
8
of
10
4
Drinking
Water
Facilities
(
Public
Water
Supply)
0
5
5
Region:
III
Brian
Trulear
drinking
water
treatment
draft
guidelines
never
finalized
Region:
VI
Jack
Ferguson
drinking
water
supply
­
the
chemicals
in
use
need
to
be
controlled.
Region:
VI
Ed
McHam
public
water
supply
treatment
plants
need
minimum
technology
based
guidelines,
esp
for
TDS,
TSS,
pH.
Region:
VII
Michael
Turvey
drinking
water
treatment
plants
disposal
of
treatment
sludges
&
backwash
waters
EPA
HQ:
OWOW
Todd
Dabolt
drinking
water
facilities
discharges
to
reaches
impaired
for
sediment
5
Meat
Products
(
CFR
432)
3
2
5
Region:
III
Allison
Wiedeman
food
processors,
esp.
ag.
animals
­
chicken,
hogs,
especially
nutrients,
nitrogen
Region:
V
Carol
Staniec
slaughterhouses
POTWs
overloaded
by
conventional
pollutants
Region:
VII
John
Dunn
beef
packers
­
to
cut
ammonia
discharges
Region:
VIII
Bruce
Kent
meat
products
­
for
ammonia/
nitrogen
limits
Region:
VIII
Curt
McCormick
slaughterhouses
­
copper
issues
6
Coal
Bed
Methane
(
CFR
435)
1311
0
4
4
State:
Wyoming
Mike
Read
coal
bed
methane
moderate
concern
­
salinity,
plugging
soils
and
preventing
return
of
water
to
groundwater
Region:
VIII
Carol
Campbell
coal
bed
methane
revise
oil
and
gas
ELGs;
depleting
aquifers,
erosion,
sedimentation,
barium
concentrations
exceeded,
salinization
of
land,
adverse
impact
on
farmers
Region:
VIII
Bruce
Kent
coal
bed
methane
revise
oil
and
gas
ELGs?
depleting
aquifers,
salinization
of
land,
adverse
impact
on
farmers
Citizens
Group:
Wyoming
Outdoor
Council
coal
bed
methane
depletion
of
aquifers,
salinity
impacting
soils/
vegetation
and
decreasing
infiltration;
affects
several
states:
WY,
CO,
NM,
AL,
MT,
UT
RECOMMENDED
BY
EPA/
STATES/
PUBLIC
RECOMMENDATIONS
Rank
Industry
1999
2001
Total
Page
9
of
10
7
(
tie)
Ore
Mining
and
Dressing
(
Hard
Rock
Mining)
(
CFR
440)
1
3
4
State:
Wyoming
Mike
Read
hard
rock
mining
waste
rock,
closure
(
financial
assurance)
Region:
VIII
Carol
Campbell
hard
rock
mining
revise
using
National
Mining
Team
argument;
specifically
water
budgets
and
closure
plans
Region:
VIII
Bruce
Kent
hard
rock
mining
technology
has
outstripped
ELG;
closure
plans;
ore
mining
and
dressing
­
WQ­
based
limits,
treatment
technology
much
advanced.
ELG
did
not
include
waste
rock,
spent
ore,
and
leach
material,
remediation,
definition
of
active
vs.
inactive
mine.
(
Not
double
counted)
EPA
HQ:
OWM
Benita
Best­
Wong
hard
rock
mining
7
(
tie)
Pulp
&
Paper
Subcategories
(
CFR
430)
includes
SICs
2611,
2621,
2631
1
3
4
State:
Louisiana
Gary
Aydell
paper
mills
on
small
water
bodies
State:
South
Carolina
Andrew
Yasinsac
paper
mills
most
mills
have
WQ
limits
on
DO
as
BOD5,
some
on
ammonia;
establishing
WET
limits
procedures
very
difficult
Region:
IV
Marshall
Hyatt,
Connie
Kagey,
Karrie­
Joe
Shell
remainder
of
pulp
and
paper
dyes
and
dioxin
from
bleaching
at
secondary
mills
Region:
IV
Marshall
Hyatt,
Connie
Kagey,
Karrie­
Joe
Shell
chip
mills
problems
regulating;
using
stormwater
regulations,
not
stringent
enough
8
stormwater
/
urban
runoff
2
2
4
Region:
IX
Douglas
Liden
stormwater
Region:
IX
Catherine
Kuhlman
urban
runoff/
stormwater
­
NPDES
dischargers
(
oil
and
grease,
pesticides,
pathogens,
metals,
sediment);
stormwater
cannot
use
WQBELs,
just
BMPs
Region:
IX
Robyn
Stuber
stormwater
define
MEP
to
the
maximum
extent
possible
Region:
IX
Terry
Oda
stormwater
establish
MEP
9
Metal
Molding
&
Casting
(
CFR
464)
1
2
3
Region:
VI
Lee
Boehme
metal
molding
and
casting
(
CFR
464)
(
re:
Allan
Gilliam
in
AR
DEQ)
Region:
IX
Keith
Silva
metal
molding
and
casting
­
fastener
manufacturing,
job
shop
galvanizers,
jewelry
manufacturing
Region:
X
Sharon
Wilson
metal
molding
and
casting
(
CFR
464)
phenol
problem
(
re:
David
Knight
in
WA
Dept.
of
Ecology)
RECOMMENDED
BY
EPA/
STATES/
PUBLIC
RECOMMENDATIONS
Rank
Industry
1999
2001
Total
Page
10
of
10
10
Aquaculture
2
1
3
Region:
III
Allison
Wiedeman
aquaculture
­
nutrients,
medicinals,
formaldehyde
Region:
IX
Douglas
Liden
fish
hatcheries
Region:
IX
Robyn
Stuber
offshore
fishing
operations
net
pen
operators
(
ammonia);
also
a
problem
with
Regions
2,4,6,
and
10
11
ballast
and
bilge
water
3
0
3
Region:
IX
Douglas
Liden
ballast
water
discharges
Region:
IX
Keith
Silva
bilge
water
­
oily,
metal
bearing
waste
stream
EPA
HQ:
OWOW
Suzanne
Schwartz
ballast
water
invasive
species
as
pollutants
12
(
tie)
Coal
Mining
(
CFR
434)
0
2
2
Region:
IV
Marshall
Hyatt,
Connie
Kagey,
Karrie­
Joe
Shell
coal
mines
EPA
HQ:
OWM
Benita
Best­
Wong
coal
mining
12
(
tie)
Petroleum
bulk
storage
0
2
2
Region:
VI
Ed
McHam
petroleum
bulk
storage
a
lot
of
facilities,
permit
writers
must
depend
on
BPJ,
consistency
issue,
time
consuming
Region:
VII
Michael
Turvey
petroleum
tank
farms
particularly
for
collected
stormwater
13
(
tie)
Metal
Finishing
(
CFR
433)
1
1
2
Region:
VIII
Curt
McCormick
metal
finishing
phosphaters
of
mild
steel
­
should
be
removed
from
the
scope
Region:
IX
Keith
Silva
metal
finishing
­
fastener
manufacturing,
job
shop
galvanizers,
jewelry
manufacturing
13
(
tie)
Mineral
Mining
1
1
2
State:
Maryland
Edward
Stone
mineral
mining
need
more
complete
ELGs
Region:
III
Brian
Trulear
mineral
mines
existing
guidelines
inconsistently
applied,
ELG
has
pH
limits
only,
needs
TSS
limits
14
Airports
(
Deicing
Operations)
2
0
2
State:
Maryland
Edward
Stone
airports
to
level
the
playing
field
State:
Michigan
Brenda
Sayles
airport
deicing
modeling
oxygen
demand
very
time
consuming
