Page
1
of
40
Gathering
EPA
Experts'
Input
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
December,
2003
Background
Information
Section
304(
m)
of
the
Clean
Water
Act
requires
EPA
to
develop
and
publish
a
plan
every
two
years
showing
which
effluent
limitations
guidelines
and
standards
("
effluent
guidelines")
the
Agency
will
revise
and
which
industries
currently
without
effluent
guidelines
it
will
regulate.
For
most
of
the
last
10
years,
selections
of
industries
for
guidelines
and
their
schedules
were
substantially
influenced
by
court­
ordered
consent
decree.

As
the
Agency
meets
its
final
obligations
under
the
consent
decree,
the
Engineering
and
Analysis
Division
(
EAD)
in
EPA's
Office
of
Science
and
Technology
is
developing
and
implementing
a
planning
process
to
determine
future
work
on
effluent
limitations
guidelines.
The
draft
Strategy
for
National
Clean
Water
Industrial
Regulations
describes
the
planning
process
in
detail
(
http://
www.
epa.
gov/
guide/
strategy).
The
process
will
allow
the
Agency
to
identify
existing
effluent
guidelines
(
or
specific
aspects
of
guidelines)
that
need
to
be
revised,
and
categories
(
or
specific
subcategories)
that
have
not
been
previously
addressed
that
should
be
considered
for
effluent
guidelines
development.

We
collected
information
under
four
main
topics,
or
factors,
which
were
identified
in
the
draft
Strategy
to
identify
and
prioritize
industries
(
or
parts
of
industries)
for
guideline
revision
and
development.
Those
four
factors
are
1)
human
health
and
environmental
impacts;
2)
technology
innovation
and
process
changes;
3)
cost,
performance,
and
affordability;
and
4)
implementation
and
efficiency
considerations.

A
major
component
of
the
information
collection
effort
under
Factor
4
is
consulting
with
permit
writers
and
pretreatment
coordinators
of
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
program
who
use
effluent
guidelines
in
the
development
of
permits.
During
the
spring
and
summer
of
2003,
EAD
talked
with
a
number
of
permit
writers,
pretreatment
coordinators,
and
others
involved
in
the
permitting
process
to
find
out
what
problems
they
are
encountering.

We
also
attempted
to
gather
available
information
that
is
available
about
facilities
which
may
be
employing
technologies
that
may
have
potential
for
reducing
environmental
pollution
below
current
levels.
These
would
include
technologies
that
are
in
use
by
dischargers
into
impaired
waterways
that
are
complying
with
stringent
water­
quality­
based
permit
limits
or
by
dischargers
to
waters
that
are
small
or
subject
to
special
federal
or
state
protections.
Page
2
of
40
How
the
Information
Will
be
Used
The
information
collected
will
be
reviewed
by
EAD
during
the
screening
level
review
described
in
the
draft
Strategy.
EAD
will
consider
it
along
with
information
being
developed,
for
example,
under
Factor
1
on
the
relative
risks
posed
by
the
current
estimated
loadings
by
different
discharging
categories.
The
screening
level
review
phase
will
be
followed
by
a
ranking
process,
in
which
EAD
will
sort
categories
by
relative
level
of
concern
using
all
the
information
gathered
during
the
screening
level
review.
EAD
will
then
present
a
subset
of
categories
recommended
for
a
detailed
investigation.
This
subset
will
be
reviewed
by
the
Agency
workgroup
and
by
management,
and
all
or
part
of
this
subset
will
enter
the
detailed
investigation
phase.
EAD
will
use
the
detailed
investigation
phase
to
evaluate
the
need
for
guideline
development
or
revision
for
those
categories
in
the
subset.
This
will
include
follow
up
discussions
with
respondents
to
obtain
more
details
on
information
they
provided
during
the
screening
level
phase.

Questions
We
Asked
EPA
Experts
to
Consider:

1)
Implementation,
Compliance,
Enforcement
Issues:
Are
there
existing
effluent
guidelines
that
need
to
be
revised
or
developed
because
 
°
the
current
guidelines
no
longer
reflects
the
performance
of
the
best
available
technologies?
°
there
are
problems
in
implementation,
compliance,
or
enforcement?
°
changes
in
industry
have
made
certain
provisions
or
requirements
obsolete?
°
discharges
from
the
industry
are
generating
problems?
°
problems
are
due
to
pollutants
for
which
no
water
quality
criteria/
standards
exist?

2)
Technology:
°
Are
there
facilities
which
may
be
employing
technologies
that
have
potential
for
more
widespread
application
across
an
industry
sector
to
reduce
wastewater
pollutant
discharges
below
current
levels?
°
How
should
technological
innovation
be
encouraged
and
rewarded?
°
What
drives
innovation
in
industries?
°
How
should
voluntary
loading
reductions
be
taken
into
account
and
how
do
you
verify
this,
especially
with
changing
production
by
industry?
°
What
role
should
market
incentives,
including
pollutant
trading,
have?

3)
Sources
of
Information:
°
What
additional
sources
of
information
should
we
consider?
°
How
can
we
best
obtain
information
for
the
more
detailed
analysis
of
industries
early
in
the
process?
°
How
can
we
obtain
the
information
necessary
to
fairly
evaluate
assertions
by
both
EPA
experts
and
our
stakeholders?
Page
3
of
40
Most
of
these
questions
were
included
in
a
questionnaire,
which
we
sent
to
those
who
expressed
willingness
to
supply
written
information
in
response
to
our
questions.
The
blank
questionnaire
is
attached
here
(
Attachment
1),
along
with
the
completed
questionnaires
we
received.
In
addition,
these
questions
were
posed
verbally
to
attendees
at
the
monthly
conference
calls
held
by
the
Office
of
Wastewater
Management
with
permit
writers
and
pretreatment
coordinators.

Results:

The
results
of
this
information
gathering
effort
are
summarized
by
EPA
Region.
These
recommendations
are
also
reflected
in
the
Factor
4
Screening
Level
Analysis
Report.

Region
1
Austine
Frawley
responded
by
email,
and
identified
one
discharging
category
not
currently
covered
by
an
effluent
guideline.
°
Aquaculture
(
concentrated
aquatic
feeding
operations):
Nominated
due
to
water
quality
issues.
She
recommended
EAD
contact
Ted
Lavery,
EPA's
NPDES
coordinator
in
the
Maine
State
unit
at
617/
918­
1683
and
Greg
Wood
with
the
Maine
Department
of
Environmental
Protection,
207/
287­
3901
for
more
information
on
this
industry
Region
2
We
obtained
no
feedback
from
this
Region
during
this
effort.
EPA
has
received
information
from
them
during
previous
efforts,
and
that
input
is
reflected
in
the
Factor
4
report.

Region
3
Brian
Trulear
and
John
Lovell
responded
by
sending
in
two
questionnaires
(
Attachments
2
and
3),
one
for
the
potassium
manufacturing
subpart
of
the
inorganic
chemicals
rule
and
one
for
metal
finishing.
He
recommends
contacting
Pennsylvania
for
more
information.
°
Inorganic
Chemicals,
Potassium
Manufacturing
Subcategory
(
40
CFR
415,
subpart
K):
Nominated
in
response
to
an
issue
over
the
definition
of
process
wastewater.
°
Metal
Finishing
(
40
CFR
433):
Nominated
due
to
applicability
issues.
°
Pulp,
Paper,
and
Paperboard
(
40
CFR
430):
Region
3
also
recommends
a
measurable
limit
for
color
in
the
pulp
and
paper
cluster
rule.

Region
4
EAD
received
information
from
Marshall
Hyatt,
who
responded
for
Scott
Gordon
and
Roosevelt
Childress.
They
polled
their
states
and
had
the
following
responses
from
Georgia
and
Alabama.
They
recommend
contacting
Melinda
Vickers
in
South
Carolina,
803/
898­
4186.
Rufus
Torrence
provided
recommendations
from
Arkansas
and
Robert
Heilman
reported
in
from
Florida.
Page
4
of
40
°
Pulp,
Paper,
and
Paperboard
(
40
CFR
430):
Georgia
recommends
a
limit
for
color
to
be
included.
°
Textile
Mills
(
40
CFR
410):
Georgia
recommends
a
limit
for
color
be
added;
Alabama
agreed,
adding
a
recommendation
for
a
limit
for
copper.
°
Meat
Products,
Poultry
Processing
Subcategory
(
40
CFR
432):
Alabama
suggests
addressing
this
subcategory
as
a
result
of
BOD
(
biochemical
oxygen
demand),
ammonia,
and
TSS
(
total
suspended
solids)
discharges.
°
Steam
Electric
Power
Generation
(
40
CFR
423):
Alabama
identifies
this
industry
due
to
concerns
for
temperature
at
the
cooling
outfalls,
and
for
mercury
and
arsenic
at
ash
pond
outfalls.
Florida
asserts
that
non­
detects
levels
for
priority
pollutants
in
the
1970'
s
are
quite
different
from
that
possible
today;
also
notes
that
there
are
different
additives
in
use
now.
°
Metal
Molding
and
Casting
(
Foundries)
(
40
CFR
464):
Alabama
states
that
cyanide
can
be
an
issue
if
in
the
quenching
process
molten
slag
is
allowed
to
come
into
contact
with
the
quench
water
and
recommended
EPA
consider
revising
the
guidelines
to
address
this.
Arkansas
reported
difficulties
implementing
the
guidelines
with
die
casters
especially
with
phenols,
given
the
formulas
and
using
the
model
discharge
rate.
Recommends
that
limits
on
Fundamentally
Different
Factors
be
eliminated.
Notes
that
P2
facilities
are
now
very
different
from
what
they
were
when
the
guidelines
were
promulgated.
°
Canned
and
Preserved
Seafood
(
40
CFR
408)
Alabama
suggests
revising
this
subcategory
due
to
concerns
for
discharges
of
BOD
(
biochemical
oxygen
demand)
and
pathogens,
specifically
fecal
coliform.
°
Groundwater
remediation
­
Alabama
also
suggests
effluent
guidelines
be
developed
for
this
industry,
due
to
concerns
about
discharges
of
PCBs
(
polychlorinated
biphenyls)
and
perchlorate.

Region
5
Matt
Gluckman
and
Carol
Staniec
responded
for
the
Region.
Matt
completed
three
questionnaires
(
Attachments
4,
5,
and
6)
concerning
one
category
for
which
effluent
guidelines
should
be
developed
(
dental
facilities),
and
two
existing
effluent
guidelines
which
should
be
revised
(
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers;
and
Metal
Finishing).
Carol
and
Grace
Scott
in
Michigan
also
provided
recommendations.
°
Dental
facilities:
Recommends
developing
effluent
guidelines
due
to
its
contributions
of
mercury
from
dental
amalgam
to
POTW
systems.
Based
on
the
toxicity
and
persistence
of
mercury,
it
appears
that
this
sector
is
at
least
contributing
to
pass­
through
of
this
pollutant,
and
thus
to
fish
consumption
advisories
around
the
U.
S.
Michigan
agrees
that
dentists
are
a
problem
and
extensive
attempts
to
encourage
voluntary
actions
have
not
worked.
°
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
40
CFR
414):
Recommends
revising
existing
guidelines
due
to
difficulties
in
getting
POTWs
and
OCPSF
facilities
to
correctly
calculate
flow
based
mass
limits,
and
to
provide
necessary
data
to
determine
compliance
with
the
standards.
In
addition,
deficiencies
in
permits
and
control
mechanisms
has
in
the
Page
5
of
40
past
hindered
enforcement
actions
against
these
facilities.

°
Metal
Finishing
(
40
CFR
433):
Recommends
revising
existing
guidelines
due
to
challenges
arising
out
of
applicability
requirements
and
structure
of
the
electroplating
standards
and
the
metal
finishing
standards,
specifically
when
determining
whether
a
facility
performs
a
core
activity
and
is
thus
categorical,
or
just
an
ancillary
activity.
°
Pulp,
Paper,
and
Paperboard
(
40
CFR
430):
Recommends
continuing
with
the
Phase
II
cluster
rule,
due
to
the
quantity
of
pollutants
discharged
by
the
chemical
mechanical
and
fiber
deinking
subcategories..
°
Metal
Molding
and
Casting
(
Foundries)
(
40
CFR
464):
Michigan
reports
that
small
aluminum
die
casters
have
problems
meeting
the
limits
they
receive
when
you
follow
the
formulas
provided.
°
Hospitals
(
40
CFR
460):
Michigan
identifies
a
need
to
revise
these
guidelines
because
hospitals
discharge
chemicals
like
mercury
and
silver,
and
do
so
without
pretreatment
standards
or
even
controls.
Based
on
the
toxicity
and
persistence
of
mercury,
it
appears
that
this
sector
may
be
contributing
to
pass­
through
of
this
pollutant,
and
thus
to
fish
consumption
advisories
around
the
U.
S.
°
Steam
Electric
Power
Generation
(
40
CFR
423):
Michigan
noted
that
the
footnotes
in
these
guidelines
contain
errors.

Region
6
Scott
Wilson
responded
for
the
Region.
He
did
not
fill
out
the
questionnaire,
but
provided
the
following
information.
An
additional
contact
is
Brian
Mueller
in
the
Regional
Office.
°
Petroleum
Refining
(
40
CFR
419):
Recommends
revising
the
effluent
guidelines
for
this
category
since
they
are
very
outdated
relative
to
the
industry
and
should
be
a
high
priority.
Many
refineries
have
two
to
four
times
the
throughput
that
was
used
when
the
permits
were
first
issued
a
number
of
years
ago
and
can
easily
meet
the
limits.
The
technologies
seem
to
have
changed
significantly
since
those
guidelines
were
issued.
°
Steam
Electric
Power
Generation
(
40
CFR
423):
Recommends
revising
the
effluent
guidelines
for
this
category
since
they
are
very
old
and
probably
do
not
represent
the
industry
well.
Most
plants
that
have
been
built
in
the
last
decade
are
combined
cycle
plants,
which
the
guidelines
do
not
reflect
well.
There
is
some
national
disagreement
as
to
whether
the
steam
electric
guidelines
even
cover
combined
cycle
plants.
°
Fertilizer
Manufacturing
(
40
CFR
418):
Recommends
revising
the
effluent
guidelines
for
this
category
since
they
are
very
old
and
do
not
seem
to
be
at
all
stringent.

Region
7
Paul
Marshall
responded
for
the
Region.
He
provided
a
questionnaire
(
Attachment
7)
for
Metal
Molding
and
Casting
focusing
on
aluminum
casting
facilities.
In
response
to
the
question
about
pollutants
without
water
quality
standards
or
criteria,
he
said
it
would
be
unlikely
that
such
pollutants
would
be
a
problem
because
people
don't
sample
for
them.
Because
of
that,
these
pollutants
would
not
appear
to
be
a
problem.
Page
6
of
40
°
Metal
Molding
and
Casting
(
Foundries)
Aluminum
Casting
subcategory
(
40
CFR
464):
Recommends
revising
the
effluent
guidelines
for
this
category
since
they
are
difficult
to
implement,
specifically
the
aluminum
casting
subcategory.
The
method
for
determining
allowances
and
discharge
limits
has
caused
problems,
and
applicability
issues
also
arise.

Region
8
Talked
to
Deborah
Thomas,
who
reiterated
that
Region's
concerns
about
discharges
from
growing
coal
bed
methane
development
activities.
°
Oil
and
Gas
Extraction,
Coal
Bed
Methane
Development
Subcategory
(
40
CFR
435)
:
Recommends
developing
effluent
guidelines
for
this
subcategory.
Problems
encountered
include
discharges
of
pollutants
without
WQ
standards,
as
well
as
problems
identified
in
previous
efforts
by
Bruce
Kent.
Concerns
include
depletion
of
aquifers,
erosion,
sedimentation,
exceedances
of
barium
concentrations,
salinization
of
land,
adverse
impact
on
farmers
through
plugging
of
soils
which
decreases
infiltration,
and
the
loss
of
the
water's
return
to
groundwater.

Region
9
Terry
Oda,
John
Hillenbrand,
and
John
Tinger
sent
in
a
questionnaire
(
Attachment
8)
for
Hard
Rock
Mining
(
Ore
Mining
and
Dressing).
Keith
Silva
provided
input
over
the
phone,
referring
to
recommendations
provided
in
the
past
(
Attachment
9).
He
recommended
that
we
should
concentrate
on
those
issues
we
know
are
of
concern
to
the
administration
 
e.
g.
persistent
bioaccumulative
toxics
(
PBTs)
and
emerging
pollutants.
He
also
suggested
two
contacts
in
California:
Jim
Maughan
at
916/
657­
0450
and
Sue
Ma
at
510/
622­
2386.
°
Ore
Mining
and
Dressing
(
Hard
Rock
Mining)
(
40
CFR
440)
Recommends
revising
these
guidelines
based
on
concerns
for
runoff
from
waste
rock
and
overburden
piles.
They
also
have
a
table
of
data
on
Total
copper
vs.
TSS
in
mine
runoff
at
Arizona
copper
mines
that
illustrates
their
concerns.
°
Metal
Products
and
Machinery
(
40
CFR
438):
Recommends
addressing
missile
and
rocket
producers
to
address
recent
(
ground
water)
problems
with
perchlorate.
°
Electrical
and
Electronic
Components
(
40
CFR
469):
Recommend
revising
the
semiconductor
manufacturing
subcategory
based
on
major
changes
in
the
industry.
The
industry
is
moving
from
aluminum
to
copper
to
build
internal
components.
It
is
also
using
new
process
operations
not
considered
when
the
guidelines
were
developed.
°
Dental
facilities:
Asserts
that
dental
offices
need
a
nationally
consistent
categorical
standard,
since
voluntary
efforts
will
yield
highly
inconsistent
results.
°
Stormwater
Runoff:
Recommends
developing
effluent
guidelines
to
define
Maximum
Extent
Practical
(
MEP)
determinations
for
BPJs
(
Best
Professional
Judgement)
for
municipal
stormwater
controls.
Page
7
of
40
Region
10
 
Seattle
Sharon
Wilson
provided
a
recommendation
from
the
Region.
Dave
Knight
provided
input
from
Washington.
Additional
comments
from
Melodie
Selby
in
Washington
were
forwarded
by
Kelly
Huynh
(
Attachment
10).
°
Electrical
and
Electronic
Components
(
40
CFR
469):
Recommends
revising
these
guidelines
because
this
industry
has
changed
so
much
since
the
rule
was
promulgated
in
1983.
Washington
agreed
that
the
rule
does
not
suit
the
industry
today.
°
Timber
Products
Processing
(
40
CFR
429):
Suggests
revising
ELGs
to
include
effluent
limits
for
stormwater
discharges
from
associated
log
yards.
°
Fruits
and
Vegetable
Processing
(
40
CFR
407):
Asserts
that
these
ELGs
badly
need
updating
for
both
direct
and
indirect
dischargers.
Direct
dischargers
often
discharge
much
less
than
the
current
technology­
based
limits.
Since
there
are
no
WQ
criteria
for
BOD
nor
an
equitable
way
to
determine
the
farfield
impacts
of
BOD
(
short
of
a
TMDL),
revising
these
ELGs
might
help
address
the
dissolved
oxygen
problems
in
our
waterways
over
the
long
term
°
Petroleum
Refining
(
40
CFR
419):
Notes
that
the
ELGs
are
20
years
old
and
the
subject
of
a
lot
of
controversy
and
litigation
over
the
past
decade.
The
refineries
are
performing
well
below
limits
derived
from
the
guidelines,
and
there
is
no
acceptable
way
to
address
this
gap.
Suggests
that
revising
the
ELGs
to
support
lower
limits
would
be
very
helpful.
°
Canned
and
Preserved
Seafood
(
40
CFR
408):
Asserts
that
the
ELGs
are
out
of
date
and
that
an
update
of
the
ELG's
for
all
categories
of
fish
processing
would
greatly
benefit
them.
Page
8
of
40
Attachment
1
Issue/
Industry
Reporting
Form
Background
Information
°
The
Clean
Water
Act
requires
EPA
to
develop
and
publish
a
plan
every
two
years
showing
which
effluent
limitations
guidelines
the
Agency
will
revise
and
which
new
industries
it
will
regulate.
For
most
of
the
last
10
years,
selections
of
industries
for
guidelines
and
their
schedules
were
substantially
influenced
by
court­
ordered
consent
decree.
With
the
consent
decree
ending,
the
Engineering
and
Analysis
Division
(
EAD)
in
the
Office
of
Science
and
Technology
is
currently
developing
and
implementing
a
planning
process
to
determine
future
work
on
effluent
limitations
guidelines
[
the
304(
m)
planning
process].

°
For
more
details
about
the
planning
process
see
http://
www.
epa.
gov/
guide/
strategy.

°
This
will
be
an
ongoing
planning
process
with
multiple
goals,
including:
(
1)
identify
existing
effluent
limitations
guidelines
(
or
specific
aspects
of
guidelines)
that
need
to
be
revisited
(
for
example
because
the
current
guideline
no
longer
reflects
the
performance
of
the
best
available
technologies,
or
because
there
are
problems
in
implementation,
compliance,
or
enforcement;
because
changes
in
industry
have
made
certain
provisions
or
requirements
obsolete,
etc.)
and
(
2)
identify
industries
(
or
specific
parts
of
industries)
that
have
not
been
previously
addressed
that
should
be
considered
for
effluent
limitations
guideline
development.

°
It
is
also
anticipated
that
some
of
the
issues
identified
and
information
developed
through
this
process
will
point
to
the
use
of
other
tools,
in
addition
to
effluent
limitations
guidelines.

°
We
are
pursuing
many
avenues
of
investigation
to
determine
how
to
identify
and
prioritize
industries
(
or
parts
of
industries)
for
guideline
revision
and
development.
However,
in
all
of
our
many
public
stakeholder
meetings,
a
consistent
suggestion
is
that
we
start
by
consulting
with
the
people
in
the
field
who
do
the
work
 
to
find
out
what
they
think
the
problems
are.

°
We
are
also
interested
in
any
information
that
you
have
about
facilities
which
may
be
employing
technologies
that
may
have
potential
for
reducing
environmental
pollution
below
current
levels.
These
might
be
technologies
that
are
in
use
by
dischargers
into
impaired
waterways
that
are
complying
with
stringent
water­
quality­
based
permit
limits
or
by
dischargers
to
waters
that
are
small
or
subject
to
special
federal
or
state
protections,
etc.
In
this
case,
it
is
not
necessary
for
you
to
know
details
about
the
technologies,
only
just
that
they
are
apparently
being
used
and
where,
so
that
we
can
obtain
additional
information
from
the
users.
How
the
Information
Will
be
Used
Page
9
of
40
°
The
information
collected
will
first
be
reviewed
by
the
304(
m)
team
in
EAD.
It
will
be
considered
together
with
other
information
being
developed,
for
example,
on
the
relative
risks
posed
by
the
current
estimated
loadings
for
different
industries.
Recommendations
on
which
industries
to
consider
for
guideline
development
or
revision
will
then
be
provided
to
an
Agency
workgroup
for
their
consideration
and
input.
Finally,
the
information
and
recommendations
will
be
presented
to
upper
management
in
the
Office
of
Water
and
the
Agency
for
decision.
The
Agency
will
then
publish
and
take
comment
on
a
proposed
plan.
The
statute
requires
that
we
develop
a
final
plan
by
February
4,
2004
and
every
two
years
thereafter.

°
We
have
developed
a
"
formal"
questionnaire
and
a
process
for
continuing
input
because
we
believe
that
wide­
spread
and
on­
going
input
from
you
will
benefit
not
only
the
effluent
limitations
guideline
planning
process,
but
may
also
point
to
other
areas
in
which
work
could
be
done.
These
may
include
providing
technical
guidance
and
working
collaboratively
with
other
Divisions
and
Offices
to
find
the
most
appropriate
solutions
to
issues,
given
all
the
tools
provided
by
the
CWA.

°
We
would
like
to
thank­
you
in
advance
for
your
participation
and
for
any
suggestions
you
may
have
on
how
best
to
gather
and
use
this
information
in
the
future.

Issue/
Industry
Nomination
Form
The
Engineering
and
Analysis
Division
in
the
Office
of
Science
and
Technology
is
currently
developing
a
planning
process
to
determine
future
work
on
effluent
limitations
guidelines.
Among
the
goals
of
this
process
are:
(
1)
identify
existing
effluent
limitations
guidelines
(
or
specific
aspects
of
guidelines)
that
need
to
be
revisited
(
for
example
because
the
current
guideline
no
longer
reflects
the
performance
of
the
best
available
technologies,
or
because
there
are
problems
in
implementation,
compliance,
or
enforcement;
because
changes
in
industry
have
made
certain
provisions
or
requirements
obsolete,
etc.)
and
(
2)
identify
industries
(
or
specific
parts
of
industries)
that
have
not
been
previously
addressed
that
should
be
considered
for
effluent
limitations
guideline
development.
This
information
will
be
used
in
the
planning
process
to
help
in
the
selection
of
industries
for
guideline
revision
or
guideline
development.

We
are
also
interested
in
any
information
that
you
have
about
facilities
which
may
be
employing
technologies
that
may
have
potential
for
reducing
environmental
pollution
below
current
levels.
These
might
be
technologies
that
are
in
use
by
dischargers
into
impaired
waterways
that
are
complying
with
stringent
water­
quality­
based
permit
limits
or
by
dischargers
to
waters
that
are
small
or
subject
to
special
federal
or
state
protections,
etc.
In
this
case,
it
is
not
necessary
for
you
to
know
details
about
the
technologies,
only
just
that
they
are
apparently
being
used
and
where,
so
that
we
can
obtain
additional
information
from
the
users.

Please
use
separate
forms
if
you
would
like
to
report
information/
suggestions
on
more
than
Page
10
of
40
one
industry
or
technology.

1.
Date:

2.
Name:

3.
Contact
Information
4.
Office/
Division/
Branch/
Region:

Issues/
Industries
5.
Identification
of
Industry
or
Issue
Please
provide
a
brief
and
very
direct
statement
identifying
existing
effluent
limitations
guidelines
(
or
specific
aspects
of
guidelines)
that
need
to
be
revisited
(
for
example,
because
the
current
guideline
no
longer
reflects
the
performance
of
the
best
available
technologies,
or
because
there
are
problems
in
implementation,
compliance,
or
enforcement;
because
changes
in
industry
have
made
certain
provisions
or
requirements
obsolete,
etc.)
and
industries
(
or
specific
parts
of
industries)
that
have
not
been
previously
addressed
that
should
be
considered
for
effluent
limitations
guideline
development.
Please
explain
why
you
think
this
action
should
be
taken.
As
you
write
this
brief
description
and
answer
other
questions
on
this
form,
please
bear
in
mind
that,
in
general,
those
issues/
industries
that
are
likely
to
be
of
most
concern
will
possess
several
of
the
following
characteristics:
°
the
problem
is
recurring
and
widespread
among
facilities
in
the
industry
(
can
it
be
quantified
or
characterized?)
°
there
is
a
resulting
environmental
or
human
health
problem
(
can
it
be
quantified
or
characterized?)
°
there
has
been
a
general
change
in
industry
practice
that
is
associated
with
the
problem
(
this
might
be
especially
the
case
for
a
guideline
that
needs
to
be
revisited)
°
without
attention
through
the
effluent
limitations
guideline
program
the
issue
may
otherwise
go
unaddressed
6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
Page
11
of
40
8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
Please
provide
any
information
that
you
have
about
facilities
which
may
be
employing
technologies
that
have
potential
for
more
widespread
application
across
an
industry
sector
to
reduce
wastewater
pollutant
discharges
below
current
levels.
Describe
the
technologies
used
by
these
facilities
and
characterize
(
quantifying,
if
possible)
how
pollutant
discharges
would
be
improved.

13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).

14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.
Page
12
of
40
16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
13
of
40
Attachment
2
Issue/
Industry
Nomination
Form
Potassium
Metal
Subcategory
of
Inorganic
Chemicals
Manufacturing
1.
Date:
June
5,
2003
2.
Name:
John
Lovell
3.
Contact
Information
e­
mail
address:
lovell.
john@
epa.
gov
phone:
215­
814­
5790
fax:
215­
814­
2318
4.
Office/
Division/
Branch/
Region:
Pretreatment
Team
Office
of
Municipal
Assistance
Water
Permits
Division
Region
III
Issues/
Industries
5.
Identification
of
Industry
or
Issue
The
PSNS
for
the
potassium
metal
subcategory
of
the
inorganic
chemicals
manufacturing
standards
(
40
CFR
415,
subpart
K)
require
no
discharge
of
process
wastewater
pollutants.
Based
on
the
development
document
for
these
standards,
the
no
discharge
requirement
was
established
because
the
one
facility
in
the
category
was
not
discharging
process
wastewater.
We
have
received
a
baseline
monitoring
report
from
Mine
Safety
Appliances
in
Evans
City,
PA
which
indicates
that
they
have
constructed
a
new
potassium
manufacturing
operation
which
essentially
duplicates
their
existing
operation
and
is
therefore
a
new
source.
The
facility
discharges
wastewater
from
scrubber
blowdown,
process
area
floor
washing,
process
equipment
cleaning,
salt
byproduct
storage
runoff,
safety
shower/
eyewash,
and
sanitary.
The
facility
claims
that
it
is
the
only
potassium
manufacturing
facility
in
the
country,
and
was
the
facility
that
was
studied
during
the
effluent
guideline
development.
The
discharges
from
the
new
operation
are
essentially
the
same
as
the
discharges
from
the
existing
operation,
except
as
a
new
source,
would
be
subject
to
the
no
discharge
requirement.
The
facility
claims
that
it
was
discharging
these
wastestreams
from
its
existing
operations
when
the
guideline
was
developed
and
EPA
found
that
there
was
no
process
wastewater
discharges
from
the
studied
facility,
and
therefore
these
discharges
cannot
be
process
wastewater
(
although
many
of
the
wastestreams
clearly
fall
within
the
process
wastewater
definition).
They
also
claim
that
for
safety
reasons,
they
cannot
convert
the
operations
to
dry
operations
or
reuse
the
wastewater
in
their
operations
(
although
they
agree
that
they
can
cover
the
material
storage
area
to
prevent
runoff),
and
therefore
the
guidelines
are
impossible
to
meet
if
Page
14
of
40
the
discharges
are
classified
as
process
wastewater.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
We
know
of
no
other
potassium
manufacturers,
and
the
facility
has
claimed
it
is
the
only
one
in
the
country.

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
The
standard
needs
to
be
reevaluated
to
determine
if
the
no
discharge
requirement
is
reasonable.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
PADEP
previously
issued
an
NPDES
permit
to
the
facility
without
applying
the
effluent
guideline
because
it
found
that
the
discharge
did
not
constitute
process
wastewater
because
EPA
had
found
that
the
facility
did
not
discharge
process
wastewater.
The
facility
has
since
connected
to
a
POTW,
thus
prompting
the
applicability
of
the
PSNS
standards.

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?
None
anticipated.

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes.

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
No
one
outside
of
the
company.

Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
Page
15
of
40
None
known.
Facility
in
question
uses
equalization,
pH
adjustment/
chemical
addition,
and
clarification.

13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
Baseline
Monitoring
Report
and
effluent
monitoring
reports
available
at
the
Regional
office.

14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
Contact
listed
in
BMR:

Mark
B.
Finch
Manager,
Environmental
and
Site
Services
Mine
Safety
Appliances
1420
Mars­
Evans
City
Road
Evans
City,
PA
16033
Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.

16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
16
of
40
Attachment
3
Issue/
Industry
Nomination
Form
Metal
Finishing
1.
Date:
June
5,
2003
2.
Name:
John
Lovell
3.
Contact
Information
e­
mail
address:
lovell.
john@
epa.
gov
phone:
215­
814­
5790
fax:
215­
814­
2318
4.
Office/
Division/
Branch/
Region:
Pretreatment
Team
Office
of
Municipal
Assistance
Water
Protection
Division
Region
III
Issues/
Industries
5.
Identification
of
Industry
or
Issue
Over
the
years
,
there
have
been
many
questions
regarding
the
applicability
of
the
Metal
Finishing
regulations
which
have
not
been
resolved.
These
issues
include
distinctions
between
phosphate
coating
and
cleaning,
and
between
acid
etching
and
acid
cleaning.
In
addition,
the
distinction
between
the
applicability
of
the
metal
finishing
regulations
and
other
regulations
such
as
iron
&
steel
manufacturing
(
steel
finishing
without
steel
manufacturing)
or
nonferrous
metals
manufacturing
(
when
tube/
rod/
sheet
is
purchased
and
finished
including
some
forming
operations).
Since
the
pretreatment
regulations
are
self­
implementing
(
the
regulation
is
enforced
rather
than
an
NPDES
permit),
it
is
important
that
the
applicability
of
the
standards
is
clear.
There
have
been
many
questions
and
disagreements
between
the
Regions
on
the
applicability
of
the
metal
finishing
standards
which
have
been
raised
to
HQ
and
have
not
been
resolved.
Since
there
are
thousands
of
facilities
covered
by
the
metal
finishing
standards,
it
is
important
that
these
issues
be
resolved.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
Thousands
of
facilities
all
over
the
country.
This
is
the
single
largest
category
of
industrial
users
in
the
pretreatment
program.
Page
17
of
40
7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
May
be
possible
to
compile
a
list
of
issues
and
issue
guidance
or
clarifications
rather
than
restudy
the
industry.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
To
the
best
of
my
knowledge,
all
of
the
Regions
have
dealt
with
some
or
all
of
these
issues,
and
the
guidelines
are
being
applied
inconsistently.
The
issues
have
been
raised
and
discussed
repeatedly
during
the
monthly
pretreatment
conference
calls,
with
no
final
resolution.

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?
It
would
seem
that
this
would
be
of
great
interest
to
many
Regions,
States,
and
POTWs.

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes.

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).

14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
Page
18
of
40
Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.

16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
19
of
40
Attachment
4
Issue/
Industry
Nomination
Form
Dental
Facilities
1.
Date:
6/
2/
03
2.
Name:
Matt
Gluckman
Pretreatment
Program
Mgr
3.
Contact
Information
e­
mail
address:
gluckman.
matthew@
epa.
gov
phone:
312/
886­
6089
fax:
312/
886­
7804
4.
Office/
Division/
Branch/
Region:
U.
S.
EPA
Region
5,
Water
Division,
NPDES
Programs
Branch
Issues/
Industries
5.
Identification
of
Industry
or
Issue
Dental
facilities.
Development
of
effluent
guidelines
and
standards
should
be
considered
for
this
sector,
due
to
its
contributions
of
mercury
from
dental
amalgam
to
POTW
systems.
Studies
conducted
by
POTWs
have
identified
dental
facilities
as
the
largest
commercial
contributors
of
mercury
to
their
systems.
Based
on
the
toxicity
and
persistence
of
mercury,
it
appears
that
this
sector
is
at
least
contributing
to
pass
through
of
this
pollutant,
and
thus
to
fish
consumption
advisories
around
the
U.
S.

For
several
years,
EPA
has
worked
with
other
regulators
to
promote
sound
management
practices
regarding
management
and
disposal
of
dental
amalgam.
With
the
adoption
by
our
states
of
more
stringent
mercury
water
quality
criteria
to
implement
the
Great
Lakes
Water
Quality
Guidance
(
typically
1.3ng/
l),
coupled
with
EPA's
adoption
of
more
sensitive
analytical
methods
which
can
detect
mercury
at
0.2ng/
l,
control
of
all
sources
of
mercury
discharges
to
Publicly
Owned
Treatment
Works
(
POTW)
has
taken
on
additional
importance
in
Region
5
states.
Upon
reissuance
of
their
NPDES
permits,
many
POTWs
will
be
unable
to
meet
their
new
water
quality
based
effluent
limits,
and
will
need
to
obtain
variances
to
address
this
situation.
As
a
condition
for
a
variance,
POTWs
will
be
required
to
develop
Pollutant
Minimization
Programs
(
PMP),
which
will
involve
identifying
mercury
sources,
developing
strategies
to
minimize
or
eliminate
mercury
from
these
sources,
monitoring
and
reporting.
At
this
point,
all
PMPs
would
be
expected
to
address
contributions
from
dental
facilities,
hospitals,
schools
and
laboratories,
along
with
other
sectors
identified
as
contributors
of
local
concern.
Page
20
of
40
Some
states
and
POTWs
have
promoted
voluntary
adoption
of
best
management
practices
by
dentists,
but
in
the
last
couple
of
years,
focus
has
been
shifting
to
the
use
of
amalgam
separators,
which
recent
studies
indicate
can
remove
95­
99%
of
mercury
that
would
have
otherwise
been
discharged
to
sewers,
and
at
a
reasonable
cost
(
from
$
160­
3500
uninstalled,
plus
300­
500
O&
M/
yr).
Other
studies
have
indicated
that
widespread
use
of
separators
in
a
POTW
system
can
substantially
reduce
mercury
loadings
to
the
POTW's
influent
and
sludge,
and
their
use
is
beginning
to
be
required
in
certain
cities
and
states.
Together
with
our
states,
we
are
currently
considering
various
approaches
for
promoting
use
of
separators
or
comparable
technologies.
Effluent
guidelines
for
this
sector
could
potentially
simplify
POTW
efforts
to
implement
PMPs,
minimize
the
need
to
develop
extensive
control
strategies
for
more
diffuse
sources
of
mercury,
and
result
in
POTW
compliance
with
water
quality
based
effluent
limits.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
The
ADA
estimates
about
150,000
dental
clinics
in
the
U.
S..
A
large
percentage
of
these
facilities
either
remove
old
fillings
and/
or
replace
new
restorations,
and
while
other
restoratives
are
being
used,
mercury­
silver
amalgams
are
still
commonly
used.
All
or
virtually
all
of
these
facilities
are
believed
to
discharge
to
POTWs.

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
BAT
and
pretreatment
standards
could
be
developed
based
on
a
set
of
identified
best
management
practices
for
dentists,
including
the
use
of
ISO
approved
amalgam
separation
technologies.

Currently,
all
Industrial
Users
that
are
subject
to
categorical
standards
are
automatically
considered
significant
IUs,
and
would
have
to
be
permitted,
inspected,
monitored,
etc..
There
would
need
to
be
ways
to
structure
a
regulation
for
this
sector
that
recognizes
the
large
number
of
small
facilities,
so
as
not
to
overburden
POTW
and
other
Control
Authorities.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
See
discussion
above.
Initially,
dentists
were
encouraged
to
follow
voluntary
BMPs.
With
the
advent
of
amalgam
separators,
certain
POTWs
facing
tight
water
quality­
based
effluent
limits
are
beginning
to
require
installation
of
separators
and
use
of
BMPs.
More
(
including
many
of
the
POTWs
in
the
Great
Lakes
Basin)
will
need
to
consider
such
requirements
in
the
next
several
years.
In
some
states,
such
as
Minnesota
and
Wisconsin,
the
States
are
working
with
state
dental
associations
to
support
the
use
of
separators
as
a
standard
practice
for
the
industry.
Based
on
a
pilot
effort
in
Minnesota
and
early
results
from
a
program
in
Toronto,
Ontario,
widespread
Page
21
of
40
adoption
of
this
technology
can
lead
to
significant
reductions
in
influent
and
sludge
levels
of
mercury.

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?

Several
of
our
States
have
been
active
in
this
area,
in
conjunction
with
their
state
dental
associations
and
certain
POTWs­
Wisconsin,
Michigan,
Minnesota,
Milwaukee
Metropolitan
Sewerage
District,
Metropolitan
Council
Environmental
Services,
Western
Lake
Superior
Sanitary
District,
Northeast
Ohio
Regional
Sanitary
District,
Detroit
Water
and
Sewerage
District.
The
Naval
Institute
for
Biological
and
Dental
Research
has
also
been
at
the
forefront
of
testing
and
implementation
of
separator
technologies.

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes.

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
Randy
Case,
Wisconsin
Mercury
Coordinator,
WDNR
608/
267­
7639
Grace
Scott,
Pretreatment
Coordinator,
Michigan
DEQ
517/
335­
4107
Tim
Tuominen,
Western
Lake
Superior
Sanitary
District,
Duluth
MN,
218/
722­
3336
ext.
324
Peter
Berglund,
Metropolitan
Council
Environmental
Services,
St.
Paul,
MN,
612/
772­
7001
Tom
Nowicki,
Milwaukee
Metropolitan
Sewerage
District,
WI,
414/
272­
5100
Keith
Linn,
NEORSD,
Cleveland,
OH,
216/
641­
6000,
ext.
2202
Dr.
Mark
Stone,
Naval
Institute
for
Biological
and
Dental
Research
Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
Naval
Institute
for
Biological
and
Dental
Research,
Great
Lakes,
IL
Facilities
in
Duluth,
MN
and
St.
Paul/
Minneapolis,
MN
13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
ADA
has
done
a
comparison
study
of
amalgam
separators
with
respect
to
ISO
Standards,
and
all
Page
22
of
40
units
tested
achieved
>
95%
removal.
JADA
Vol.
133,
May
2002
14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
Dr.
Mark
Stone
(
see
above)

Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.

16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
23
of
40
Attachment
5
Issue/
Industry
Nomination
Form
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
OCPSF)

1.
Date:
6/
2/
03
2.
Name:
Matt
Gluckman
Pretreatment
Program
Mgr
3.
Contact
Information
e­
mail
address:
gluckman.
matthew@
epa.
gov
phone:
312/
886­
6089
fax:
312/
886­
7804
4.
Office/
Division/
Branch/
Region:
U.
S.
EPA
Region
5,
Water
Division,
NPDES
Programs
Branch
Issues/
Industries
5.
Identification
of
Industry
or
Issue
OCPSF.
Since
promulgation
of
this
rule,
there
have
been
difficulties
in
getting
POTWs
and
OCPSF
facilities
to
correctly
calculate
flow
based
mass
limits,
and
to
provide
necessary
data
to
determine
compliance
with
the
standards.
Deficiencies
in
permits
and
control
mechanisms
has
in
the
past
hindered
enforcement
actions
against
these
facilities.

Much
effort
has
also
been
expended
in
having
to
determine
which
SIC
codes
apply
to
facilities,
with
some
not
being
subject
to
OCPSF
even
though
they
appear
to
be
doing
similar
operations
as
covered
facilities.
There
are
some
facilities,
such
as
adhesive
manufacturers
and
solvent
recovery
facilities,
that
fall
through
the
cracks
of
categorical
coverage.

This
rule
should
be
reevaluated
to
consider
more
general
coverage,
which
is
not
tied
to
SIC
codes
(
or
expands
on
covered
SICs),
and
to
consider
allowing
the
concentration
standards
to
be
applied
directly.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
We
have
a
significant
number
of
these
facilities
in
R5.
Data
for
direct
discharging
facilities
would
be
in
PCS.
PCS,
as
currently
maintained,
does
not
contain
information
for
most
indirect
discharging
industrial
users
such
as
OCPSF
facilities.
Page
24
of
40
7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
See
above
8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
Guidance
on
calculating
flow
based
mass
limits
has
been
of
some
help,
and
training
has
been
provided
on
these
calculations,
but
the
structure
and
limited
scope
of
the
regulation
still
create
permitting
and
enforcement
challenges.

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes.

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).

14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
Page
25
of
40
Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.

16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
26
of
40
Attachment
6
Issue/
Industry
Nomination
Form
Metal
Finishing
1.
Date:
6/
2/
03
2.
Name:
Matt
Gluckman
Pretreatment
Program
Mgr
3.
Contact
Information
e­
mail
address:
gluckman.
matthew@
epa.
gov
phone:
312/
886­
6089
fax:
312/
886­
7804
4.
Office/
Division/
Branch/
Region:
U.
S.
EPA
Region
5,
Water
Division,
NPDES
Programs
Branch
Issues/
Industries
5.
Identification
of
Industry
or
Issue
Metal
finishing.
Applicability
requirements
and
structure
of
the
electroplating/
metal
finishing
standards
have
resulted
in
ongoing
challenges
in
determining
whether
a
facility
performs
a
core
activity
and
is
thus
categorical,
or
just
an
ancillary
activity,
in
which
case
it
is
not.
Determining
whether
changes
at
an
existing
electroplating
job
shop
result
in
the
new
operations
being
subject
to
433
also
continues
to
pose
challenges.

While
upgrading
facilities
from
part
413
to
433
was
considered
in
the
Metal
Products
and
Machinery
rulemaking,
this
approach
should
be
reconsidered,
from
the
perspective
of
common
use
of
the
treatment
technology
for
433,
and
implementation
issues
associated
with
having
two
separate
standards
for
facilities
essentially
performing
the
same
activities.

Determining
whether
activities
are
core
or
ancillary
metal
finishing
operations
is
an
ongoing
technical
and
resource
issue.
Consideration
should
be
given
to
expanding
the
list
of
core
operations,
such
that
certain
activities
that
are
currently
considered
ancillary,
and
thus
not
independently
covered
by
433,
would
become
core
metal
finishing
activities.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
We
have
an
estimated
2000
metal
finishers
in
R5,
most
of
which
discharge
to
POTWs.
Data
for
Page
27
of
40
direct
discharging
facilities
would
be
in
PCS.
PCS,
as
currently
maintained,
does
not
contain
information
for
most
indirect
discharging
industrial
users
such
as
metal
finishing
facilities.

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
See
above.
If
regulatory
revision
isn't
feasible,
guidance
should
be
provided
regarding
distinguishing
between
certain
core
and
ancillary
metal
finishing
processes,
and
national
guidance
regarding
when
existing
operations
constitute
a
new
source
should
be
finalized.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
There
are
numerous
category
determinations
dealing
with
these
issues,
including
existing
and
new
source
issues.
Definitive
national
guidance
in
these
areas
continues
to
be
needed.

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?
Any
of
our
delegated
states
would
be
interested
in
providing
input
on
these
issues.
Other
stakeholders
from
the
MPM
rulemaking
process
should
also
be
involved.

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes.

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
Page
28
of
40
14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.

16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
29
of
40
Attachment
7
Issue/
Industry
Nomination
Form
Metal
Molding
and
Casting,
Aluminum
Casting
Subcategory
1.
Date:
June
20,
2003
2.
Name:
Paul
Marshall
3.
Contact
Information
e­
mail
address:
marshall.
paul@
epa.
gov
phone:
913­
551­
7419
fax:
913­
551­
9419
4.
Office/
Division/
Branch/
Region:
US
EPA
Region
7,
Water
Management
Division,
NFMB
Branch,
Pretreatment
Coordinator
Issues/
Industries
5.
Identification
of
Industry
or
Issue
Note:
The
following
comments
are
based
on
my
experience
with
the
Aluminum
Casting
portion
of
the
40
CFR
Part
464
Regulations
(
Metal
Molding
and
Casting).
The
problems
I
identify
might
also
be
applicable
to
subparts
other
than
Aluminum
Casting.

The
Metal
Molding
and
Casting
Regulations
are
difficult
to
implement
for
two
reasons.
One
is
that
the
nature
of
the
regulation
itself
and
the
building
block
method
of
determining
allowances,
and
hence
discharge
limits.
Many
aluminum
casting
facilities
are
very
small,
and
consequently
only
receive
an
allowance
for
their
die
casting
operations,
as
none
of
the
other
processes
are
on
site.
When
this
happens,
the
facility
gets
roped
into
a
phenol
limit
for
which
they
receive
a
minuscule
allowance.
However,
phenol
is
not
used
for
this
operation,
since
the
operations
are
dry,
yet,
phenol
is
ever­
present
as
a
background
pollutant.
This,
then
results
in
a
phenol
limit
when
phenol
isn't
present
to
control
and
almost
certain
noncompliance
because
there
is
no
possible
way
to
remove
the
phenol
at
these
low
levels
for
any
sensible
reason,
since
this
level
would
easily
be
treated
in
municipal
secondary
treatment.

Other
"
building
blocks"
provide
for
more
generous
phenol
allowances,
however,
if
the
facility
doesn't
qualify
for
any
of
these
allowances,
the
insignificant
allowance
for
Die
Casting
Operations
merely
creates
a
facility
in
noncompliance
at
a
level
that
doesn't
even
approach
environmental
significance.

Another
problem
with
the
Aluminum
Casting
Subcategory
is
the
horribly
confusing
language
describing
applicability.
The
Subcategory
seems
to
imply
that
once
a
casting
has
cooled
Page
30
of
40
any
further
work
on
it
is
no
longer
covered
by
the
464
regulations.
Yet
obviously,
once
a
casting
has
been
quenched
it
has
been
cooled
and
the
casting
cleaning
step
is
done
on
a
cooled
piece.
This
language
needs
to
be
rewritten.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
The
facilities
that
I
am
familiar
with
are
all
indirect
dischargers,
and
generally
small
in
nature.
Consequently,
there
are
no
NPDES
permit
numbers
to
direct
you
to.
However,
if
EAD
decides
to
revisit
this
regulation,
I
would
be
happy
to
provide
all
known
aluminum
casting
facilities
in
the
Region.

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
The
simplest
solution
would
be
to
eliminate
the
phenol
allowance
from
the
Die
Casting
Operations
"
building
block".

Clarify
the
applicability
language.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
NA
9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?
Anyone
who
must
write
permits
and
enforce
this
standard
should
have
an
interest
in
it.
This
includes
States
and
approved
Pretreatment
Program
cities.
Also,
the
Industry
may
want
to
help
participate.

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes.

11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
Page
31
of
40
knowledge/
expertise).
Allen
Gilliam,
Pretreatment
Coordinator
AR
Department
of
Environmental
Quality
P.
O.
Box
8913
8001
National
Drive
Little
Rock,
AR
72219­
8913
(
501)
682­
0625
FAX
(
501)
682­
0910
gilliam@
adeq.
state.
ar.
us
Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).

14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.

16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).

Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
32
of
40
Attachment
8
304(
m)
Issue/
Industry
Nomination
Form
Ore
Mining
and
Dressing
(
Hard
Rock
Mining)

1.
Date:
June
17,
2003
2.
Name:
John
Hillenbrand
&
John
Tinger
3.
Contact
Information
e­
mail
address:
Tinger.
john@
epa.
gov;
Hillenbrand.
john@
epa.
gov
phone:
415
972­
3518
/
415
972­
3494
fax:
415
947­
3545
4.
Office/
Division/
Branch/
Region:

John
Tinger:
Region
IX
Water
Division,
Permits
John
Hillenbrand:
Region
IX
Water
Division,
Enforcement
Issues/
Industries
5.
Identification
of
Industry
or
Issue
Background
Hard
Rock
Mines
are
covered
by
40
CFR
Part
440
­
Ore
Mining
and
Dressing.
Subparts
include:
A:
Iron
B:
Aluminum
C:
Uranium,
Radium,
and
Vanadium
D:
Mercury
E:
Titanium
F:
Tungsten
G:
Nickel
H
Vanadium
I:
Antimony
J:
Copper,
Lead,
Zinc,
Gold,
Silver
and
Molybdenum
K:
Palatinum
M:
gold
placer
mining
On
August
7,
1998,
EPA
published
the
Multi
Sector
General
Permit
(
MSGP)
for
Industrial
Activities,
Sector
G
for
Metal
Mining
(
Ore
Dressing
and
Mining).
Table
G­
4
listed
what
wastewaters
from
mining
activities
are
covered
by
Part
440
and
what
wastewaters
are
to
be
covered
by
the
industrial
MSGP.
Initially,
EPA
said
that
runoff
from
waste
rock
and
overburden
piles
were
covered
by
effluent
guidelines.
However,
the
National
Mining
Association
challenged
EPA
on
this
interpretation
and
contended
that
the
runoff
from
waste
rock
and
overburden
was
not
considered
in
the
ELGs
and
is
not
a
problem.
As
a
result,
it
was
determined
that
runoff
from
waste
rock
and
overburden
is
not
subject
to
the
effluent
guidelines.
It
is
therefore
considered
industrial
stormwater
and
is
covered
under
Part
G
of
the
MSGP
unless
it
"
naturally
drains
(
or
is
intentionally
diverted)
to
a
point
source
and
combines
with
"
mine
drainage"
that
is
otherwise
subject
to
the
ELGs."
The
final
MSGP
was
published
on
October
30,
2000.
Page
33
of
40
The
MSGP
establishes
benchmark
monitoring
for
pollutants
including:
TSS,
pH,
hardness,
arsenic,
beryllium,
cadmium,
copper,
iron,
lead,
manganese,
mercury,
nickel,
selenium,
silver,
zinc,
uranium.
The
data
from
this
sampling
is
now
becoming
available
due
to
the
2000
MSGP
requirements.

Problem
Preliminary
data
indicate
high
concentrations
of
metals
in
active
and
inactive
mine
site
runoff
that
are
violating
water
quality
standards.
The
volumes
of
discharge
are
significant
due
to
the
large
land
area
covered
by
the
mine
sites.
Constituents
include
toxic
pollutants
such
as
arsenic,
copper,
mercury
and
selenium
as
well
as
pH
problems.
The
requirements
of
the
MSGP
are
not
sufficient
to
control
this
wastewater.

The
current
guidelines
do
not
represent
the
best
technology.
Numerous
mines
sites
have
installed
what
may
be
considered
BAT
(
see
below).

If
not
addressed:
Most
mine
sites
continue
to
be
covered
under
the
MSGP.
The
MSGP
only
includes
very
general
benchmark
values
for
sampling;
general
requirements
to
develop
a
stormwater
pollution
prevention
plan,
and
does
not
establish
numeric
limits
or
stormwater
containment/
treatment
requirements.
For
mines
that
fail
to
comply
with
the
MSGP,
enforcement
at
every
mine
site
to
require
individual
NPDES
permits
or
to
develop
an
individual
BMP
plan
is
a
long
and
time
consuming
process.
Currently,
we
do
not
believe
that
most
states
are
not
addressing
mine
site
runoff.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
Number
of
hard
rock
mines:
we
estimate
around
100
of
active
hard
rock
mines.
Geographic:
mostly
Western
states
&
Alaska,
but
throughout
U.
S.
Note
that
many
mine
sites
are
covered
only
by
the
stormwater
permit.

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
BAT
may
be
considered:
°
Reclamation
of
wasterock
or
overburden
and
tailings
piles
(
regrading
and
revegetating
to
natural
contours);
and/
or
°
Containment
of
stormwater
through
grading,
berms,
retention
ponds
(
e.
g,
designed
to
contain
100
year,
24
hour
storm)

Potential
to
be
cost­
effective.
This
is
a
relatively
simple
technology
­
largely
moving
dirt
around
on
a
mine
site
(
thats
what
mines
do)
and
reclamation
(
which
they
are
supposed
to
have
to
do
Page
34
of
40
anyways).
Volumes
of
wastewater
can
be
very
large
due
the
large
size
of
many
sites,
and
pollutants
found
in
runoff
can
be
toxic.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
limitations
guideline)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?
EPA
Region
IX
(
When
it
retained
permitting
authority
for
Arizona)
has
required
several
mine
sites
to
contain
mine
site
runoff.
These
were
the
result
of
enforcement
actions
(
due
to
continued
non­
compliance
with
MSGP
and
water
quality
standard
violations)
for
several
mines
sites,
and
EPA
has
issued
several
permits
that
require
the
mine
to
contain
stormwater.

Due
to
the
time
and
resources
involved
in
implementing
BAT,
we
do
not
believe
that
most
other
states
are
addressing
this
issue.
Many
states
have
general
industrial
stormwater
permits
but
these
tend
not
to
be
enforced
(
including
mines)
because
of
the
workload.
No
specific
program
to
address
contaminated
runoff
from
mine
tailings,
wasterock
or
overburden
exists
in
CA,
NV,
AZ.
We
do
not
believe
any
other
states
are
implementing
programs
either.

9.
Potential
Partners/
Leveraging
Opportunities.
Are
there
others
in
EPA
or
outside
organizations
(
States,
trade
organizations,
non­
profits,
etc.)
that
may
have
an
interest
in
joining
an
effort
to
address
this
problem/
industry?
Great
Basin
Mine
Watch
­
Environmental
organization
Western
Mining
Action
Project
Sierra
Club
(
Nevada)

10.
Do
you
want
to
be
involved
or
be
kept
informed
on
how
we
are
addressing
the
issue/
industry
which
you
have
identified?
Yes
11.
Do
you
know
of
any
experts
or
other
people
knowledgeable
on
this
issue/
industry
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).
HQ
­
Bill
Telliard
EPA
(
EAD)
202­
566­
1061
Jeff
Smith
EPA
OWM
202­
564­
0652
Bryan
Rittenhouse,
EPA
OWM,
water
permits
division,
Headquarters
202­
564­
0577
Steve
Sweeney
OGC
lead
in
negotiating
`
98
MSGP
revision
with
NMA
202­
564­
5491
Region
8
­
Steve
Bubnick
303
312­
6829
Vern
Berry,
Region
8,
helped
write
MSGP
303­
312­
6234
Page
35
of
40
Region
10
Bill
Riley,
CWA
Compliance
206
553­
1412
Technologies
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Technology
Known
facilities
with
potential
BAT:

Asarco
Mission
copper
mine
(
Arizona)
­
has
stormwater
controls
to
contain
100
year
storm
event
for
most
of
site,
other
areas
contained
for
10
year
storm
event.

BHP
Pinto
Valley
copper
mine
(
Arizona)
­
has
stormwater
controls
to
contain
100
year
storm
event
for
all
of
the
waste
rock
and
overburden
piles
amd
most
all
tailings
facilities.

Silver
Bell
copper
mine
(
Arizona)
­
most
of
the
stormwater
containment
up
to
100
year/
24
hour
storm
event
from
waste
rock
and
overburden.

Phelps
Dodge
Morenci
(
Arizona)
stormwater
contaiment
at
all
facilities
to
a
minimum
100
year
24
hour
capacity
as
of
1996
from
maste
rock,
overburden
and
tailings
facilities.

13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology
and
its
effluent
quality.
Also,
please
identify
relevant
EPA
and
external
data
sources
(
e.
g.
permit
numbers).
Performance
and
reduction
in
pounds
of
pollutants
are
mainly
due
to
elimination
of
discharge
and
containment.
Reduction
of
pollutants
should
be
in
the
mid­
to
high
90
percent
removal
based
on
containment
for
24
hour
storm
or
100
year
storm.

Enclosed
is
a
summary
graph
of
copper
concentration
vs
TSS
of
mine
site
discharges
of
stormwater
from
Copper
mines
in
Region
IX.
Note
that
much
of
this
data
have
been
collected
as
part
of
the
MSGP
and
may
be
available
from
other
states.

Summarizing
from
the
58
data
points
collected
so
far:
­
70
%
are
over
1
ppm
total
copper.
­
91
%
are
over
0.1
ppm
total
copper.
­
81%
of
all
stormwater
samples
are
above
the
Agricultural
Livestock
standard
of
0.5
ppm
total
copper.
­
Aquatic
standards
(
warmwater,
coldwater,
effluent
dominated
and
ephemeral
acute
and
chronic)
range
from
.002
to
.085
ppm
dissolved
copper.
A
plot
of
dissolved
copper
concentrations
would
yield
a
similar
problem
of
many
discharges
above
these
standars
also.
Page
36
of
40
14.
Do
you
know
of
any
experts
or
other
people
knowledgeable
about
this
facility
or
technology
that
we
should
contact?
(
If
so
please
provide
names,
contact
information,
and
area
of
knowledge/
expertise).

Other
Suggestions
15.
Please
provide
any
suggestions
you
have
on
how
best
to
collect
this
type
of
information
in
the
future.
None
16.
Please
provide
any
other
information
that
you
believe
would
be
useful
in
the
effluent
limitations
guideline
planning
process
(
for
example,
2c
applications,
fact
sheets,
etc.).
DMRs
from
MSGP
by
mine
category
The
`
98
lawsuit
from
NMA
Randal
Directory
­
lists
active
and
inactive
mine
sites
by
state
and
basic
info
about
mine
Size
of
mine
sites
and
area
of
waste
rock
piles
and
overburden
Rainfall
data
to
estimate
total
volume
of
flows
Please
return
completed
form
to
e­
mail:
Harrigan.
Patricia@
epa.
gov
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Patricia
Harrigan
at
mail
code
4303T.
Pat's
phone
number
is
202/
566­
1666.
Page
37
of
40
Attachment
9
From:
Keith
Silva
on
10­
15­
99
05:
49
pm
To:
Harrigan.
Patricia@
EPA.
GOV@
EPA
cc:
Alexis
Strauss/
R9/
USEPA/
US@
EPA,
Frace.
Sheila@
EPA.
GOV@
EPA,
Terry
Oda/
R9/
USEPA/
US@
EPA,
Robert
Wills/
R9/
USEPA/
US@
EPA,
Greg
Arthur/
R9/
USEPA/
US@
EPA
Subject:
Identifying
high
priority
discharge
categories
for
effluent
guideline
development
Pat:

Here
is
Region
9'
s
response
to
Sheila's
9­
23­
99
e­
mail
message
asking
for
suggestions
for
new
categorical
standards.
I've
used
blue
text
to
respond
to
each
of
Sheila's
three
questions
which
are
repeated
below:

1)
Are
there
categories
of
dischargers
who
are
repeatedly
at
issue
in
impaired
waters?

Oil
Refineries
­
We
need
to
relook
at
these
for
metals,
particularly
selenium.

Dental
Offices
and
Clinics
­
We
believe
that
these
are
an
important
source
of
mercury.
The
water
quality­
based
approach
to
regulating
these
sources
using
NPDES
permits
and
pretreatment
local
limits,
however,
is
made
very
complicated
by
atmospheric
deposition
issues.
A
technology­
based
categorical
standard
could
be
a
very
efficient
control
measure.

2)
Are
there
categories
of
dischargers
for
whom
you
always
must
rely
on
water
quality­
based
limitations
because
there
are
no
effluent
guidelines
or
the
existing
effluent
guidelines
are
not
sufficiently
stringent?

Photoprocessing
­
These
facilities
are
everywhere
in
modern
society
and
generally
are
lightly
controlled.
The
metal
finishing
standards
do
not
cover
nondestructive
photoimaging
testing.
In
addition,
although
we
regulate
silver
recyclers
under
Part
421,
we
discourage
such
recycling
by
allowing
photoprocessors
to
dispose
of
photographic
wastes
into
the
sanitary
sewer
under
lenient
local
limits
or
voluntary
measures.
The
industry
has
been
masterful
at
exploiting
the
complicated
and
weak
water
quality
basis
for
regulation
by
NPDES
permits
and
pretreatment
local
limits
under
the
Act.
Considering
the
size
and
scope
of
this
industry,
a
national
standard
is
appropriate.

Fastener
Manufacturing
­
This
industry
manufactures
screws,
bolts
and
other
small
parts,
frequently
for
aerospace
applications.
These
facilities
are
always
covered
by
the
metal
finishing
standards
and
metal
forming
standards.
Due
to
the
small
and
complicated
configuration
of
the
parts,
however,
it
is
extremely
difficult
to
apply
the
existing
categorical
standards
correctly.
This
industry
generates
a
metal­
bearing,
oily
wastestream
that
is
difficult
to
treat
and
it
is
not
well
reflected
in
the
current
categorical
standards.
Page
38
of
40
Job
Shop
Galvanizers
­
These
sources
are
not
covered
under
Part
420
and
are
not
limited
for
zinc
under
Part
413
(<
10K
gpd).
We
should
revise
Part
413
or
433
to
cover
these
small,
but
very
dirty
discharges.
One
approach
to
this
problem
is
to
add
a
new
subcategory
for
job
shop
galvanizers
to
Part
433.

Bilge
Water
­
This
is
an
oily,
metal­
bearing
wastestream
that
could
greatly
benefit
from
BAT
treatment.
The
episodic
discharge
mode
complicates
the
application
of
local
limits
and
POTWs
often
depend
on
dilution
with
domestic
wastewater
to
prevent
problems
at
a
treatment
plant.
Uniform
national
standards
for
all
coastal
areas
are
appropriate
in
view
of
the
mobile
nature
of
the
pollutant
"
sources"
(
ships).

Jewelry
Manufacturing
­
This
industry
is
concentrated
in
Los
Angeles
and
New
York.
In
these
locations,
many
small
manufacturers
typically
occupy
one
building.
This
arrangement
complicates
the
application
of
the
metal
finishing
categorical
standards.
Los
Angeles
has
implemented
a
solution
requiring
shared,
centralized
BAT
treatment
in
each
building.
It
would
be
helpful
if
there
were
categorical
standards
specifically
reflecting
the
unique
circumstances
of
jewelry
manufacturers
with
a
uniform
national
approach
for
regulation.
In
addition,
we
would
like
to
see
stand­
alone
jewelry
manufacturers
that
discharge
less
than
100
gpd
to
be
excluded
from
the
categorical
standards,
along
with
jewelry
repair
operations
that
are
performed
at
locations
where
the
primary
business
is
retail
sales.
One
approach
to
this
problem
is
to
add
a
new
subcategory
for
jewelry
manufacturing
to
Part
433.

3)
Are
there
categories
of
dischargers
for
whom
you
wish
you
had
more
technical
support?

Biotechnology
­
This
industry
is
concentrated
in
California
and
New
England.
A
frequent
concern
is
organic
pollutants
and
low­
level
radioactive
waste
that
ultimately
partitions
to
municipal
sludge.

If
you
have
any
questions,
please
contact
me
at
415.744.1907
or
Greg
Arthur
at
415.744.1900.

Regards,
Keith
Silva
Page
39
of
40
Attachment
10
October
28,
2003
Comments
on
EPA
ELG
from
WA
Dept.
of
Ecology
Direct
Dischargers
°
Part
429,
Timber
Products
Processing
point
source
category
revised
to
include
effluent
limits
for
stormwater
discharges
from
associated
log
yards.

°
The
Fruit
&
Vegetable
Processors
(
40
CFR
407)
badly
need
updating
for
both
direct
and
indirect
dischargers.
For
direct
dischargers,
they're
often
putting
out
only
15
to
25%
of
the
technology­
based
limits
that
appear
in
the
ELGs.
And,
since
we
have
neither
WQ
criteria
for
BOD
nor
an
equitable
way
to
determine
the
farfield
impacts
of
BOD
(
short
of
a
TMDL),
the
Part
407
ELGs
might
help
us
address
the
dissolved
oxygen
problems
in
our
waterways
over
the
long
term.

°
Petroleum
refineries
­
These
effluent
guidelines
are
20
years
old
and
have
been
the
subject
of
a
lot
of
controversy
and
litigation
over
the
last
7
or
so
years.
The
refineries
are
all
performing
well
below
limits
derived
from
the
guidelines.
We
have
found
it
difficult
to
address
this
gap
in
a
way
that
would
not
be
considered
arbitrary
and
capricious
or
that
uses
the
"
dreaded"
(
by
the
industry)
BPJ.
We
are
going
into
a
new
permit
cycle
for
the
refineries
and
anticipate
this
issue
coming
up
once
again.
It
would
be
nice
to
eventually
have
some
EPA
rules
to
support
lower
limits.

°
Fish
Processors
­
The
ELG's
are
terribly
out
of
date
for
this
category.
We
could
really
benefit
from
an
update
of
the
ELG's
for
all
categories
of
fish
processing.

Pretreatment
One
of
the
most
problematic
areas
of
the
Federal
Pretreatment
program
is
the
lack
of
flexibility
for
dischargers
that
have
small
quantities
of
effluent
and/
or
those
which
are
processing
small
volumes
of
material.
The
federal
rules
are
generally
designed
for
facilities
that
have
a
certain
economy
of
scale.
Application
of
the
same
pollutant
concentration
or
mass
limits
to
much
smaller
facilities
often
requires
them
to
implement
a
level
of
treatment
far
in
excess
of
what
was
envisioned
as
the
best
available
technology
reasonably
achievable.
This
(
in
combination
with
other
regulatory
burdens)
can
and
too
often
does
force
them
out
of
business.
While
the
representatives
of
the
"
industry"
from
which
EPA
receives
comments
and
negotiates
may
not
be
adverse
to
burdening
these
start­
up
and
niche
industries
with
the
same
standards,
and
thus
preserving
their
market
share,
I
believe
we
have
stifled
competition
and
innovation
by
not
defending
them
better.
There
are
two
ways
to
fix
this,
one
would
be
to
have
each
categorical
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40
of
40
industry
include
a
deminimus
level
of
production
or
discharge
at
which
only
local
limits
need
be
applied.
The
second
is
to
provide
a
process
by
which
Control
and
Approval
authorities
can
exempt
categorical
facilities
from
unduly
burdensome
regulations.

I
favor
the
second
approach.
Part
of
the
reason
is
that
pretreatment
programs
have
been
operating
at
the
local
level
for
about
20
years
now,
and
are
doing
an
outstanding
job.
I
believe
their
success,
and
that
of
the
states
overseeing
them,
merits
a
greater
level
of
empowerment.
I
believe
that
the
approval
authority
(
the
state),
upon
request
by
any
control
authority,
should
be
given
the
authority
to
waive
categorical
pretreatment
standards
for
any
industry
that
has
less
than
10,000
gallons
per
day
of
categorical
process
wastewater
flow
as
a
highest
monthly
average,
but
would
be
subject
to
categorical
pretreatment
standards.
I
envision
that
such
industries
should
still
be
subject
to
obtain
a
permit
which
included
applicable
local
discharge
limitations
(
and
any
pollutant
that
would
have
been
regulated
under
categorical
standards
would
be
applicable)
and
all
other
pretreatment
requirements
would
need
to
be
met.
The
state
should
have
the
same
ability
for
permittees
which
it
directly
oversees,
and
the
process
would
be
for
the
permit
writer
to
document
the
concurrence
of
the
same
regional
pretreatment
program
coordinator
that
would
approve
such
a
request
by
a
delegated
program.

In
a
similar
vein,
I
also
believe
that
requests
for
modified
standards
due
to
fundamentally
different
factors
requests
should
be
handled
at
the
state
level,
not
EPA
level,
and
there
should
be
no
time
limit
on
how
when
such
a
request
can
come
in.
Fundamentally
different
processes
are
put
in
place
all
the
time.
It
appears
that
EPA's
vision
is
to
have
this
done
at
the
national
level
for
each
industry
that
is
granted
a
FDF
request
because
standards
will
be
revisited
every
five
years,
and
that
this
data
will
be
collected
and
used
in
the
next
iteration
of
standards.
Neither
of
these
activities
occurs
though.

Melodie
Selby,
Section
Manager,
Water
Quality
Program
