UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
WATER
MEMORANDUM
June
24,
2004
SUBJECT:
2003
National
Coordinators
Workshop
Feedback
for
the
304(
m)
Planning
Process
for
the
2004/
2005
Plan
FROM:
Patricia
Harrigan,
USEPA/
OW/
OST
(
202)
566­
1666
(
harrigan.
patricia@
epa.
gov)

TO:
Public
Record
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
EPA
Docket
Number
OW­
2003­
0074
(
www.
epa.
gov/
edockets/)

The
purpose
of
this
memorandum
is
to
describe
suggestions
and
issues
identified
by
pretreatment
coordinators
attending
the
November,
2003
National
Coordinators
Workshop
hosted
by
the
Association
of
Metropolitan
Sewerage
Agencies.
EPA
solicited
feedback
from
workshop
attendees
during
roundtable
discussions
and
will
consider
these
suggestions
during
development
of
the
final
Effluent
Guidelines
Program
Plan
for
2004/
2005.

Additional
feedback
triggered
by
this
workshop
was
sent
to
EPA
through
an
email
discussion
chain.
That
feedback
is
documented
in
a
separate
memo
titled
"
Additional
Feedback
from
State
Pretreatment
Coordinators
to
the
304(
m)
Planning
Process
for
the
2004/
2005
Plan."

Overview
As
outlined
in
the
preliminary
Effluent
Guidelines
Program
Plan
for
2004/
2005
published
on
December
31,
2003
in
the
Federal
Register
(
68
FR
75515),
EPA
is
using
four
major
factors
to
determine
whether
to
revise
a
set
of
existing
effluent
guidelines.
These
four
factors
are:


Factor
1:
Consideration
of
the
extent
to
which
the
pollutants
discharged
by
an
industry
category
pose
adverse
impacts
(
including
potential
risks)
to
human
health
or
the
environment.


Factor
2:
Identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
alternative
that
can
effectively
reduce
the
pollutants
discharged
by
the
industry
category
and
thereby
substantially
reduce
any
potential
risk
to
human
health
or
the
environment
associated
with
those
pollutants.


Factor
3:
Evaluation
of
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
measures
identified
using
the
second
factor.
Page
2
of
3

Factor
4:
Evaluation
of
implementation
and
efficiency
considerations.
Under
this
factor,
EPA
would
consider
whether
existing
effluent
guidelines
could
be
revised,
for
example,
to
eliminate
inefficiencies
or
impediments
to
technological
innovation,
or
to
promote
innovative
approaches
such
as
water
quality
trading,
including
within­
plant
trading.
This
factor
might
also
prompt
EPA
to
decide
not
to
revise
effluent
guidelines
for
an
industry
category
where
the
pollutant
source
is
already
being
addressed
by
another
regulatory
program,
such
as
EPA's
stormwater
requirements,
or
by
non­
regulatory
programs
that
may
more
effectively
address
the
problem.

This
memo
consolidates
suggestions
received
in
response
to
7
questions
posed
by
Deborah
Nagle,
chief
of
the
Industrial
Branch
in
EPA's
Office
of
Wastewater
Management.
These
suggestions
are
not
formal
comments,
but
EPA
wanted
to
record
them
here
for
the
public
record.
An
excerpt
from
the
summary
report
is
attached
to
this
memo.
The
complete
summary
report
can
be
viewed
at
http://
www.
amsa­
cleanwater.
org/
meetings/
03pret/
ppt/
2003prceed.
pdf.

Centralized
Waste
Treatment
(
40
CFR
437):
Several
attendees
noted
issues
with
the
Centralized
Waste
Treatment
(
CWT)
ELG,
including
the
belief
that
the
limits
are
so
low
that
matrix
interference
puts
detection
limits
above
discharge
limits.
More
generally,
respondents
mentioned
the
need
for
further
guidance
on
general
implementation
of
the
CWT
rule.

Hospitals
(
40
CFR
460):
Attendees
identified
this
point
source
category,
along
with
healthcare
in
general,
as
one
which
could
provide
opportunities
for
multi­
media
pollutant
reductions.

Metal
Finishing
(
40
CFR
433):
Attendees
identified
this
point
source
category
as
one
which
could
provide
opportunities
for
multi­
media
pollutant
reductions.
The
workshop
attendees
noted
significant
technological
improvements
in
this
sector.

Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
40
CFR
414):
Attendees
identified
this
point
source
category
as
one
which
could
provide
opportunities
for
multi­
media
pollutant
reductions.
The
workshop
attendees
noted
significant
technological
improvements
in
the
organic
chemical
sector,
with
better
overall
treatment
(
stripping,
improved
filtration
ahead
of
carbon).

Pharmaceutical
Manufacturing
(
40
CFR
439):
This
ELG
was
commonly
mentioned
as
one
requiring
assistance
in
applying.
Responders
specifically
noted
that
biotech
companies
should
not
be
included
in
the
scope,
as
their
wastestreams
are
basically
clean
and
relatively
minor.
Attendees
also
identified
this
point
source
category
as
one
which
could
provide
opportunities
for
multimedia
pollutant
reductions.

Pulp,
Paper,
and
Paperboard
(
40
CFR
430):
Attendees
identified
this
point
source
category
as
one
which
could
provide
opportunities
for
multi­
media
pollutant
reductions.
Page
3
of
3
New
Point
Source
Categories:
The
overwhelming
response
was
that
there
is
no
need
to
introduce
new
categorical
standards
or
regulations.
Most
attendees
believed
that
local
limits
were
more
than
effective
to
control
pollutants.
Many
also
believed
that
resources
should
be
spent
on
guidance
on
existing
ELGs
as
opposed
to
creating
new
ones
that
are
already
controlled
on
the
local
level.
However,
printers
and
fiberglass
manufacturers
were
identified
as
point
source
categories
which
could
provide
opportunities
for
multi­
media
pollutant
reductions.
Dentists
were
identified
as
a
sector
with
innovative
approaches
to
minimize
pollutant
releases.
Dye
manufacturers
were
also
identified
as
a
sector
with
innovative
approaches
to
minimize
pollutant
releasesm
with
their
practice
of
evaporating
wastes.

General
for
All
Effluent
Guidelines:
Generally,
any
concentration­
based
ELG
was
thought
to
impede
adoption
of
water
conservation
practices.
POTWs
expressed
interest
in
converting
to
mass
limits
to
allow
for
greater
water
conservation,
but
would
still
like
to
retain
the
ability
to
choose
whichever
method
is
more
appropriate.
Attachment:
Combined
Roundtable
Discussions
at
2003
National
Pretreatment
Coordinators
Workshop
Excerpted
from
Summary
Report
Combined
Roundtable
Discussions
Workshop
attendees
were
seated
at
tables
of
10
people,
given
introductory
presentations,
and
then
asked
to
comment
on
each
of
the
three
topics
through
a
series
of
discussion
questions.

The
first
topic
discussed
was
the
issue
of
effluent
guidelines
implementation.
Deborah
Nagle,
Chief,
Industrial
Branch,
OWM,
posed
a
series
of
questions
regarding
implementation
issues
which
were
then
discussed
in
at
each
roundtable.

The
questions
posed
and
a
summary
of
what
was
discussed
are
outlined
as
follows:

1.
Identify
any
current
Effluent
Guideline/
pretreatment
standard
that
you
find
you
need
assistance
in
applying.
Specifically,
for
that
guideline
or
industrial
sector:


What
specific
issues
are
you
grappling
with?


What
tools
could
aid
your
permit
writing
for
these
facilities?

Several
attendees
noted
issues
with
the
Centralized
Waste
Treatment
(
CWT)
ELG,
including
the
belief
that
the
limits
are
so
low
that
matrix
interference
puts
detection
limits
above
discharge
limits.
More
generally,
respondents
mentioned
the
need
for
further
guidance
on
general
implementation
of
the
CWT
rule.

Another
ELG
commonly
mentioned
was
the
Pharmaceutical
rule,
specifically
noting
that
biotech
companies
should
not
be
included
as
their
wastestreams
are
basically
clean
and
relatively
minor.

2.
Should
EPA
consider
new
categorical
guidelines
for
any
industrial
operations
that
are
currently
not
regulated
by
a
categorical
guideline
or
revise
existing
guidelines?
What
problem
would
a
categorical
guideline
or
study
address?

The
overwhelming
response
was
that
there
is
no
need
to
introduce
new
categorical
standards
or
regulations.
Most
attendees
believed
that
local
limits
were
more
than
effective
to
control
pollutants.
Many
also
believed
that
resources
should
be
spent
on
guidance
on
existing
ELGs
as
opposed
to
creating
new
ones
that
are
already
controlled
on
the
local
level.
3.
What
industry
sectors
may
provide
an
opportunity
for
multimedia
pollutant
reductions?

Among
those
sectors
listed
by
the
attendees
that
could
provide
opportunities
for
multimedia
pollutant
reductions
were
pulp
and
paper,
organic
chemicals,
printers,
pharmaceuticals,
health
care,
metal
finishers,
and
fiberglass
manufacturers
and
plastics.

4.
What
industry
sectors
reflect
innovative
approaches
to
minimize
pollutant
releases?

Responses
to
this
question
included
BMPs
for
dentists,
the
use
of
wash
down
waters
as
dilution
for
next
batches
by
dye
manufacturers,
the
practice
of
"
evaporating"
wastes
as
opposed
to
discharging
them.
One
attendee
mentioned
that
finalization
of
the
Pretreatment
Streamlining
Rule
would
greatly
increase
opportunities
for
innovation.

5.
What
current
industry
sectors
reflect
significantly
improved
treatment
technologies
since
adoption
of
the
categorical
standards
(
e.
g.,
water
use
or
pollutant
treatment)?

The
workshop
attendees
noted
significant
technological
improvements
in
the
organic
chemical
sector,
with
better
overall
treatment
(
stripping,
improved
filtration
ahead
of
carbon)
,
and
the
metal
finishing
sector.
It
was
also
noted
that
ISO
standards
drive
categorical
standards
through
pollution
prevention
actions.

6.
Provide
specific
examples
where
a
categorical
guideline
may
impede
adoption
of
water
conservation
or
pollution
reduction
technologies.
Generally,
any
concentration­
based
ELG
was
thought
to
impede
adoption
of
water
conservation
practices.
POTWs
expressed
interest
in
converting
to
mass
limits
to
allow
for
greater
water
conservation,
but
would
still
like
to
retain
the
ability
to
choose
whichever
method
is
more
appropriate.

7.
To
the
extent
possible,
discuss
whether
your
recommended
reforms
(
above)
would
increase
or
decrease
water
pollution
discharges
or
sludge
quality:


Identify
the
number
of
these
facilities
(
per
industrial
sector)
that
you
have.

The
roundtable
notes
did
not
reflect
any
discussion
on
this
question.
