UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
WATER
MEMORANDUM
June
24,
2004
SUBJECT:
Additional
Feedback
from
State
Pretreatment
Coordinators
to
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
several
state
pretreatment
coordinators
for
EPA
consideration
during
development
of
the
final
Effluent
Guidelines
Program
Plan
for
2004/
2005.
These
suggestions
were
triggered
by
the
2003
National
Coordinators
Workshop
and
were
transmitted
to
EPA
via
e­
mail.

Feedback
gathered
during
the
course
of
this
workshop
is
documented
in
a
separate
memo
titled
"
2003
National
Coordinators
Workshop
Feedback
for
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
4

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
relevant
to
Factor
4
soon
after
the
publication
of
the
preliminary
Plan
and
as
a
result
of
discussions
at
the
2003
National
Meeting
of
State
Pretreatment
Coordinators.
Eight
state
pretreatment
coordinators
contributed
their
feedback
on
the
preliminary
Plan:

°
Steve
Caspers,
Kansas
°
Randall
Dunnette,
Minnesota
°
Allen
Gilliam,
Arkansas
°
Gary
Kelman,
Maryland
°
Rick
Koplitz,
Colorado
°
Nilesh
Naik,
New
Jersey
°
Grace
Scott,
Michigan
°
Al
Spangler,
South
Dakota
These
suggestions
are
not
formal
comments,
but
EPA
wanted
to
record
them
here
for
the
public
record.
A
transcript
of
the
e­
mails
we
received
is
attached
to
this
memo.

Dairy
Products
Processing
(
40
CFR
405):
A
coordinator
identifies
problems
caused
by
cheese
plants
in
small
towns.
(
AS)

Electroplating
(
40
CFR
413):
There
is
no
technical
basis
for
the
4­
day
averaging
approach,
and
there
is
no
time­
frame
specified
for
doing
it.
Facilities
can
select
either
consecutive
days
or
days
spread
out
over
many
months.
In
addition,
facilities
that
were
grand­
fathered
into
the
regulation
 
job
shops
and
printed
circuit
board
manufacturing
 
as
a
way
to
provide
them
short­
term
relief,
avoid
being
moved
to
their
appropriate
category
of
metal
finishing
by
making
small
replacements
or
repairs
to
their
process
equipment.
(
GS)

Hospitals
(
40
CFR
460):
The
original
regulations
did
not
consider
discharges
of
many
of
the
pollutants
causing
concern
today,
including
mercury,
silver,
pharmaceuticals
(
including
radioactive
substances),
chromic
acid
cleaners,
and
biologicals
such
as
blood.
(
GS)

Meat
and
Poultry
(
40
CFR
432):
One
coordinator
notes
that
some
poultry
kill
plants
in
his
state
are
causing
organic
overloading
(
GA).
A
second
coordinator
identifies
problems
caused
by
meat
packers
in
small
towns
(
AS).
A
third
coordinator
asserts
that
meat
processing
facilities
in
smaller
towns
often
overwhelm
their
POTW
with
BOD
and
TSS
discharges.
His
solution
has
been
to
require
installation
of
a
dissolved
air
flotation
system
by
the
facility,
or
have
them
ship
their
wastes
to
a
rendering
facility.
(
RK)
Page
3
of
4
Metal
Finishing
(
40
CFR
433):
One
coordinator
asserts
that
pH
is
the
only
pollutant
of
concern
for
this
industry,
and
that
metal
testing
should
be
eliminated
for
the
Phosphating
subcategory.
(
GK)
Another
coordinator
suggests
that
iron
phosphaters
be
exempted.
In
addition,
there
are
zinc
phosphaters
discharging
significant
amounts
of
zinc
which
should
not
be
exempted.
(
SC)
Many
job
shops
and
printed
circuit
board
manufacturing
facilities
that
belong
in
this
category
remain
under
the
electroplating
guidelines
as
a
result
of
grand­
fathering
that
is
still
in
place.
(
GS)

Metal
Molding
and
Casting
(
40
CFR
464):
The
guidelines
for
this
point
source
category
received
the
most
attention
from
the
pretreatment
coordinators
­
4
out
of
the
8
discussed
it.
One
coordinator
notes
that
die
casting
is
production
based.
This
results
in
a
lot
of
small
shops
being
often
out
of
compliance
because
they
can't
meet
the
limits
at
their
low
production
volumes.
(
GS).
A
second
coordinator
reports
that
die
casters
have
constant
problems
with
the
total
phenols
and
oil
&
grease
limits.
(
AG)

Another
coordinator
identifies
a
problem
with
the
definitions
for
casting
cleaning
operations
(
listed
in
the
aluminum
casting
and
ferrous
casting
subcategories).
Because
of
the
way
the
definitions
at
464.02
(
a)
"
Aluminum
Casting"
and
464.02
(
b)
"
Ferrous
Casting"
are
written,
cleaning
operations
are
not
captured
by
the
regulation.
A
simple
solution
is
to
correct
the
general
definitions.
See
suggestions
in
the
following
paragraph.
An
alternative
to
changing
the
definitions
would
be
to
eliminate
the
allocations
for
casting
cleaning
from
these
subcategories
since
it
applies
to
an
operation
that
cannot
exist
under
this
regulation
the
way
it
is
written.

For
the
aluminum
casting
definition,
insert
the
underlined
text
"
Processing
operations
following
the
cooling
of
castings
not
covered
under
aluminum
forming,
except
for
grinding
scrubber
operations
and
casting
cleaning
operations,
which
are
covered
here,
are
covered
under
electroplating
and
metal
finishing
point
source
categories
(
40
CFR
413
&
433)."
For
the
ferrous
casting
definition,
insert
the
underlined
text
"
Except
for
grinding
scrubber
operations
and
casting
cleaning
operations
which
are
covered
here,
processing
operations
following
the
cooling
of
castings
are
covered
under
electroplating
and
metal
finishing
point
source
categories
(
40
CFR
413
&
433)."
(
RD)

A
fourth
coordinator
notes
that
in
the
aluminum
forming
subcategory,
production
standards
result
in
extremely
low
permit
limits.
Whenever
production
changes
by
as
little
as
20%,
permit
limits
have
to
be
changed
accordingly.
Concentration
based
standards
would
save
the
endless
modification
and
the
associated
administrative
burden.
It
also
seems
inconsistent
to
require
metal
finishers
to
discharge
a
pollutant
at
the
ppm
level
while
the
production
based
industry
is
required
to
meet
a
ppb
level.
(
SC)

Nonferrous
Metals
Forming
(
40
CFR
421):
Precious
Metals
Forming
Subcategory
has
production­
based
standards
that
result
in
below­
detection
concentration
limitations.
(
NM)
Page
4
of
4
Pharmaceutical
Manufacturing
(
40
CFR
439):
Ther
are
three
specific
parameters
that
facilities
must
monitor
for
annually,
whether
or
not
it
is
present,
are
isobutyraldehyde,
methyl
formate,
and
isopropyl
ether
Analysis
must
be
performed
using
Method
1666
(
per
40
CFR
439.4).
Very
few
labs
are
capable
of
analysis
for
these
parameters
using
this
method.
Therefore,
facilities
often
have
to
send
their
samples
to
out­
of­
state
labs.(
GS).

Prisons:
There
are
a
wide
range
of
substances
discharged
from
prisons,
and
includes
both
industrial
and
sanitary
wastes.
Discharges
may
be
low
and
are
often
not
continuous
(
e.
g.
only
during
daytime
hours
of
operation).
(
GS)

Soap
and
Detergent
Manufacturing
(
40
CFR
417):
This
is
the
only
industrial
category
for
which
a
COD/
BOD
ratio
approach
is
used
to
determine
compliance.
(
GS).

Steam
Electric
Power
Generation
(
40
CFR
423):
There
is
a
footnote
in
section
423.16
(
pretreatment
standards
for
existing
sources)
that
specifies
"
in
detectable
amount"
which
is
not
included
in
section
423.17
(
new
sources).
This
coordinator
assumes
EPA
intended
to
include
this
stipulation
in
both
sections,
but
it
needs
to
be
specified.
In
addition,
"
detectable
amounts"
have
changed
a
lot
since
the
regulation
was
promulgated,
and
EPA
needs
to
provide
guidelines
to
address
this
issue.
Finally,
these
guidelines
do
not
include
mercury.
(
GS)

Transportation
Equipment
Cleaning
(
40
CFR
442):
The
pollutant
minimization
plan
(
PMP)
is
causing
a
problem,
since
it
allows
facilities
to
ignore
the
limits
by
implementing
the
plan;
in
addition,
the
plan
does
not
need
POTW
acceptance
or
approval.
This
makes
it
difficult
to
evaluate
facility
compliance
(
GS).

General
for
All
Effluent
Guidelines:
One
coordinator
suggested
that
EPA
develop
water
quality
before
it
develops
any
new
categorical
limits
for
new
or
existing
pollutants.
This
would
prevent
premature
efforts
to
regulate
pollutants
whose
effects
are
not
thoroughly
characterized.
(
GK)
Leather
tanning
is
the
only
guideline
that
requires
that
a
minimum
of
8
samples
be
taken
when
determining
a
facility's
compliance
with
the
regulation.
(
See
section
425.02
section
(
i).)
Without
this
requirement,
pretreatment
coordinators
are
often
reduced
to
using
a
single
sample
point
to
determine
compliance
with
both
maximum
and
average
limits.
In
addition,
boiler
blowdown
(
produced
by
a
lot
of
industries)
discharge
effluent
containing
pollutants
of
concern,
including
biocides.
(
GS)
Page
1
of
16
Attachment:
Pretreatment
Coordinator
Email
Discussions
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
33
AM
­­­­­

"
Gary
F.
Kelman"
<
gkelman@
mde.
state.
md.
us>

01/
05/
2004
12:
01
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
·
Why
regulate
something
if
you
don't
know
how
bad
it
is?
·
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
don't
already
have
water
quality
criteria.
·
Don't
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
·
Phosphating
B
eliminate
metal
testing
·
pH
only
pollutant
of
concern
Grace
Scott
·
Need
200.8
approved
for
metals
instead
of
ATP
·
ND
B
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
B
Production
Based
·
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
·
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
·
Transportation
Equipment
Cleaning
B
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
·
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
B
there
has
got
to
be
a
better
way.
·
Pharmaceutical
Manufacturing
B
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
B
NJDEP
·
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
·
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
Page
2
of
16
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
§
Produces
a
wastewater
§
Is
not
post
cooling
and
§
Is
not
casting
quench.

­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
34
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Mee
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
34
AM
­­­­­

Grace
Scott
<
SCOTTG@
michigan.
gov>

01/
05/
2004
01:
52
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Mee
Thanks
Gary..
EPA
in
its
wisdom
has
excluded
indirect
industries
from
its
Effluent
Guidelines
Plan.
Can
somebody
help
me
understand
this?

Grace
L.
Scott
Pretreatment
Coordinator
MDEQ­
Water
Division
Constitution
Hall,
2
Flr,
S
PO
Box
30273
Lansing,
MI
48909­
7773
Phone:
517­
335­
4107
Fax:
517­
373­
2040
e­
mail:
scottg@
mi.
gov
>>>
gkelman@
mde.
state.
md.
us
01/
05/
04
12:
01PM
>>>
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.
Page
3
of
16
Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
+
Why
regulate
something
if
you
donÆt
know
how
bad
it
is?
+
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
donÆt
already
have
water
quality
criteria.
+
DonÆt
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
+
Phosphating
û
eliminate
metal
testing
+
pH
only
pollutant
of
concern
Grace
Scott
+
Need
200.8
approved
for
metals
instead
of
ATP
+
ND
û
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
û
Production
Based
+
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
+
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
+
Transportation
Equipment
Cleaning
û
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
+
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
û
there
has
got
to
be
a
better
way.
+
Pharmaceutical
Manufacturing
û
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
û
NJDEP
+
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
+
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
º
Produces
a
wastewater
º
Is
not
post
cooling
and
º
Is
not
casting
quench.

­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
34
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Page
4
of
16
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
34
AM
­­­­­

"
Gilliam,
Allen"
<
GILLIAM@
adeq.
state.
ar.
us>

01/
05/
2004
02:
56
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Question
to
all
to
help
kick
this
around
more
with
some
finger
pointing....

If
you
had
one
or
two
cats
or
even
a
non­
cat
siu
that
was
almost
continually
in
non­
compliance,
who
might
that
be?
Or
some
that
just
can't
stay
in
compliance
for
a
half
year
for
a
parameter
or
two?

I
got
some
die
casters
who
are
always
fighting
their
(
almost
n.
d.)
t.
phenols
and
o&
g
limits
and
some
poultry
kill
plants
that
are
always
causing
organic
overloading
over
here.
Amsa's
"
don't
touch
our
city's
surcharges"
hasn't
caught
on
real
good
over
here
with
the
amsa
non­
members
and
local
politics.

Anyone
got
some
problem
industries
that
epa
could
re­
focus
on
because
of
unrealistic
limits
basis
(
recycle
rates
unachievable,
eg),
water
conservation,
changed
processes
and
p2,
or
epa
being
skeert
off
because
of
amsa's
4000
duplicated
comments
("
we
don't
need
no
more
steenking
regulations!")?

­­­­­
Original
Message­­­­­
From:
Gary
F.
Kelman
[
mailto:
gkelman@
mde.
state.
md.
us]
Sent:
Monday,
January
05,
2004
11:
01
AM
To:
statepretcoord
Subject:
[
statepretcoord]
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
·
Why
regulate
something
if
you
don't
know
how
bad
it
is?
·
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
don't
already
have
water
quality
criteria.
·
Don't
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
Page
5
of
16
·
Phosphating
­
eliminate
metal
testing
·
pH
only
pollutant
of
concern
Grace
Scott
·
Need
200.8
approved
for
metals
instead
of
ATP
·
ND
­
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
­
Production
Based
·
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
·
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
·
Transportation
Equipment
Cleaning
­
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
·
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
­
there
has
got
to
be
a
better
way.
·
Pharmaceutical
Manufacturing
­
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
­
NJDEP
·
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
·
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
§
Produces
a
wastewater
§
Is
not
post
cooling
and
§
Is
not
casting
quench.

­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
35
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
Page
6
of
16
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
35
AM
­­­­­

SCaspers@
kdhe.
state.
ks.
us
01/
05/
2004
03:
41
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Gilliam@
adeq.
state.
ar.
us,
gkelman@
mde.
state.
md.
ks
Subject:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Allen,
I
do
not
have
any
IU's
consistently
out
of
compliance
any
longer.
Once
we
had
them
install
treatment
systems,
the
occasional
but
chronic
compliance
problems
all
went
away.

I
do
have
one
general
comment
regarding
production
based
standards,
like
the
Aluminium
Forming
(
casting)
standard
Production
based
standards
are
a
pain
and
usually
end
up
with
unbelievably
low
permit
limits,
as
mentioned
by
Allen.
Each
time
production
changes
+/­
20%,
permit
limits
have
to
change,
accordingly.
I
finally
changed
our
permits
to
have
"
floating"
limits,
in
lieu
of
the
tiered
permit
approach
used
in
the
past,
due
to
the
administrative
headaches
of
having
to
constantly
modify
permits.
My
point
is
I
would
rather
EPA
develop
concentration
based
standards
in
the
future,
in
lieu
of
production
based
standards.
To
me
it
does
not
make
any
sense
to
allow
a
metal
finisher
to
discharge
a
pollutant
in
ppm
but
only
allow
a
production
based
industry
to
discharge
the
same
pollutant
in
ppb.

Gary,
I
hope
to
add
to
your
list
sometime
this
week.
I
also
propose
you
modify
the
item
on
Metal
Finishing
to
specify
that
we
exempt
"
iron
phosphaters",
in
particular.
There
are
cases
where
zinc
phosphaters,
subject
to
433
can
contribute
significant
amounts
of
zinc,
which
should
not
be
exempted.

*****************************************************************************

Steve
Caspers,
Pretreatment
Specialist,
State
of
Kansas
E­
mail
address:
SCaspers@
kdhe.
state.
ks.
us
785­
296­
5551
Fax
785­
296­
0086
*****************************************************************************
roup:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
·
Why
regulate
something
if
you
don't
know
how
bad
it
is?
·
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
don't
already
have
water
quality
criteria.
·
Don't
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
·
Phosphating
B
eliminate
metal
testing
·
pH
only
pollutant
of
concern
Grace
Scott
·
Need
200.8
approved
for
metals
instead
of
ATP
Page
7
of
16
·
ND
B
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
B
Production
Based
·
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
·
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
·
Transportation
Equipment
Cleaning
B
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
·
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
B
there
has
got
to
be
a
better
way.
·
Pharmaceutical
Manufacturing
B
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
B
NJDEP
·
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
·
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
§
Produces
a
wastewater
§
Is
not
post
cooling
and
§
Is
not
casting
quench.

­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
36
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
b
y
State
Coordinators
from
2003
National
Meeting
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
36
AM
­­­­­

Albert.
Spangler@
state.
sd.
us
01/
05/
2004
03:
48
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
b
y
State
Coordinators
from
2003
National
Meeting
Page
8
of
16
My
main
problem
children
are
the
meat
packers
and
cheese
plants
in
small
towns.
The
approved
cities
in
SD
have
some
problems
with
metal
finishers
but
these
are
almost
always
local
limits
issues
and
not
problems
with
the
categorical
standards.

­­­­­
Original
Message­­­­­
From:
Gilliam,
Allen
[
mailto:
GILLIAM@
adeq.
state.
ar.
us]
Sent:
Monday,
January
05,
2004
1:
56
PM
To:
statepretcoord
Subject:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Question
to
all
to
help
kick
this
around
more
with
some
finger
pointing....

If
you
had
one
or
two
cats
or
even
a
non­
cat
siu
that
was
almost
continually
in
non­
compliance,
who
might
that
be?
Or
some
that
just
can't
stay
in
compliance
for
a
half
year
for
a
parameter
or
two?

I
got
some
die
casters
who
are
always
fighting
their
(
almost
n.
d.)
t.
phenols
and
o&
g
limits
and
some
poultry
kill
plants
that
are
always
causing
organic
overloading
over
here.
Amsa's
"
don't
touch
our
city's
surcharges"
hasn't
caught
on
real
good
over
here
with
the
amsa
non­
members
and
local
politics.

Anyone
got
some
problem
industries
that
epa
could
re­
focus
on
because
of
unrealistic
limits
basis
(
recycle
rates
unachievable,
eg),
water
conservation,
changed
processes
and
p2,
or
epa
being
skeert
off
because
of
amsa's
4000
duplicated
comments
("
we
don't
need
no
more
steenking
regulations!")?

­­­­­
Original
Message­­­­­
From:
Gary
F.
Kelman
[
mailto:
gkelman@
mde.
state.
md.
us]
Sent:
Monday,
January
05,
2004
11:
01
AM
To:
statepretcoord
Subject:
[
statepretcoord]
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
·
Why
regulate
something
if
you
don't
know
how
bad
it
is?
·
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
don't
already
have
water
quality
criteria.
·
Don't
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
·
Phosphating
­
eliminate
metal
testing
·
pH
only
pollutant
of
concern
Grace
Scott
Page
9
of
16
·
Need
200.8
approved
for
metals
instead
of
ATP
·
ND
­
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
­
Production
Based
·
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
·
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
·
Transportation
Equipment
Cleaning
­
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
·
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
­
there
has
got
to
be
a
better
way.
·
Pharmaceutical
Manufacturing
­
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
­
NJDEP
·
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
·
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
§
Produces
a
wastewater
§
Is
not
post
cooling
and
§
Is
not
casting
quench.

­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
36
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
36
AM
­­­­­
Page
10
of
16
Rick
Koplitz
<
rick.
Koplitz@
state.
co.
us>

01/
05/
2004
03:
55
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
RE:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Since
Colorado
is
not
a
delegated
state
we
only
permit
categoricals
in
non­
approved
programs.
However
I
have
spent
most
of
my
time
in
smaller
towns
that
have
meat
processing
facilities
that
overwhelm
the
POTW.
Mostly
from
BOD
and
TSS
discharges.
In
each
case
I
have
had
to
require
the
meat
processor
to
install
a
DAF
system,
(
depending
on
the
size
of
the
facility),
or
completely
containerize
all
waste
and
ship
it
off
to
a
renderer.

Happy
New
Year
to
all
you
state
coordinizers!

Rick
Rick
Koplitz
Pretreatment
Coordinator
Water
Quality
Control
Division
4300
Cherry
Creek
Drive
South
Denver,
CO
80246
Phone:
303­
692­
3618
Fax:
303­
782­
0390
email:
rick.
koplitz@
state.
co.
us
>>>
GILLIAM@
adeq.
state.
ar.
us
1/
5/
2004
12:
56:
13
PM
>>>
Question
to
all
to
help
kick
this
around
more
with
some
finger
pointing....

If
you
had
one
or
two
cats
or
even
a
non­
cat
siu
that
was
almost
continually
in
non­
compliance,
who
might
that
be?
Or
some
that
just
can't
stay
in
compliance
for
a
half
year
for
a
parameter
or
two?

I
got
some
die
casters
who
are
always
fighting
their
(
almost
n.
d.)
t.
phenols
and
o&
g
limits
and
some
poultry
kill
plants
that
are
always
causing
organic
overloading
over
here.
Amsa's
"
don't
touch
our
city's
surcharges"
hasn't
caught
on
real
good
over
here
with
the
amsa
non­
members
and
local
politics.

Anyone
got
some
problem
industries
that
epa
could
re­
focus
on
because
of
unrealistic
limits
basis
(
recycle
rates
unachievable,
eg),
water
conservation,
changed
processes
and
p2,
or
epa
being
skeert
off
because
of
amsa's
4000
duplicated
comments
("
we
don't
need
no
more
steenking
regulations!")?

­­­­­
Original
Message­­­­­
From:
Gary
F.
Kelman
[
mailto:
gkelman@
mde.
state.
md.
us]
Sent:
Monday,
January
05,
2004
11:
01
AM
To:
statepretcoord
Subject:
[
statepretcoord]
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Meeting
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Page
11
of
16
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
·
Why
regulate
something
if
you
don't
know
how
bad
it
is?
·
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
don't
already
have
water
quality
criteria.
·
Don't
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
·
Phosphating
­
eliminate
metal
testing
·
pH
only
pollutant
of
concern
Grace
Scott
·
Need
200.8
approved
for
metals
instead
of
ATP
·
ND
­
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
­
Production
Based
·
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
·
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
·
Transportation
Equipment
Cleaning
­
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
·
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
­
there
has
got
to
be
a
better
way.
·
Pharmaceutical
Manufacturing
­
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
­
NJDEP
·
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
·
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
§
Produces
a
wastewater
§
Is
not
post
cooling
and
§
Is
not
casting
quench.

­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Page
12
of
16
­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
37
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
37
AM
­­­­­

Grace
Scott
<
SCOTTG@
michigan.
gov>

01/
05/
2004
04:
25
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Yes,
exactly.
Seems
like
a
logical
fit
for
it
to
be
considered
with
304(
m).
Will
we
see
a
304(
g)
assessment
performed
separately?

>>>
Pickrel.
Jan@
epamail.
epa.
gov
01/
05/
04
03:
53PM
>>>

Clean
Water
Act
(
CWA)
Section
304(
m),
which
requires
the
Effluent
Guidelines
Program
Plan,
is
specifically
for
direct
dischargers.
The
December
31,
2003,
Federal
Register
notice
states
that
it
presents
the
"
results
of
EPA's
annual
review
of
of
the
effluent
guidelines
that
EPA
has
promulgated
under
CWA
section
304(
b)."

Indirect
dischargers
are
referenced
in
CWA
Section
304(
g)
and
are
promulgated
under
CWA
307(
b).
See
68
FR
75518
of
the
December
31,
2003
notice
(
Section
IV)
for
discussion.

Grace:
I
think
your
question,
therefore,
is:
"
Where
are
the
results
of
the
annual
review
required
by
CWA
304(
g)?!"

~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
Grace
Scott
<
SCOTTG@
michigan.
gov>
Page
13
of
16
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:
Subject:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
01/
05/
2004
01:
52
PM
by
State
National
Mee
Coordinators
from
2003
Please
respond
to
statepretcoord
Thanks
Gary..
EPA
in
its
wisdom
has
excluded
indirect
industries
from
its
Effluent
Guidelines
Plan.
Can
somebody
help
me
understand
this?
Grace
L.
Scott
Pretreatment
Coordinator
MDEQ­
Water
Division
Constitution
Hall,
2
Flr,
S
PO
Box
30273
Lansing,
MI
48909­
7773
Phone:
517­
335­
4107
Fax:
517­
373­
2040
e­
mail:
scottg@
mi.
gov
>>>
gkelman@
mde.
state.
md.
us
01/
05/
04
12:
01PM
>>>
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
+
Why
regulate
something
if
you
donÆt
know
how
bad
it
is?
+
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
donÆt
already
have
water
quality
criteria.
+
DonÆt
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
+
Phosphating
û
eliminate
metal
testing
+
pH
only
pollutant
of
concern
Grace
Scott
+
Need
200.8
approved
for
metals
instead
of
ATP
+
ND
û
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
û
Production
Based
+
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
+
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
+
Transportation
Equipment
Cleaning
û
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
+
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
û
there
has
got
to
be
a
better
way.
+
Pharmaceutical
Manufacturing
û
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
û
NJDEP
+
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
Page
14
of
16
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
+
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
º
Produces
a
wastewater
º
Is
not
post
cooling
and
º
Is
not
casting
quench.

­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

­­­­­
Forwarded
by
Carey
Johnston/
DC/
USEPA/
US
on
06/
07/
2004
02:
39
PM
­­­­­

Jan
Pickrel
06/
07/
2004
11:
37
AM
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA
cc:
Subject:
Fw:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Mee
~*^*~*^*~*^*~*^*~*^*~*^*~
Jan
Pickrel
Water
Permits
Division,
Industrial
Branch
US
Environmental
Protection
Agency
phone:
(
202)
564­
7904.
fax:
(
202)
564­
6431.
pickrel.
jan@
epa.
gov
­­­­­
Forwarded
by
Jan
Pickrel/
DC/
USEPA/
US
on
06/
07/
2004
11:
37
AM
­­­­­

Grace
Scott
<
SCOTTG@
michigan.
gov>

01/
05/
2004
04:
56
PM
Please
respond
to
statepretcoord
To:
statepretcoord
<
statepretcoord@
lists.
epa.
gov>
cc:

Subject:
[
statepretcoord]
Re:
Comments
on
Categorical
Standards,
Etc
by
State
Coordinators
from
2003
National
Mee
As
a
clarification
*
the
issue
is
to
have
all
136
info
reported.
403.12(
g)(
5)
requires
all
monitoring
to
be
reported
for
CIUs.
403.12(
h)
places
the
burden
on
the
POTW
to
require
appropriate
reporting.
Of
course
this
should
include
all
monitoring
that
is
performed
using
136,
not
just
the
minimum
required.
Page
15
of
16
>>>
gkelman@
mde.
state.
md.
us
01/
05/
04
12:
01PM
>>>
Group:

Here
are
the
comments
on
categorical
standards
from
the
State
Pretreatment
Coordinators
came
up
with
at
the
national
meeting
in
Seattle.
I
know
that
we
have
more
than
this
judging
from
the
conversations
at
our
meeting.
Additional
comments
may
be
included
in
the
notes
from
the
meeting.
If
I
misinterpreted
your
comments
please
offer
your
corrections.

Gary
Kelman,
Maryland
State
Pretreatment
Coordinator
+
Why
regulate
something
if
you
donÆt
know
how
bad
it
is?
+
Develop
water
quality
criteria
for
any
categorically
regulated
pollutants
that
donÆt
already
have
water
quality
criteria.
+
DonÆt
develop
any
new
categorical
limits
for
new
or
existing
pollutants
without
first
developing
water
quality
criteria.

Metal
Finishing
+
Phosphating
û
eliminate
metal
testing
+
pH
only
pollutant
of
concern
Grace
Scott
+
Need
200.8
approved
for
metals
instead
of
ATP
+
ND
û
Power
Plants
o
4­
day
ave
Electroplating
o
Grandfathering
of
job
shops
and
PCB
manufacturing
o
Die
Casting
û
Production
Based
+
Would
like
to
see
minimum
monitoring
like
leather
tanning
(
8
samples).
+
403
needs
fix
to
require
all
monitoring
not
just
CIU
to
be
136.
+
Transportation
Equipment
Cleaning
û
PMP
problem
no
limits.
Difficult
to
evaluate
compliance.
+
Soap
and
Detergent
Manufacturing:
COD/
BOD
ratio
û
there
has
got
to
be
a
better
way.
+
Pharmaceutical
Manufacturing
û
Very
few
labs
capable
of
analyis
for
some
parameters.

Nicesh
Maik
û
NJDEP
+
471
Non­
Ferrous
Metals
Forming,
Precious
Metals
Forming
Subcategory
o
production
based
standards
results
in
below
detection
concentration
limitations.

Randy
Dunnette
+
Metal
Molding
and
Casting
Category
o
The
casting
cleaning
operation,
listed
in
aluminum
casting
and
ferrous
casting
subcategories,
does
not
occur
and
cannot
possibly
occur
given
the
definitions
and
conditions
in
the
regulation.
o
The
casting
cleaning
operation
should
be
eliminated,
or
the
definitions,
etc.
changed
so
that
the
casting
cleaning
operation
applies
properly.
o
The
definitions
of
the
specific
types
of
casting
make
it
clear
that
this
categorical
standard
applies
only
to
pre­
cooling
operations
(
except
grinding
scrubber).
o
All
sub­
categories
have
a
casting
quench
operation.
I
cannot
conceive
of
a
casting
cleaning
operation
that:
º
Produces
a
wastewater
º
Is
not
post
cooling
and
º
Is
not
casting
quench.
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