
.
Signature:
Project
No.:
0172.01.005.071
 
DISTRIBUTION
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Project
Name:
304m
Industry
Investigations:
Timber
Products
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
January
20,
2004
Time:
11:
30
AM
Company
Name:
Eastern
Research
Group,
Inc.
Contact
Name:
Sheri
Festoso,
Alabama
DEP
Phone
No.:
334­
271­
7945
Name:
Laurie
Morgan
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
NPDES
Permits
for
Wood
Treating
Facilities
TOPICS
DISCUSSED
AND
ACTION
TAKEN
I
was
referred
to
Sheri
Festoso,
Alabama
DEP,
by
Roosevelt
Childress,
EPA
Region
4.
I
sent
her
an
e­
mail
message
explaining
that
ERG
is
supporting
EPA
Office
of
Water,
Engineering
and
Analysis
Division
in
their
development
of
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
(
and
subsequent
plans,
as
well).
Part
of
our
support
includes
reviewing
wastewater
discharges
reported
in
TRI
and
PCS,
giving
high
priority
to
industrial
categories
with
larger
loads
of
toxic
pollutants.
One
of
these
industries
is
the
wood
preserving
industry.

I
explained
that
I
wanted
to
know
more
about
NPDES
permits
issued
to
wood
preserving
facilities.

How
you
determine
which
wastewaters
are
stormwater
(
and
not
process
waters
that
should
not
be
discharged)?
Sheri
explained
that
Alabama
does
not
have
a
general
stormwater
permit
for
wood
preserving
facilities.
Instead,
each
facility
is
issued
an
individual
NPDES
permit.
For
most
of
these
facilities,
the
permitted
wastewater
discharge
is
stormwater.
She
estimated
that
fewer
than
5
facilities
have
process
wastewater
discharges
(
note
that
the
effluent
guidelines
for
40
CFR
Part
429,
are
no
discharge
of
process
wastewater
for
waterborne
(
CCA)
preserving
and
the
Bolton
process
subcategories.
There
are
only
BPT
discharge
limits
for
the
steam
subcategory).
Sheri
estimated
that
75%
of
the
wood
treaters
in
Alabama
are
small
CCA
operations.

Facilities
submit
an
application
(
2F)
for
their
NPDES
permit
on
which
they
certify
that
they
have
no
process
wastewater
discharges.
For
the
CCA
treaters,
runoff
collected
from
the
wood
yard
and
drip
pad
is
reused
in
the
treatment
process,
sometimes
after
some
simple
treatment
to
remove
solids.

Production
information
is
submitted
with
the
permit
application
on
an
"
8M
form."
This
includes
the
type
of
wood
preservatives
used
as
well
as
the
amount
of
wood
treated.

Each
facility
must
submit
an
application
which
is
reviewed
by
the
state.
The
individual
permits
are
very
similar,
in
terms
of
the
pollutants
that
are
monitored
(
usually
metals)
and
the
frequency
of
monitoring.
Permit
Page
2
of
2
.
Signature:
requirements
include
a
written
BMP
plan,
with
steps
to
minimize
the
contact
of
stormwater
with
process
chemicals.
The
BMP
plans
are
not
submitted
to
the
state,
but
kept
at
the
facility.
The
permits
also
include
monitoring,
on
a
quarterly
or
2x/
yearly
basis.
The
monitoring
results
are
submitted
to
the
state.
"
Minor
industrial
dischargers"
permitted
after
July
1,
2001
are
submitting
their
monitoring
results
on
pre­
printed
forms.
These
results
are
entered
into
a
database.
Sheri
wasn't
certain,
but
suggested
that
the
database
would
get
to
PCS.
The
state
contact
is
Mike
McCarry.
Facilities
with
permits
dating
before
July
2001
are
submitting
their
results
on
spreadsheets,
and
these
results
are
not
included
in
the
database.

Sheri
said
that
the
Alabama
wood
preserving
facilities
typically
have
two
to
four
discharge
points,
with
usually
one
that
is
the
most
contaminated.
Discharges
from
the
fueling
areas
may
have
limits
for
O&
G
and
BTEX,
but
for
the
other
discharges
typically
only
monitoring
is
required.
Some
sites
may
have
an
oil/
water
separator
to
meet
the
O&
G
limits.

Evaluation
of
compliance
includes
review
of
the
monitoring
results.
If
high
releases
are
noted,
the
state
might
ask
for
a
copy
of
the
BMP
plan
and
ask
for
revisions
to
the
plan
if
it
is
found
deficient.
During
inspections,
they
check
to
make
sure
the
process
wastewater
is
not
discharged,
but
handled
in
a
closed­
loop
system.
Sheri
feels
that
there
is
pretty
good
compliance
with
BMPs
and
reporting
requirements.

How
do
you
determine
which
treatment
units
are
wastewater
treatment
units,
and
not
RCRA
TSD
units?
Sheri
has
not
had
interaction
with
RCRA
permitting
or
enforcement
at
wood
preserving
facilities.
She
did
not
have
anything
to
say
about
the
potential
for
permitting
wastewater
releases
in
order
that
the
treatment
units
would
have
a
wastewater
exemption
from
RCRA
requirements.
She
offered
to
try
to
identify
a
RCRA
enforcement
contact.

What
do
you
find
the
most
confusing
and
controversial
issues
in
permitting
wood
treating
facilities,
and
if
any
changes
to
the
existing
effluent
guidelines
(
40
CFR
Part
429)
would
help.
Sheri
was
not
familiar
with
the
existing
effluent
guidelines,
since
they
don't
apply
to
stormwater
releases.
She
noted
that
it
is
very
difficult
to
develop
water­
quality
based
permits
for
the
wood
preserving
facilities,
because
the
stormwater
releases
are
intermittent
and
quite
variable
in
flow
volume
and
pollutant
concentration.
