Page
1
of
3
2006
Effluent
Guidelines
Program
Plan
Issue/
Industry
Voluntary
Nomination
Form
Instructions:

(
1)
Please
use
separate
forms
if
you
would
like
to
report
information/
suggestions
on
more
than
one
industry
or
technology.

(
2)
Please
return
the
completed
form
to
the
following
e­
mail
­
johnston.
carey@
epa.
gov
­
with
the
subject,
"
304(
m)
Issue/
Industry
Nomination
Form".
Any
additional
hard
copy
information
should
be
sent
to
Mr.
Carey
Johnston
at
mail
code
4303T.
Questions
on
this
form
can
also
be
directed
to
Mr.
Johnston
(
202­
566­
1014)

(
3)
Deadline
for
Submission
is
May
31,
2005.

Submission
Form
1.
Date
of
Submission:
May
31,
2005
2.
Name:
David
Phillips
3.
Contact
Information:
(
404)
562­
9773
4.
Office/
Division/
Branch/
Region/
State:
Region
4/
WMD/
WPEB
Issues/
Industries
5.
Identification
of
Industry
or
Issue.

Since
the
pretreatment
standards
for
40
CFR
423
were
promulgated,
there
have
been
changes
in
the
Steam
Electric
Power
Generating
industry
which
warrant
revision
to
the
applicability
section
of
this
regulation.
When
they
were
promulgated,
refuse
derived
fuel
(
RDF)
facilities
were
not
in
existence
and
therefore
were
not
considered
under
the
rule.
These
facilities
generate
large
quantities
of
ash
with
the
same
and/
or
greater
pollutant
loads
than
conventional
systems
presently
covered.
Office
of
General
Counsel
has
informed
us
that
Part
423
does
not
presently
apply
to
RDF
facilities
as
they
read
the
present
regulation.
Since
RDF
facilities
may
be
owned
by
the
same
municipality
that
has
pretreatment
Control
Authority,
there
are
internal
politics
that
often
prevent
self­
policing.
Updating
Part
423
so
it
will
apply
to
these
facilities
is
paramount
if
POTW
pass­
through
and
interference
is
going
to
protected
from
these
operations.

6.
Please
provide
any
information
that
you
have
which
describes
the
universe
and
geographic
distribution
of
affected
facilities.
Also,
please
identify
relevant
EPA
and
Page
2
of
3
external
data
sources
(
e.
g.
permit
numbers).

In
Region
4,
we
have
at
least
one
massive
RDF
facility
that
has
caused
problems
for
its
pretreatment
Control
Authority
with
ash
interference,
to
the
point
monitoring
samples
can
not
be
taken
and
the
flow
monitor
is
rendered
inoperable.
EPA
issues
the
NPDES
permit
for
Miami­
Dade
County
(
FL0024805).
The
name
of
the
RDF
facility
they
permit
is
Dade
County
Resources
Recovery.
It
has
four
boilers
which
power
two
turbines
used
to
generate
electricity.
The
boilers
are
fueled
by
a
combination
of
yard
waste
and
solid
waste
that
has
been
separated
from
other
recyclable
components.
The
facility
has
the
largest
capacity
of
its
type
in
the
world
(
according
to
the
contract
operators,
Montenay
Power
Corp.),
processing
more
than
1.2
million
tons
of
waste
annually,
about
4,200
tons
per
day.
The
power
facility
generates
up
to
76
Megawatts,
enough
to
power
itself
and
45,000
homes.

7.
Do
you
have
suggestions
on
how
to
address
the
issue/
industry
which
you
have
identified?
Do
you
think
an
effluent
guidelines
rulemaking
is
warranted?

Revise
the
applicability
section
of
Part
423
to
include
operations
which
generate
electricity
from
processes
using
refuse­
derived
fuel.

8.
Have
EPA
or
the
States
dealt
with
this
issue/
industry
in
the
past
(
other
than
through
an
effluent
guidelines)?
If
so,
do
you
know
what
prompted
that
activity
and
can
you
describe
the
results?

Not
to
my
knowledge.
I
know
that
Part
423
has
been
on
the
Effluent
Guidelines
Development
Plan
list
for
regulations
subject
to
revision.

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?

EPA
Regional
Pretreatment
Coordinators
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA)

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

You
can
keep
me
informed.

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).
Page
3
of
3
I
know
the
pretreatment
coordinator
for
Miami­
Dade,
Mr.
Fernando
Bestard
(
305­
372­
6510).
He
is
familiar
with
the
Dade
Co.
Resources
Recovery
facility
and
the
history
of
problems
it
has
caused.
The
pretreatment
inspector
for
that
facility,
whom
he
supervises,
is
Mr.
Erlando
Javellana
(
305­
372­
6530).

Information
on
Pollution
Prevention
or
Treatment
Technology
12.
Identification
of
Facilities
That
May
be
Using
Advanced/
Innovative
Pollution
Prevention
or
Treatment
Technology
Unknown
13.
Please
provide
any
information
that
you
have
which
can
be
used
to
characterize
the
performance
of
the
technology.

N/
A
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).

Unknown
