VWEA Pretreatment Training Course: Categorical Standards

Transcription

1 VWEA Pretreatment Training Course: Categorical Standards Sponsored by Virginia Water Environment Association Industrial Waste & Pretreatment Committee

2 40 CFR Part 403 U.S. Code of Federal Regulations(CFR) >Title 40 - Protection of the Environment >Chapter I - Environmental Protection Agency >Subchapter N - Effluent Guidelines and Standards > Part General Pretreatment Regulations for Existing and New Sources of Pollution

3 40 CFR Part 403 Objectives To prevent the introduction of pollutants into POTWs which will: interfere, pass through, and/or be incompatible. To improve opportunities to recycle and reclaim wastewaters and sludges. To protect POTW workers.

4 Injury to Workers from Hazardous Fumes Limitations on Sludge Disposal Options and/or Greater Expense Corrosion of Collection System and/or Treatment Plant Explosions Interference with Wastewater Treatment Facility Pass-Through of Toxics into Surface Waters

5 Standards Prohibitions Categorical (Effluent Guidelines) Local Limits

6 General Prohibitions Pass-through - Discharge which exits the POTW into waters of the U.S. in quantities or concentrations which, alone or in conjunction with other sources, results in a violation of any provision of the POTW s discharge permit. Interference - Discharge which, alone or in conjunction with other sources, inhibits or disrupts the POTW s treatment processes or sludge disposal practices and is the cause of a discharge permit violation and/or prevents proper sludge disposal.

7 Specific Prohibitions [40 CFR 403.5(b)] 1) Pollutants which create a fire or explosion hazard; 2) Pollutants which will cause corrosive structural damage to the POTW; 3) Solid or viscous pollutants causing obstruction and resulting in interference; 4) Pollutants released at a flow rate and/or concentration causing interference

8 Specific Prohibitions [40 CFR 403.5(b)] 5) Heat in amounts which will inhibit biological activity in the POTW resulting in interference; 6) Oils in amounts that will cause interference or pass through; 7) Pollutants which result in the presence of toxic gases, vapors, or fumes; and 8) Trucked or hauled pollutants, except at discharge points designated by the POTW.

9 Categorical Standards National, uniform, technologybased standards Specific industrial categories Specific pollutants Protect POTW 40 CFR Parts

10 Categorical Pretreatment Standards (or simply Categorical Standards) Technology-based CWA ''307(b) and (c)

11 From Proposal to Codification Proposed Regulations Proposed Development Document Public Comment Revisions Code of Federal Regulations Promulgation of Final Regulations Final Development Document

12 Categorical Regulations: Subparts Manufacturing processes employed Raw materials used Types of items produced Characteristics of typical wastes generated

13 Categorical Regulations: Existing vs. New Source New source, 40 CFR 403.3(m) Construction date Total replacement Substantially independent Compliance dates Interpretations

14 Categorical Regulations: General Provisions Applicability Definitions Monitoring and reporting requirements Compliance dates for PSES Other

15 Categorical Regulations: Elements of a Subpart Applicability Specialized definitions Effluent limitations and standards, i.e., BPT, BAT, BCT, PSES, NSPS, and PSNS

16 Effluent Limitations and Standards: Best Practicable Control Technology Currently Available (BPT) Average of best existing performance by plants Relationship of costs, burden, and benefits considered in development Apply to direct dischargers only

17 Effluent Limitations and Standards: Best Available Technology Economically Achievable (BAT) Best existing performance Principal national means for control of direct discharges of toxic and nonconventional pollutants Apply to direct dischargers only

18 Effluent Limitations and Standards: Best Conventional Pollutant Control Technology (BCT) Replaces BPT for control of conventional pollutants Development involves cost reasonableness test Cannot be less stringent than BPT Apply to direct dischargers only

19 Effluent Limitations and Standards: New Source Performance Standards (NSPS) Best available demonstrated technology Toxic, conventional, and nonconventional pollutants Apply to direct dischargers only

20 Effluent Limitations and Standards: Pretreatment Standards (PSES and PSNS) Requires EPA determine Pass through Pollutant by pollutant For removal of toxic pollutants PSES are analogous to BAT PSNS are analogous to NSPS

21 PART 433 METAL FINISHING POINT SOURCE CATEGORY Subpart A Metal Finishing Subcategory Sec Applicability; description of the metal finishing point source category Specialized definitions Monitoring requirements Effluent limitations representing the degree of effluent reduction attainable by applying the best practicable control technology currently available (BPT) Effluent limitations representing the degree of effluent reduction attainable by applying the best available technology economically achievable (BAT) Pretreatment standards for existing sources (PSES) New source performance standards (NSPS) Pretreatment standards for new sources (PSNS).

22 Applicability; description of the metal finishing point source category. (a) Except as noted in paragraphs (b) and (c), of this section, the provisions of this subpart apply to plants which perform any of the following six metal finishing operations on any basis material: Electroplating, Electroless Plating, Anodizing, Coating (chromating, phosphating, and coloring), Chemical Etching and Milling, and Printed Circuit Board Manufacture. If any of those six operations are present, then this part applies to discharges from those operations and also to discharges from any of the following 40 process operations: Cleaning, Machining, Grinding, Polishing, Tumbling, Burnishing, Impact Deformation, Pressure Deformation, Shearing, Heat Treating, Thermal Cutting, Welding, Brazing, Soldering, Flame Spraying, Sand Blasting, Other Abrasive Jet Machining, Electric Discharge Machining, Electrochemical Machining, Electron Beam Machining, Laser Beam Machining, Plasma Arc Machining, Ultrasonic Machining, Sintering, Laminating, Hot Dip Coating, Sputtering, Vapor Plating, Thermal Infusion, Salt Bath Descaling, Solvent Degreasing, Paint Stripping, Painting, Electrostatic Painting, Electropainting, Vacuum Metalizing, Assembly, Calibration, Testing, and Mechanical Plating. (b) In some cases effluent limitations and standards for the following industrial categories may be effective and applicable to wastewater discharges from the metal finishing operations listed above. In such cases these part 433 limits shall not apply and the following regulations shall apply: Nonferrous metal smelting and refining (40 CFR part 421) Coil coating (40 CFR part 465) Porcelain enameling (40 CFR part 466) Battery manufacturing (40 CFR part 461) Iron and steel (40 CFR part 420) Metal casting foundries (40 CFR part 464) Aluminum forming (40 CFR part 467) Copper forming (40 CFR part 468) Plastic molding and forming (40 CFR part 463) Nonferrous forming (40 CFR part 471) Electrical and electronic components (40 CFR part 469) (c) This part does not apply to: (1) Metallic platemaking and gravure cylinder preparation conducted within or for printing and publishing facilities; and (2) Existing indirect discharging job shops and independent printed circuit board manufacturers which are covered by 40 CFR part 413.)

23 PART 413 ELECTROPLATING POINT SOURCE CATEGORY GENERAL PROVISIONS Sec Applicability and compliance dates General definitions Monitoring requirements Standards for integrated facilities. Subpart A Electroplating of Common Metals Subcategory Applicability: Description of the electroplating of common metals subcategory Specialized definitions [Reserved] Pretreatment standards for existing sources. Subpart B Electroplating of Precious Metals Subcategory Applicability: Description of the electroplating of precious metals subcategory Specialized definitions [Reserved] Pretreatment standards for existing sources. Subpart C Electroplating of Specialty Metals Subcategory [Reserved] Subpart D Anodizing Subcategory Subpart E Coatings Subcategory Subpart F Chemical Etching and Milling Subcategory Subpart G Electroless Plating Subcategory Subpart H Printed Circuit Board Subcategory

24 PART 455 PESTICIDE CHEMICALS Sec General definitions. Subpart A Organic Pesticide Chemicals Manufacturing Subcategory Compliance date for pretreatment standards for existing sources (PSES) Applicability; description of the organic pesticide chemicals manufacturing subcategory Specialized definitions Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best conventional pollutant control technology (BCT) Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best available control technology economically achievable (BAT) New source performance standards (NSPS) Pretreatment standards for existing sources (PSES) Pretreatment standards for new sources (PSNS).

25 Subpart C Pesticide Chemicals Formulating and Packaging Subcategory Applicability; description of the pesticide formulating, packaging and repackaging subcategory Special definitions Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available, (BPT) Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best conventional pollutant control technology (BCT) Effluent limitations guidelines representing the degree of effluent reduction attainable by the application of the best available control technology economically achievable (BAT) New source performance standards (NSPS) Pretreatment standards for existing sources (PSES) Pretreatment standards for new sources (PSNS).

26 Pretreatment standards for existing sources (PSES). (a) Except as provided in 40 CFR and or in paragraph (b) of this section, no later than November 6, 1999, any existing source subject to this subpart which introduces pollutants into a publicly owned treatment works must comply with 40 CFR part 403 and achieve PSES as follows: There shall be no discharge of process wastewater pollutants. (b) Except as provided in 40 CFR and , any existing source subject to paragraph (a) of this section which introduces pollutants into a publicly owned treatment works must comply with 40 CFR part 403 and may have a pollution prevention allowable discharge of wastewater pollutants, as defined in (d), if the discharger agrees to control mechanism or pretreatment agreement conditions as follows:

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28 Industrial Categories Without PSES and PSNS Part Phosphate Manufacturing Part Coal Mining Part Mineral and Mining Processing Part Ore Mining and Dressing Part Landfills Part Gum and Wood Chemicals Manufacturing Part Explosives Manufacturing Part Photographic Processing Part Hospitals Part Metal Products & Machinery Part Concentrated Aquatic Animal Production

29 Industrial Categories Without Specific PSES and/or PSNS For example: Any existing source subject to this subpart that introduces process wastewater pollutants in a POTW must comply with 40 CFR Part 403.

30 No discharge of process wastewater pollutants

31 Categorical Pretreatment Standards Examples Concentration-based 40 CFR Parts 433 (Metal Finishing) Production-based 40 CFR Part 464 (Metal Molding & Casting) Flow-based 40 CFR Part 414 (OCPSF)

32 Wastestream Types Regulated vs. Not Regulated Unregulated Dilute

33 Wastestream Types Regulated Wastestream from an industrial process that is subject to a categorical pretreatment standard: Contains Regulated Pollutants

34 Wastestream Types Not Regulated - Unregulated Wastestream from an industrial process that is not subject to a categorical pretreatment standard and is not dilute Contains Pollutants

35 Wastestream Types Not Regulated - Dilute Wastestream considered to have only compatible pollutants and/or trace levels of regulated pollutants. Contains No Pollutants

36 Types of Standards Daily maximum Long term averages 4-day 30-day Monthly

37 Certifications, Alternative Monitoring, and Estimates Certifications Compounds not used/generated Pollutants discharge in accordance to plan Alternative monitoring Calculated estimates

38 Other Considerations... Removal credits - credit for POTW s ability to [40 CFR '403.7] remove pollutant. Fundamentally different factors - within 180 days [40 CFR '403.13] of PSES promulgation Net/Gross calculation - adjust for pollutants in [40 CFR '403.15] intake source.