FEDERAL CATEGORICAL PRETREATMENT STANDARDS
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1 FEDERAL CATEGORICAL PRETREATMENT STANDARDS Categorical Standards 101 9/22/10 MWEA Summer Camp East Lansing, MI Grace L. Scott Pretreatment Coordinator
2 Categorical Pretreatment Standards Technology-based CWA '307(b) and (c) CWA '304(m) Plan
3 Industry (IU) Categories Targeted 1976 EPA/NRDC agreement 56 categories to date 30 have Pretreatment Standards 40 CFR Parts Effluent Guidelines Plan (every 2 years)
4 From Proposal to Codification Proposed Regulations Proposed Development Document Public Comment Revisions Code of Federal Regulations Promulgation of Final Regulations Final Development Document
5 Categorical Standards: Subparts Manufacturing processes employed Raw materials used Types of items produced Characteristics of typical wastes generated
6 Categorical Standards: Existing vs. New Source New source, 40 CFR 403.3(m) Construction Total replacement Substantially independent Compliance dates Many gray areas, esp. if replacement was gradual
7 Categorical Standards: General Provisions Applicability Definitions Monitoring and reporting requirements Compliance dates for PSES Other
8 Categorical Standards: Elements of a Subpart Applicability Specialized definitions Effluent limitations and standards, i.e., BPT, BAT, BCT, PSES, NSPS, and PSNS YOU only have to be concerned with PSES & PSNS
9 Pretreatment Standards for Existing Sources and New Sources: (PSES and PSNS) Requires EPA to determine Pass through Pollutant by pollutant For removal of toxic pollutants PSES are analogous to BAT PSNS are analogous to NSPS
10 Industrial Categories Without PSES or PSNS (regs are silent ) (11 of em) CFR 422 Phosphate Mfg CFR 432 Meat & Poultry Products CFR 434 Coal Mining CFR 436 Mineral Mining & Processing CFR 438 Metal Products & Machinery CFR 440 Ore Mining and Dressing
11 Industrial Categories Without PSES or PSNS (regs are silent ) CFR 445 Landfills CFR 454 Gum & Wood Chemical Mfg CFR 457 Explosives Mfg CFR 459 Photographic Processing CFR 460 Hospitals
12 Industrial Categories Without Specific PSES and/or PSNS 11 categories too For example: Any existing source subject to this subpart that introduces process wastewater pollutants in a POTW must comply with 40 CFR Part 403.
13 CATEGORIES THAT MUST COMPLY WITH 40 CFR 403 CFR 405 Dairy Products CFR 406 Grain Mills (but, has a BOD 5 / TSS formula) CFR 407 Canned & Preserved Fruits CFR 408 Canned & Preserved Seafood CFR 409 Sugar Processing
14 CATEGORIES THAT SIMPLY MUST COMPLY WITH 40 CFR 403 CFR 410 Textile Mills CFR 411 Cement Mfg CFR 424 Ferroalloy Mfg CFR 426 Glass Mfg CFR 427 Asbestos Mfg CFR 463 Plastics Molding & Forming
15 CATEGORIES WITH NO DISCHARGE OF PROCESS WASTEWATER (just 4 of em) CFR 435 Oil & Gas Extraction CFR 446 Paint Formulating CFR 447 Ink Formulating CFR 451 Concentrated Aquatic Animal Production
16 CATEGORIES WITH SOME SORT OF PRETREATMENT STANDARD Standards could be: Concentration based ( easy to apply) Mass based (a little more difficult to apply but, not rocket science) Production based (the most difficult to apply). YOU have to know A LOT MORE about this type IU s processes including flows and production)
17 CATEGORIES WITH PSES and/or PSNS CFR 412 Confined Animal Feeding CFR 413 Electroplating CFR 414 Organic Chemicals, Plastics & Synthetic Fibers CFR 415 Inorganic Chems Mfg (weird.) CFR 417 Soap & Detergent Mfg (weird ) CFR 418 Fertilizer Mfg (weird ) CFR 419 Petroleum Refining
18 CATEGORIES WITH PSES and/or PSNS CFR 420 Iron & Steel Mfg CFR 421 Non-Ferrous Metals Mfg CFR 423 Steam Elect. Power Generating CFR 425 Leather Tanning CFR 426 Rubber Mfg CFR 429 Timber Products Processing CFR 430 Pulp, Paper & Paperboard CFR 433 Metal Finishing CFR 437 Centralized Waste Treatment
19 CATEGORIES WITH PSES and/or PSNS CFR 439 Pharmaceutical Mfg CFR 442 Transportation Equipment Cleaning CFR 443 Paving & Roofing Mtrls (Tars & Asphalt) (100 mg/l O&G) CFR 444 Waste Combustors CFR 455 Pesticide Chems CFR 458 Carbon Black Mfg (100 mg/l O&G) CFR 461 Battery Mfg
20 CATEGORIES WITH PSES and/or PSNS CFR 464 Metal Molding & Casting CFR 465 Coil Coating CFR 466 Porcelain Enameling CFR 467 Aluminum Forming CFR 468 Copper Forming CFR 469 Electrical & Electronic Components CFR 471 Non-Ferrous Metals Forming & Metal Powders
21 Pretreatment Standards Concentration-based Direct approach Mass based approach Production-based Direct approach Imposition of equivalent limits
22 CFR 433 Metal Finish Standards - PSES ( easy to apply ) (mg/ l) Daily Max Monthly Avg Cadmium (T) Chromium (T) Copper (T) Lead (T) Nickel (T) Silver (T) Zinc (T) Cyanide (T) TTO
23 CFR 414 Organic Chemicals, Plastics & Synthetic Fibers PSES (a little harder to apply) Must achieve discharges not exceeding the quantity (mass) determined by multiplying the process wastewater flow subject to this subpart times the concentration listed in the following table. (ug/l) Daily Max Monthly Avg Acenaphthene Anthracene Benzene Bis(2-ethylhexyl) phthalate Carbon Tetrachloride Chlorobenzene
24 PRODUCTION BASED INDUSTRY Aluminum Forming PSNS Subpart A, Casting Cleaning Subcategory mg/off-kg (pounds/per million off pounds) of aluminum cleaned or etched
25 THE DREADED COMBINED WASTESTREAM FORMULA (CWF) C T = alt. conc. limit C i = conc. limit for reg d stream F i = avg flow for reg d stream F D = avg flow for dilution streams
26 Similar CWF for Mass based alternative
27 Types of Standards Daily maximum Long term averages 4-day 30-day Monthly Values with no duration
28 Certifications, Alternative Monitoring, and Estimates Certifications Compounds not used/generated Pollutants managed in accordance w/plan Alternative monitoring Calculated estimates
![Other Considerations... Removal credits - credit for POTW s ability to [40 CFR 403.7] remove pollutant.](/docs-images/60/44850685/images/29-5.png "Fundamentally different factors - adjust for [40 CFR 403.13] unique industry.")
29 Other Considerations... Removal credits - credit for POTW s ability to [40 CFR 403.7] remove pollutant. Fundamentally different factors - adjust for [40 CFR ] unique industry. Net/Gross calculation - adjust for pollutants in [40 CFR ] intake source.
30 Questions??
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