United States Environmental Protection Agency Office of Water Office of Water Enforcement and Permits Washington, DC 20460 (EN-335) PRETREATMENT BULLETIN Date; November 6, 1987 No. 3 Pretreatment Bulletins, this being the third to date, are issued on an as-needed basis to transmit policy, guidance, regulatory changes and other specific information to all pretreatment POIWs to assist them in the development and implementation of pretreatment programs. CLEAN WATER ACT AMENDMENTS EFFECT ON PRETREATMENT On February 4, 1987, Congress enacted amendments to the Federal Clean Water Act. These amendments (contained in the Water Quality Act of 1987) generally reinforce the pretreatnvent program requirements and add greater enforcement authority to EPA. The areas of the amendments most significant to pretreatment are: increasing the civil penalty authority of EPA fron $10,000 per day for each violation to $25,000 per day for each violation (§313) changing the criminal penalty from a misdemeanor to a% felony (§312) clarifying that IU violations of the requirements in a local pretreat- ment program are Federally enforceable (§312 and 313) adding two classes of administrative penalties of up to $25,000 for a Class I penalty or $125,000 for a Class II penalty. This provision of the Act substantially reduces the procedures for EPA's assessment of fines (§314) 0 requiring EPA to promulgate sewage sludge regulations including specific numeric criteria for various uses or disposal practices. The sludge requirements are to be implemented either through the NPDES permit or an alternative State sludge permit program. Until final national rules are promulgated, EPA is directed to make case-by-case determinations on appropriate requirements for a POTWs sludge management (see article on page 2 of this bulletin regarding the status of sludge requlation development) (§406) 0 requiring EPA to report to Congress on the pretreatment program and means of improving its effectiveness. The report is due in four years (§519) requiring the Administrator of EPA to ensure that an adequate number of employees are working within the pretreatment program to enable better implementation of pretreatment requirements and overview of approved local POTW programs (§309). The full text of the Water Quality Act of 1987 can be found in the Congressional Record and will be published in'the United States Code. ------- ------- (2) EGJLA IORY UPD IXtIESTIC The E) *i stic Sewage Study (DSS) was sulznitted to Congress by EPA in SEWAGE S’IUDY response to Section 3018(a) of the Resource Conservation and Recovery Act (RCRA). That provision directed the Agency to report to Congress on wastes discharged to P(YIWs through sewer systems that are exei t fran regulation under RCRA as a result of the Dcn stic Sewage Exclusion. On June 22, 1987, EPA issued a Federal Register notice (52 FR 23477) which sunir arizes the principal public carments on the Agency’ s prelim- inary approaches to fulfilling the recaniendations of the E S. This notice also discusses the program and research activities which EPA has under way to aid in this effort. Changes to the General Pretreatment Regulations to implement sane t S recctrnendations are scheduled to be proposed in the Spring of 1988. SLULGE The 1987 amendments to the Clean Water Act (CWA) require that permits REGULATIO ?TS issued to treatment works contain sludge standards. EPA is scheduled to issue proposed standards for pollutants of concern in sewage sludge in March 1988. EPA also will be proposing regulations for incorporat- ing sludge standards in NPDES permits and for State sludge management progrartis in December 1987. The 1987 CWA amendments also state that, prior to developient of the standards, the ? ministrator rrust put sludge conditions in permits issued to POThs or take other appropriate action to protect pt. blic health and the environment. To meet this requirement, EPA and States will begin incorporating sludge conditions, developed on a case—by-case basis , in fIWs’ NPDES permits as they expire and are reissued. EPA has developed a “Strategy for Interim Irnplenentation of Sludge Requirenerits in Permits Issued to PCTIWs”. In addition, EPA is preparing guidance to permit writers on developing interim case-by-case sludge requirements. Public notice of availability of each of these documents for public can nent is expected to be published in the Federal Register in the Fall of 1987. FDF VARIANCES Before passage of the Water ia1ity Act of 1987 (WQA), EPA had provided FOR INDIRECr for a fundamentally different factors (FDF) variance frcm pretreatment DISCI-IP .RGEFS standards for indirect dischargers. Procedural and substantive regulat- ions were contained in 40 CFR §403.13. Section 306 of the WQA codified (into section 301(n) of the Clean Water Act), and in sate cases changed, EPA’s existing FDF decision making criteria and procedures. For indirect dischargers, FDF variances are available fran pretreatment standards for existing sources for conven- tional, nonconventiorial, and toxic pollutants. The statute established, among other requiren nts; (1) four statutory criteria ( 301(n)(l)), (2) time limits for applications within 180 days after the standard is established or revised ( 3Ol(n)(2)), and (3) time limits on decision making within 180 days after submittal of a variance request ( 3O1(n)(3)) Legislative history indicates these provisions are se1f-iit 1ementing and should be used instead of existing regulations, to the extent the provisions are inconsistent with existing regulations. EPA intends to propose changes to the General Pretreatment Regulations to make them consistent with the new provisions of the Clean Water Act. For further information, contact Gary Hudiburgh at (202) 475—9531. ------- (3) PE7IOVALJ On pri1 30, 1986, the United States Court of Appeals for the Third CREDITS Circuit upheld the Natural Resources Defense Council’s challenge to REGULATIC4 T EPA’s rerroval credit regulation (see Bulletin No. 2). The effect UPDATE of the Third Circuit ruling was to invalidate several provisions of 1984 renoval credits art ndments, thus leaving in effect the 1981 versions of those provisions. The current status of the renoval credits regulation is: 1) portions of the 1984 amendmants not invalidated by the Third Circuit remain in effect, and 2) the 1981 versions of the invalidated regulatory provisions are in effect. Since the 1986 published version of 40 CFR §403.7 did not accurately reflect the current status of the renoval credits regulation in wake of the Third Circuit’s decision, on November 5, 1987, EPA published a revised version of the rule (52 FR 42434). Announcing the status of this rule does not in itself entitle EPA to authorization of rerroval credits. EPA rrn.ist still ca ly with the Third Circuit’s ruling requiring a rrcre comprehensive set of sludge regulations under section 405 of the Act as a precondition for granting renoval credits. EPA is working to comply with that ruling and will be proposing an extensive set of sludge guidelines under the authority of Section 405(d) (see article on page 2 of this bulletin). Until the sludge regulations are prorra.ilgated, rio PCYIW can be authorized to grant raroval credits. On September 1, 1987, previously existing renoval credits becanE invalid, and industrial users (lUs) were required to achieve ccii 1iance with categorical pretreatnent standards without renoval credits. Control Authorities (CA’s) should reissue IU permits or ncxlify control rrechanisms to incor rate a coripliance schedule. Alternatively, the CA may issue an administrative order or similar nech— anism that contains an appr riate schedule. Whatever vehicle is used, the schedule should be set by the CA specifying the earliest possible date by which the Iii can feasibly attain ccxrpliance. EPA will be issuing rerroval credits enforcenEnt guidance shortly. CATEX3ORICAL STANDARDS IMPLEMENTATI Since the publication of the last pretreatnent bulletin in March OF W TICtIAL of this year, final dates for carpliance with categorical pretreat- CATEGORICPIL ment standards have passed for the follcming industry categories: PPErRE ATMEN9’ STANDARDS ° Nonferrous Metals Manufacturing- Phase I (Subparts A-M) 6/7/87 o Battery Manufacturing 6/7/87 In addition, the final date for compliance with the Electrical and Electronic Ccmponents (Phase II) standards for the Cathode Ray Thbe and Luminescent Materials Subcategories was 7/14/86. The 90-day Compliance Reports for these subcategories were due on 10/12/86. Please note, Pretreatn nt Bulletin No. 2 (page 6) incorrectly stated these milestone dates as occurring in 1987, rather than 1986. (continued on next page) ------- (4) IMPLE 1 TATION EPA continues to prepare guidance manuals for impleinentating OF NATIONTL categorical standards for specific industry categories. These CATEX3OPJCAL manuals are designed for use by Control Authorities and industrial PRFrREPTMENI’ users. The gui dance manual for the Battery Manufacturing category STANDT tRDS was issued in August 1987 (see document request sheet on page 13 of (con’t) this bulletin to receive a copy). Guidance or the Nonferrous Metals, Ccpper, and Aluminum Forming industry categories, to be covered in one manual, is expected out later this year (see document request sheet on page 13 of this bulletin to receive this publication when it is available). CPITD3ORICAL Pretreatment Standards for the Organic Chemicals, Plastics, and STANDARDS Synthetic Fthers industry were published in the Federal Register on UPDATE ‘Tovernber 5, 1987 (52 FR 42522). These standards cover the following subcategories: rayon fibers, other fibers, thern plastic resins, thermosetting resins, coimi dity organic chemicals, bulk organic chenti cals, and specialty organic chemicals. Certain key dates should be noted, as follows: o Baseline nitoring Reports are due on June 20, 1988. o Conpliance must be achieved by November 5, 1990. • 90-day cou liance reports are due on February 5, 1991. EPA is also assessing the need for additional dategorical standards for the following industries: o hazardous waste treaters o solvent reclaimers o barrel reclaimers o waste oil reclaimers o equipment manufacturers and rebuilders ° paint manufacturers 0 transportation 0 industrial laundries ° hospitals o textiles O tizr ber 0 pharmaceutiCals By the end of 1987, decision documents, which include a rationale for whether the Agency will continue further work to establish categorical standards, will be published for hazardous waste treaters, solvent reclaimers and pharmaceuticals. Data for the remaining industries will be available in summary form at the same time. Categorical standards for the Pesticides Industry are scheduled to be issued in 1992. ------- For some industries, EPA issued standards that simply refer to the General Pretreatment Regulations. There has been confusion and inconsistencies in identifying whether such industrial users (lUs) are categorical. In the Textile category, for example, PSES requires that lUs “rtust cc ply with 40 CFR Part 403”. Such lUs, which have no categorical limits beyond the General Pretreatment Regulations, are not considered categorical lUs. H iever, for Pharmaceutical Manufacturing, PSES applies to facilities “where cyanide is used or generated”, but requires a certificati.on if cyanide is not used or generated. Pharmaceutical facilities (and in a similar manner Pulp, Paper, and Paperboard facilities) are considered categorical even if the requirement is simply a certif- ication. Such certifications ra st be su1 itted as part of semi-annual repDrts. Noncategorical lUs are still subject to the General Pretreatment Regulations, local limits, and may still be considered significant lU’s which warrant ircriitoring and reporting. The Pretreatment Implementation Review Task Force (PIRr), while recog- nizing that, at a minJ nim, research and development (R&D) facilities are covered by national prohibitive standards, local prohibitive standards, and local limits, reca mended EPA issue guidance as to whether these facilities are regulated by categorical pretreatment standards. To respond to the PIR recni rendation and to correct pre— vicxisly conflicting interpretations provided to EPA Regions, the Office of Water and the Office of General Counsel recently completed a thorough review of the applicability of categorical pretreatment standards to stand alone R&D facilities. Based on the records supporting the categorical pretreatiTerit standards, EPA has determined that stand alone R&D facilities are not subject to the categorical standards currently pranulgated. For a plant to be considered a stand alone R&D facility, there should be no ccmTercial sale of products made at the facility. This position is stated in a letter from Ms. Rebecca W. Uanmsr, Deputy Assistant A fliinjstrator for Water, June 26, 1987. EPA reserves the right to issue specific categorical standards which are applicable to stand alone R&D facilities -- hc iever, such activity is not currently underway. The lack of currently appli- cable categorical standards does not mean that pollution controls are not necessary. Noncategorical indirect dischargers are still required to caply with the General Pretreatment Standards (General and Specific Prohibitions) and with limits that may be established by local or State authorities. When local or State authorities address needed pollution controls for noncategorical industrial users, EPA does consider the categorical standards and the accom- panying development documents as excellent guidance on the performance of pollution control technologies. HcMever, other site-specific factors may be considered in setting limits (potential for inter- ference or pass through, raw waste load, age, size, land availability, flcw, non—water quality impacts, energy, and costs). (5) CATEGORICAL INDUSTRIAL USERS APPLICABILITY OF CATEGORICAL PRETREAThIENT STAND R TO RESEA H AND DEVEIOR4ENI FACILITIES ------- (6) GUID .NCE MATERIAL P ME In July 1986, the Office of Water Enforcement and Permits issued the TRAINING “Pretreatment Compliance Monitoring and Enforcement Guidance” manual MATERIALS (see document request sheet on page 13 of this bulletin to receive a copy). This document offers assistance and guidance to Control Auth- orities in implementing their pretreatment programa by providing: o A definition of Significant Industrial Users (SIUs) o Recoin nded industrial user nonitoring frequencies o Guidance on semi—annual reports by industrial users o A definition of Significant Noncompliance (SNC) for industrial users o A description of EPA’s “Enforcement Management System” as a guide for Control Authorities o A Pretreatment Performance Surrmary, that EPA reconvnends Approval Authorities make part of annual report requirements. To promote the use of definitions and procedures within the guidance, EPA has developed the Pretreatment Compliance Monitoring and Enforce- ment Training Course Instructor’s Manual . The training materials are intended for use by EPA and States when conducting pretreatment com- pliance monitoring and enforcement training workshops for Control Authorities. Each EPA Regional office. will receive a complete copy of the training manual with slides. This manual should be reviewed by EPA Regions and States planning to conduct a pretreatment seminar during the next 12 months. Regions and States are encouraged to give presentations using in—house personnel. Hcygever, EPA headquarters is willing to provide speakers for any of the subject areas. Three pilot training workshops have been held in Pittsburgh, PA; Richmond, VA; and Baltimore, MD. Control Authorities should contact their State or EPA Regional office regarding availability/scheduling of training workshops in your area. PCME To aid U1’Ws and States in implementing the Pretreatment Program, and SOFIWARE in particular the Agency’s guidance on Pretreatment Compliance Monitor- ing and Enforcement (PCME), EPA is developing F(ME computer software for IBM® (and compatible) personal computers. The software (with accompanying user’s manual) currently performe these basic functions: 1) Serves as a computerized mechanism for storing general infor- mation (name, address, outfall and IU code), effluent limits, and monitoring data on industrial users. 2) Identifies instances of noncompliance and evaluates whether industrial users are in significant noncompliance (based on the definition in the guidance document). 3) Prepares summery reports on industrial users, monitoring data, and compliance status. (continued on next page) ------- (7) PCIE EPA is nc i expanding the capabilities of the software to track all SOFIWARE the it s listed in the PC 1E ‘S Pretreatment Performance SulTrnary, (con’t) including: 1) sulziiission or reports: 2)inspections and sairq ling events and 3) enforcement actions. The software should be available in early 1988 in lxth a dBase III Plus® version (for those that have this package and may wish to n dify the program) and a ccxpiled version (which can be run without dBase III Plus® software). Copies may be obtained, when available, by using the document request form in the back of this bulletin. PRF RENTMENT EPA has developed an autarated national pretreatment data tracking PER’IITS AND system known as the Pretreatment Permits and Enforcement Tracking E F0 iEI 7 System (Ppcrs). This system became operational in C tober 1987 and TRACKING will provide EPA Regions and States with a valuable tool for oversight SYSTEM of pretreatment program implementation by FOIWs. PPETS will be a subpart of the Permit Cc* 1iance System (PCs), the existing mainframe cariputer national database which tracks the car 1iance status of direct discharging facilities. PPE S will consist of data obtained by Regions and States fran POIWs by means of pretreatment audits, pretreatment cciiipliance inspections, annual reports (including pre- treatment performance surmaries), and other carpliance reports. GUID .NCE FOR The Office of Water Enforcement and Permits has developed guidance for EMALUATING AND EPA Regions and States to evaluate and report noncompliance by PCIIWs REPORTING P(YIW that have failed to inpiement their approved pretreatment programs NONC 4PLIANCE (a copy of the guidance will be mailed shortly to all EO1 , State, and Regional pretreatment personnel). The criteria specified in the guidance were developed by an EPA rkqroup and presented to the States and EPA Regions at the National Pretreatment Coordinators Meeting in December 1986. Draft guidance was developed and circulated to the Regions, States and former Pretreatment Lrpleirentation Task Force merr bers for carment in May 1987. The guidance identifies criteria for evaluating the principal P0 1W activities that are essential to fully iiiipl nt irost local programs. If one or rtore of the following lettered irplemehtation criteria are not met, PONs should be reported by EPA and approved States on the o.iarterly Nonca liance Report (QNCR) for violations of their approved pretreatment programs: Issuance of industrial user (lu) control mechanisms a) failed to issue, reissue, or ratify IU permits, contracts, or other control mechanisms, where required, for “significant IUs’ (SIUs) within six nonths after program approval. There- after, each SIU control mechanism permit should be reissued within 90 days after the date required in the approved program, NPDES permit, or enforcement order*. (continued on next page) ------- (8) GUIDAN FOR P01W cczi pliance n riitoring and inspections EVALUATING AND REPORI’ING b) failed to conduct at least eighty percent of the inspections P 0 1W and sarrplings of SIUs required by the NPDES permit, the approved NONCCMPLIANCE program, or enforcement order*. (con’t) c) failed to establish and enforce self—n nitcrthg requirements that are necessary to assess SIUs canpliance as required by the approved program, the NPDES permit, or enforcement order*. P01W enforcement d) failed to irr lement pretreatment standards (including categorical standards and local limits) in an effective and timely menner or as required by the approved program, the NPDES permit, or enforcement order*. e) failed to undertake effective enforcaient against the lU(s) for instances of pass through or interference as defined in 40 CFR *403.3 and required by §403.5. P01W reporting to the Approval Authority f) failed to su1 it a pretreatment report (e .g., annual report or publication of the names of significant violators) to the Apptoval Authority within thirty days of the due date specified in the permit, enforcement order, or approved program. Other P01W ii lementation violations g) failed to ccz lete a pretreatment iirplerentation catpliance schedule milestone within 90 days of the due date specified in the permit, enforcement order*, or approved program. h) any other violation or group of violations of local program in 1ementation requirements based on the permit, approved program or 40 CFR Part 403 which the State Director or EPA Regional Administrator considers to be of substantial concern. These criteria will be applied to violations of specific requir tents in an NPDES permit, the approved program, or enforcement order*. In sate cases, approved States and Regions may need to nodify the approved local program and/or NPDES permit because the existing requirements are inadequate or because conditions have changed. There- fore, PCJIWs that lack specific program requirements for these inpie— itentation activities may receive permit trodifications. In general, PCYIWs that meet the definition of reportable nonccxnpliance should be priorities for resolving the inadequacies in approved programs or permits. EPA plans to incorporate specific criteria into the NPDES Regulations for noncaipliance reporting of PO’IWs which fail to adequately implement their pretreatment programs. * the term enforcement order means an administrative canpliance order, judicial order, or consent decree. (see 40 FR §123.45) ------- (9) GUID .NCE FOR PCYIWs that accept hazardous wastes by truck, rail, or dedicated pipe POfl within the boundary of the plant may be hazardous waste treatment, RECEIVING storage, and disposal facilities (TSDFs) -and, if so, are subject to HA2ARIX)US regulation under the Resource Conservation and Recovery Act (RCRA). WASTE EPA has developed the Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly O ned Treatment rks by Truck, Rail, or Dedicated Pipe to offer adininstrative and technical recommend- ations to PO’IWs seeking to preclude the receipt of hazardous wastes by these transportation methods, and to discuss the responsibilities of P(YIWs choosing to accept hazardous wastes by these transportation methods. A copy of this manual was mailed to all pretreatment roIws in late September/early October 1987. In accomplishing the dual purposes mentioned above, the manual provides the statutory and regulatory definitions of hazardous wastes. It also describes the RCRA regulatory status of wastes that P01W operators typically may encounter. The manual provides some guideposts which will assist the operator in making these deter- minations. The manual also discusses the legal, administrative, and technical methods to preclude the receipt of hazardous wastes, many of which are already in use. A description of potential liabilities that POTWs may incur as a result of accepting hazardous wastes is also provided. The manual describes the responsibilities of POIWs that choose to accept hazardous wastes by truck, rail, or dedicated pipeline, ex- plaining the special regulatory provisions, kncwn as permit by rule requirements, that the RCRA program imposes upon PO’IWs accepting hazardous wastes by the aforementioned methods. GUID .NCE FOR EPA is preparing the Guidance Manual for the Development of Industrial DEVELOPING Pretreatment Permits to provide training in the development of waste— INDUSTRIAL water discharge permits to Control Authorities required to implement PRETREAThIENT a local pretreatment program. It is designed for new permit writers, PERMITS but may also serve as a refresher for experienced permit writers. The manual ass nes the Control Authority has selected to regulate its industrial users (lUs) by means of a wastewater discharge permit system. It focuses on elements of the permit process which are comron to any Control Authority using this procedure, with particular emphasis on the mare difficult steps. The guidance addresses establishment of a permitting strategy, IU information collection and verification, draf t— ing permit language (including determining discharge limits, n nitoring, and reporting requirements). The guidance manual will be mailed directly to all pretreatment PCYIWs, States, and EPA Regions in the late 1987. Control Authorities should not delay issuance of IU permits while this guidance is being developed . ------- (10) P01W SLuG EPA is preparing a guidance manual to assist PCIIWs in controlling DISC iA1 3E industrial user (iu) slug discharges, including both accidental CONT L spills and intentional batch discharges. The guidance will draw GUIDANCE upon and update current P01W control practices and guidance issued by EPA on control of industrial discharges, and will assist in iu 1ementation of pretreatment regulations currently being developed in response to the Domestic Sewage Study (DSS). The DSS documented discharges of large quantities of toxic pollutants and hazardous constituents, sai portion of which are received at PCT1 s as a result of slug discharges by lUs. In addition, a recent survey undertaken by the Association of Metropolitan Sewerage Agencies (AMSA ) indicated that nearly every respondent has received hazardous wastes at its treatrrent plants. The rt st camon source cited was spills into sewage systems. Sixty—six percent of AMSA survey respondents have spill response plans, and 82% have prevention and control plans. Given the large quantities of toxics and hazard- ous constituents received at PCYIWs, it is apparent that not all of these plans are effective and that improvement of the plans and their inpiementation is warranted. The manual will cover methods for improved control of batch discharges via pretreatment permits and sewer use ordinances, as well as spill control plans and measures for IU spill prevention and P01W spill response. Protecting against such slug discharges will help prevent IW interference and pass through including plant upsets or damage, danger to rker safety or public health, irrpairment of water quality, sludge contamination, or NPDES permit violations. The anticipated final issuance date for the manual is Spring 1988. The manual will be distributed to all pretreatnent POIWs, State, and EPA Regional personnel, and will be available to other interested PGNs arid lUs, as well. RADIOACTIVE Sarc POIWs may be receiving radioactive waste frau industrial users MATERIP L utilizing sanitary sewers for disposal. In addition to being reg- DISPOSAL TO ulated try the general and specific prohibitions in the General Pre- SANITA ( treatment Regulations, those entities using such materials are Sfl ERS regulated by the Nuclear Regulatory Ca’rimission (NRC) and, very likely, many States. NRC and States issue licenses and establish disposal alternatives arid requirements. 10 CFR Part 20, ‘Standards for Protection Against Radiation”, Section 20.303 establishes the Federal requir i nt that no licensee shall discharge licensed material into a sanitary sewerage system unless certain conditions are met. PCIIWs which receive radioactive waste fran licensees may wish to consider periodic review and confirmation of self-nonitoring logs kept by the users, and perform analysis of sludge and calpDst to determine if there are any impacts. If impacts are detected, tOrIWs may choose to develop radiological nonitoring program to address the problem. - ------- (11) EPA REGION IL/ The foll dng is a list of EPA Regional and Headquarters pretreatir nt HEPJJQUARrEPS personnel. If, after first contacting the appropriate State pretreat- PRE REAThENT ment office, PCflWs need further asistance with program developrent or PERSONNEL in l ntation questions or probl s, please contact the EPA Regional office responsible for your State. Should the need of assistance persist, please contact the appropriate individual listed belo.q: PRETPEMM lT PEPS I .. irrs cttn’ .cr irpcr Joan Serra Lee Bo Wren Stenqer EPA Region I EPA Region VI 6W-ED JFK Federal Bldg. Allied Bank T r (6W—PM) (214) 655—6470 S B —2l09 1445 I ss Avenue Boston, MA 02203 DeLlag, TX 75202 (617) 565—3490 (214) 655—7175 .ith ?de].nun Pat wrack Lee Devall sane EPA Region II (212) 264—9826 EPA Region VII 26 Federal PLaza 726 Minnesota Avenue New York, NY 10278 Fa.nsas City, KS 66101 (212) 264—2911 (919) 236—2817 C ar1ene Harrison Jdtn L ve1l Marshall Flsdter EPA Region III (215) 597—6279 EPA Region vi i i 841 O estnut Street Cite Denver Place 3 152 999 18th Street Philadelphia, PA 19107 Denver, aD 80202 (215) 597—9406 (303) 293—1592 Al Iierr at sane Keith Silva sane EPA Region IV EPA Region IX 345 ( urtiaxxi Street, 215 Fr ront Street (W-5—1) Atlanta, GA 30365 San Francisco, 94105 (404) 881—2211 (415) 974—8298 Dive Renkin sane Ribert bicJ,aed sane EPA Region V EPA Region X 230 S th Dearbern Street Pezmits 8ran ± CM/S 521) CDücago, U. 60604 1200 6th Avenue (312) 353—Gill Seattle, 99101 (206) 442—1448 HEArC UARrE — all written requests shc*iid be addressed to: U.S. EPA Pertnits Division ( 4—336) or Enforc ient Division (E -338) 401 M Street, q — % &u.ngta1, 20460 Pez its E force rent Ed Ovserujc (202) 475-9529 Ricthard Kindt (202) 475—8319 aig Jacubo .iics (202) 475—9516 Edward Bender (202) 475—8331 Denise Scott (202) 475—9521 Salahiin Pbdul—Haqq (202) 382—4373 thuck Prorok (202) 475—7053 Andy H iock (202) 382—7745 George Utting (202) 475—7460 Divid S edroff (202) 475—8329 ------- (12) NATION L The EPA is considering holding a National Pretreatment Meeting in MEETING the second half of l9 3 to include participation by P01W, State, and EPA representatives. Such a neeting would last two to three days, would address a broad range of pretreatment inp1 ntation, cat liance, and enforcement topics, and would allow for substantial participation by State and P01W representatives. EPA solicits your ccm ents regarding the timing, location, format, and content (including specific topics to be addressed) of such a meeting. Please send your cai nts, and indicate your level of interest in participating in such a meeting, by Dec er 15, 1987 to: Thaitas Laverty, Cnief Program Section Permits Division/OWEP (EN—336) 401 M Street, SW Washington, CC 20460 ------- (13) AVAILABLE EOCrJMENTS The docun nts listed on this basis frcm EPA. To obtain a please provide your nazie and and return the information to: Nane: Address: request form are available on a limited copy of any of the follc iing docunents, address, check the requested docun nt Cs), Cluck Pror U.S. Environnental Protection Agency 401 M Street, SW (E —336) shinqton, DC 20460 PpL’rRE?I! T JLtZ INS Pretreatirent. Bulletin No. 1 (Septather 30, Pretreatt r t Bulletin No. 2 (Mar 6, 1987) CATEX ORICAL S ANt RDS FiGuidance Manual for Electrcplatjng and Matal Finishing Pretreatment Standards Guidance Manual for Iron and Steel Manufacturing Pretreatment Standards Guidance Manual for Battery Manufacturing Pretreatment Standards Guidance Manual for Nonferrons Metals, O.çç er, and A1txnintm Fbrrniog Pretreatment Standards (piblication atheduled for late 1987) G ERAL DR’ TICtT * ( ) Guidance Manual for Inpl enting Total Toxic Organic (Tro) Pretreatiient Standards * C ) Guidance Manual for the. Use of Production-Based Pretreatment Standards and the thined Wastestream Fornula * ( ) Metorand .nn: Local Limits Reguirai nts for P0Th ’ Pretreatment Programs (August 5, * ( ) Guidance Manual on the Develqi ent of Local Distharge Limitations Under the General Pretrea ent Regulations ( *thlication sd’ eduled for late 1987) The National Pretreatment Program ( wiro ntai Regulations and Te&nology doc .uient EPA/625/lO—86/oo5, 3Uly 1986) * ( ) Guidance Manual for the Develcpt nt of Industrial User Permits (p.iblication scheduled for late 1987) * ( ) Guidance Manual for Preventing Interference at Y1S s Pretreatment O pliance iitoring and Enfor Tent Guidance (PCIE) * ( ) Guidance for Evaluating and Reporting iW Noncatpliance PA *( RA Infornatjon on Hazardous Wastes for POIWs Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly O.Qned Treatment Works by Trudc, Rail, or Dedicated Pipe SOF1 .RE PQ Software and User’ s Manual (delivery sdteduled for early 1988) PR IM and User’s Manual (EPA ’s Tputer nodel for calculating local limits) * THESE CM rs W VE BE S OR S} DR LY WILL BE, MAILED DIR TLY ¶10 ALL PO1’, ’J, STATE , - fl c’ ,r.,rn ,. —- -- * * 1985) 1985) e v tPA iLA W 1. LAJt lU 11-EE Llru.it.±) b4u- , AVAflJ , j , , PLEASE BE SURE Y J DD r ALREADy 1 VE A ODPY BEFORE MN(1 A R JEST . ------- First Class Mail &EPA ____ Postage and Fees P::1 EPA Permit No G-35 United States Environmental Protection Agency Washington, DC 20460 (EN—3 35) Official Business Penalty for Private Use $300 ------- |