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Presentation on theme: "FEDERAL CATEGORICAL PRETREATMENT STANDARDS"— Presentation transcript:

Module 4 Pretreatment 101 Short Course 8/4/09 Addison, TX Allen Gilliam ADEQ State Pretreatment Coordinator

2 Categorical Pretreatment Standards (for YOU
Categorical Pretreatment Standards (for YOU? Just “Categorical 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 just “google” 40 CFR 4?? to locate the category Effluent Guidelines Plan Effluent Guidelines Task Force Original 1976 consent decree identified 21 categories; later modified to 34 in a 1979 agreement. Currently there are about 60 published categories that have effluent guidelines (for direct dischargers) and/or categorical pretreatment standards (for indirect dischargers). There are 27 with quantifiable pretreatment standards. Region 6 has a Summary Table revised July 2001 [see me after if you want a copy] Plans for EPA's expansion and modification of the list is detailed in the Effluent Guidelines Plan, published in the Federal Register biennially as required in section 304(m) of the CWA. An “Effluent Guidelines Task Force” is responsible to evaluate how guidelines are developed and looks for ways to make the development process more efficient. Typically, the first step is a preliminary study to evaluate likelihood of need for limitations, based on nature of pollutant discharges and comparison with other categories. Industries identified as primary sources of toxic pollutants are typically targeted for effluent guideline and categorical standard development. CONTACT YOUR REGIONAL COORDINATOR IF YOU HAVE INFO TO SUBMIT TO THE TASK FORCE

4 From Proposal to Codification
Code of Federal Regulations Proposed Regulations IU data on processes conducted, wastestreams generated, current treatment and management practices, availability and cost of control technologies, non-water quality environmental impacts, available pollution prevention measures, and economic impacts are identified, and used to derive proposed effluent guidelines and pretreatment standards. These findings and determinations are presented along with the proposed regulations in a proposed develop document published in the federal register. Affected industry, public interest groups, and State agencies and local programs are given opportunities to provide written comments. Public hearings may also be conducted for EPA to present the basis of the proposed regulations, answer questions and allow other comments. EPA is responsible for analyzing comments and determining their validity. Final comments along with promulgation of the final regulations are published in the federal register. EPA will then publish and make available the FINAL DEVELOPMENT DOCUMENT and FINAL REGULATIONS. Proposed Development Document Promulgation of Final Regulations Final Development Document Public Comment Revisions

5 53 Categoricals & Possible SIC code Correlatons
Industry Category 40 CFR Relevant SIC code(s) -‘87 SIC Manual Dairy products processing 405 2021, 2022, 2023, 2024, 2026 Grain mills manufacturing 406 2041, 2043, 2044, 2045, 2046, 2047 Fruits / vegetable processing 407 2033, 2034, 2035, 2037 Canned / preserved seafood 408 2091, 2092 Sugar processing 409 2061, 2062, 2063 Textile mills 410 2211, 2221, 2231, 2241, 2251, 2252, 2253, 2254, 2257, 2258, 2259, 2261, 2262, 2269 Cement manufacturing 411 3241 Concentrated Animal Feeding Operations 412 0211, 0213, 0214 Electroplating 413 3471, 3672 Organic chems, plastics, synthetic fibers 414 2821, 2823, 2824, 2865, 2869

6 Categoricals & Possible SIC code Correlatons (cont.)
Inorganic chemicals 415 2812, 2813, 2816, 2819 Soaps and detergents manufacturing 417 2841 Fertilizer manufacturing 418 2873, 2874, 2875 Petroleum refining 419 2911 Iron and steel manufacturing 420 3312, 3315, 3316, 3317, 3479 Nonferrous metals manufacturing 421 2819, 3331, 3334, 3339, 3341 Phosphate manufacturing 422 2819, 2874 Steam electric power generation 423 4911 Ferroalloy manufacturing 424 3313

7 Categoricals & Possible SIC code Correlatons (cont.)
Leather tanning / finishing 425 3111 Glass manufacturing 426 3211, 3221, 3296 Asbestos manufacturing 427 2621, 3292 Rubber manufacturing 428 2822 Timber products processing 429 2491, 2493 Pulp, paper and paperboard 430 2611, 2621, 2631 Meat products 432 2011, 2013, 2077 Metal finishing 433 groups: 34, 35, 36, 37 and 38XX Coal mining 434 1221, 1222, 1231, 1241

8 Categoricals & Possible SIC code Correlatons (cont.)
Oil and gas extraction 435 1311 Mineral mining and processing 436 1422, 1423, 1429, 1442, 1446, 1455, 1459, 1474, 1475, 1479, 1499 Pharmaceutical manufacturing 439 2833, 2834 Ore mining and dressing 440 1011, 1021, 1031, 1041, 1044, 1061, 1094, 1099 Transportation equipment cleaning 442 4491, 4499, 4741, 7699 Paving and roofing materials (tars and asphalt) 443 2951, 2952, 3996 Waste combustors (commercial incinerators combusting hazardous waste) 444 4953, 2819, 2869, 3241, 1422, 1429, 1459, 9999 Landfills 445 4953 Paint formulating 446 2851

9 Categoricals & Possible SIC code Correlatons (cont.)
Ink formulating 447 2893 Gum and wood chemicals 454 2861 Pesticide chemicals manufacturing, formulation and packaging 455 2879 Explosives 457 2892 Carbon black manufacturing 458 2895 Photographic 459 7221, 7335, 7384, 7819 Hospital 460 8062, 8063, 8069 Battery manufacturing 461 3691, 3692 Plastic molding and forming 463 3081, 3082, 3083, 3084, 3085, 3086, 3087

10 Categoricals & Possible SIC code Correlatons (cont.)
Metal molding and casting (foundries) 464 3321, 3322, 3324, 3325, 3365, 3366, 3369 Coil coating 465 3479, 3492, 3411 Porcelain enameling 466 3431, 3631, 3632, 3633, 3639, 3469, 3479 Aluminum forming 467 3353, 3354, 3355, 3357, 3363 Copper forming 468 3351, 3357, 3463 Electrical and electronic components 469 3671, 3674, 3679 Nonferrous metals forming and metal powders 471 3356,3357, 3363, 3497

11 Other Categoricals with no SIC Correlations Found
Centralized Waste Treatment – CFR 437 Metal Products and Machinery – CFR 438 Concentrated Aquatic Animal Prod. – CFR 451

12 Categorical Standards: Subparts
Manufacturing processes employed Raw materials used Types of items produced Characteristics of typical wastes generated The Control Authority must identify applicable processes subject to the regulations. As part of categorical standards development, EPA will typically subcategorize within an industrial category based on variability in: Manufacturing processes employed Raw materials used Types of items produced Characteristics of typical wastes generated. Where such variables result in differences in the nature of pollutants of concern contained in the discharge and/or concentration of pollutants of concern in the discharge, standards-specific to each type of process operation wastewater discharge may be promulgated. An example is 40 CFR Part 465, Coil Coating, where EPA developed standards for four different subcategories: steel basis, galvanized basis, aluminum basis and can-making.

13 Categorical Standards: Existing vs. New Source
New source, 40 CFR 403.3(m) Construction date Total replacement Substantially independent Compliance dates Interpretations are “all over the board…” There are different standards imposed on an IU based on whether they are a new or existing source. The CA must determine if a facility is a new or existing source, and what impact it has on the date for achieving compliance with categorical pretreatment standards. New Source Definition: Any building, structure, facility or installation from which there is (or may be) a discharge of pollutants, the construction of which commenced after publication of the proposed pretreatment standards applicable to such source if such standards are thereafter promulgated. [these “Promulgation Dates” are listed in the Region 6 Summary Table] Provided that: (a) The building, structure, facility or installation is constructed at a site at which no other discharge source is located; or (b) The building, structure, facility or installation totally replaces the process or production equipment that causes the discharge of pollutants at an existing source; or (c) The production or wastewater generating processes of the building, structure, facility, or installation are substantially independent of an existing source at the same site. The extent to which the new facility is integrated with the existing plant, and the extent to which the new facility is engaged in the same general type of activity as the existing source, should be considered when making this evaluation. [40 CFR §403.3(k)(3)] Construction is considered to have commenced if: The owner/operator has begun or caused to begin site preparation (e.g., clearing, removal of existing or installation of new stuff) or placement assembly or installation of facilities or equipment; or Entered into a binding contractual obligation for the purchase of facilities or equipment that are intended to be used in its operation within a reasonable time. For interpretations/questions CONTACT your STATE COORDINATOR

14 Categorical Standards: General Provisions
Applicability Definitions Monitoring and reporting requirements Compliance dates for PSES Other The General Provisions sections are located at the beginning of a Category Part and/or Subpart and may be comprised of such sections as: Applicability; such section may detail: Processes specifically covered or excluded from coverage Similar processes that are covered by other regulations Where another regulation applies based on other processes performed Minimum production levels for facilities to be covered Definitions, such as The analytical requirements in defining a pollutant, e.g. TOTAL TOXIC ORGANICS (TTO) for Metal Finishing at 40 CFR The units of production to use for calculating production-based discharge limits) Monitoring and reporting requirements, e.g.: Coil Coating at specifies analytical methods (petroleum based O&G-E), variance from periodic monitoring for CN and requires special notification for use of a specific aluminum alloy for Canmaking; and 40 CFR §433.12, Certification and plan required in lieu of monitoring for TTO Compliance Dates [PSES at 40 CFR Coil Coating] Other: Categorical standards may also contain specific types of provisions that apply only to that one category. For example: Iron & Steel 40 CFR §420 Calculation of pretreatment standards, 40 CFR §420.04 Removal credits for phenols (4AAP), 40 CFR §420.06 The inclusion of these types of requirements dictates that the Control Authority be intimately familiar with the entire categorical standard.

15 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 Note that not all parts have subparts. Applicability While General Provisions of a categorical standard may provide insight to facilities covered by a regulation, subparts may have their own applicability section. Such a section under a subpart can specifically identify facilities/facility operations covered by the specific subpart, identifying use of specific materials, processes, etc. and even production levels. This section may also specifically list facilities not covered and the reason why. (Note-more descriptive applicability section may be found in the development document or specific regulation’s preamble.) Specialized definitions Like general definitions for a part, subparts may include specific definitions of terms used within the subpart. As a result of EPA’s standard development process, effluent limits are calculated. As presented in the CFR, these include a variety of types of standards, including: Best Practicable control Technology currently available (BPT) Best Available Technology economically achievable (BAT) Best conventional pollutant control technology (BCT) Pretreatment standards for existing sources (PSES) New source performance standards (NSPS) Pretreatment standards for new sources (PSNS) BPT, BAT, BCT & NSPS all apply only to Direct dischargers and will not be covered here. PSES and PSNS apply to Indirect dischargers.

16 Pretreatment Standards for Existing Sources and New Sources: (PSES and PSNS)
Pretreatment standards are designed to prevent the discharge of pollutants that pass through, interfere with, or are otherwise incompatible with the operation of a POTW. WWTP processes and sludge disposal methods are both addressed in development In determining where pretreatment standards (for existing and new sources) are necessary, EPA first determines if there is pass through of pollutants. Secondly, EPA determines if the nationwide average percentage of pollutants removed by a well-operated POTW achieving secondary treatment is less than the percent removed by the BAT model treatment system. Pretreatment standards for existing source (PSES) are technology-based and analogous to the direct discharge BAT effluent limitation guidelines for removal of toxic pollutants Pretreatment standards for new sources (PSNS), like PSES, are designed to protect the POTW and since new sources have the opportunity to incorporate in their plant the best available demonstrated technologies, EPA considers these factors in promulgating PSNS. NOTE - while the standards developed are based on various treatment technologies, there is no requirement for an IU subject to a categorical pretreatment standard, to install such specific technology, merely that they comply with the standard(s). Requires EPA to determine Pass through Pollutant by pollutant For removal of toxic pollutants PSES are analogous to BAT PSNS are analogous to NSPS

17 Whether contained in the General Provisions or sections specific to a subpart, categorical pretreatment standards: May be numerical or narrative in form; May be imposed for various periods of time Instantaneous, daily, or long term average (e.g., monthly, 30-day, 4-day); May be specific to individual wastewater streams; May require specific IU information for application Production info, wastewater flow volumes. Further, some PSES and PSNS may not exist, be reserved, require compliance with 40 CFR Part 403 only or require no discharge of process wastewater pollutants or no pollutant allowance of the discharge. Understanding the significance of the variability is key to applying standards properly in local control mechanisms.

18 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 Categories without PSES or PSNS not on Region 6 Summary Table/not considered CIU In accordance with pretreatment standards development, discharges from these industrial categories were not determined to contain pollutants at concentrations that pass through, interfere with, or are otherwise incompatible with the operations of POTWs. Part 422, Phosphate Manufacturing Part 434, Coal Mining Part 436, Mineral and Mining Processing Part 438, Metal Products and Machinery Part 440, Ore Mining and Dressing Part 454, Gum and Wood Chemicals Manufacturing Part 457, Explosives Manufacturing Part 459, Photographic Processing Part 460, Hospitals Note that EPA will periodically review these determinations to see if still applicable. Control Authorities are still obligated to identify and inventory these facilities (IWS) and to control (permit) their discharges even though they were found at a National level to not need control through categorical pretreatment standards. Note that categorical pretreatment standards are not developed for conventional pollutants that may be of significance to a POTW [e.g. If Significant (5% flow/load or potential) must permit]

19 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

20 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.” Some categories may exclude only one of PSES/PSNS, or indicate they are reserved, others may merely require compliance with 40 CFR Part 403 (40 CFR , Dairy Products Processing, Subpart A - Receiving Stations is detailed in the slide). These 11 categories are: Part 405, Dairy Products Processing Part 406, Grain Mills (also includes a special requirement to protect against excessive loading – may be CIU due to requirement) Part 407, Canned and Preserved Fruits and Vegetables Processing Part 408, Canned and Preserved Seafood Processing Part 409, Sugar Processing Part 410, Textile Mills Part 411, Cement Manufacturing Part 424, Ferroalloy Manufacturing Part 427, Asbestos Manufacturing Part 432, Meat Products Part 463, Plastics Molding and Forming Note: Also not on Region 6 Summary Table / since there are no specific limitations (Cat Std) listed, EPA Region 6 does not consider them CIU Same as with excluded PSES/PSNS Control Authorities are obligated to identify and inventory these facilities (IWS) and to control (permit) their discharges even though they were found at a National level to not need control through categorical pretreatment standards. Note that categorical pretreatment standards are not developed for conventional pollutants that may be of significance to a POTW [e.g. If Significant (5% flow/load or potential) must permit]

CFR 405 Dairy Products CFR 406 Grain Mills (but, has a BOD5 / TSS formula) CFR 407 Canned & Preserved Fruits CFR 408 Canned & Preserved Seafood CFR 409 Sugar Processing

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

CFR 435 Oil & Gas Extraction CFR 446 Paint Formulating CFR 447 Ink Formulating CFR 451 Concentrated Aquatic Animal Production

“Standards” could be: Concentration based (“easy” to apply) Mass based (a little more difficult to apply but, not rocket surgery) Production based (closer to brain science than mass based. YOU have to know A LOT MORE about this type IU’s processes including flows and production)

CFR 412 Confined Animal Feeding (regs “silent” except for duck feeding ops?) 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

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

CFR 439 Pharmaceutical Mfg CFR 442 Transportation Equipment Cleaning CFR 443 Paving & Roofing Mtrls (Tars & Asphalt) O&G Limits only CFR 444 Waste Combustors CFR 455 Pesticide Chems CFR 458 Carbon Black Mfg (O&G Limits only) CFR 461 Battery Mfg

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

29 Pretreatment Standards
Concentration-based Direct approach Mass based approach Production-based Imposition of equivalent limits Having identified all the categories with no specific numerical standards, there are still quite a few categories that have discharge limits. A key element if these is the limit type. Limits are presented as two different types. Where there is no correlation between production and pollutant discharge, concentration limits are established. Occasionally, a regulation may specify a concentration-based standard but require it be multiplied by a long-term average process wastewater flow to derive a mass limit to be imposed. In cases where dilution of the wastestream may occur purposely or inadvertently to achieve compliance, mass equivalents may be imposed. 40 CFR '403.6(d) states: Except where authorized to do so by an applicable pretreatment standard or requirement, no IU shall ever increase the use of process water, or in any other way attempt to dilute a discharge as a partial or complete substitute for adequate treatment to achieve compliance with a pretreatment standard or requirement. The Control Authority may impose mass limitations on IUs that are or potentially will use dilution to meet applicable pretreatment standards or requirements and in other cases where the imposition of mass limitations is appropriate. Where there is a correlation between production rates and levels of pollutants discharged, production-based limits are established.

30 CFR 433 Metal Finish Standards - PSES (“easy to apply”)
(mg/ l) Daily Max Monthly Avg Cadmium (T) ………………… Chromium (T) …………………. 1.71 Copper (T) …………………. 2.07 Lead (T) ………………… 0.43 Nickel (T) ………………… 2.38 Silver (T) ………………… 0.24 Zinc (T) ………………… 1.48 Cyanide (T) ………………… 0.65 TTO

31 CFR 414 Organic Chems, 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 ………………………… 19 Anthracene ………………………… 19 Benzene ……………….……….. 57 Bis(2-ethylhexyl) phthalate ……………………….. 95 Carbon Tetrachloride ………………………. 142 Chlorobenzene ………………………..142

32 PRODUCTION BASED INDUSTRY CALCS? (won’t even get into the Calc’s)
Aluminum Forming Subpart A, Casting Cleaning Subcategory kg/1,000 kkg (pounds per million pounds) of metal poured Daily Max Avg Monthly Copper (T) …….……… Lead (T) …………… Zinc (T) ………………

33 Wastestream Types CFR 403.6(e)
Two types of wastewater streams are defined in the regulations Regulated & Non-regulated Regulated vs. Nonregulated - Unregulated or Dilute?

THE DREADED COMBINED WASTESTREAM FORMULA (CWF) CT = alt. conc. limit Ci= conc. limit for reg’d stream Fi= avg flow for reg’d stream FD= avg flow for dilution streams

35 Similar CWF for Mass based alternative

36 Wastestream Types CFR 403.6(e)
A regulated process wastestream is a wastestream from an industrial process that is subject to a federal categorical pretreatment standard for a pollutant being applied. i.e.) The wastestream “contains regulated pollutants” Regulated Wastestream from an industrial process that is subject to a categorical pretreatment standard: “Contains Regulated Pollutants”

37 Wastestream Types CFR 403.6(e)
Two types of NONREGULATED wastestreams Unregulated Dilute A NONREGULATED / unregulated process wastestream is a wastestream from an industrial process that is not subject to a federal categorical pretreatment standard for a pollutant, but is not a dilute wastestream. i.e.) The wastestream “contains pollutants” Nonregulated - Unregulated Wastestream from an industrial process that is not subject to a categorical pretreatment standard and is not “dilute” “Contains Pollutants”

38 “Contains No (neglible) Pollutants”
Wastestream Types Nonregulated - Dilute Wastestream considered to have only compatible pollutants and/or trace levels of regulated pollutants. “Contains No (neglible) Pollutants” A NONREGULATED / Dilute wastestream is a wastestream considered to have only compatible pollutants and/or only trace levels of regulated pollutants. i.e.) The wastestream “contains no pollutants” Sanitary wastewater; Demineralized backwash, Stormwater, Boiler blowdown, Noncontact cooling water Where such streams contain a significant amount of a pollutant, and the combination of such streams, prior to treatment, with an industrial user's regulated process wastestream(s) will result in a substantial reduction of that pollutant, the Control Authority, upon application of the industrial user, may exercise its discretion to determine whether such stream(s) should be classified as dilute or unregulated. In its application to the control authority, the industrial user must provide engineering, production, sampling and analysis, and such other information so the control authority can make its determination. Process wastestreams specified in 40 CFR Part 403, Appendix D; …”for the purposes of the combined wastestream formula”…

39 Types of Standards Daily maximum Long term averages 4-day 30-day
In addition to identifying types of wastestreams, the Control Authority must also apply all applicable categorical pretreatment standards. In most instances, EPA develops daily maximum and long-term average limits for each discharge. Of course, there are exceptions to that and the definitions of long-term average vary between categories. Daily maximum Long term averages 4-day 30-day Monthly Values with no duration Limitations may be established as a daily maximum, 4-day average, 30-day average, monthly average, or even as a value with no duration of measure. Daily Maximum Daily maximums are based on the 99th percentile distribution of daily measurements Daily is defined as any 24-hour period Several parts/subparts just have daily maximum limits [419, 423, 428, 429, 430, 431] Long term averages Long term (usually monthly) averages are based on the 95th percentile distribution of average daily values. 4-day, such as 413 Independent results from 4 consecutive sampling days. For the sampling days to be independent, each calculated 4-day average should not include sampling data used in another 4-day average. 30-day [415, 418,420, 426, 428, 439, 469, or portions thereof] The average of any daily measurements collected and accepted during a 30 consecutive calendar day period (independent of calendar month) Technically, this is a rolling 30-day period. Note: historically EPA has considered a 30-day average to mean a monthly average. Monthly e.g., 40 CFR Parts 414, 421, 425, 433, 455, 461, 464, 465, 466, 467, 468, 469, 471, or portions thereof All daily measurements collected and accepted for a calendar month. “Standard” / No duration e.g., 40 CFR Parts 443 Subparts A-D and 458 Subparts A-D, Oil and Grease Standards of 100 mg/l. This means it’s an instantaneous measurement type.

40 Certifications, Alternative Monitoring, and Estimates
As discussed earlier, as part of regulation development EPA identifies variability's in processes and wastestreams that may result in development of additional standards or approaches that are unique for a given industrial category or practice. Certifications (industry specific, in regulation) Occasionally, EPA encounters situations Certifications Compounds not used/generated Pollutants discharge in accordance to plan Alternative monitoring Calculated estimates where industries that perform the regulated process do not use or generate the compound/pollutant determined to need regulating, e.g., due to chemical substitution. In such cases, EPA allows in the regulation, for the affected IU to certify to the POTW that they do not use or generate the pollutant of concern(s) e.g., 40 CFR Parts 430-Pulp, paper and paperboard & 431-The builders’ paper and board mills (Pentachlorophenol and Trichlorophenol), 40 CFR Part 439-Pharmaceutical manufacturing (CN-). Note that these facilities are to be considered CIUs subject to the same requirements as all CIUs. Alternate monitoring Allowed where EPA identifies a relationship, i.e., proportional relationship, between pollutants present in the wastestream, alternate monitoring may be allowed. Typically this is seen where monitoring for a group of pollutants, e.g., TTO, is quite costly whereas the alternate pollutant, e.g., O&G, is more affordable. Calculated estimates While not common, a calculated estimate based on engineering calculations such as that allowed in 40 CFR Part 423 to demonstrate compliance with the “no detectable amount” of 124 priority pollutants in cooling tower maintenance chemicals may be justified especially where pollutants enter the wastestream primarily through isolated introduction of chemicals by the IU. The Control Authority may or may not allow the variance from monitoring to demonstrate compliance.

41 Other Considerations... Removal credits - credit for POTW’s ability to [40 CFR '403.7] remove pollutant. Fundamentally different factors - adjust for [40 CFR '403.13] unanticipated impacts of compliance. Net/Gross calculation - adjust for pollutants in [40 CFR '403.15] intake source. We’re not going to spend much time on these, but there are other provisions in 40 CFR Part 403 that may allow a CIU a different set of numerical limitations. Removal credits POTWs receiving wastes from CIUs can grant removal credits to reflect POTW removal of pollutants regulated by categorical standards, thereby allowing discharges above those specified in the respective categorical standards Must receive approval from Approval Authority. Fundamentally different factors Request for variance must be made within 180 days of Federal Register notice of final categorical standard Examples of factors considered fundamentally different include: Nature/quality of pollutants in User’s raw waste load Volume of user’s process wastewater and effluent discharges Processes employed, process changes Engineering aspects of application of control technology Cost of compliance with required control technology Examples not considered to be fundamentally different include: Feasibility of installing equipment w/i specified period of time User’s ability to pay for required waste treatment Impact of discharge on quality of POTWs receiving waters. Net/Gross calculation application/approval process Categorical standards adjusted due to pollutants in intake water POTW must discharge to the same source as the IU's intake water. Additional information is provided in 40 CFR Part 403.


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