DEEP Changes to Pretreatment Programs NEIWPCC Fall Managers Forum November 16, 2017

DEEP Changes to Pretreatment Programs Why Change? Current Pretreatment Program Proposed Changes Categorical General Permit Miscellaneous General Permit

Why Change? Increasing federally-regulated universe Increased EPA requirements Greater focus on environmental priorities Declining staffing levels: 1993 - 48 FTEs 2010 - 38 FTEs 2017 - 28 FTEs

Current Pretreatment Program Individual Permits 149 Significant Industrial Users (“SIU” or “Pretreatment”) Permits 28 Non-SIU Permits

Current Pretreatment Program General Permits Categorical/Metal Finishing, 21 SIUs, to be reissued Miscellaneous, 61 regs. (22 SIUs), to be reissued Groundwater Remediation, 459 regs., to be reissued Low-Flow Water Treatment, no-reg, expires March 2018 Food Processing, 32 regs., expires February 2018 Printing & Publishing, 151 regs., expires February 2018 Water Treatment, et. al., expires March 2018 Swimming Pool, expires July 2019 Vehicle Maintenance, 1368 regs., expires January 2021

What is an SIU? Based on 40 CFR 403.3(v), a Significant Industrial User essentially means: All Industrial Users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR Chapter I, subchapter N; and

What is an SIU? …and Any Industrial User discharging an average of 25,000 gpd or more of process wastewater to the POTW; contributes a process wastestream which makes up 5% or more of average dry weather hydraulic or organic capacity of the POTW; or is designated an SIU on the basis there is reasonable potential for adversely affecting the POTW’s operation or violating any Pretreatment Standard

Proposed Changes DEEP to continue regulating all SIUs Individual Permits Categorical Industrial User GP & SIUs from MISC GP merged to become SIU GP Non-SIUs covered by MISC GP WPCAs to have primary role regulating non-SIUs MISC General Permit to be reissued/modified DEEP seeks comment/input from WPCAs

Proposed Changes Miscellaneous General Permit Group I Discharges Air compressor condensate & blowdown Boiler blowdown Contact cooling & heating water* Cutting and grinding wastewater* Non-destruct testing rinsewater* Printing and photo processing wastewater* Tumbling and cleaning wastewater* Water treatment wastewater* Other processing wastewater* *Process Wastewaters

Proposed Changes Miscellaneous General Permit Group II Discharges Non-contact cooling water Hydrostatic pressure testing wastewater Commercial laundry wastewater* Food processing wastewater* Reverse osmosis reject water* *Process Wastewaters

Proposed Changes Miscellaneous General Permit Group III Discharges Building maintenance wastewater Fire suppression testing wastewater Swimming pool wastewaters Potable water system maintenance/sampling wastewaters

Proposed Changes Miscellaneous General Permit Group IV Discharges Discharges of Group I, II, or III which are hauled by a Connecticut licensed transporter to a POTW that has been approved by the commissioner to accept over-the-road wastewater.

Proposed Changes Miscellaneous General Permit Other Proposed Changes Registration submitted to WPCA, not to DEEP Registration would still require P.E./CHMM sign-off Authorization based on WPCA approval Comply with more protective of either WPCA ordinance or MISC GP WPCA receives monitoring/reporting information, not DEEP WPCA has primary role for assuring compliance

Next Steps Public Notice Draft SIU & MISC GPs Fall 2017 30-day Comment Period Opportunity for Continued Stakeholder Input Final Decision Issuance

QUESTIONS?

Oswald “Ozzie” Inglese Jr Oswald “Ozzie” Inglese Jr. Director Water Permitting & Enforcement Division CT DEEP oswald.inglese@ct.gov 860-424-3025