WELCOME

- SIU Meeting -

Massachusetts Water Massachusetts Water Resources AuthorityResources Authority

Carolyn M. FioreCarolyn M. FioreCarolyn M. FioreDirectorDirector

Toxic ReductionToxic Reduction and and ControlControl

Annual Meeting for Annual Meeting for Significant Industrial Significant Industrial

UsersUsers

April 14, 16, and 17, 2009April 14, 16, and 17, 2009

AgendaAgenda

Welcome and Introductions Carolyn FioreWelcome and Introductions Carolyn FiorePretreatment OverviewPretreatment Overview Carolyn FioreCarolyn FioreProposed RegulationsProposed Regulations Carolyn FioreCarolyn FioreMercury SourcesMercury Sources Peter Yarossi Peter Yarossi

BreakBreakEPA UpdateEPA Update Carolyn FioreCarolyn FioreSIUsSIUs/SNC/SNC Tracy McGrathTracy McGrathMeet with TRAC staffMeet with TRAC staff AllAll

MWRA ESSENTIAL STATISTICS MWRA ESSENTIAL STATISTICS

2.5 million people served2.5 million people served890,000 households served890,000 households served5,500 businesses served 5,500 businesses served 230 million gallons per day of water supplied230 million gallons per day of water supplied350 million gallons per day of sewage treated350 million gallons per day of sewage treated43 sewerage communities43 sewerage communities5,400 miles of local sewers transport the wastewater 5,400 miles of local sewers transport the wastewater 228 miles of MWRA interceptor sewers. 228 miles of MWRA interceptor sewers. 50 water communities 50 water communities 61 communities collectively61 communities collectively

What is the Pretreatment Program?What is the Pretreatment Program?

•• Required by Federal Clean Water ActRequired by Federal Clean Water Act•• Implemented through regulations developed by Implemented through regulations developed by

U.S. EPA U.S. EPA (40 CFR Part 403)(40 CFR Part 403)•• Specific requirements: NPDES Permits for Specific requirements: NPDES Permits for

Deer Island and Clinton Wastewater Treatment Deer Island and Clinton Wastewater Treatment PlantsPlants

Pretreatment Program ObjectivesPretreatment Program Objectives

•• Prevent pass through of pollutants into receiving Prevent pass through of pollutants into receiving waters waters

•• Improve opportunities to recycle and reclaim Improve opportunities to recycle and reclaim municipal and industrial wastewaters and municipal and industrial wastewaters and sludgessludges

•• Prevent interference with operation of treatment Prevent interference with operation of treatment plant, including protecting worker health and plant, including protecting worker health and safetysafety

Federal Pretreatment Program Federal Pretreatment Program

40 CFR Part 40340 CFR Part 403Rules for pretreatment programsRules for pretreatment programsGeneral rules for facilities subject to National General rules for facilities subject to National Categorical StandardsCategorical StandardsGeneral rules for other permitted facilitiesGeneral rules for other permitted facilities

40 CFR Part 13640 CFR Part 136Approved methods for analysis in pretreatment Approved methods for analysis in pretreatment programprogram

40 CFR Parts 40440 CFR Parts 404--471471National Categorical Standards for specific industriesNational Categorical Standards for specific industries

Elements of ProgramElements of Program

•• Regulations and Local Limits Regulations and Local Limits •• Industrial SurveyIndustrial Survey•• InspectionsInspections•• PermittingPermitting•• MonitoringMonitoring•• Enforcement Enforcement

TRAC OrganizationTRAC Organization

•• 45 positions 45 positions •• Functional AlignmentFunctional Alignment

•• MonitoringMonitoring•• Inspections & PermittingInspections & Permitting•• Enforcement & MISEnforcement & MIS

•• Supported by staff in Law Division and Supported by staff in Law Division and Field Operations DepartmentField Operations Department

TRAC HighlightsTRAC Highlights

PIMSPIMSAnnual Report to EPA October 31, 2008Annual Report to EPA October 31, 2008EPA Audit Report from December 2007 EPA Audit Report from December 2007 Audit of Pretreatment ProgramAudit of Pretreatment ProgramProposed Regulations ChangesProposed Regulations ChangesProposed Charges IncreasesProposed Charges IncreasesMolybdenumMolybdenum

PIMSPIMS

Consolidated several standConsolidated several stand--alone alone information systemsinformation systemsData was migrated from these systemsData was migrated from these systemsAugust 18, 2008 GoAugust 18, 2008 Go--Live Date Live Date Anything received after August 18, 2008 Anything received after August 18, 2008 was entered into PIMSwas entered into PIMSExpected date for System Acceptance: Expected date for System Acceptance: June 18, 2009June 18, 2009

PIMS FeaturesPIMS Features

WebWeb--SMR for reporting selfSMR for reporting self--monitoring monitoring resultsresultsDocument generation Document generation Relatively simple access to informationRelatively simple access to informationInterfaces with other MWRA systems for Interfaces with other MWRA systems for analytical data, billing, wordanalytical data, billing, word--processingprocessing

PIMS FuturePIMS Future

Integration with GISIntegration with GISIntegration with new LIMS (July 1, 2009)Integration with new LIMS (July 1, 2009)IU filing of data through IU filing of data through WebSMRWebSMROnOn--line permit applicationline permit applicationCROMERR complianceCROMERR compliance

October 2008 Annual ReportOctober 2008 Annual Report

226 226 SIUsSIUs537 permits issued or renewed537 permits issued or renewed996 inspections completed996 inspections completed2156 sampling events2156 sampling events

EPA AuditEPA Audit

Significant Finding: Regulations update Significant Finding: Regulations update requiredrequiredOther issues: Other issues:

Specific permit changes Specific permit changes RecordRecord--keeping suggestionskeeping suggestionsPermit design suggestionsPermit design suggestions

Proposed Regulations ChangesProposed Regulations Changes

EPA Mandated ChangesEPA Mandated Changes

MWRA ClarificationsMWRA Clarifications

Incentive and Other ChargesIncentive and Other Charges

EPA and MWRA ClarificationsEPA and MWRA Clarifications

Update to incorporate changes to EPA Update to incorporate changes to EPA regulations at 40 CFR Part 403regulations at 40 CFR Part 403

DefinitionsDefinitionsBMPsBMPsReporting requirementsReporting requirements

Regulatory clarificationsRegulatory clarificationsAdministrative procedures (360 CMR 1.00)Administrative procedures (360 CMR 1.00)Enforcement procedures (360 CMR 2.00)Enforcement procedures (360 CMR 2.00)Sewer use requirements (360 CMR 10.000)Sewer use requirements (360 CMR 10.000)

Incentive and Other ChargesIncentive and Other Charges

Across the board, 4.5% increase in FY10, Across the board, 4.5% increase in FY10, FY11, FY12FY11, FY12Last changed FY06Last changed FY06Recovers about 60% of costs of Recovers about 60% of costs of pretreatment program pretreatment program Provides incentives to reduce pollutant Provides incentives to reduce pollutant loadings, maintain complianceloadings, maintain compliance

Draft ScheduleDraft Schedule

Informal Comments: April 24, 2009Informal Comments: April 24, 2009MWRA Board for approval to publish: MWRA Board for approval to publish: June 3, 2009June 3, 2009Public Notice: June 26, 2009Public Notice: June 26, 2009Public Hearing: July 17, 2009Public Hearing: July 17, 2009Final Regulations: August 21, 2009 orFinal Regulations: August 21, 2009 orReturn to MWRA BoardReturn to MWRA BoardFinal Regulations: October 3, 2009Final Regulations: October 3, 2009

MolybdenumMolybdenumMetal used in corrosion inhibition chemicals in Metal used in corrosion inhibition chemicals in cooling systemscooling systemsDuring summer into fall, MWRADuring summer into fall, MWRA’’s pellets exceed s pellets exceed state limit for unrestricted usestate limit for unrestricted useMWRAMWRA’’s contractor manages this by selling s contractor manages this by selling pellets out of state pellets out of state MWRA will be reviewing for possible regulationsMWRA will be reviewing for possible regulationsReminder: Switch if possible to nonReminder: Switch if possible to non--molybdatemolybdate--based corrosion inhibitorsbased corrosion inhibitors

Molybdenum Concentrations in Biosolids (mg/l)

0

10

20

30

40

50

60

70

80

M A M J J A S O N D J F

Molybdenum DEP Type 1 LimitEPA Interim Limit Previous 12 Months

DEP Pollutant SurveyDEP Pollutant Survey

DEP Regulations require DEP to evaluate DEP Regulations require DEP to evaluate potential for pollutants in discharges to potential for pollutants in discharges to POTWsPOTWsJuly 2009, July 2009, ““SurveySurvey”” instrument to 3400 instrument to 3400 facilities (facilities (targettedtargetted))Recipients will have 90 days to completeRecipients will have 90 days to completeRecipients must respond Recipients must respond

DEP Pollutant SurveyDEP Pollutant Survey

Instrument will be available onInstrument will be available on--linelineLooking for pollutants expected to be in Looking for pollutants expected to be in wastewaterwastewaterWill be able to download list of pollutantsWill be able to download list of pollutantsNo quantities will be requiredNo quantities will be required1900 toxics are on the list1900 toxics are on the listFailure to respond will result in Failure to respond will result in enforcement by DEPenforcement by DEP

Contact InformationContact Information

John Reinhardt, Industrial Wastewater, John Reinhardt, Industrial Wastewater, DEP DEP

617617--292292--56675667

Looking for Beta Testers in June 2009Looking for Beta Testers in June 2009

RemindersRemindersCourtesy comment period on proposed Courtesy comment period on proposed regulations changes (comments by 4/24/09)regulations changes (comments by 4/24/09)Formal comment period on regulations changesFormal comment period on regulations changesAnnual Incentive and Other Charges Invoices to Annual Incentive and Other Charges Invoices to be issued midbe issued mid--November 2009November 2009Review data in letters (October) for Review data in letters (October) for discrepancies, call your IC as soon as possible discrepancies, call your IC as soon as possible so bills are correctso bills are correctPayment due 30 days from billing datePayment due 30 days from billing dateBilling reflects status as of June 30, 2009 and Billing reflects status as of June 30, 2009 and data from July 1, 2008 data from July 1, 2008 –– June 30, 2009June 30, 2009

Contact UsContact Us

www.mwra.comwww.mwra.com

Email Carolyn Fiore:Email Carolyn Fiore:cfiore@mwra.state.ma.uscfiore@mwra.state.ma.us

Industrial Sources of Industrial Sources of MercuryMercuryPeter YarossiPeter Yarossi

Regional ManagerRegional ManagerToxic Reduction and ControlToxic Reduction and Control

Sources of MercurySources of MercuryChemicals Chemicals

contaminationcontaminationpreservativepreservative

Infrastructure Infrastructure PlumbingPlumbingFloorsFloorsLightingLighting

EquipmentEquipmentThermometer Thermometer Pressure gaugesPressure gaugesSwitchesSwitches

Controlling SourcesControlling Sources

ChemicalChemicalCheck grades of raw materials and treatment Check grades of raw materials and treatment chemicalschemicalsWork with vendors and purchasing Work with vendors and purchasing departmentdepartmentDonDon’’t trust MSDSt trust MSDS

Controlling SourcesControlling Sources

InfrastructureInfrastructureCheck plumbing for poolingCheck plumbing for poolingRemove biological growth from tanksRemove biological growth from tanksProperly clean spills to floorsProperly clean spills to floorsTreat broken fluorescent lights like a mercury Treat broken fluorescent lights like a mercury release.release.

Controlling SourcesControlling Sources

EquipmentEquipmentReplace mercury containing equipmentReplace mercury containing equipment•• ThermometersThermometers•• ThermostatsThermostats•• HydrometersHydrometers•• BarometersBarometers•• SwitchesSwitches•• FlowmetersFlowmeters

PretreatmentPretreatment

Filtration of particulateFiltration of particulateCarbon absorptionCarbon absorptionIon exchangeIon exchangePrecipitation/filtrationPrecipitation/filtration

ResourcesResources

DEP website DEP website http://www.mass.gov/dep/toxics/stypes/hglampshttp://www.mass.gov/dep/toxics/stypes/hglamps.htm.htmMWRA website MWRA website http://www.mwra.com/03sewer/html/trac.htmhttp://www.mwra.com/03sewer/html/trac.htmYour Industrial CoordinatorYour Industrial Coordinator

Break

National Pretreatment National Pretreatment Program UpdateProgram Update

Justin PimpareRegional Pretreatment Coordinator

EPA New EnglandU.S. Environmental Protection Agency

OverviewOverview

Streamlining Guidance, Updates and Fact Streamlining Guidance, Updates and Fact Sheet DevelopmentSheet DevelopmentClean Water Act Awards UpdateClean Water Act Awards UpdateRegulations in DevelopmentRegulations in Development304m Plan and Associated Studies304m Plan and Associated StudiesNACWA/ADA/EPA MOUNACWA/ADA/EPA MOUWhatWhat’’s New on Our Webs New on Our Web

Streamlining Guidance Updates and Streamlining Guidance Updates and Tool DevelopmentTool Development

Guidance Manual Updates/RevisionsGuidance Manual Updates/Revisions

In Final Editing In Final Editing ““Control Authority Pretreatment Audit Checklist and Control Authority Pretreatment Audit Checklist and InstructionsInstructions””““Industrial User Permitting Guidance ManualIndustrial User Permitting Guidance Manual””

Under ReviewUnder Review““Introduction to the National Pretreatment ProgramIntroduction to the National Pretreatment Program””

Under DevelopmentUnder Development““Procedures Manual for Reviewing a POTW Procedures Manual for Reviewing a POTW Pretreatment Program SubmissionPretreatment Program Submission””““Guidance Manual for the POTW Program Guidance Manual for the POTW Program DevelopmentDevelopment””

Streamlining Rule Guidance Updates Streamlining Rule Guidance Updates and Tool Development (cont.)and Tool Development (cont.)

Fact SheetsFact Sheets8 Fact Sheets Completed and Published on the EPA8 Fact Sheets Completed and Published on the EPA’’s Websites Website

Fact Sheet 1.0: Summary of Changes Made Under the Streamlining Fact Sheet 1.0: Summary of Changes Made Under the Streamlining Rule Rule Fact Sheet 2.0: Required Changes Fact Sheet 2.0: Required Changes Fact Sheet 3.0: Equivalent Mass Limits for Concentration LimitsFact Sheet 3.0: Equivalent Mass Limits for Concentration LimitsFact Sheet 4.0: Equivalent ConcentrationFact Sheet 4.0: Equivalent Concentration--Based Limits for FlowBased Limits for Flow--Based Based StandardsStandardsFact Sheet 5.0: New Classifications for Categorical Industrial UFact Sheet 5.0: New Classifications for Categorical Industrial UserssersFact Sheet 6.0: Optional Sampling Waiver for Pollutants Not PresFact Sheet 6.0: Optional Sampling Waiver for Pollutants Not PresententFact Sheet 7.0: Best Management PracticesFact Sheet 7.0: Best Management PracticesFact Sheet 8.0: Slug Control Plans Fact Sheet 8.0: Slug Control Plans

2 Additional Fact Sheets under Development:2 Additional Fact Sheets under Development:Significant NonSignificant Non--Compliance (SNC)Compliance (SNC)General PermitsGeneral Permits

Updating Clean Water Act Updating Clean Water Act Award ProgramAward Program

Previously, awards given for:Previously, awards given for:Most Improved POTWMost Improved POTWBest Operations and MaintenanceBest Operations and MaintenancePretreatment Program ImplementationPretreatment Program ImplementationOtherOther

Updating Clean Water Act Updating Clean Water Act Award Program (cont.)Award Program (cont.)

Now updating the CWA Awards Program to:Now updating the CWA Awards Program to:Increase ParticipationIncrease ParticipationRenew Focus on InnovationRenew Focus on InnovationEmphasize Watershed ManagementEmphasize Watershed ManagementIncrease Focus on Sustainable Infrastructure Increase Focus on Sustainable Infrastructure ““4 Pillars4 Pillars””

Better Management Better Management of Water & Wastewater Utilitiesof Water & Wastewater UtilitiesRates that Reflect the Rates that Reflect the Full Cost PricingFull Cost Pricing of Services of Services Efficient WaterEfficient Water UseUseWatershed ApproachesWatershed Approaches to Protectionto Protection

Regulations Regulations –– Construction and Construction and Development RuleDevelopment Rule

Nearly 600,000 acres of land are developed annually in the U.S. Nearly 600,000 acres of land are developed annually in the U.S. Construction Construction stormwaterstormwater contains sediment, nutrients, metals and other contains sediment, nutrients, metals and other toxic pollutants. Sediment and turbidity are leading sources oftoxic pollutants. Sediment and turbidity are leading sources ofimpairment to receiving waters nationwide.impairment to receiving waters nationwide.Proposed rule published on Nov. 28, 2008Proposed rule published on Nov. 28, 2008

Construction sites 30 acres or larger that also meet rainfall/clConstruction sites 30 acres or larger that also meet rainfall/clay content ay content criteria must meet an effluent limit of 13 criteria must meet an effluent limit of 13 NTUsNTUs (turbidity). (turbidity). Sites between 1 and 10 acres Sites between 1 and 10 acres –– Best Management Practices (Best Management Practices (BMPsBMPs).).All other sites, All other sites, BMPsBMPs plus properly sized sediment basins.plus properly sized sediment basins.

Public comment period closed Feb. 26, 2009. Many comments from Public comment period closed Feb. 26, 2009. Many comments from all all directions.directions.Under court order, final rule must be published in the Federal RUnder court order, final rule must be published in the Federal Register egister by Dec. 1, 2009.by Dec. 1, 2009.

Regulations Regulations –– Airport DeicingAirport Deicing

About 330 commercial airports conduct occasional or About 330 commercial airports conduct occasional or frequent deicing operations producing an estimated 25 million frequent deicing operations producing an estimated 25 million gallons of Aircraft Deicing Fluid creating 128 million lbs of gallons of Aircraft Deicing Fluid creating 128 million lbs of Chemical Oxygen Demand (COD) annually. Also, about 8.2 Chemical Oxygen Demand (COD) annually. Also, about 8.2 million lbs. of urea is applied to runways generating both million lbs. of urea is applied to runways generating both ammonia and COD.ammonia and COD.Control Technologies Control Technologies –– can collect the deicing fluid with can collect the deicing fluid with Glycol Recovery Vehicles (GRV), Plug & Pump storm drains Glycol Recovery Vehicles (GRV), Plug & Pump storm drains in aircraft spraying areas, and Deicing Pads. in aircraft spraying areas, and Deicing Pads. Treating the Collected Deicing Fluid Treating the Collected Deicing Fluid ---- onsite biological onsite biological treatment systems or offtreatment systems or off--site options using POTW or site options using POTW or contractor (centralized waste treatment/disposal). contractor (centralized waste treatment/disposal). Expect proposed rule this summer.Expect proposed rule this summer.

304m Plan 304m Plan –– OverviewOverviewThe Preliminary 2010 304m Plan will present the 2009 annual The Preliminary 2010 304m Plan will present the 2009 annual review of existing effluent guidelines and pretreatment standardreview of existing effluent guidelines and pretreatment standards for s for all 56 point source categories. all 56 point source categories.

Will review pollutant discharges from the PCS, ICISWill review pollutant discharges from the PCS, ICIS--NPDES, and TRI NPDES, and TRI databases (2007 data).databases (2007 data).Status updates and/or findings for three detailed studies and thStatus updates and/or findings for three detailed studies and the e preliminary study of Ore Mining and Dressing.preliminary study of Ore Mining and Dressing.Soliciting public comment for 2010 annual review.Soliciting public comment for 2010 annual review.

Three detailed studies Three detailed studies CoalbedCoalbed Methane ExtractionMethane ExtractionSteam Electric Power GenerationSteam Electric Power GenerationHealth Care Industry (Unused Pharmaceutical Management)Health Care Industry (Unused Pharmaceutical Management)

Timing for Preliminary Plan Timing for Preliminary Plan ---- Fall 2009.Fall 2009.

304m Studies 304m Studies –– Coal Bed MethaneCoal Bed Methane

Growing industry sector with potential environmental Growing industry sector with potential environmental impacts from produced water; depends on quality and impacts from produced water; depends on quality and quality of the water. Also beneficial water reuse issues. quality of the water. Also beneficial water reuse issues. Quality of water can vary within and between basins. Quality of water can vary within and between basins. Objectives and Scope Objectives and Scope

Evaluate availability and affordability of technology options Evaluate availability and affordability of technology options for CBM produced water discharges in current and future for CBM produced water discharges in current and future CBM basins. CBM basins. Evaluate potential environmental issues associated with Evaluate potential environmental issues associated with the discharge of CBM produced water.the discharge of CBM produced water.

TimingTimingSurvey of industry Survey of industry –– 11stst of two part survey recently sent to of two part survey recently sent to well owners. 2well owners. 2ndnd part later this year.part later this year.Final decision on whether to initiate a rulemaking in Final Final decision on whether to initiate a rulemaking in Final 2010 304m Plan currently scheduled for Fall 2010.2010 304m Plan currently scheduled for Fall 2010.

304m Study 304m Study –– Steam ElectricSteam Electric

In previous 304m Plan, industry ranked high on In previous 304m Plan, industry ranked high on potential hazard list using PCS and TRI data.potential hazard list using PCS and TRI data.MultiMulti--year study which includes sampling and year study which includes sampling and site visits, and other data collection, including site visits, and other data collection, including industry questionnaire.industry questionnaire.Key waste streams of interest are flue gas Key waste streams of interest are flue gas desulfurization wastewater and ash ponds.desulfurization wastewater and ash ponds.Timing Timing ---- study to be completed this year.study to be completed this year.

304m Study 304m Study –– Unused PharmaceuticalsUnused Pharmaceuticals

GoalsGoalsUnderstand state of industry (hospitals, longUnderstand state of industry (hospitals, long--term care facilities, term care facilities, veterinary clinics, as well as several other sectors)veterinary clinics, as well as several other sectors)Identify Best Management PracticesIdentify Best Management PracticesEstimate amount of unused pharmaceuticals being flushedEstimate amount of unused pharmaceuticals being flushed

Lot of outreach; learning a great dealLot of outreach; learning a great dealPreliminary observationsPreliminary observations

Unused pharmaceutical management is of is a national interest ofUnused pharmaceutical management is of is a national interest ofconcern to state and local pretreatment programs.concern to state and local pretreatment programs.Management of unused pharmaceutical is greatly influenced by Management of unused pharmaceutical is greatly influenced by Federal regulations, ease of disposal, and costs.Federal regulations, ease of disposal, and costs.Policies vary greatly.Policies vary greatly.

Timing Timing Plan to survey industry. First of two required Federal RegisterPlan to survey industry. First of two required Federal Registernotices published in August 2008.notices published in August 2008.Plan to complete study by Final 2010 304m Plan in Fall 2010.Plan to complete study by Final 2010 304m Plan in Fall 2010.

New OWM PublicationsNew OWM Publications

Effective Utility ManagementEffective Utility Management10 attributes of Effectively Managed Utilities10 attributes of Effectively Managed Utilities5 Keys to Management Success5 Keys to Management Success““A Primer for Water and Wastewater UtilitiesA Primer for Water and Wastewater Utilities””-- June 2008June 2008http://www.epa.gov/waterinfrastructure/pdfs/tools_si_watereum_prhttp://www.epa.gov/waterinfrastructure/pdfs/tools_si_watereum_primerfimerforeffectiveutilities.pdforeffectiveutilities.pdf

Innovative Technologies Publications:Innovative Technologies Publications:““Municipal Nutrient Removal Technologies Reference Document,Municipal Nutrient Removal Technologies Reference Document,”” EPA EPA 832832--RR--0808--006, Sept 2008 006, Sept 2008 http://www.epa.gov/owm/mtb/mnrthttp://www.epa.gov/owm/mtb/mnrt--volume1.pdfvolume1.pdf http://www.epa.gov/owm/mtb/mnrthttp://www.epa.gov/owm/mtb/mnrt--volume2.pdfvolume2.pdf““Emerging Technologies for Wastewater Treatment and InEmerging Technologies for Wastewater Treatment and In--Plant Wet Plant Wet Weather Management,Weather Management,”” EPAEPA--832832--RR--0606--006, Feb 2008006, Feb 2008http://www.epa.gov/owm/mtb/emerging_technologies.pdfhttp://www.epa.gov/owm/mtb/emerging_technologies.pdf““Emerging Technologies for Conveyance Systems: New Installations Emerging Technologies for Conveyance Systems: New Installations and Rehabilitation Methods,and Rehabilitation Methods,”” EPA 832EPA 832--RR--0606--004, July 2006004, July 2006http://www.epa.gov/owm/mtb/epahttp://www.epa.gov/owm/mtb/epa--conveyanceconveyance--report.pdfreport.pdf

WhatWhat’’s New on Our Webs New on Our WebWeb sites for both methods and Effluent Guidelines have been Web sites for both methods and Effluent Guidelines have been redesigned.redesigned.

Methods Methods –– www.epa.gov/waterscience/methodswww.epa.gov/waterscience/methods•• All Part 136 methodsAll Part 136 methods•• Validated methods not in Part 136Validated methods not in Part 136•• Alternative Test Procedure ProgramAlternative Test Procedure Program•• ““Special TopicsSpecial Topics”” such as Qs and As on O&Gsuch as Qs and As on O&G•• ““Current ActivitiesCurrent Activities””

Effluent Guidelines Effluent Guidelines –– www.epa.gov/guidewww.epa.gov/guide•• All industry sectors, including those under developmentAll industry sectors, including those under development•• Continually adding detailed technical support documents to indivContinually adding detailed technical support documents to individual idual

industry sectorsindustry sectors•• 304m planning304m planning•• FAQsFAQs

New web site on New web site on CECsCECs (or (or PPCPsPPCPs) ) ––www.epa.gov/waterscience/ppcpwww.epa.gov/waterscience/ppcp

Final 2008 Effluent Guidelines Program Plan:Final 2008 Effluent Guidelines Program Plan:

An ADAAn ADA--funded study showed that approximately funded study showed that approximately 50% of mercury entering 50% of mercury entering POTWsPOTWs is from dental is from dental officesofficesEPA estimates that dentists discharge approximately EPA estimates that dentists discharge approximately 3.7 tons of mercury each year to 3.7 tons of mercury each year to POTWsPOTWsAmalgam separators increase the amount of Amalgam separators increase the amount of amalgam that is recycled (amalgam separators are at amalgam that is recycled (amalgam separators are at least 95% efficient).least 95% efficient).Use of amalgam separators generally results in Use of amalgam separators generally results in reductions in POTW influent and reductions in POTW influent and biosolidsbiosolidsconcentrations. concentrations. 2929--50% reduction in 50% reduction in biosolidsbiosolids have been reportedhave been reported

ADA/EPA/NACWA MOUADA/EPA/NACWA MOU

Provides for voluntary program to promote the proper Provides for voluntary program to promote the proper installation and maintenance of dental amalgam installation and maintenance of dental amalgam separators; signed in Dec. 2008.separators; signed in Dec. 2008.Provides for establishment of Provides for establishment of

Baseline of current separator usage, Baseline of current separator usage, Goals for increased usage, and Goals for increased usage, and Tracking of progress.Tracking of progress.

Parties agree to promote program, raise awareness, Parties agree to promote program, raise awareness, outreach.outreach.EPA works with ADA on recognition of dentists.EPA works with ADA on recognition of dentists.

MOU IntentionsMOU Intentions

To be used as a vehicle for examining the To be used as a vehicle for examining the % of dentists using amalgam separators % of dentists using amalgam separators and their effectiveness at recovering and their effectiveness at recovering dental amalgam and reducing mercury dental amalgam and reducing mercury discharges to discharges to POTWsPOTWsAfter such examination, EPA may reAfter such examination, EPA may re--evaluate its view not to initiate an effluent evaluate its view not to initiate an effluent guidelines rulemaking for the dental sectorguidelines rulemaking for the dental sector

Significant Industrial Significant Industrial Users and Users and Significant Significant

NoncomplianceNoncompliance

Tracy McGrathTracy McGrathProgram Manager Program Manager -- ComplianceCompliance

EPA Definition of EPA Definition of Significant Industrial UserSignificant Industrial UserProcess covered by Categorical Process covered by Categorical Pretreatment Standards (EPA Regulations Pretreatment Standards (EPA Regulations @ 40 CFR 403@ 40 CFR 403--471). Even when there is 471). Even when there is no discharge.no discharge.Discharges an average total process flow Discharges an average total process flow > or = 25,000 gpd.> or = 25,000 gpd.Contributes a process wastestream > or = Contributes a process wastestream > or = 5% of the average dry weather hydraulic 5% of the average dry weather hydraulic or organic capacity of plant.or organic capacity of plant.Facility has a reasonable potential to Facility has a reasonable potential to violate pretreatment standards or violate pretreatment standards or requirements (PTV)requirements (PTV)

SIU Definition (conSIU Definition (con’’t)t)

Factors Considered in determining PTV:Factors Considered in determining PTV:

FlowFlowNature of process and dischargeNature of process and dischargeCompliance historyCompliance historyHave or need pretreatment to meet a Have or need pretreatment to meet a limit(s)limit(s)

Total SIUS:FY02Total SIUS:FY02--FY08FY08

260 254 248 243 240 226 226

0

100

200

300

FY02 FY03 FY04 FY05 FY06 FY07 FY08

MWRA Program for SIUsMWRA Program for SIUsInspect and Sample at least annuallyInspect and Sample at least annuallyEvaluate compliance quarterlyEvaluate compliance quarterly

Reporting requirementsReporting requirementsDischarge limitsDischarge limitsCompliance schedule milestonesCompliance schedule milestones

Report to EPA annuallyReport to EPA annuallyPublish SIUs in SNC in newspaper Publish SIUs in SNC in newspaper annuallyannually

Determination of Determination of Significant Noncompliance Significant Noncompliance

(SNC)(SNC)

Four major categoriesFour major categories::Discharge (SNC A and B)Discharge (SNC A and B)Reporting (SNC F)Reporting (SNC F)Compliance schedule milestones (SNC Compliance schedule milestones (SNC E)E)Other (SNC H)Other (SNC H)

4 Overlapping Periods4 Overlapping Periods

Q1: April 1 Q1: April 1 -- September 30September 30Q2: July 1 Q2: July 1 -- December 31December 31Q3: October 1 Q3: October 1 -- March 31March 31Q4: January 1 Q4: January 1 -- June 30June 30

SNC: Discharge ViolationsSNC: Discharge ViolationsSNC is evaluated by sample location, SNC is evaluated by sample location, by parameter, and by limit (daily, by parameter, and by limit (daily, monthly, 4monthly, 4--day, and 30day, and 30--day average day average limits)limits)SNC A: (Chronic) SNC A: (Chronic) 66% or more of the sample results66% or more of the sample resultsexceed the limit in a six month periodexceed the limit in a six month period

SNC B: (Technical Review Criteria)SNC B: (Technical Review Criteria)33% or more of the sample results 33% or more of the sample results exceed the TRC limit in a six month exceed the TRC limit in a six month periodperiod

SNC SNC -- A and BA and BZinc Limit (1.0 mg/l)Zinc Limit (1.0 mg/l)3 Samples in Period Oct 3 Samples in Period Oct -- MarMar2/3 (66.7%) in violation = SNC A2/3 (66.7%) in violation = SNC A1/3 (33.3%) in violation at >1.2 x limit of 1/3 (33.3%) in violation at >1.2 x limit of 1.0 = SNC B1.0 = SNC B1 Sample in Period Jan 1 Sample in Period Jan -- JuneJune1/1 (100%) in violation, greater than limit 1/1 (100%) in violation, greater than limit and at >1.2 x limit = SNC A + Band at >1.2 x limit = SNC A + B

Oct Nov Dec Jan Feb Mar Apr May Jun.08 1.1 2.5

How to Avoid SNC for How to Avoid SNC for Discharge ViolationsDischarge Violations

Sample earlySample early in the sampling periodin the sampling periodSample oftenSample often! (More than required by ! (More than required by your permit, if necessary.)your permit, if necessary.)Submit results using Submit results using http://http://websmr.mwra.comwebsmr.mwra.com::

all sample results for samples analyzed in all sample results for samples analyzed in accordance with EPA/MWRA approved accordance with EPA/MWRA approved proceduresprocedures

How to Avoid SNC for How to Avoid SNC for Discharge Violations Discharge Violations (continued)(continued)

Remember that both MWRA and SelfRemember that both MWRA and Self--monitoring results countmonitoring results countFed Cats: Remember monthly or other Fed Cats: Remember monthly or other average limitsaverage limitsWhen you do have a violation: Report When you do have a violation: Report it to MWRA; Investigate the cause; it to MWRA; Investigate the cause; Correct the problem; and sample again.Correct the problem; and sample again.

SNC for Reporting ViolationsSNC for Reporting Violations

Report received >45 after the due dateReport received >45 after the due dateBaseline Monitoring ReportBaseline Monitoring Report90 Day Compliance Report90 Day Compliance ReportSelfSelf--Monitoring ReportsMonitoring ReportsCompliance Schedule ReportsCompliance Schedule Reports

Sampling outside of the required periodSampling outside of the required period

How to Avoid SNC for How to Avoid SNC for Reporting ViolationsReporting Violations

Read your permit and know your Read your permit and know your monitoring and reporting requirements, monitoring and reporting requirements, inc. parameters, frequencies, sampling inc. parameters, frequencies, sampling periods, and report due datesperiods, and report due dates

Make sure your laboratory knows your Make sure your laboratory knows your monitoring and reporting requirementsmonitoring and reporting requirements

Sample during the correct periodSample during the correct period

How to Avoid SNC for How to Avoid SNC for Reporting Violations Reporting Violations (continued)(continued)

Review your laboratory results as soon Review your laboratory results as soon as you receive them and confirm that as you receive them and confirm that all required parameters have been all required parameters have been reportedreported

Submit your permit application and Submit your permit application and other reports (e.g, BMR) on timeother reports (e.g, BMR) on time

Why Stay Out of SNC?Why Stay Out of SNC?

You can avoid negative publicity.You can avoid negative publicity.

You can avoid higher level and more You can avoid higher level and more costly enforcement actions (NONs, costly enforcement actions (NONs, Orders, PANs).Orders, PANs).

ItIt’’s better for the environments better for the environment

Why Stay Out of SNC?Why Stay Out of SNC?

ItIt’’s cheaper: lower monitoring s cheaper: lower monitoring charges (SNC discharge violations charges (SNC discharge violations double your monitoring points for double your monitoring points for the parameter(s) in violation), and no the parameter(s) in violation), and no charges for missed or late reports!charges for missed or late reports!

Total SIUS in SNC: FY02Total SIUS in SNC: FY02--FY08FY08

92

68 7460

51 50 50

020406080

100120

FY02 FY03 FY04 FY05 FY06 FY07 FY08

FY08: SNC BreakdownFY08: SNC Breakdown

Reporting Violations Only: 10 Reporting Violations Only: 10

Discharge & Reporting: 40Discharge & Reporting: 40

FY08 Enforcement ActivitiesFY08 Enforcement Activities

Total Enforcement Actions: 346 Total Enforcement Actions: 346 Total for SIUs:Total for SIUs:

168 Notices of Violation168 Notices of Violation13 Enforcement Orders13 Enforcement Orders6 Administrative Settlement6 Administrative Settlement2 Penalty Assessment Notices2 Penalty Assessment Notices1 Notice of Proposed Permit Suspension1 Notice of Proposed Permit Suspension

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