Al Garcia Northwest Pretreatment Workshop September
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Final 2016 Effluent Limitation Guidelines Plan
Published for Public CommentMay 2, 2018
https://www.gpo.gov/fdsys/pkg/FR-2018-05-02/pdf/2018-09320.pdf
Final 2016 ELG PlanIndustry Review
Petroleum Refining Electrical and Electronic Components
Manufacturing Continued Study of the CWT Facilities – oil
and gas Conventional Extraction - Oil and Gas
Industry Produced Water Discharges in the Oil and
Gas Industry (well treatment, workover fluids)
Final 2016 ELG PlanNew Rulemaking
Potentially Revise Requirements in the 2015 Steam Electric Rule PSES – November 2018Bottom Ash Transport Water and
Flue Gas Desulfurization (FGD) wastewater
National Rulemaking Process and Local Program Input
Local Program Implementation New Pretreatment Standards IUs in Service Area Existing SIUs
National Studies – Oil and Gas, EEC, Petroleum Refining
Local Program Interpretation New Pretreatment Standards IUs in Service Area Existing SIUs
Metal Finishing Study https://www.epa.gov/sites/production/files/2018‐05/documents/metal‐finishing_prelim‐
review_april‐2018.pdfEtching vs. Cleaning (use of citric acid, acetic acid, weak acids on metal)
Ancillary Processes
Published on June 14, 2017…with correction – June 26, 2017…and corrections, *sigh* ‐ July 5, 2017.
40 CFR Part 441
Effective Date – July 14, 2017
New Source Date – July 14, 2017ApplicabilityProvisions: Installation of an ISO 11143‐compliant Amalgam Separator (or equivalent device)
Compliance with 2 BMPs Line cleanersWaste amalgam must be treated
Dental Facilities, including institutions, temporary offices, clinics, home offices and dental facilities owned by Federal, State or Local governments.
Oral pathology/radiology/surgery, orthodontics, periodontics, prosthodontics
Mobile UnitsDental dischargers that do not discharge amalgam process wastewater to the POTW
Dentists that transfer waste to a CWT facility
Do not place or remove amalgam, except in limited emergency or unplanned, unanticipated circumstances, and
Certify to the control authority to the effect that they do not and will not use or remove amalgam
Unless otherwise designated by the Control Authority, dental dischargers subject to this part are not Significant Industrial Users as defined in 40 CFR part 403, and are not ‘‘Categorical Industrial Users’’ as a result of applicability of this rule.
Successful Sector Control Programs‐based on BMPs: Requirement to install Treatment Technology
Requirement for Adequate Sizing Requirement to Operate and Maintain Treatment
Requirement to Maintain Records
Installation of an adequately sized amalgam separator
Meets ISO 11143 certification standardsRemoval efficiency of at least 95%
Installation of an adequately sized amalgam separator
What is an amalgam separator? Solids collector Capture Hg by default Avg Annual Costs ‐$800.00
Operation and Maintenance Inspected in accordance with manufacturers operating manual
Must be repaired within 10 business days, if discovered to be not functional
Maintained by replacing the cartridge, canister or unit collector of retained solids when the design capacity is reached.
Prohibition of oxidizing line cleaners, including but not limited to bleach, chlorine, iodine or peroxide that have a pH lower than 6 or greater than 8.
Ensure all amalgam process wastewater, including chair side traps, screens, vacuum pump filters, dental tools, cuspidors, or collection devices are treated through the amalgam separator.
RecordkeepingMaintain for three years: Inspection records/logsMaintenance of SeparatorManifest/shipping records of cartridge replacement
Documentation of repairs or replacement
Existing Source: Compliance with Rule by July 14, 2020 Provide a one‐time compliance report‐October 12, 2020
New Source Compliance with Rule upon startup Provide a one‐time compliance report within 90 days
Grandfather Clause: Separators installed prior to June 14, 2017 (publication date in FR)
Separator meets requirements until it is replaced or for 10 years (June 14, 2027)…whichever is sooner….and
If they continue to meet the requirements in the Rule
One time Compliance ReportContact informationCharacterize Dental officeAmalgam Separator informationO + M certificationsBMP certificationshttps://www.epa.gov/eg/dental‐effluent‐
guidelines
Legal authorityProceduresFunding/ResourcesLocal LimitsEnforcement Response Plan (Compliance Evaluation)
IU inventory
Coordinated with State ADA officesProvided the EPA Region 8 One‐time Compliance report
Receiving reports from dentists in non‐approved program
Phase II IU inventory in 2019Gather list of dentist offices
Every report but 1 is incomplete; Outreach to every dental office to ensure interpretation of
complianceDo I have to complete the report? (Orthodontists, oral surgeon, etc.)
If more than one dentist in the practice do we each have to complete the form?
What about multiple practices in one building?
EPA Effluent Limitations Guidelines
https://www.epa.gov/eg/industrial-effluent-guidelines
Electronic CFRhttp://www.ecfr.gov/cgi-bin/ECFR?page=browse
Federal Register – October 22, 2015
Final Rule‐NPDES E‐Reporting Rule‐FR Vol 80, No 204‐pp 64064‐64158
Effective Date – December 21, 2015
Reduces burden of existing paper‐based reporting from regulated facilities and reduces third‐party data entry errors by instead requiring electronic data submissions;
Phase 1 – DMR Submissions & Biosolids Reports (21 Dec 2016)
Phase 2 – General Permit and Program Reports (21 Dec 2020)
Cross Media Electronic Reporting Rule40 CFR 403.8(g) – “A POTW that chooses to receive electronic documents must satisfy the requirements of 40 CFR part 3.”
https://www.epa.gov/sites/production/files/2018‐
05/documents/cromerr_potw_1.pdf
System Standards to ensure Integrity and Enforceability of electronic received data Criteria for establishing a copy of record; Integrity of the electronic document; Validity of the electronic signature; Determination of the identity of the individual uniquely entitled to use a signature device; and
Opportunity to review and repudiate the copy of record.
PDFs do not meet these data integrity elements
Guidance issued May 2018
https://www.epa.gov/sites/production/files/2018‐05/documents/cromerr_potw_1.pdf
May 2018Roles and Responsibilities of Pretreatment Programs:Verify Legal Validity of Electronic SignaturesPrepare CROMMER system documentationReview and Update Pretreatment Program Requirements
Legal authority (Program Modification)ProceduresFunding/ResourcesLocal LimitsEnforcement Response Plan IU inventory
40 CFR 403.8(f)(2)(iv) : “Receive[s] and analyze[s] self‐monitoring reports and other notices submitted by Industrial Users in accordance with the self‐monitoring requirements in § 403.12”
40 CFR 403.8(f)(5) and 403.9(b) ‐ Identify POTW organizational duties
40 CFR 403.8(f)(3) and 403.9(b): Ensure that the POTW has sufficient resources (funding) and qualified personnel
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