Chris Hornback \<chornback@nacwa.org\>

09/06/2005 03:42 PM To

Group Ow-Docket@EPA

cc

Tom Born/DC/USEPA/US@EPA

bcc

Subject

Docket OW-2004-0035

Attached are the National Association of Clean Water Agencies (NACWA\'s)

comments on Docket ID OW-2004-0035. Please let me know if you have any

problems accessing the file.

Chris Hornback

Director, Regulatory Affairs

National Association of Clean Water Agencies

1816 Jefferson Place, NW

Washington, DC 20036

p 202/833-9106

f 202/833-4657

http://www.nacwa.org

September 6, 2005

![](media/image1.jpeg){width="1.625in" height="0.43680555555555556in"}

EPA Docket Center

U.S. Environmental Protection Agency

Water Docket (Mail Code 4101T)

1200 Pennsylvania Ave., NW.

Washington, DC 20460

Via Electronic Mail: *OW-Docket@epa.gov*

Dear Sir or Madame:

On September 1, 2005, representatives from the National Association of
Clean Water Agencies (NACWA) met with U.S. Environmental Protection
Agency (EPA or Agency) Office of Water staff to discuss the Agency's
information collection activities related to the drinking water
treatment facility effluent guideline effort (July 5, 2005; 70 *Fed.
Reg.* 38675). During that meeting, NACWA members provided EPA officials
with verbal comments on the content of both the screener survey and the
detailed questionnaire. This letter formally transmits those verbal
comments to the Docket for this information collection request.

NACWA's most fundamental comment was that neither survey recognized that
many water and wastewater agencies have long histories of working
together to manage the myriad wastestreams generated in the process of
treating drinking water. These arrangements have been appropriately
controlled through local limits as well as other provisions of approved
pretreatment programs as needed. In addition, the surveys were focused
primarily on the solids generated from the process, but there are other
wastestreams that are also generated and usually discharged to
wastewater treatment plants. These other wastestreams are discussed
below.

![](media/image2.jpeg){width="14.75in" height="3.0in"} drinking water
solids with their solid wastes.

The detailed comments below include suggested revisions to the surveys
to address the issues discussed above:

-   Section 3 - Residuals Destination Codes should include a code POH
    for POTW -- Headworks and a code POSH for POTW -- Solids Handling.

-   Section 3.1 - Schematic does not reference anything about the
    addition of Zinc Ortho phosphate.

-   Section 4 - Suggest the addition of a question after 4-1 that reads
    "Does your facility discharge residuals to POTW headworks, solids
    handling or both?"

-   Section 4-3 - Suggest section start with the question "Does your
    facility have an indirect discharge permit?" Then, if yes, provide
    permit number and date of permit.

-   Section 4-4 and Question 10 of the Screener Survey - Suggest
    addition of other possible wastestreams including: laboratory
    wastewater, regeneration water from water softener for boiler
    make-up, chlorine analyzer wastewater, equipment wash-down
    wastewater, contact and non-contact cooling water, boiler blow-down
    and raw water pumping from sample collection.

-   Section 4-11 - Suggest item J be modified to "Haul or Pump to
    POTW/PrOTW/FOTW/CWT."

-   Table 4-11 - Suggest item J include Haul/Pump to
    POTW/PrOTW/FOTW/CWT. Suggest Item A also include question "Does your
    facility dispose of residuals by hauling or pumping to a POTW,
    PrOTW, FOTW or CWT?" Item I should reference "Percent solids of
    sludge hauled or pumped to facility."

-   The following pollutants could be added to Section 2-5 (except for
    TCLP) and Section 4-14: TKN, Total Solids, Volatile Suspended Solids
    and TCLP. Also Nitrate should be revised to Nitrate-Nitrite.

NACWA appreciates the opportunity to comment on this information
collection request. Please contact me at 202/833-9106 if you have any
questions.

Sincerely,

/signature

Chris Hornback

Director, Regulator Affairs