From: "Norman, Russell@Waterboards" <RNorman@waterboards.ca.gov>

SendTo: Maria Gomez-Taylor/DC/USEPA/US@EPA
 

CopyTo: Robin Oshiro/DC/USEPA/US@EPA,"'Christine.Wong@tetratech.com'"

<Christine.Wong@tetratech.com>

Subject: RE: [statepretcoord] State Pretreatment Coordinators' 

conference call TODAY, June 13 at 2 PM Eastern - Requested submission of

comments
 

DeliveredDate: 07/10/2012 02:58:49 PM
 

Hello Maria:
 

I have attached the information we were able to dig up from our Regional

Boards for Oil & Grease Local Limits. I just added these to the 

spreadsheet we previously sent with the NPDES O&G limit info. We didn’t 

get from on the local limits but, I think the limits reported are typical 

for California.
 

Please contact me if you have any questions.
 

Thank you,
 

W. Russell Norman, P.E. 

Water Resources Control Engineer

Statewide SSO Program

http://www.swrcb.ca.gov/water_issues/programs/sso

State Water Resources Control Board 

Division of Water Quality

1001 I St, 15th Floor

Sacramento, CA 95814

rnorman@waterboards.ca.gov

Ph: (916) 323-5598

Fax: (916) 341-5463 

<o))))>< This communication is privileged and confidential, and is

intended only for the individual or entity named above. If you are not 

the intended recipient, please do not read, copy, use, or disclose this 

communication to others. <o))))>< 

Water is the driving force of all nature.

Leonardo da Vinci 
RB Facility Limit Units Note

5R Redding 300 mg/l 

5R Chico 300 mg/l 

1 Crescent City 50 mg/l 

1 Eureka 100 mg/l 

1 Arcata 100 mg/l "fats,oils, or greases of animal or vegetable origin" 

1 Arcata 200 ppm TPH 
From: "Knerr, Lisa A." <Lisa.Knerr@dphe.state.co.us>

SendTo: Maria Gomez-Taylor/DC/USEPA/US@EPA,Robin Oshiro/DC/USEPA/US@EPA 

Subject: FW: State Pretreatment Coordinators' conference call TODAY, 

June 13 at 2 PM Eastern - Requested submission of comments

DeliveredDate: 06/20/2012 04:48:13 PM 

Maria and Robin, 

Per our state regulation in Colorado, the limit for oil and grease is 10 

mg/L as determined by the results of any single grab sample. A numeric 

effluent limit will be a ssigned in permits for discharges to s urface

waters, however, monitoring for a "visual sheen" will generally be

required. Where a visual sheen is detected, the discharger will be 

required to collect a grab sample and have it analyzed for oil and

grease.

Monitoring for oil and grease may be required where there is a reasonable 

potential that oil and grease will be present in the effluent at

concentrations at or above 10 mg/l. Check out the bottom of p age 3 

(http://www.cdphe.state.co.us/regulations/wqccregs/62_2012(07).pdf). 

Thiis for a direct discharger. For an indirect discharger, the limit 

would 

depend on the POTW’s local limits and any applicable ELGs along with the

general and specific pretreatment standards. 

Lisa 

Lisa Knerr 

Environmental Protection Specialist

Water Quality Control Division

Colorado Department of P ublic Health and Environment

4300 Cherry Creek Drive South

Denver, CO 80246-1530

www.coloradowaterpermits.com

303-692-3004 | Lisa.Knerr@state.co.us 

http://10.1.0.25/cdphegraphics/images/statesealanddepttitle.gif round 

YouTube 

From: Russell Norman <RNorman@waterboards.ca.gov>

SendTo: Robin Oshiro/DC/USEPA/US@EPA,Maria GomezTaylor/DC/USEPA/US@EPA,<Christine.Wong@tetratech.com>

Subject: Re: [statepretcoord] State Pretreatment Coordinators' 

conference call TODAY, June 13 at 2 PM Eastern - Requested submission of

comments 

DeliveredDate: 06/19/2012 01:46:35 PM 

Body: Hello Christine: 

 

The breakdown in California for O&G permit limits for direct dischargers

with approved PT programs is all are less than 200 mg/l. See attached 

list. 

 

We're still researching typical local limits in approved PT programs and

evaluating implementation issues as requested in question 2 below. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Thank you, 

W. Russell Norman, P.E.

Water Resources Control Engineer

Statewide SSO Program

http://www.swrcb.ca.gov/water_issues/programs/sso

State Water Resources Control Board 

Division of Water Quality

1001 I St, 15th Floor

Sacramento, CA 95814

rnorman@waterboards.ca.gov

Ph: (916) 323-5598

Fax: (916) 341-5463 

<o))))>< This communication is privileged and confidential, and is

intended only for the individual or entity named above. If you are not 

the intended recipient, please do not read, copy, use, or disclose this 

communication to others. <o))))>< 

When the well is dry, we know the worth of water. BENJAMIN FRANKLIN

(1706-1790), Poor Richard's Almanac, 1746 

>>> "Wong, Christine" <Christine.Wong@tetratech.com> 6/13/2012 2:10 PM

>>> 

HI All, 

Per today’s state Coordinators’ call, this is the reminder to submit

comments about a) the potential new oil and grease method and b) the

proposed outline for the POTW Pretreatment Program Development Guidance 

Manual. 

Comments regarding: 

(1) Do you have information on the typical concentration range for oil

and grease limits in permits; what would be the breakdown of permits 

above and below 200 mg/L? Please specify applicable limits for both

direct dischargers and indirect dischargers (and identify which are 

which!). 

(2) What implementation problems do you anticipate if EPA were to approve

the ASTM method? What would be the State and Regional burden if EPA goes

with approval with side-by-side data required? 

should be sent to Maria Gomez-Taylor (Gomez-Taylor.Maria@epamail.epa.gov) 

and Robin Oshiro (Oshiro.robin@Epa.gov) of EPA’s Office of Science and 

Technology. 

Comments about the proposed outline for the POTW Pretreatment Program 

Development Guidance Manual should be sent to Robin Danesi 

(Danesi.Robin@epamail.epa.gov) of EPA’s Office of Wastewater Management. 

Please send comments on these topics ASAP, as significant project efforts 
------------------------------------------

------------------------------------------

 

 

 

 

 

 

 

 

 

 

 

are being made in the near future. 

Thank you! 

~Christine 

Christine Wong | Environmental Scientist IV

Phone: 703.385.6000, ext. 363 | Fax: 703.385.6007

christine.wong@tetratech.com 

Tetra Tech | Complex World, Clear Solutions

10306 Eaton Place, Suite 340 | Fairfax, VA 22030-2201 | www.ttwater.com 

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Date: Tue, 19 Jun 2012 10:26:24 -0700

From: David Cooper <DCooper@waterboards.ca.gov>

To: Russell Norman <RNorman@waterboards.ca.gov>

Subject: NPDES Permit Effluent Limits

Content-Type: multipart/mixed; boundary="=__Part210F8350.2__="

MIME-Version: 1.0
 

Hi Russ,
 

See the attached excel sheet for the Oil and Grease limits. I grabbed 

the NPDES dischargers from CIWQS and then searched their CA NPDES ID's in

ICIS to get the oil and grease limits from their permits. I just

searched facilities that have pretreatment programs since I though that 

was the most applicable.
 

I noticed that the highest daily max allowable was 75 mg/L. Although

there were a few with the oil and grease parameter in their permit but no 

established limit yet. I think there were about 3-5 of them. The only
 

one that I do remember was Sac Regional. These would be the only ones 

with limits over 200 since they don't have a limit yet. All of the other 

limits were below 75. I'll have to research which ones have monitoring 
 

 

 

 

 

 

requirements for oil and grease but no established limit because I didn't 

mark them while recording the limits and didn't think about it until I

finished. 

Let me know if you have any questions. 

-David 

- NPDES.permit.pretreatment.XLSX 
RB FACILITY NAME NPDES # Mo Avg Hi Wk Avg Daily Max 

1 Crescent City WWTP CA0022756 25 40 75 m

2 MILLBRAE WWTP CA0037532 10 20 m

4 Ojai Valley WWTP CA0053961 n/a n/a n/a m

5R Stillwater WWTF CA0082589 n/a n/a n/a m

5S El Dorado Hills WWTP CA0078671 n/a n/a n/a m

2 BENICIA WWTP CA0038091 10 20 m

3 LOMPOC REGIONAL WWTP CA0048127 5 10 m

5S Brentwood WWTP CA0082660 10 15 m

1 Eureka City Elk River WWTP CA0024449 25 40 75 m

2 BURLINGAME WWTP CA0037788 10 20 m

5F ATWATER WWTF (5C240100001) CA0079197 10 15 m

4 Saugus Water Reclamation Plant CA0054313 10 15 m

5R Oroville WWTP CA0079235 n/a n/a n/a m

2 NOVATO AND IGNACIO WWTP CA0037958 10 20 m

2 PETALUMA ELLIS CREEK WATER RECYCLING FACIL CA0037810 10 20 m

8 Henry N. Wochholz WWRF CA0105619 n/a n/a n/a m

3 SCRWA WWTP CA0049964 n/a n/a n/a m

5S Davis WWTP CA0079049 n/a n/a n/a m

8 WRCRWA Regional WWRF CA8000316 n/a n/a n/a m

2 City of Livermore Water Reclamation Plant CA0038008 10 20 m

5S White Slough Water Pollution Control Facility CA0079243 n/a n/a n/a m

5R Clear Creek WWTP CA0079731 n/a n/a n/a m

5S Tracy WWTP CA0079154 n/a n/a n/a m

2 CENTRAL MARIN SAN. AGCY. WWTP CA0038628 10 20 m

5S Woodland Water Pollution Control Facility CA0077950 n/a n/a n/a m5S Yuba City WWTF CA0079260 n/a n/a n/a m

3 EL ESTERO WWTP NPDES CA0048143 25 40 75 m

8 Corona WWRF No. 1 CA8000383 n/a n/a n/a m

5F Merced WWTF CA0079219 n/a n/a n/a m

8 Rialto WWRF CA0105295 n/a n/a n/a m3 WATSONVILLE WWTP CA0048216 25 40 75 m

5R Chico Water Pollution Control Plant CA0079081 n/a n/a n/a m

5S Pleasant Grove WWTP CA0084573 n/a n/a n/a m

4 Burbank WWRP CA0055531 10 15 m

6B VICTOR VALLEY MUNI WTP CA0102822 n/a n/a n/a m

2 South San Francisco-San Bruno WQCP CA0038130 10 20 m4 Ventura WRF CA0053651 10 15 m4 Whittier Narrows Water Reclamation Plant, El Monte CA0053716 10 15 m4 Pomona Water Reclamation Plant CA0053619 10 15 m

5S Easterly WWTP CA0077691 n/a n/a n/a m

2 NAPA SD WWTP (Soscol Water Recycling Facility) CA0037575 10 20 m

2 VALLEJO SFCD WWTP CA0037699 10 20 m

2 SAN MATEO WWTP CA0037541 10 20 m

4 Tapia WRF CA0056014 5 10 m

2 DELTA DIABLO SD WWTP CA0038547 10 20 m

Oil & Grease Concentration Limits 

[03582] 

Programs = 79, Average Flow = 39.88 mgd, Max = 45
3 SANTA CRUZ WWTP CA0048194 25 40 75 m

2 FSSD SUBREGIONAL WWTP CA0038024 10 m

5S Manteca WW Quality Control Facility CA0081558 n/a n/a n/a m

8 Michelson WWRF CA8000326 n/a n/a n/a m9 HARRF DISCH to San Elijo Ocean Outfall CA0107981 25 40 75 m

5S Dry Creek WWTP CA0079502 n/a n/a n/a m

4 Los Angeles-Glendale WWRP CA0053953 10 15 m

5S Turlock WWTP CA0078948 n/a n/a n/a m

2 DUBLIN SAN RAMON SD WWTP CA0037613 10 20 m

4 Valencia Water Reclamation Plant CA0054216 10 15 m

9 LA SALINA WWTP, OCEANSIDE OCEAN OUTFALL CA0107433 25 40 75 m2 SBSA WWTP CA0038369 10 20 m

2 SUNNYVALE WPCP CA0037621 5 10 m

3 MRWPCA REG TRTMT & OUTFALL SYS CA0048551 25 40 75 m4 Terminal Island Water Reclamation Plant CA0053856 10 15 m4 Oxnard Wastewater Treatment Plant CA0054097 25 40 75 m9 LATHAM WWTP CA0107417 25 40 75 m

2 PALO ALTO REGIONAL WQCP CA0037834 5 10 m2 SF - OCEANSIDE WPCP CA0037681 n/a n/a n/a m9 BUENA SD, SHADOWRIDGE WRP CA0107395 25 40 75 m

2 CENTRAL CONTRA COSTA SD WWTP CA0037648 10 20 m

5S Stockton Regional WW Control Facility CA0079138 n/a n/a n/a m

5S Modesto Water Quality Control Facility (primary trtmt) CA0079103 n/a n/a n/a m

4 Donald C. Tillman WWRP CA0056227 10 15 m8 IEUA Regional Plant No. 1 CA8000409 n/a n/a n/a m2 SF-SE WPCP, N-Point & Bayside CA0037664 10 20 m

4 San Jose Creek Water Reclamation Plant CA0053911 10 15 m2 EBDA COMMON OUTFALL CA0037869 10 20 m2 EBMUD WPCP CA0037702 10 20 m2 SAN JOSE/SANTA CLARA WPCP CA0037842 5 10 m

5S Sacramento Regional WWTP CA0077682 n/a n/a n/a m

9 Point Loma WWTP & Ocean Outfall CA0107409 25 40 75 m

4 Joint Water Pollution Control Plant, Carson CA0053813 15 22.5 75 m

4 Hyperion WWTP CA0109991 25 40 75 m
79 

THREAT TO WATER QUALITY COMPLEX PRETREATMENT PROGRAMF PROGRA

1 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 2 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 2 B Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 B Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 3 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 

1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 
1 A Y - POTW has EPA approved pretreatment program NPDES 2 

1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 3 C Y - POTW has EPA approved pretreatment program NPDES 1 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 2 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 4 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 1 1 A Y - POTW has EPA approved pretreatment program NPDES 2 1 A Y - POTW has EPA approved pretreatment program NPDES 2 
NPDES # CA# MAJOR-M NPDES TYSTATUS STATUS DAT EFFECTIVE EXPIRATIONMOST RECENT AMENDMENT NUMBE

CA0022756 Major MUN Active 7/12/2011 6/30/2011 6/29/2016 CA0037532 Major MUN Active 2/10/2012 10/1/2008 9/30/2013 R2-2011-0009 CA0053961 Major MUN Active 9/6/2009 8/29/2008 6/10/2013 CA0082589 Major MUN Active 2/15/2011 6/21/2007 6/1/2012 CA0078671 Major MUN Active 9/18/2008 8/11/2007 6/1/2012 CA0038091 Major MUN Active 2/10/2012 6/1/2008 5/30/2013 R2-2011-0009 CA0048127 Major MUN Active 1/31/2012 1/13/2012 1/13/2017 CA0082660 Major MUN Active 3/15/2010 3/15/2008 12/31/2012 R5-2008-0087 CA0024449 Major MUN Active 11/16/2011 7/24/2009 7/24/2014 CA0037788 Major MUN Active 2/10/2012 4/1/2008 3/31/2013 R2-2011-0009 CA0079197 Major MUN Active 4/26/2011 6/22/2007 6/21/2012 CA0054313 Major MUN Active 10/17/2009 7/24/2009 5/10/2014 CA0079235 Major MUN Active 3/10/2011 5/27/2010 5/1/2015 CA0037958 Major MUN Active 2/10/2012 7/1/2010 6/30/2015 R2-2011-0009 CA0037810 Major MUN Active 2/10/2012 3/1/2011 2/28/2016 R2-2011-0009 CA0105619 Major MUN Active 12/24/2009 2/2/2007 2/2/2012 CA0049964 Major Active 4/26/2010 3/18/2010 3/18/2015 CA0079049 Major MUN Active 9/30/2011 12/14/2007 10/1/2012 R5-2010-0097 CA8000316 Major MUN Active 7/21/2008 7/18/2008 7/1/2013 CA0038008 Major MUN Active 3/1/2012 3/1/2012 2/28/2017 CA0079243 Major MUN Active 1/22/2008 11/3/2007 9/1/2012 CA0079731 Major MUN Active 3/7/2011 9/23/2010 9/1/2015 CA0079154 Major MUN Active 3/11/2010 6/23/2007 5/1/2012 R5-2011-0012 CA0038628 Major MUN Active 2/10/2012 4/1/2007 3/31/2012 R2-2011-0009 CA0077950 Major MUN Active 5/11/2010 3/27/2009 2/1/2014 CA0079260 Major MUN Active 1/6/2011 12/14/2007 10/1/2012 R5-2010-0007 CA0048143 Major MUN Active 6/2/2010 5/13/2010 5/13/2015 CA8000383 Major MUN Active 2/16/2010 3/2/2007 3/2/2012 CA0079219 Major MUN Active 5/6/2008 5/5/2008 3/13/2013 CA0105295 Major MUN Active 9/20/2010 3/2/2007 3/2/2012 R8-2010-0034 CA0048216 Major MUN Active 4/22/2009 5/9/2008 5/9/2013 CA0079081 Major MUN Active 5/17/2011 1/29/2010 1/1/2015 CA0084573 Major MUN Active 8/13/2008 8/1/2008 6/1/2013 CA0055531 Major MUN Active 3/13/2012 4/22/2012 2/10/2017 CA0102822 Major Active 10/4/2011 2/14/2008 2/14/2013 CA0038130 Major MUN Active 2/10/2012 1/1/2009 12/31/2013 R2-2011-0009 CA0053651 Major MUN Active 4/26/2012 3/6/2008 2/10/2013 R4-2008-0208 CA0053716 Major MUN Active 6/29/2011 7/24/2009 5/10/2014 CA0053619 Major MUN Active 10/20/2009 7/24/2009 5/10/2014 CA0077691 Major MUN Active 9/2/2010 6/14/2008 4/1/2013 R5-2010-0027 CA0037575 Major MUN Active 2/13/2012 4/1/2011 3/31/2016 R2-2011-0009 CA0037699 Major MUN Active 2/21/2012 4/1/2012 3/31/2017 CA0037541 Major MUN Active 2/10/2012 2/1/2008 1/31/2013 R2-2011-0009 CA0056014 Major MUN Active 5/1/2012 10/22/2010 8/10/2015 R4-2010-0165-A01 CA0038547 Major MUN Active 2/10/2012 5/1/2009 4/30/2014 R2-2011-0009 
CA0048194 Major MUN Active 1/13/2011 12/9/2010 12/9/2015 

CA0038024 Major MUN Active 2/10/2012 6/1/2009 5/31/2014 R2-2011-0009 CA0081558 Major MUN Active 12/8/2009 10/8/2009 10/1/2014 CA8000326 Major Active 7/3/2008 11/30/2007 11/1/2012 R8-2008-0072 

CA0107981 Major MUN Active 3/20/2012 10/28/2010 10/27/2015 Addendum No. 1 CA0079502 Major MUN Active 7/20/2008 8/1/2008 6/1/2013 CA0053953 Major MUN Active 4/2/2012 1/27/2012 11/10/2016 CA0078948 Major MUN Active 7/15/2010 3/19/2010 1/1/2015 CA0037613 Major MUN Active 3/8/2012 3/1/2012 3/1/2017 CA0054216 Major MUN Active 10/20/2009 7/24/2009 5/10/2014 CA0107433 Major MUN Active 1/20/2011 3/3/2011 3/2/2016 CA0038369 Major MUN Active 4/24/2012 4/1/2007 3/31/2012 R2-2011-0009 CA0037621 Major MUN Active 2/10/2012 10/1/2009 9/30/2014 R2-2011-0009 CA0048551 Major MUN Active 5/29/2009 4/30/2008 4/30/2013 CA0053856 Major MUN Active 12/27/2010 6/25/2010 4/10/2015 CA0054097 Major MUN Active 4/20/2012 6/20/2008 4/10/2013 R4-2010-0048 CA0107417 Major MUN Active 4/20/2012 5/31/2012 5/31/2017 CA0037834 Major MUN Active 2/10/2012 6/1/2009 5/31/2014 R2-2011-0009 CA0037681 Major MUN Active 2/10/2012 10/1/2009 9/30/2014 R2-2011-0009 CA0107395 Major MUN Active 3/20/2012 6/2/2011 6/1/2016 Addendum No. 1 CA0037648 Major MUN Active 2/28/2012 4/1/2012 3/31/2017 CA0079138 Major MUN Active 5/25/2011 12/12/2008 10/1/2013 CA0079103 Major MUN Active 1/5/2011 6/14/2008 4/1/2013 R5-2010-0040 CA0056227 Major MUN Active 1/30/2012 2/3/2012 11/10/2016 CA8000409 Major MUN Active 1/20/2012 7/20/2009 1/2/2014 R8-2010-0008 CA0037664 Major MUN Active 2/10/2012 4/1/2008 3/31/2013 R2-2011-0009 CA0053911 Major MUN Active 3/9/2010 7/24/2009 5/10/2014 CA0037869 Major MUN Active 3/1/2012 3/1/2012 2/28/2017 CA0037702 Major MUN Active 2/10/2012 5/1/2010 4/30/2015 R2-2011-0009 CA0037842 Major MUN Active 2/10/2012 6/1/2009 5/31/2014 R2-2011-0009 CA0077682 Major MUN Active 2/2/2012 1/28/2011 12/1/2015 R5-2011-0083 CA0107409 Major MUN Active 7/23/2010 8/1/2010 7/31/2015 CA0053813 Major MUN Active 9/20/2011 10/1/2011 8/10/2016 CA0109991 Major MUN Active 5/18/2012 12/24/2010 12/23/2015 
NDMENT DATE 
 

 

 

-----

 

 

 

 

 

 

 

 

From: Melissa Bouatene/DC/USEPA/US

To: Jan Matuszko/DC/USEPA/US@EPA

Date: 06/18/2012 02:18 PM

Subject: Fw: Data Request 

Hi JanMeghan Camp from ERG processed your queries from a database that only her 

could access and came up with the results below. 

Her results are different from what I would've gotten from using the

loading tool because the loading tool shows the number of permits for 

major facilities that have some type of permit requirement for O&G

(includes permits with effluent limits and permits with only monitoring 

requirements). 

The results below represents the number of permits with effluent limits

for O&G (excludes permits that only require O&G monitoring and do not

have 

limits). 

Melissa Bouatene 

ORISE Fellow 

OW| OST| EAD

U.S. EPA HQ

202-566-1634 

----- Forwarded by Melissa Bouatene/DC/USEPA/US on 06/18/2012 02:11 PM

From: "Meghan Camp" <Meghan.Camp@erg.com> 

To: Melissa Bouatene/DC/USEPA/US@EPA 

Cc: Carey Johnston/DC/USEPA/US@EPA

Date: 06/15/2012 04:43 PM

Subject: Re: Data Request 

Melissa, 

I ran your queries for our 2010 dataset and got the following results 

Majors with O&G limits = 1,907

Majors with concentration-based O&G limits = 1,833 

Majors with concentration-based O&G limits >= 200mg/L = 3 (TX0003191, 

CT0001716, and PA0027715) For TX003191 and PA0027715 the average

concentration limit is below 200 mg/L, but the daily max is above 200 

mg/L. CT0001716 only has a daily max limit. 

Please let me know if you have any questions or these results are 

unexpected. 

Meghan 

Meghan Camp

Chemical Engineer

ERG 

14555 Avion Parkway 
 

 

 

 

Chantilly, VA 20151

703-633-1684 

meghan.camp@erg.com 

>>> Melissa Bouatene <Bouatene.Melissa@epamail.epa.gov> 

6/14/2012 11:12 AM >>>

Subject: regional pretreatment conf call notes 

SendTo: Gomez-Taylor.Maria@epamail.epa.gov 

CopyTo: CN=Jan Matuszko/OU=DC/O=USEPA/C=US@EPA 

From: CN=Robin Oshiro/OU=DC/O=USEPA/C=US

DeliveredDate: 06/14/2012 02:48:54 PM 

Body: Bottom line: if approved w/ side by side testing, it's a huge

burden. 
 

 

Regional pretreatment coordinators conference call on D7575 implementation 6-14-12 

Participants: Regions 1-8, 10 (if Region 9 was on, I didn't hear them identify themselves) 

Region 4 

•	 Lots of POTW's lack the sophistication to do a side-by-side study, even with the guidance 

document 

•	 Have seen lots of O&G results that are > 200 mg/L 

•	 They mostly have contract labs, who would have to know that they must do Method 1664 

if the D7575 results are > 200 mg/L 

Region 8 

•	 Have seen < 200, but also way above 200 mg/L 

•	 Direct dischargers are 35 mg/L but also some at 10 mg/L 

•	 It would be a big burden to review side by side data for each discharger 

• D7575 is not practical for pretreatment program 

Region 3 

• Most common pretreatment limit is 100 mg/L, but have seen 300-500 mg/L 

Region 2 

•	 Where the legal authority has been delegated (e.g., New York City), they would have to 

change the regs if we approve the method 

Other unspecified Regions 

•	 Pretreatment is mostly 100 mg/L but some are way above this, and direct dischargers are 

mostly 15-20 mg/L (you won't see POTWs discharging higher than this) 

•	 Huge burden to review side by side data for each discharger, it can takes years for a 

single ATP to be approved 

•	 An option might be to just approve D7575 outright in the next MUR instead of requiring 

side by side testing 
 

 

 

 

 

 

 

 

 

 

From: "Scott, Grace (DEQ)" <SCOTTG@michigan.gov>

SendTo: Jan Pickrel/DC/USEPA/US@EPA,Maria Gomez-Taylor/DC/USEPA/US@EPA
 

CopyTo: "Wong, Christine" <Christine.Wong@tetratech.com>,"Lam, Alvin 

(DEQ)" <LAMA@michigan.gov>,Robin Oshiro/DC/USEPA/US@EPA
 

Subject: RE: O&G
 

DeliveredDate: 06/14/2012 11:36:48 AM
 

The NPDES permit language on analytical methods usually requires “an 

approved method or alternate method approved by the Department”. This 

allows us to handle that outside the permit and avoid any modifications.

Indirect permits normally have similar language. It general enough that

we would not require user permit modifications for an approved ATP.
 

Grace
 

From: "Lam, Alvin (DEQ)" <LAMA@michigan.gov>

To: Jan Pickrel/DC/USEPA/US@EPA
 

Cc: "Scott, Grace (DEQ)" <SCOTTG@michigan.gov>, "Wong, Christine" 

<Christine.Wong@tetratech.com>, Robin Oshiro/DC/USEPA/US@EPA, Maria 

Gomez-Taylor/DC/USEPA/US@EPA

Date: 06/14/2012 11:07 AM

Subject: RE: O&G
 

Jan,
 

Only EPA has the authority to approve ATP requests. The approval letter

will specify which pollutant(s) and NPDES permit(s) if the requester is a 

permittee or which program(s) and location(s) if the requester is a 

laboratory that the approval would apply. Thanks.
 

From: Jan Pickrel [mailto:Pickrel.Jan@epamail.epa.gov] 

Sent: Thursday, June 14, 2012 10:58 AM

To: Maria Gomez-Taylor

Cc: Scott, Grace (DEQ); Wong, Christine; Lam, Alvin(DEQ); Robin Oshiro

Subject: Re: O&G
 

Grace ­

Another question for implementation resources.

Let's say that someone [either MI or Region 5] approved an ATP. Would 

each permit need to be modified to specifically incorporate this ATP for

the specific permittee?

Thanks!
 

- -Jan
 

~*^*~*^*~*^*~*^*~*^*~*^*~
 

From: Maria Gomez-Taylor/DC/USEPA/US

To: "Scott, Grace (DEQ)" <SCOTTG@michigan.gov>

Cc: "Wong, Christine" <Christine.Wong@tetratech.com>, Jan 

Pickrel/DC/USEPA/US@EPA, "Lam, Alvin(DEQ)" <LAMA@michigan.gov>, Robin 

Oshiro/DC/USEPA/US@EPA

Date: 06/14/2012 10:16 AM

Subject: Re: O&G 
 

 

 

 

Grace, 

Thanks for your input. I will pass this on to our management. 

Maria Gomez-Taylor, Ph.D.

1200 Pennsylvania Avenue

N.W. Washington, D.C.20460

Phone: 202-566-1005 

E-mail: gomez-taylor.maria@epa.gov 

From: "Scott, Grace (DEQ)" <SCOTTG@michigan.gov>

To: Maria Gomez-Taylor/DC/USEPA/US@EPA, Robin Oshiro/DC/USEPA/US@EPA, 

"Wong, Christine" <Christine.Wong@tetratech.com>, Jan

Pickrel/DC/USEPA/US@EPA

Cc: "Lam, Alvin(DEQ)" <LAMA@michigan.gov>

Date: 06/14/2012 10:12 AM

Subject: O&G 

I talked to our ATP coordinator after our conference call. We do not have 

any resources available to review the comparative analysis for the new 

oil and grease method. Should EPA continue with adoption, we would either 

not approve the alternative (or if Region V agreed perhaps we could 

forward it to EPA for review). This would still create a burden on us for 

tracking. It is indeterminate how much effort this would take, since it 

is unpredictable how many requests would be received. 

Grace L. Scott 

Pretreatment Coordinator 

Water Resources Division 

Mi Dept of Environmental Quality (DEQ)

517-335-4107 

Fax 517-373-2040 

scottg@michigan.gov 
 

Subject: shapiro + state conf call notes 

SendTo: Gomez-Taylor.Maria@epamail.epa.gov 

From: CN=Robin Oshiro/OU=DC/O=USEPA/C=US

DeliveredDate: 06/14/2012 10:25:22 AM 
 

 

13 June 2012, conf call State pretreatment 

Alaska 

•	 Narrative statement only, no numerical value 

•	 Visual monitoring only, no lab analysis 

• Up to individual facility to have own limits, e.g., if linked to restaurant 

Utah 

•	 Narrative only 

•	 Generally 10 mg/L, use best professional judgement 

•	 Pretreatment = indirect, 100-500 mg/L 

• They would refuse limited use ATP 

Iowa 

•	 Narrative only 

• Indirect 50 mg/L average, generally would not approve greater than this 

West Virginia (Nate) 

•	 Indirect only, e.g., vehicle wash facility 

•	 If applied, need maintenance narrative or monitor for O&G, usually 50 mg/L 

• For direct, narrative only 

Florida 

•	 Direct 5 mg/L, plus narrative, no visible (undissolved) oil 

• Indirect 50-400 mg/L [2 separate limits, total & petroleum] 

Missouri (Walter) 

•	 Direct 10 mg/L 

• Indirect 100-300 mg/L 

Tennessee 

• Indirect only – local limits 100-300 mg/L 

Minnesota 

• Indirect up to POTW based primarily on operational use, 100-300 mg/L 

Michigan 

•	 Direct – narrative only, no visible sheen, 10-15 mg/L based on best professional
 

judgement
 

•	 Indirect – 50-700 mg/L in municipalities, some divided into polar/nonpolar, normal is 

100 mg/L 

•	 "We talked to our ATP coordinator. We do not have any resources available to review the 

comparative analysis for the new oil and grease method. Should EPA continue with 

adoption, we would either not approve the alternative (or if Region V agreed perhaps we 

could forward it to EPA for review). This would still create a burden on us for tracking. 

It is indeterminate how much effort this would take, since it is unpredictable how many 

requests would be received." 
 

 

 

----- 

 

 

 

 

 

 

 

Subject: Fw: Re: Questions about oil and grease 

From: CN=Maria Gomez-Taylor/OU=DC/O=USEPA/C=US

SendTo: CN=Robin Oshiro/OU=DC/O=USEPA/C=US@EPA

DeliveredDate: 06/12/2012 07:03:27 AM 

FYI. Jan asked about you attending/listening in. 

Maria Gomez-Taylor, Ph.D.

1200 Pennsylvania Avenue

N.W. Washington, D.C. 20460

Phone: 202-566-1005 

E-mail: gomez-taylor.maria@epa.gov 

-----Forwarded by Maria Gomez-Taylor/DC/USEPA/US on 06/12/2012 07:02AM

To: Maria Gomez-Taylor/DC/USEPA/US@EPA

From: Jan Pickrel/DC/USEPA/US

Date: 06/11/2012 04:36PM

Cc: "Lee, I-Hsin" <I-Hsin.Lee@tetratech.com>, 

christine.wong@tetratech.com, Robin Danesi/DC/USEPA/US@EPA

Subject: Re: Questions about oil and grease
 

OK, Great.

Right now, I think you have the only agenda item!

We'll make sure to send you the meeting scheduler.

We haven't formally set up a room yet, but I'll let you know if we do.
 

- -Jan
 

~*^*~*^*~*^*~*^*~*^*~*^*~
 

Jan Pickrel
 

Water Permits Division, Industrial Branch

US Environmental Protection Agency

phone: (202) 564-7904.
 

fax: (202) 564-6431.

pickrel.jan@epa.gov

~*^*~*^*~*^*~*^*~*^*~*^*~
 

From: Maria Gomez-Taylor/DC/USEPA/US

To: Jan Pickrel/DC/USEPA/US@EPA

Date: 06/11/2012 04:21 PM

Subject: Re: Questions about oil and grease
 

Jan Matuszko asked me to participate if possible in the next pretreatment

coordinators calls June 13 and 14 (she is not available). Let me know if

that is possible or whether you already have a full agenda. What I would

like to do is briefly explain the new method being considered for oil and 

grease and what we said in the NODA, and specifically ask input on:
 

(1) Do they have information on the typical concentration range for oil 

and grease permits, and what would be the breakdown of permits above 200 

mg/L and below that number. 
 

 

 

 

 

 

 

(2) What implementation problems do they anticipate if EPA were to

approve the ASTM method? What would be the State and Regional burden if 

we go with approval with side-by-side data required? 

Maria Gomez-Taylor, Ph.D.

1200 Pennsylvania Avenue

N.W. Washington, D.C. 20460

Phone: 202-566-1005 

E-mail: gomez-taylor.maria@epa.gov 

Jan Pickrel---06/11/2012 03:44:14 PM---what I have are that 9,800 of

those 22,800 SIUs are subject to PSES and PSNS. I don't have a breakou 

From: Jan Pickrel/DC/USEPA/US

To: Maria Gomez-Taylor/DC/USEPA/US@EPA

Date: 06/11/2012 03:44 PM

Subject: Re: Questions about oil and grease 

what I have are that 9,800 of those 22,800 SIUs are subject to PSES and 

PSNS. 

I don't have a breakout per which ELG tho

We hope to get that type of detail if/when the NPDES Electronic Reporting 

rule ever comes to fruition. 

- -Jan 

~*^*~*^*~*^*~*^*~*^*~*^*~
 

Jan Pickrel
 

Water Permits Division, Industrial Branch

US Environmental Protection Agency

phone: (202) 564-7904.
 

fax: (202) 564-6431.

pickrel.jan@epa.gov

~*^*~*^*~*^*~*^*~*^*~*^*~
 

From: Maria Gomez-Taylor/DC/USEPA/US

To: Jan Pickrel/DC/USEPA/US@EPA

Date: 06/11/2012 01:52 PM

Subject: Re: Questions about oil and grease
 

Hi Jan,
 

Forgot to add that it will be helpful if you can get numbers of those 

SIUs that are subject to PSES and PSNS. Thanks.
 

Maria Gomez-Taylor, Ph.D.

1200 Pennsylvania Avenue

N.W. Washington, D.C. 20460

Phone: 202-566-1005 

E-mail: gomez-taylor.maria@epa.gov 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jan Pickrel---06/11/2012 12:41:55 PM---Hello - We have a monthly call 

with the EPA Regional Pretreatment Coordinators, and a bimonthly cal
 

From: Jan Pickrel/DC/USEPA/US

To: Maria Gomez-Taylor/DC/USEPA/US@EPA

Date: 06/11/2012 12:41 PM

Subject: Re: Questions about oil and grease
 

Hello ­

We have a monthly call with the EPA Regional Pretreatment Coordinators, 

and a bimonthly call with the State Pretreatment Coordinators.

Both occur this week - June 13 and June 14 - at 2 pm. These are the 2nd 

Wednesday and 2nd Thursday of the month.

We can be somewhat flexible about the times, and in fact it's not all 

that unusual for us to move it to 3 pm periodically.

Is this week too soon for Jan M?
 

Regarding the number of indirect dischargers...

We can easily estimate the number of SIGNIFICANT industrial users*: 

22,000 However, probably the vast majority of IUs that are regulated for

oil and grease are not "significant" with the aspects of federal 

permitting requirements. Example, restaurants / food service

establishments. We have no good estimation of the number of those IUs.

Most of these, however, don't take regular samples for compliance with a

numeric limitation but by implementing BMPs. 

*Definition of Significant Industrial Users includes those subject to 

effluent guidelines and standards [PSES and PSNS], process flows > 25,000

gpd, process flows > 5% of the organic or dry weather capacity of the

receiving POTW [which, for a 5 MGD POTW would be 25,000 gpd.] We keep 

tabs on the number of those that are subject to PSES and PSNS, if that

number would help you, and which ELGs contain oil and grease limits. 

- - -Jan 

~*^*~*^*~*^*~*^*~*^*~*^*~ 

Jan Pickrel 

Water Permits Division, Industrial Branch

US Environmental Protection Agency

phone: (202) 564-7904. 

fax: (202) 564-6431.

pickrel.jan@epa.gov

~*^*~*^*~*^*~*^*~*^*~*^*~ 

Maria Gomez-Taylor---06/11/2012 11:59:16 AM---Hi Jan, I am following up

on my phone message last week. 

From: Maria Gomez-Taylor/DC/USEPA/US

To: Jan Pickrel/DC/USEPA/US@EPA

Date: 06/11/2012 11:59 AM

Subject: Questions about oil and grease 

Hi Jan, 
 

 

 

 

 

 

 

 

I am following up on my phone message last week. 

We are looking at a new analytical method for oil and grease and need

more concrete info on oil and grease requirements for indirect

dischargers. We are using Carey's tool to access and synthesize 

information reported by major permitted dischargers. 

What we need to know about indirect dischargers is: 1) approximately, how 

many indirect dischargers?, 2) of those, do you have any idea of how many 

may have oil and grease limits? and 3) of those with limits, how many or

what percent have oil and grease limits in excess of 200 mg/L? 

The reason for the 200 mg/L question is that the new method measures up 

to 200 mg/L while the existing method measures up to 1,000 mg/L so this 

information will be useful in determining the universe of permits that

could use the new method, if approved. 

We need this information for an upcoming briefing with Mike Shapiro. Is 

this something you can provide? 

By the way, Jan Matuszko also wants to have some time at the next monthly 

meeting with pre-treatment coordinators to discuss with them our next 

steps with this method and to ask about the potential burden. Or is there 

any other input mechanism that you would recommend. 

Thanks in advance. 

Maria Gomez-Taylor, Ph.D.

1200 Pennsylvania Avenue

N.W. Washington, D.C. 20460

Phone: 202-566-1005 

E-mail: gomez-taylor.maria@epa.gov