UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY

Mr. Lee McDonnell REGION III 1650 Arch Street Philadelphia,Pennsylvania 19103-2029

Director, Bureau ofPoint and Non-Point Source Management PennsylvaniaDepartment ofEnvironmental Protection 

### 11th Floor, Rachel Carson State Office Building P.O. Box 8774 Harrisburg, Pennsylvania 

### 17105 Dear

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# ~~nnell: AUG 2 8 201J

The purpose ofthis letter is to informNational Pollutant Elimination System (NPDES) permitting authorities in the Mid-Atlantic Regionthat conventional and nonconventional pollutants, such as bromide, must be tested by existing dischargers as part ofthe permit applicationprocess ifsuch pollutants are expected to be present in effluent. The U.S. Environmental Protection Agency (EPA) Region III believes that bromide in wastewater from industrial discharges has the potential to contribute to elevated levels of bromide in rivers and streams, and that these elevated levels may cause impacts at downstream drinking watertreatment plants, inparticular contributionto the formation ofTrihalomethanes (THMs) and other disinfection-by-products (DBPs). Human exposure to THMs and other DBPs in drinking water is associated with bladder cancer and other healthproblems. Based onEPA'sreview ofavailable monitoring data, bromide is often present in the effluent ofcertain types ofindustrial facilities, including, butnot limited to, wet flue gas desulfurization (FGD) units at steam electric powerplants and facilities that treat or accept oil and gas extraction wastewater. With respect to steam electric powerplants, EPA notedthat such plants with wet flue gas desulfurization units and certaintypes ofFGD wastewater treatment may discharge bromide in large quantities. 1 With respect to discharges from Shale Gas Extraction (SGE) wastewater, EPA notes thatbromide can also be present in SGE wastewater in significant concentrations.2 Applicants for NPDES permits must, as part oftheirpermit application, indicate whether they know orhave reason to believe that conventional and/or nonconventional pollutants listed in Table IV ofAppendix D to 40 CFRPart 122, including bromide, are discharged from each

1 See 40 CFRPart 423, Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category; Proposed Rule", Federal Register 78:110 (June 7, 2013) p. 34505
2 See attachmentto memorandum from James Hanlon, Director ofEPA's Office ofWastewater Managementto the EPA Regions titled, "Natural Gas Drilling in the Marcellus Shale under the NPDES Program" dated March 17, 2011

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### t..J Printedon 100% recycled/recyclablepaper with 100%post-consumer fiber andprocess chlorine free. CustomerServiceHotline: 1-800-438-2474outfall. For every pollutant in Table IV ofAppendix D discharged which is not limited in an applicable effluent limitations guideline, the applicant must eitherreport quantitative data or briefly describe the reasons the pollutant is expected to be discharged as set forth in 40 CFR § 122.2l(g)(7)(vi)(A). NPDES permits do not authorize permittees to discharge pollutants that have not been characterized during the permit development and issuance processes ifsuch discharges are at levels causing, havingthe reasonable potential to cause, or contributing to an excursion above any effluent limitation guidelines and/or State water quality standards, including State narrative criteria for water quality. In addition to ensuringpermit applications include proper wastewater characterization and are complete, EPA recommends that state programs incorporate appropriate monitoring and reporting requirements as set forth in 40 CFR §§ 122.44(i) and 122.41(1)(4) for facilities that have identified the presence ofbromide in effluent in significant quantities aridthat are in proximity to downstream watertreatmentplants. We look forward to working with you and supporting your efforts toward the recognition ofbromide source(s) and how they may impact drinking water. Ifyouhave any questions concerning this matter, please contact Brian Trulear at (215) 814-5723, ofthe NPDES Permits Branch.



# G.~~ fn M. Capacasa, Director Water Protection Division

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