UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Mr. Lee McDonnell 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

Director, Bureau of Point and Non-Point Source Management 

Pennsylvania Department of Environmental Protection 

11th Floor, Rachel Carson State Office Building 

P.O. Box 8774 

Harrisburg, Pennsylvania 17105 

Dear __ ~~nnell: 

AUG 2 8 201J 

The purpose of this letter is to inform National Pollutant Elimination System (NPDES) 

permitting authorities in the Mid-Atlantic Region that conventional and nonconventional 

pollutants, such as bromide, must be tested by existing dischargers as part of the permit 

application process if such 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 water treatment plants, in particular contribution to 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 health problems. 

Based on EPA's review of available monitoring data, bromide is often present in the 

effluent of certain types of industrial facilities, including, but not limited to, wet flue gas 

desulfurization (FGD) units at steam electric power plants and facilities that treat or accept oil 

and gas extraction wastewater. With respect to steam electric power plants, EPA noted that such 

plants with wet flue gas desulfurization units and certain types ofFGD wastewater treatment 

may discharge bromide in large quantities. 1 With respect to discharges from Shale Gas 

Extraction (SGE) wastewater, EPA notes that bromide can also be present in SGE wastewater in 

significant concentrations. 2 

Applicants for NPDES permits must, as part of their permit application, indicate whether 

they know or have reason to believe that conventional and/or nonconventional pollutants listed in 

Table IV of Appendix D to 40 CFR Part 122, including bromide, are discharged from each 

1 See 40 CFR Part 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 attachment to memorandum from James Hanlon, Director ofEPA's Office of Wastewater Management to the 

EPA Regions titled, "Natural Gas Drilling in the Marcellus Shale under the NPDES Program" dated March 17, 2011 

ft t..J Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. 

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outfall. For every pollutant in Table IV of Appendix D discharged which is not limited in an 

applicable effluent limitations guideline, the applicant must either report 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 if such discharges are at levels causing, having the 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 ensuring permit 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 arid that are in 

proximity to downstream water treatment plants. 

We look forward to working with you and supporting your efforts toward the recognition 

of bromide source(s) and how they may impact drinking water. If you have any questions 

concerning this matter, please contact Brian Trulear at (215) 814-5723, of the NPDES Permits 

Branch. 

G.~~ fn M. Capacasa, Director 

Water Protection Division 

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