United States Office of Water EPA 821-B-01-003

Environmental Protection (4303) June 2001

Agency Version 3.0

SMALL ENTITY COMPLIANCE GUIDE

Centralized Waste Treatment

Effluent Limitations Guidelines

and Pretreatment Standards

(40 CFR 437)
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i

DISCLAIMER

T

heEngineeringandAnalysisDivision ofEPA’sOffice ofWaterpreparedthis guidepursuant

to section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA),

Public Law 104-121. EPA intends this guide to aid small regulated entities that are direct or

indirect industrial dischargers in complying with recentlypublishednationalregulations, “Effluent

Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards for the

Centralized Waste Treatment Industry Point Source Category” (Federal Register, Vol. 65, No. 247,

pages 81242 - 81313, December 22, 2000).

The discussion in this document is intended solely as guidance. This guide is not a

regulation itself nor does not it substitute for any requirements under Clean Water Act or EPA’s

regulations. Thus, itdoesnotimpose legally-bindingrequirements onEPA, States, or the regulated

community, and the general description provided here may not apply to a particular situation

based upon the circumstances. This guide does not confer legal rights or impose legal obligations

upon any member of the public. 

Among other things, in the course of the guide, the document describes new and existing

requirements with respect to industrial dischargers under the Clean Water Act and its

implementing regulations at 40 CFR §§ 122, 123, 124 403 and chapter 1, subchapter N. A

discharger’s legal duty requires it to comply with the CWA and its implementing regulations.

While EPA has made every effort to ensure the accuracy of the discussion in this guide, a

discharger’s obligations are determined, in the case of direct dischargers by the terms of their

NPDESpermit andEPA’s regulations orinthe case ofindirectdischargers by permits or equivalent

control mechanisms issued to POTW industrial users or by regulatory requirements. Nothing in

this guide, of course, changes any statutory or regulatory requirement. In the event of a conflict

between the discussion in this guide and any permit or regulation, the guide would not be

controlling. EPA and local decision makers retain the discretion to adopt approaches on a case-bycase basis that differ from those described in this guidance where appropriate. However, in any

civil or administrative action against a small business for violation of the effluent limitations

guidelines,pretreatment standards ornew source performance standards forthe centralized waste

treatment industry under 40 CFR Part 437, the content of this guide may be considered as evidence

of the reasonableness or appropriateness of proposed fines, penalties or damages.

Mention of trade names or commercial products does not constitute endorsement or

recommendation for their use. 

EPAmaydecide to revise this guide without public notice to reflect changes in the Agency’s

approach to implementing effluent limitations guidelines, pretreatment standards, and new source

performance standards for the centralized waste treatment industry, orto clarify and update text.

To determine whether the Agency has revised this guide and/or to obtain copies, contact EPA’s

Small Business Ombudsman Office at (202)260-0490. You can also determine whether EPA has

revised or supplemented the information in this guide by accessing the document at:

www.epa.gov/ost/guide/cwti.html.
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CHAPTER 1

INTRODUCTION

T

hisdocumentispublishedby theU.S.EnvironmentalProtectionAgency (EPA) as our official

compliance guide for small entities, as required by the Small Business Regulatory

Enforcement Fairness Act of 1996. Before you begin using this guide you should know that

the rule for which EPA has prepared this guide was published on December 22, 2000. EPA is

continually improvingandupgrading its rules, policies, compliance programs and outreach efforts.

You can determine whether EPA has revised or supplemented any of the rules or information

provided in this guide by visiting www.epa.gov/ost/guide/cwti.html.

EPA published the regulation titled “ Effluent Limitations Guidelines and Pretreatment

Standards for the Centralized Waste Treatment Industry” (Federal Register, Volume 65, No. 247,

pages 81242 - 81313) on December 22, 2000 under the authority of the Clean Water Act (CWA).

EPA has prepared this small entity compliance guide because Section 212 of the Small Business

RegulatoryEnforcement Fairness Act of 1996, Public Law No. 104-121, requires EPA to prepare and

publish such guides for any rule for which it has prepared a regulatory flexibility analysis under

the Regulatory Flexibility Act, 5 U.S.C. § 601, et seq. EPA prepared a regulatory flexibility analysis

of this rule and consequently also has developed this guide.

 EPA designed this guide to help owners and operators of centralized waste treatment

(CWT) facilities that are small entities – whether they are small businesses, small government

jurisdictions or small non-profit organizations -- understand and comply with the CWT effluent

guidelines limitations and pretreatment standards (“the rule”). EPA has focused this guide on

what a small entity will need to know to comply with the regulation. Small entity is defined as (1)

a small business with gross revenue under $6 million (basedon SmallBusinessAdministration size

standards); (2) a small governmental jurisdiction that is a government of a city, county, town,

school district or special district with a population less than 50,000; and (3) a small organization

that is any not-for-profit enterprise which is independently owned and operated and is not

dominant in its field.

 1.1 Why is Proper Implementation Important? 

Implementation of a regulation is obviously a critical component in achieving the desired

objectives of the regulation. If this regulation is not effectively implemented, then expected

reductions in pollutant discharges and the environmental benefits expected to be obtained from

the reduced discharges may not occur. Furthermore, CWT facilities that do not properly

implement the rule may not be able to comply with it and consequently may violate the CWA.
INTRODUCTION CWT SMALL ENTITY COMPLIANCE GUIDE

1 - 2

Effective implementation of this regulation will require the cooperation of the CWT

facilities that are discharging their wastewater and the Federal, State and local authority that

regulate discharges from these facilities. In discussions with permitting control authorities, many

stressed the need for close communication with CWT facilities. Federal, State and local permit and

control authorities need to have a thorough understanding of a CWT facility’s operations to

implement this rule properly. Likewise, CWT facilities must maintain close communication with

the generators and sources of the wastes and wastewater treated at the CWT facility in order to

accurately characterize and treat the incoming waste streams.

 1.2 Who Should Use This Guide?

EPA developed this guide to aid small entities that are CWT facilities. CWT facilities treat

or recover hazardous or non-hazardous industrial waste, wastewater, or used material from offsite. The entities that are subject to this rule include small entities that are CWT facilities that

either discharge wastewater directly into surface water orthat introduce wastewaterinto publicly

owned treatment works. 

Because the regulation establishes the same requirements for all affectedfacilities, this guide

is helpful for both small and large businesses that are CWT facilities.

 1.3 What Does This Guide Cover?

EPA designed this information to provide guidance on implementing effluent limitations

guidelines and standards for the CWT industry. As part of this guidance, EPA included general

information on effluent limitations guidelines and pretreatment standards (that is, what are they?)

and specific information on those promulgated forthe CWT industry. This guidance also enables

the reader to determine whether a facility is a CWT and, thus, affected by this rule, what CWT

wastewater discharges are subject to this rule, and what requirements a CWT facility may have to

meet to comply with this rule. 

 1.4 How to Use this Guide

This guide contains 11 chapters and 1 appendix:

Chapter 2 provides basic information on effluent guidelines and pretreatment standards. EPA

developed this chapter primarily for readers with little or no experience with

effluent limitations or pretreatment standards. 

Chapter 3 provides a general overview of the CWT industry and summarizes the CWT rule.

This summary includes a description of the requirements of the CWT rule along

with a compliance timetable.

Chapter 4 provides guidance on what type of facilities and operations must comply with this

rule. 

Chapter 5 provides information on determining what subcategories apply to a facility’s

operations.
INTRODUCTION CWT SMALL ENTITY COMPLIANCE GUIDE

1 - 3

Chapter 6 provides information on implementing the rule for facilities complying with a

single subcategory only.

Chapter 7 provides information on implementing the rule for facilities complying with more

than one CWT subcategory.

Chapter 8 provides information on establishing equivalent treatment forfacilities complying

with the multiple wastestream subcategory.

Chapter 9 includes information on the compliance assurance process. This chapter describes

how EPA determines compliance and how violations may be corrected.

Chapter 10 presents questions frequently asked during the development of this rule and EPA’s

responses to those questions.

Chapter 11 provides a list of resources for additional help in complying with the regulation.

Appendix A presents the final limitations and standards for the CWT regulation.

How Do I Obtain a Complete Copy of the Rule?

You may obtain a complete copy of this rule at 65 Fed. Reg. 81242 (December 22, 2000) or by

visiting www.epa.gov/ost/guide/cwti.html.
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CHAPTER 2

OVERVIEW OF EFFLUENT LIMITATIONS GUIDELINES AND

PRETREATMENT STANDARDS

E

PA is providing basic information in this chapter on effluent limitations guidelines and

pretreatment standards (ELGs). EPA has simplified the information presented so as to make

it useful to individuals with little or no experience with ELGs. You will find addition

information on ELGs in the preamble of the CWT rule. 

 2.1 What Are Effluent Limitations Guidelines and Pretreatment Standards?

Effluent limitations guidelines and pretreatment standards are restrictions which may apply to

wastewater discharges from CWT facilities. The Clean Water Act (CWA) prohibits the discharge

of pollutants into navigable waters except as otherwise authorized by the statute. It establishes

restrictions on the types and amounts of pollutants discharged from various industrial,

commercial, and public sources of wastewater. Among these are restrictions on the direct

discharge of effluent,i.e. wastewater,intonavigable waters (“effluent limitations”) and restrictions

on the indirect discharge of pollutants to navigable waters (“pretreatment standards”) through

theirintroduction publicly owned treatment works (which, in turn, discharge to navigable waters).

These effluent limitations and pretreatment standards do not prevent CWT facilities from

discharging wastewater. However, they impose a requirement, or limit, on the concentration of

pollutants a CWT may discharge, regardless of its location in the United States or the condition of

the receiving water. ELGs are not water quality or health based requirements. Rather, as required

by the CWA, EPA bases ELGs on the performance of wastewater treatment technologies applied

to CWT wastestreams. ELGs represent the greatest pollutant reductions economically achievable

for the CWT industry. 

CWT facilities are not the only facilities that may be subject to effluent limitations

guidelines and pretreatment standards. EPA develops ELGs on an industry-by-industry basis and

has developed effluent guidelines limitations and pretreatment standards for over 55 categories

of industries. Therefore, a facility which is required to meet the restrictions established by this rule

may also be required to meet the restrictions for another rule if it also performs industrial

operations in another regulated industrial category.

Effluent limitations and pretreament standards represent different sets of restrictions. As

noted above, effluent limitations apply to direct dischargers and pretreatment standards apply to

indirect dischargers. Finally, as mentioned above, ELGs are minimum requirements. The permit

writer or control authority may establish additional or tighter restrictions (based on site-specific

local POTW pretreatment ordinance limits, water quality standards, and other authority) than
OVERVIEW OF ELGS CWT SMALL ENTITY COMPLIANCE GUIDE

 

1Conventional pollutants also include fecal coliform, but EPA has not regulated

fecal coliform in the CWT rule.

2 - 2

A CWT facility discharging wastewater

directly to waters of the U.S., the

construction of which commenced after

August 28, 2000 is considered a new source.

BPT - Best Practicable Control Technology,

Economically Achievable.

BAT - Best Available Control Technology,

Economically Achievable.

BCT - Best Conventional Control Technology,

Economically Achieveable.

NSPS - New Source Performance Standards.

PSNS - Pretreatment Standards for New Sources.

PSES - Pretreatment Standards for Existing Sources.

In this guide and the CWT rule

and preamble, EPA refers to the

POTW or the state collectively

as the “control authority.”

those established by this rule. Therefore, discharge requirements may be more restrictive than the

ELGs, but not less restrictive than the ELGs. 

 2.2 Direct Dischargers and Effluent Guidelines

A direct discharger is a facility that

discharges pollutants directly to waters of the

U.S. such as a river or stream. If a CWT facility

is a direct discharger, it is required to have a

permit to discharge wastewater -- an NPDES

permit. NPDES permits are drafted by

“Permitting Authorities” and contain effluent limitations.

For CWT direct discharging facilities, EPA has established four overall sets of limits which

may apply. These are referred to as BPT, BCT, BAT, or NSPS. These acronyms stand for Best

Practicable Control Technology Currently Available, Best Conventional Pollutant Control

Technology, Best Available Technology

Economically Achievable, and New Source

Performance Standards, respectively.

Existing direct discharging CWT facilities

are required to comply with BPT for

conventional pollutants1(BOD5,TSS, oil and

grease, pH) and BAT for all other regulated

pollutants. New source direct dischargers

must comply with NSPS for all regulated

pollutants. The BPT, BCT, BAT, and NSPS

limits are listed in Appendix A. 

 2.3 Indirect Dischargers and Pretreatment Standards

An indirect discharger is a facility that discharges

pollutants to surface water indirectly by introducing

pollutants into a publically owned treatment works

(POTW). POTWs are often referred to as municipal

wastewater treatment plants. If a CWT facility discharges

wastewater to a sewer, then it is an indirect discharger. It is

also an indirect discharger if it trucks or sends its

wastewater to a POTW by barge or rail. Permits for indirect dischargers are drafted by “Control

Authorities” and contain pretreatment standards.
OVERVIEW OF ELGS CWT SMALL ENTITY COMPLIANCE GUIDE

 

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A CWT facility discharging wastewater

to a POTW, the construction of which

commenced after August 28, 2000 is

considered a new source. 

In the remainder of this

document, EPA refers to control

mechanism or permit to

discharge to a POTW collectively

as the “control mechanism.”

ForCWTindirect discharging facilities, EPA

has established two overall sets of pretreatment

standards which may apply. These are referred to

as PSES and PSNS. These acronyms stand for

Pretreatment Standards for Existing Sources and

Pretreatment Standards for New Sources. Existing

indirect dischargers must comply with PSES. New sources that are indirect dischargers must

comply with PSNS. PSES and PSNS do not contain restrictions for conventional pollutants because

POTWs are generally designed to treat these parameters effectively. PSES and PSNS are listed in

Appendix B. 

 2.4 Zero or Alternative Dischargers and ELGs

Some CWTfacilities do not discharge process wastewaterinto waters oftheU.S. or aPOTW.

These facilities are referred to as zero or alternative dischargers. Zero or alternative discharging CWT

facilities dispose of their process wastewater through

evaporation, land application, deep well injection, or offsite transfer to a facility other than a POTW. These

facilities do not have to meet the restrictions established

by this rule (these facilities may have to meet restrictions

established under other acts or rules, such as the Clean

Air Act or RCRA). However, if a CWT transfers its

process wastewater off-site directly to a POTW, then the

CWT standards would continue to apply to that wastewater (this would not be true if the CWT

wastewateris sent off-site to another CWT). If a zero or alternative discharging CWT facility alters

its disposal method and becomes a direct or indirect discharger, then it will be required to comply

with the applicable CWT restrictions. A CWT facility which is currently a direct or indirect

discharging facility and alters its wastewater disposal method to become a zero or alternative

discharger would no longer be regulated under this rule.
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Treatment means any method, technique,

or process designed to change the

physical, chemical or biological character

or composition of any metal-bearing,

oily, or organic waste so as to neutralize

such wastes, to render such wastes

amenable to discharge or to recover

energy or recover metal, oil, or organic

content from the wastes.

In this document, wastes are defined as

aqueous, non-aqueous, and solid waste,

wastewater, and/or used material.

Waste receipts are those wastes that CWT

facilties receive from off-site for the

purpose of treatment. Waste receipts do

not include those wastes generated at the

CWT as part of its regular operation.

CHAPTER 3

THE CWT INDUSTRY AND THE CWT RULE

T

his chapter provides a general overview of the CWT industry and the CWT rule. It also

includes general information on the requirements of the CWT rule. EPA developed this

chapter primarily for readers unfamiliar with this industry or this rule. Interested parties

may obtain additional information from the preamble or the technical development

document for the rule. 

 3.1 What Is A CWT Facility?

A CWT facility is one that accepts fortreatment and/orrecovery used industrial materials

generated off-site (at another location). These used materials may be hazardous, non-hazardous,

solid, or liquid. A CWT facility may be a stand alone operation (i.e., centralized waste treatment

is the only operation at that site) or it may be operated in conjunction with other industrial

operations (such as production of chemicals).

CWT facilities do not fall into a single

description. Some treat used materials or wastes

from a few generating facilities while others treat

wastes from hundreds of generators. Some treat

non-hazardous wastes exclusively while others

treathazardous andnon-hazardous wastes. Some

primarily treat concentrated wastes while others

primarily treat dilute wastes. Some primarily

perform wastewater treatment or materials

recovery and recycling, while others perform both.

EPA estimates there are 223 centralized

waste treatment facilities in 38 states. The major concentration of centralized waste treatment

facilities is in EPA Region 4, 5 and 6 due to the proximity of the industries generating the wastes

undergoing treatment. The vast majority of CWT

facilities are indirect dischargers. Fewer than

10% are direct dischargers. The average volume

of wastewater discharged on an annual basis by

anindirectdischargingCWTfacility is 9.3 million

gallons while a direct discharging CWT facility

averages 38 million gallons/year. EPA estimates

that sixty-three small companies own

discharging facilities that are subject to the

requirements of this rule. 
THE CWT INDUSTRY AND THE CWT RULE CWT SMALL ENTITY COMPLIANCE GUIDE

3 - 2

Chapter 8 provides

more information on

demonstrating

equivalent treatment.

Chapter 5 provides

guidance on determining

the applicable subcategories.

Figure 3-1EPA Regions

 3.2 What is the CWT Rule and What Does It Require?

The CWTrule contains effluentlimitations guidelines andstandards forthe CWTindustry.

These are numerical restrictions that may be applied to the discharge of wastewaters from CWT

facilities to waters of the U.S. or the introduction of wastewater from a CWT facility into a POTW.

The CWT rule requires facilities that are subject to this rule to meet these discharge requirements.

EPA developed different effluent limitations and

standards for the CWT operations depending on the type of

waste received by the CWT. There are four types, or

subcategories, of waste (oily, metals, and organics wastes and

a fourth, a mixture of any of the three previously listed waste

types). The subcategories are as follows :

 

• Subcategory A: Facilities that treat orrecover metal from metal-bearing waste, wastewater,

or used material received from off-site;

• Subcategory B: Facilities that treat or recover oil from oily waste, wastewater, or used

material received from off-site; 

• Subcategory C: Facilities that treat or recover organics from organic waste, wastewater, or

used material received from off-site; and

• Subcategory D: Facilities that treat or recover some combination of metal-bearing, oily, or

organic waste, wastewater, or used material received from off-site.

CWT facilities that fall within multiple subcategories (A, B, or C) may

elect to comply with each set of restrictions separately or those

established for Subcategory D. If a facility elects to comply with the

Subcategory D limitations, the CWT rule requires the facility to

demonstrate equivalent treatment.
THE CWT INDUSTRY AND THE CWT RULE CWT SMALL ENTITY COMPLIANCE GUIDE

1

The treatment technology basis for PSES for the metals subcategory does not include sand

filtration

3 - 3

The CWT rule does not

require a specific

treatment technology.

 3.3 What Treatment Technologies Were Used to Establish the CWT Limitations and

Pretreatment Standards?

EPA based the effluent limitations for existing CWT facilities on the following technologies:

Table 3-1 Technology Basis for the Final CWT Limitations for Existing Facilities

Subpart Name of Subcategory Technology Basis

A Metal-Bearing Waste

Treatment and Recovery

(metals)

Batch Precipitation, Liquid-Solid Separation, Secondary

Precipitation, Clarification, and Sand Filtration

For Metal-Bearing Waste Which Includes Concentrated

Cyanide Streams:

Alkaline Chlorination in a two step process

B Used/Waste Oil Treatment

and Recovery

(oils)

Emulsion Breaking/Gravity Separation, Secondary

Gravity Separation and Dissolved Air Flotation

C Organic Waste Treatment

(organic) 

Equalization and Biological Treatment

EPA based the pretreatment standards for the metals1 and organics subcategories on the same

technologies as those listed in Table 3-1. For the oils subcategory, however, the technology basis

for the pretreatment standards is emulsion breaking/gravity separation and dissolved air flotation.

 The technology basis for the effluent limitations and standards for new CWT facilities for the

oils and organics subcategories are the same as those listed in Table 1. For new CWT metals

facilities, however, the technology basis for the limitations is selective metals precipitation, liquidsolid separation, secondary precipitation, liquid-solid separation, tertiary precipitation, and liquidsolid separation. 

The CWT rule only establishes numerical restrictions on a CWT

facility’s discharge. It does not establish monitoring frequencies nor

does it require that a particular technology be used. A CWT facility

may use any technology it deems appropriate as long as its

discharges are not in excess of those established in the rule.
THE CWT INDUSTRY AND THE CWT RULE CWT SMALL ENTITY COMPLIANCE GUIDE

3 - 4

See Chapter 14 of the technical

development document for a

detailed description of

stormwater (contaminated and

non-contaminated) and

wastewaters subject to this rule.

Discharges of non-contaminated

stormwater are not subject to this rule

and should not be mixed with discharges

subject to this rule prior to complete

treatment of covered wastewaters.

 3.4 What CWT Discharges Are Subject to This Rule?

The wastewater discharges covered by this

rule include some or all discharges related to

materials received from off-site (waste receipts)

and on-site CWT wastewater generated as a

result of CWT operations. Examples of off-site

waste receipts include metal finishing rinse

waters and sludges, used oils, and leachate or

groundwater cleanup. On-site CWT wastewater include:

solubilization wastewater, emulsion breaking/gravity

separation wastewater, used oil processing wastewater,

treatment equipment washes, transport washes (tanker

truck, drum, and roll-off boxes), laboratory-derived

wastewater, air pollution control wastewater, landfill

wastewater from on-site landfills, and contaminated storm

water. 

 3.5 Compliance Timetable

As described above, the CWT rule requires facilities subject to the rule to comply with the

applicable set(s) of effluent limitations or standards. The following table summarizes these

requirements and the required compliance dates. 

Table 3-2 Compliance Times for CWT Facilities

Type of CWT Facility1 Requirement Deadline

Existing Direct Discharger Comply with BPT (conventional

pollutants) and BAT (other regulated

pollutants) 

when your federal or

state NPDES permit is reissued

New Direct Discharger Comply with NSPS when you begin

discharging

Existing Indirect Discharger Comply with PSES December 22, 2003

New Indirect Discharger Comply with PSNS when you begin

discharging

1 A new discharger is a CWT facility that commences construction after August 28, 2000
THE CWT INDUSTRY AND THE CWT RULE CWT SMALL ENTITY COMPLIANCE GUIDE

3 - 5

The effective date

of the CWT rule is

January 22, 2000.

The CWT rule does not require a

BMR; the general pretreatment

regulations do. BMRs for

existing indirect discharging

CWTs are due on July 21, 2001.

 3.6 How Does This Regulation Relate to Other Federal, State, and Local Requirements?

Effluent limitations and standards act as a primary mechanism to control the concentration of

pollutants discharged into waters of the United States. These effluent limitations and standards

are applied to individual facilities through NPDES permits or control mechanisms developed by

POTWs or authorizedStates under Section 402 oftheCWAandlocalpretreatmentprogramsunder

Section 307 of the CWA. 

A CWT facility may be required to comply with more stringent limits than those contained in

the CWT rule, pursuant to (1) federal or state statutes orrules or(2) local ordinances. For example,

certain POTWs are required by federal regulations to develop local limits to protect against passthrough and interference. This means the control authority must develop local limits that protect

the treatment plant from pollutants that may upset the plant, pass-through the plant untreated (or

inadequately treated), may endanger the well being of workers, or would inhibit sludge

management practices. These local limits may be more stringent than the CWT pretreatment

standards.

In addition to CWT requirements, other federal, state, or local requirements may also apply

to a CWT facility. These may include, but are not limited to, other NPDES program and general

pretreatment requirements (CWA), waste tracking requirements (RCRA, EPCRA), waste

managementplanningrequirements (RCRA), spill prevention, reporting and emergency response

requirements (SPCC, EPCRA), and maximum achievable control technology (MACT) requirements

(CAA). In general, the CWT rule will not impact these other requirements.

 3.7 What Steps Do I Need to Take to Comply With This Rule?

1. A CWT facility should determine if its operations are subject to the CWT rule. Chapter 4

describes the applicability of the CWT rule to various CWT operations. 

2. If a facility is subject to the CWT rule, it should determine what subcategory its wastes may

be classified into. Chapter 5 provides guidance on classifying wastes.

3. If a CWT facility accepts wastes in more than one subcategory, it must decide to comply with

each applicable set of limitations or standards separately or to comply with the applicable set

of multiple wastestream subcategory effluent limitations or standards. If the facility chooses

the later, it will be required to demonstrate equivalent treatment (See Chapter 8). 

4. A CWT facility must determine if its treatment system will allow it to meet the required

discharge restrictions. If not, it will be required to alter its operation or treatment system prior

to the compliance date to achieve the discharge restrictions.

5. If a CWT facility is an indirect discharger, it must also

comply with the general pretreatment reporting

requirements which includes submission of a baseline

monitoring report within 180

days of the effective date of the

CWT rule, or July 21, 2001. This

baseline monitoring report
THE CWT INDUSTRY AND THE CWT RULE CWT SMALL ENTITY COMPLIANCE GUIDE

3 - 6

You can obtain 40 CFR §

403.12 through EPA’s

web site: www.epa.gov

(BMR) must include results of sampling and analysis identifying

the concentration of all regulated pollutants in its discharges.

Additional information on this requirement can be foundin 40 CFR

§ 403.12(b).

 3.8 What Compliance Monitoring Is Required by the CWT Rule?

The CWTrule does not establish monitoring frequency requirements. Monitoring frequencies

are found in other sections of the CWA regulations. For example, §403.12(e) requires industrial

users (IUs) subject to categorical pretreatment standards, such as the CWT regulations, to selfmonitor and report at least twice per year. Additionally, pursuant to 40 CFR 403, POTWs, or

control authorities, have developed industrial pretreatment programs (IPPs). IPPs generally

contain guidelines for determining monitoring frequencies. Permitting and control authorities look

towards these rules,IPPs, andguidelines todeterminemonitoring frequencies. They also consider

the individual characteristics of a site, such as compliance history of the facility and otherrelevant

factors.
4 - 1

See also Section V of the

preamble and Chapter 3 of the

Development Document.

CHAPTER 4

APPLICABILITY

T

his chapter provides guidance on the types of facilities and CWT operations that must

comply with this rule. It is only a summary. The preamble to the rule contains detailed

information on many of these operations. 

 4.1 Regulated and Non-Regulated CWT Activities

The CWT rule applies to all wastewater discharges to

a receiving stream orto a POTW from a facility defined by the

rule as a CWT facility unless specifically excluded. As

previously noted, the rule does not establish different

requirements for CWT that are small entities. The rule defines

a CWT facility as “any facility that treats and/or recovers or recycles any hazardous or nonhazardous industrial waste, hazardous or non-hazardous industrial wastewater, and/or used

material from off-site.” The following table provides a general summary of regulated and nonregulated CWT activities.

Table 4-1 Examples of Regulated and Non-Regulated CWT Operations

Centralized Waste

Treatment Activity Regulated by this rule Not Regulated by this rule

Those performed at

federally owned

facilities all federally owned CWT operations none

POTWs none all

Thermal drying of

POTW biosolids none all

Sanitary wastes or

toilet wastes none all

Food processing

wastes none all
APPLICABILITY CWT SMALL ENTITY COMPLIANCE GUIDE

Table 4-1 Examples of Regulated and Non-Regulated CWT Operations

Centralized Waste

Treatment Activity Regulated by this rule Not Regulated by this rule

4 - 2

Manufacturing

facilities

those that accept off-site wastes for treatment

and/or recovery that are not generated in a

manufacturing process subject to the same

limitations/standards as on-site generated waste

and that the permit writer determines are not

similar to, and compatible with treatment of, the

on-site waste

all others

Product stewardship

those that accept waste materials from use of

their products that are not similar to, and

compatible with, treatment of waste generated

on-site

those that accept back their

unused products, shipping

and storage containers with

product residues, and offspecification products

Pipeline materials

materials received via pipeline from waste

consolidators or commingled with other covered

CWT wastewaters

all other piped materials and

POTWs

Recycle/recovery

activities all unless specifically excluded elsewhere

Traditional solvent

recovery

none all

Fuel blenders those that generate a wastewater “Dry” operations

Scrap metals

recyclers none all

Silver recovery

only included where wastewater generated from

these activities is commingled with other

covered wastes 

all others

Used oil filters & oily

absorbent recycling those that generate a wastewater “Dry” operations

High Temperature

Metals Recovery

(HTMR)

those that generate a wastewater “Dry” operations

Used glycol recovery all none

Re-refining all none

Solids, soils, and

sludges

those activities which generate a wastewater

unless specifically excluded “dry” operations

Stabilization/Solidifi

cation those that generate a wastewater “Dry” operations

Transfer stations and

recycling centers none all
APPLICABILITY CWT SMALL ENTITY COMPLIANCE GUIDE

Table 4-1 Examples of Regulated and Non-Regulated CWT Operations

Centralized Waste

Treatment Activity Regulated by this rule Not Regulated by this rule

4 - 3

Incineration activities

only included when the wastewater generated

from these activities is received from off-site and

commingled with other covered wastewater

all others

Transportation

and/or

transportation

equipment cleaning

only included where wastewater generated from

these activities is commingled with other

covered waters 

all others

Landfills

only included where wastewater generated from

these activities is commingled with other

covered waters 

all others

Grease

trap/interceptor

wastes

those which contain petroleum based oils those which contain animal

or vegetable fats/oils 

Marine generated

wastes

off-loaded and subsequently sent to a CWT

facility at a separate location and commingled

with other covered wastewater

all others

Waste, wastewater or

used material re-use

those activities not listed in the next column or

excluded elsewhere

not covered if the

wastewater is accepted for

use in place of potable water

or if materials are accepted

in place of virgin treatment

chemicals.

Treatability, research

and development, or

analytical activities

only included where wastewater generated from

these activities is commingled with other

covered waters

all others
(This Page Left Intentionally Blank)
5 - 1

CWT facilities accept a wide variety

of materials, such as oils and acids. 

Although many of these materials

are processed and reused, for

purposes of this guidance and the

rule, the material is collectively

referred to as ‘waste.’

CHAPTER 5

DETERMINING THE APPLICABLE SUBCATEGORIES

T

his chapter provides guidance on determining the

applicable CWT subcategories for wastes accepted

at a CWT facility. EPA developed this chapter to

provide guidance to CWT facilities. EPA is aware

that many CWT facilities may classify their wastes

differently. The CWT rule does not require CWT

facilities, control authorities, or permitting authorities to

use this subcategorization process. EPA has provided it

only as guidance. 

 5.1 Waste Acceptance Procedures

In absence of the CWT rule, CWT facilities have already established waste acceptance

procedures. The CWT rule does not establish waste acceptance procedures. However, in EPA’s

view, these procedures are critical in determining the applicable CWT subcategories and in

conducting adequate treatment or recovery, and in ensuring the wastes accepted conform to a

faciliy’s discharge permit or control mechanism. Certainly, all CWT facilities should, at a

minimum, collect adequate information from the generator on the type of waste received since this

is the minimum information required by CWT facilities to effectively treat off-site wastes.

Consequently, EPA has included information on waste acceptance procedures as the first step in

its guidance for determining subcategories. The following paragraphs describe the waste

acceptance procedures generally performed at most CWT facilities.

Before a CWT facility accepts a wastestream for treatment, the CWT facility typically

performs a pre-approval review of the proposed wastestream. This pre-approval process may

include screening the waste fortreatability and compatibility with both other wastes being treated

and the treatment system. The waste generator initially furnishes the CWT facility information

concerning the level of pollutants in the wastestream. Bench-scale treatability tests are typically

performed to determine what treatment is necessary for effective removal. At this point, the CWT

facility decides whether to approve the wastestream for acceptance. If the wastestream is

approved, each load received by the CWT facility is typically sampled to ensure that it is consistent

with the initially approved wastestream. If the sample is similar, the shipment of waste is accepted

fortreatment. If the sample is dissimilar, but falls within an allowable range as determined by the

CWT facility, the CWT facility will reevaluate acceptance. This reevaluation may include

additional testing. Once the reevaluation is completed, the generator is contacted to discuss the

discrepancy and reach a resolution. Please note that the level of screening is based on the source

of the waste and the processes used. Figure 5-1 below is an example of a waste profile form. 
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 2

ANYFIRM

ANYTOWN, USA

(555) 555-1212

GENERATOR’S WASTE

MATERIAL PROFILE SHEET

 NEW

 AMENDMENT

PROFILE NUMBER

 

GENERATOR BROKER OR SALESPERSON

Name Name

Address Address

 

Technical Contact Phone Contact Phone

Shipping Contact Phone TRANSPORTER

Business Contact Phone Name

EPA ID # Address

Contact Phone

EPA ID #

WASTE DESCRIPTION

 Applicable Manufacturing Category (if any): 

CHEMICAL & PHYSICAL STATE

 Liquid Multilayered Odor

 Semi-liquid Bilayered TSS

 Solid Single Phase Color

pH Flash Point

 # 2 8-10 % Bottoms Sediment

 2-4 10-12 % Debris

 4-6 $12 % Ash

 6-8 N/A Specific Gravity

PROCESS DESCRIPTION

(Describe process generating waste stream. Include a list of virgin materials and their Material Safety Data Sheets.)

CHEMICAL CONSTITUENTS METALS (PPM)

Petroleum Phase Aqueous Phase Arsenic Magnesium

 Cadmium Mercury

Chromium Nickel

Copper Tin

Lead Zinc

OTHER CONSTITUENTS SHIPPING INFORMATION

% Oil (or ppm Oil) RCRA Code

Shipping Method

Volume (gallons)

Figure 5-1 Sample Waste Acceptance Form
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 3

The CWT rule does not

require waste segregation. 

EPA recognizes that

commingling wastes can be

beneficial in certain cases.

For waste receipts that are

unknown or not listed in the

waste receipt classification

table, the facility should

consult the numerical criteria.

Incoming Waste

Receipt Data Collection

– collected when each

shipment is received at

the facility.

Compare Waste

Receipt Information

to Waste Receipt

Classification Table.

Furthermore, CWT facilities and waste generators complete extensive amounts of

paperwork during the waste acceptance process. The amount of paperwork necessary for

accepting a waste stream emphasizes the difficulty of operating CWT facilities.

Finally, EPA emphasizes that while the CWTruledoes

not require waste segregation, CWT facilities should encourage

their waste generators to segregate their wastestreams (i.e.,

keep metal bearing wastes separate from organic-bearing

wastes). This will help CWT facilities comply with the CWT

rule and more effectively utilize their treatment technologies.

 5.2 Initial Subcategory Determination for Existing CWT Facilities

Basedon information providedbyCWTfacilitiesduringthedevelopment of the CWT rule,

EPA has developed guidance for determining subcategorization. This guidance, which consists

of three basic steps, is illustrated in Figure 5-2 below. For many CWT facilities, however, steps 1

and 2 will be sufficient to determine into which subcategory the wastes treated at its facility should

be classified. Step 3 would only be necessary if the first two steps are inconclusive. This guidance

will help facilities classify their incoming wastes into the metals, oils, or organics subcategory. A

facility that accepts waste in more than one of these subcategories may also be classified as

“mixed”. This is detailed in Chapter 7. 

Figure 5-2 Subcategory Determination Procedure

5.2.1 Step 1: Waste Receipt Data Collection

The first step in EPA’s recommended subcategory determination procedure is to collect

information on the incoming waste receipts. This data is usually collected at the point where the

shipment is received by the CWT facility. Most (if not all) CWT facilities are already performing

this step. EPA believes that the paperwork and analyses currently performed at CWT facilities as

part of their waste acceptance procedures provide CWT facilities with sufficient information to

complete this step. Figure 5-1 shows an example of a waste acceptance form typical of those used

at existing CWT facilities.

 5.2.2 Step 2: Compare Waste Receipt Information to Waste Receipt Classification Table

In Step 2, the CWT facility should review data collected from its waste receipts for a period

of one year. The CWT facility should use common sense to determine which subcategory the waste

falls into. To assist the CWT facility, it may use the waste classification table (Table 5-1) to classify
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 4

each of its waste receipts for that one year period into Subcategory A (Metals), B (Oils), or C

(Organics). 

If the CWT facility receives the wastes listed in the waste classification table, the

subcategory determination may be made solely from this information. For purposes of this rule,

the CWT facility need not determine the percentage of each type of waste within a subcategory or

between subcategories. The CWT facility only need to determine what subcategory the wastes fall

into: one or multiple subcategories. When subcategory determination is complete, the facility may

refer to Chapter 6 for implementing the rule if only one subcategory applies or Chapter 7 if more

than one subcategory applies.

Table 5-1 Waste Receipt Classification

Metals Subcategory - spent electroplating baths and/or sludges

- metal finishing rinse water and sludges

- chromate wastes

- air pollution control blow down water and sludges

- spent anodizing solutions

- incineration wastewaters

- waste liquid mercury

- cyanide-containing wastes

- waste acids and bases with or without metals

- cleaning, rinsing, and surface preparation solutions from

 electroplating or phosphating operations

- vibratory deburring wastewater

- alkaline and acid solutions used to clean metal parts or equipment

Oils Subcategory - used oils

- oil-water emulsions or mixtures

- lubricants

- coolants

- contaminated groundwater clean-up from petroleum sources

- used petroleum products

- oil spill clean-up

- bilge water

- rinse/wash waters from petroleum sources

- interceptor wastes

- off-specification fuels

- underground storage remediation waste

- tank clean-out from petroleum or oily sources

- non-contact used glycols

- aqueous and oil mixtures from parts cleaning operations

- wastewater from oil bearing paint washes

Organics

Subcategory

- landfill leachate

- contaminated groundwater clean-up from non-petroleum sources

- solvent-bearing wastes

- off-specification organic product

- still bottoms

- byproduct waste glycol

- wastewater from paint washes

- wastewater from adhesives and/or epoxies formulation

- wastewater from organic chemical product operations

- tank clean-out from organic, non-petroleum sources
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 5

This classification is not inclusive of all possible wastestreams. It is simply a guidance of

the typical wastestreams in each subcategory.

 5.2.3 Step 3: Waste Characterization Using Numerical Criteria

For wastestreams that are from non-specific sources or not listed in the waste receipt

classification table, the facility should additionally complete Step 3. In Step 3, the facility should

usedata collectedduringthewaste acceptanceprocedures to classify the waste into the appropriate

subcategory. EPA recommends the CWT facility apply the following hierarchy:

1). If the waste receipt contains oil and grease at or in excess of 100 mg/L, the waste

receipt should be classified in the oils subcategory; 

2). If the waste receipt contains oil and grease <100 mg/L, and has any of the

pollutants listed below in concentrations in excess of the values listed below, the

waste receipt should be classified in the metals subcategory. 

cadmium 0.2 mg/L

chromium 8.9 mg/L

copper 4.9 mg/L

nickel 37.5 mg/L

3). If the waste receipt contains oil and grease < 100 mg/L and does not have

concentrations of cadmium, chromium, copper, or nickel above any of the values

listed above, the waste receipt should be classified in the organics subcategory. 

At this point, the CWT facility has determined the applicable subcategories and should refer

to Chapter 6 for implementing the rule if only one subcategory applies or Chapter 7 if more than

one subcategory applies.

 5.3 Follow-Up Subcategory Determination Procedures

Once the CWT facility’s initial subcategory determination (oils, metals, organics, or mixed)

has been made, the facility will not need to repeat this determination process where its

wastestreams remain consistent. This includes accepting a new wastestream that is within the

CWTfacility’s current subcategory. However, if a CWT facility alters its operation to accept wastes

from a subcategory outside its permit(orto no longer accept waste from a subcategory),the facility

should notify the appropriate permitting or control authority and the subcategory determination

should be re-visited. EPA notes that current permit and pretreatment regulations require

notification to the permitting or control authority when significant changes occur. EPA also

recommends that a facility revisit its subcategory determination whenever the permit or control

mechanism is re-issued, though this would not necessarily require complete characterization of a

subsequent year’s waste receipts if there is no indication that the make-up of the CWT facility’s

receipts had significantly changed.
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 6

 5.4 Subcategory Determination Procedures for New CWT Facilities

New CWT facilities should estimate the percentage of waste receipts expected in each

subcategory. Alternatively, the facility could compare the treatment technologies being installed

to the treatment technologies selected as the basis for the limitations or standards for each

subcategory. After the initial year of operation, the permit writer or control authority should

reassess the facility’s subcategory determination and follow the procedure outlined for the initial

determination for existing facilities. Because of the variable nature of waste receipts at CWT

facilities, EPA recommends issuance of short-term permits or control mechanisms for new CWT

facilities.

 5.5 On-Site Wastewater Subcategory Determination

The sections above explain how an entity might approach classifying its off-site

wastestreams. For other on-site generated wastewater sources such as those described in Chapter

4 (for example, contaminated stormwater, emulsion breaking wastewater, solubilization

wastewater), wastewater generated in support of, or as the result of, activities associated with each

subcategory should be classified in that subcategory. For facilities that are classified in a single

subcategory, this step is unnecessary as the facilities should generally classify on-site wastewater

in that subcategory. 

For facilities that are classified in more than one subcategory, and do not elect to comply

with the multiple wastestream subcategory limits, the facilities should apportion the on-site

generated wastewater to the appropriate subcategory. Certain waste streams may be associated

with more than one subcategory such as stormwater, equipment/area washdown, air pollution

control wastewater, etc. For these wastewater sources, the volume generated should be

apportioned to each associated subcategory. For example, for contaminated stormwater, the

volume can be apportioned based on the proportion of the surface area associated with operations

in each subcategory. Equipment/area washdown may be assigned to a subcategory based on the

volume of waste treated in each subcategory. Alternatively, permitting or control authorities may

assign the on-site wastestreams to a subcategory based on the appropriateness of the selected

subcategory treatment technologies. EPA notes that this is only necessary for multiple

subcategory facilities which elect not to comply with the Multiple Wastestream Subcategory

limitations or standards. 
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 7

Non-contact stormwater is not

CWT process wastewater and

does not need to be classified

into a subcategory.

 5.6 Examples

 5.6.1 Example 1

A CWT facility has been operating for ten years and services 30 customers. This facility is located around

auto manufacturers and mainly accepts metal finishing rinsewaters. Over the past two years the facility has

also accepted used oils for recovery. It also accepts wastewaters from some customers that are unknown in

origin, but which usually have oil and grease levels about 100 mg/L. This facility generates emulsion

breaking/gravity separation wastewater and equipment cleaning wastewater. It also collects and discharges

rainwater collected on its property, but all of the CWT facility’s activities occur inside a building. 

This facility may wish to review first all of its incoming waste receipts from the past year

to ensure that the wastes listed above are the only wastes accepted for treatment. It may then

compare its wastestreams to the waste receipt classification table. The waste classification table

indicates that the metal finishing rinsewaters are classified in the metals subcategory and the used

oils are classified in the oils subcategory. The wastes of non-specific origin can not be classified

using the waste classification table, so this facility should utilize Step 3 for these wastes. The

facility notes that these wastes usually have oil and grease levels in excess of 100 mg/L. Therefore,

basedon the hierarchy established for Step 3, these non-specific wastes are also classified in the oils

subcategory. Therefore, this facility is both a metals and an oils subcategory facility. 

This facility alsodischarges on-site generated wastewaters – emulsion breaking wastewater

andstormwater. The facility must determine if the discharge of these on-site wastewaters is subject

to the CWT rule (that is, defined as “CWT process wastewaters”). As described in Chapter 3,

emulsion breaking wastewaters are subject to this rule. Stormwater, however, may or may not be

subject to this rule. Based on the information provided, since the stormwater is collected outside

the building, and there are no operations whatsoever outside, this stormwater is most likely noncontact stormwater and not a CWT process wastewater subject to this rule. Necessarily, if the noncontact stormwater is introduced prior to the monitoring location, the limits would be adjusted

using the combined wastestream formula or building block approach to account for the

stormwater. If the facility maintains a waste handling area outside the building and this

stormwater comes in contact with this waste handling area, it is contact stormwater and is CWT

process wastewater subject to this rule. 

If this facility elects to comply with the mixed waste

subcategory, it does not need to classify these on-site CWT

process wastewaters. If, however, the facility elects to

comply with the limitations or standards for the metals and

oils subcategory separately, it will be additionally required

to classify the on–site CWT process wastewaters into the

metals or oils subcategory. Clearly, the emulsion breaking

wastewater and any wastewater associated with cleaning the treatment equipment for these

wastewaters will be classified in the oils subcategory. Likewise, any wastewater associated with

cleaning the treatment equipmentforthe metals subcategory wastes will be classified in the metals

subcategory. If the stormwater is contact stormwater and the facility collects the contact

stormwaterfromdedicatedareas ofthe facility for eachsubcategory, then these wastewaters would

be classified accordingly. If these contact stormwaters are not collected from dedicated areas, the
DETERMINING THE APPLICABLE SUBCATEGORIES CWT SMALL ENTITY COMPLIANCE GUIDE

5 - 8

facility could sample the wastewaterto determine the level of oil and grease. If these levels exceed

100 mg/L, then these wastewaters will be classified in the oils subcategory. The facility may use

other methods as long as they can demonstrate to the permitting or control authority that these onsite wastewaters receive adequate treatment.

 5.6.2 Example 2: 

The following is a waste receipt log for a single day for a CWT facility:

Table 5-2 Sample Waste Receipt Log

Customer Waste Type oil and grease 

(mg/L)

Chromium

(mg/L)

nickel

(mg/L)

Volatile Organic

Compounds

(VOCs)

(ug/L)

1 used oil 40,000 10 15 40

2 lubricants 50,000 2 50 non-detect

3 oily wastewater 250 non-detect nondetect20

4 leachate 20 12 39 100

5 metal finishing waste 15 200 1500 non-detect

6 bilge water 99 5 7 25

7 electroplating waste 150 100 3000 non-detect

This facility would only need to complete Step 2 to determine the waste receipt

classification for this day’s waste receipts. All of the waste types are listed in the waste

classification table. Used oils, lubricants, oily wastewater, and bilge water are all in the oils

subcategory. Leachate is in the organics subcategory, and metal finishing and electroplating wastes

are in the metals subcategory. This facility would not complete Step 3 since the waste receipt table

generally takes precedence over the numerical criteria hierarchy. Notice, however, that if the

wastewaterfromcustomer 6 was anunknown waste type,this facility wouldneedto complete Step

3. Using this step, the wastewater from customer 6 would be classified in the organics subcategory.

This is a different subcategory than was established using Step 2.

 
6 - 1

CHAPTER 6

SINGLE SUBCATEGORY FACILITIES

C

hapter 6 provides guidance to aid small entities in determining what CWT subcategories

may apply to their CWT discharges. Many CWT facilities are subject to discharge limits

for a single subcategory only. This chapter describes how CWT facilities that accept waste

in only one CWT subcategory may comply with the CWT rule. 

 6.1 How Will the Permitting or Control Authority Establish My Limitations or Standards?

An adequate waste management program is an important ingredient of a successful

wastewatertreatment systematCWTfacilities. Thepermittingor control authority should confirm

the CWT facility’s single subcategory determination by looking at a sampling of the waste receipts

at the CWT facility. The permitting or control authority will then establish the appropriate

discharge limitations or standards. Available guidance in calculating NPDES categorical

limitations for direct discharge facilities can be found in the U.S. EPA NPDES Permit Writers’

Manual (December 1996, EPA-833-B-96-003). Sources of information used for calculating Federal

pretreatment standards for indirect discharge facilities include 40 CFR Part 403.6, the Guidance

Manualforthe Use of Production-Based Pretreatment Standards and the Combined Waste Stream

Formula (September 1985) (CWF Guidance), and EPA’s Industrial User Permitting Guidance

Manual (September 1989).

 6.2 What Compliance Options Do Facilities That Accept Wastes in a Single Subcategory Have?

CWT facilities that are subject to effluent limitations and standards for more than one

subcategory have a choice of either complying with limitations or standards determined for each

applicable subcategory or complying with a single set of limitations and standards for multiple

wastestreams. A single subcategory facility does not have a similar option and must comply with

the limitations or pretreatment standards forthe applicable subcategory (i.e. a metals subcategory

must comply with the limitations (or standards) for the metals subcategory, etc.)

 6.3 How Will the Permitting or Control Authority Incorporate the Cyanide Limit in the Metals

Subcategory?

Whenever a CWT facility accepts a waste stream that contains more than 136 mg/L of total

cyanide, the CWT regulation requires that the CWT facility monitor for cyanide when the

wastewater exits the cyanide destruction process rather than after mixing with other process

wastewater. Alternatively, under the regulations, the facility may monitor for compliance after

mixing if the permitting or control authority adjusts the cyanide limitations (or standards) using

the “building block approach” or “combined waste stream formula,” assuming the cyanide
6 - 2

limitations do not fall below the minimum analytical detection limit. For further information on

the “building block approach” or “combined waste stream formula”, see Section 14 of

Development Document for Effluent Limitations Guidelines and Standards for the Centralized

Waste Treatment Industry – Final, (EPA 821-R-00-020, referred to herein as TDD) and the CWF

Guidance referred to in 6.1 above.
7 - 1

A multiple subcategory facility accepts wastes in

more than one CWT subcategory. It is different from

the case in which metal-bearing waste streams may

include low-level organic pollutants or that oily

wastes may include low level metal pollutants due to

the origin of the waste stream accepted for treatment.

CHAPTER 7

MULTIPLE SUBCATEGORY FACILITIES

E

PA estimates that many facilities in the CWT industry accept wastes in two or more

subcategories (a combination of wastes in Subcategory A, B or C). This chapter describes

how CWT facilities that accept

wastes in more than one subcategory

may comply with the CWT rule. 

 7.1 What Steps Should I Take To Help

Ensure Compliance with My

Limitations or Standards?

An adequate waste management program is an important ingredient of a successful

wastewatertreatment system at CWT facilities. The first step in such a system is identification and

segregation of wastestreams. By identifying and segregating waste streams in different

subcategories to the extent possible, a CWT facility is more likely to ensure obtaining optimal mass

removals of pollutants from industrial wastes. Next, the CWT facility should employ treatment

technologies designed and operated to optimally treat all off-site wastes received, as appropriate.

For example, biological treatment is inefficient fortreating concentrated metals waste streams like

those found in the metals subcategory or wastestreams with oil and grease compositions and

concentrations like those found in the oils subcategory. In fact, concentrated metals streams and

high levels of oil and grease compromise the ability of biological treatment systems to function.

Likewise, emulsion breaking/gravity separation, and/or dissolved air flotation is typically

insufficient for treating concentrated metals wastewaters or wastewaters containing organic

pollutants which solubilize readily in water. Finally, chemical precipitation is insufficient for

treating organic wastes and waste streams with high oil and grease concentrations. This step is

only required for facilities that elect to make an equivalent treatment determination.

Once the CWT facility is segregating its wastestreams and has appropriate treatment

technologies in place for all off-site wastes received, as appropriate, the CWT facility should make

sure it is operating its treatment technologies optimally. 

Finally, simply employing appropriate technologies may not ensure compliance with the

regulations. It is equally important that the CWT facility operate these treatment technologies

effectively.
MULTIPLE SUBCATEGORY FACILITIES CWT SMALL ENTITY COMPLIANCE GUIDE

7 - 2

Multiple subcategory CWT facilities

that comply with each subcategory’s

limitations separately do not have to

demonstrate equivalent treatment.

 7.2 What Compliance Options Do Facilities Have if they Accept Wastes from More Than One

Subcategory?

 Multiple subcategory facilities may comply with this rule in one of two ways. Facilities

may:

1. elect to comply with the effluent limitations or standards for each applicable subcategory

directly following treatment (before commingling with different subcategory wastes); or

2. certify equivalent treatment and comply with one of the four sets of limitations or

standards for the mixed waste subcategory (Subcategory D). Each of these options is

discussed further below.

The choice of compliance is up to the CWT facility. The percentage of waste in a particular

subcategory is irrelevant to the compliance method selected by the CWT facility.

7.2.1 Comply with Limitations or Standards for Subcategory A, B or C 

If a multi-subcategory CWT facility elects to comply with each applicable subcategories

limitations or standards individually, the CWT facility must monitor for compliance with each

subcategory’s effluent limitations or standards priorto commingling wastestreams from different

subcategories. For example, a CWT facility may accept metal finishing rinsewaters and used oils

for treatment and recovery. In this case, the CWT facility must treat/recover the metal finishing

rinsewaters andmonitorfor compliance with the metals subcategory limitations (or standards) and

treat/recovery the used oil and monitor for compliance with the oils subcategory limitations (or

standards). In other words, the example facility must monitor in two separate locations for the two

different sets of subcategory limitations (or standards). 

This option can be beneficial in the case of CWT facilities that have separate treatment

systems for their incoming waste receipts, for facilities that only accept a small amount of waste

in one subcategory, or facilities that do not want to

complete the paperwork required to demonstrate

equivalent treatment. However, compliance

monitoring costs for this option will be more

expensive since it requires monitoring at more than

one sample point.

Figure 7-1 and the example 7-1 below illustrate this option.
MULTIPLE SUBCATEGORY FACILITIES CWT SMALL ENTITY COMPLIANCE GUIDE

7 - 3

Oils Waste

10,000 L/day

Organics Waste

45,000 L/day

Metals Waste

20,000 L/day

Oils

Treatment

Sample Point 1 Sample Point 2 Sample Point 3

Organics

Treatment

Metals

Treatment

Example 7-1

Facility A accepts wastes in all three CWT subcategories with separate subcategory

treatment systems and has elected to comply with each set of pretreatment standards

separately. This facility treats 20,000 L/day of metal-bearing wastes, 10,000 L/day of oily

wastes, and 45,000, L/day of organic wastes and discharges to its local POTW.

Figure 7-1 Facility Accepting Waste in All Three Subcategories With Treatment in Each

For this example, the control authority establishes monitoring points 1, 2, and 3. The

control authority requiresthatthefacility complywith themetalssubcategory pretreatment

standards at Sample Point 1, the oils subcategory pretreatment standards at Sample Point

2, and the organics subcategory pretreatment standards at Sample Point 3. Note that the

specific analytes requiring compliance monitoring vary at each sampling point since the

pollutants regulated vary among subcategories.

7.2.2 Comply with Limitations or Standards for Subcategory D

If a multi-subcategory CWT facility elects to comply with the limitations or standards for

Subcategory D, then the permitting or control authority will establish a single monitoring point

prior to discharge and apply the appropriate set of limitations or standards from Subcategory D.

This option can be beneficial in the case of existing CWT facilities that have sequential treatment

systems or to facilities that want to monitor at a single point. For example, if a CWT facility

accepts wastes in both the metals and oils subcategory, the permitting or control authority

establishes limits or standards for Subcategory D facilities that commingle wastes from

Subcategories A and B. Examples 6-2 and 6-3 illustrate this approach. EPA notes that under this

approach,thepermittingor control authority must allow a multi-subcategory facility to commingle

wastestreams prior to discharge. Also, facilities that select this compliance method must first

establish equivalent treatment as detailed in Chapter 8. 
MULTIPLE SUBCATEGORY FACILITIES CWT SMALL ENTITY COMPLIANCE GUIDE

7 - 4

Oils Waste

10,000 L/day

Organics Waste

45,000 L/day

Metals Waste

20,000 L/day

Oils

Treatment

Discharge

75,000 L/day

Organics

Treatment

Metals

Treatment

Monitoring

Point

Example 7-2

Facility B accepts wastes in all three CWT subcategories with separate subcategory

treatment systems and has elected to comply with Subcategory D pretreatment standards

at a combined outfall. This facility treats 20,000 L/day of metal-bearing wastes, 10,000

L/day of oily wastes, and 45,000 L/day of organic wastes and discharges to its local POTW.

Figure 7-2 Facility Accepting Waste in All Three Subcategories With Treatment in Each and

Combined Outfall

First, the CWT facility must demonstrate equivalent treatment for

all three subcategories. The control authority then establishes a

single monitoring point. The control authority requires the facility

to comply with Subcategory D pretreatment standards for facilities

which commingle wastes from Subcategory A, B, and C.

Facilities may only

use this approach if

they establish

equivalent treatment.
MULTIPLE SUBCATEGORY FACILITIES CWT SMALL ENTITY COMPLIANCE GUIDE

7 - 5

Oils Waste

Metals Waste

Oils

Treatment

Discharge

Metals

Treatment

Monitoring

Point

Example 7-3

Facility C accepts wastein the oils and metalssubcategory. The total volume of wastewater

discharged to the local POTW is 100,000 liters per day. The facility segregates oils and

metals waste receipts and first treats the oils waste receipts using two stage emulsion

breaking/gravity separation and dissolved air flotation. The facility then commingles this

wastewater with metal subcategory waste receipts and treats the combined wastestreams

using primary and secondary chemical precipitation and solid/liquid separation followed by

multimedia filtration.

Figure 7-3 Facility Accepting Wastes in Multiple Subcategories and Treating Separately

First, the CWT facility must demonstrate equivalent treatment for the metals and the oils

subcategory. Like example 7-2, the control authority then establishes a single monitoring

point. This monitoring point follows the metals treatment. The control authority requires

the facility to comply with Subcategory D pretreatment standards for facilities which

commingle wastes from Subcategories A and B. 

 7.3 How Will the Permitting or Control Authority Incorporate the Cyanide Limit in the Metals

Subcategory?

Whenever a CWT facility that is a small entity accepts a waste receipt that contains more

than 136 mg/L of total cyanide, the CWT facility must monitor for cyanide when the wastewater

exits the cyanide destruction process rather than after mixing with other process wastewater.

Alternatively, the facility may monitor for compliance after mixing if permitting or control

authority adjusts the cyanide limitations using the “building block approach” or “combined waste

stream formula,” assuming the cyanide limitations do not fall below the minimum analytical

detection limit. For further information on the “building block approach” or “combined waste

stream formula”, see Section 14 of the TDD. Example 7-4 illustrates this approach.
MULTIPLE SUBCATEGORY FACILITIES CWT SMALL ENTITY COMPLIANCE GUIDE

7 - 6

Oils Waste

 Metals Waste

with Cyanide

Cyanide

Pretreat

Oils

Treatment

Discharge

Metals

Treatment

Cyanide

Monitoring

Point

Discharge

Monitoring

Point

Example 7-4

Facility C in example 7-3 also accepts concentrated cyanide baths. 

Figure 7-4 Facility Accepting Multiple Subcategory Wastes (including Cyanide) and Treating

Separately

In addition to monitoring for compliance with the multiple wastestream subcategory

pretreatment standards for a combination of metals and oils wastes, this facility would be

required tomonitorfor compliance with cyanide pretreatmentstandards. Alternatively, the

control authority may allow the facility to monitor for compliance with the cyanide

pretreatment standards at the monitoring point at the point of discharge if the control

authority adjusts the limit appropriately and that limit does not fall below the minimum

analytical detection limit.
8 - 1

The initial certification

statement should be signed by

the same person who signs the

compliance status reports. 

CHAPTER 8

EQUIVALENT TREATMENT DETERMINATION

A

s described in Chapter 7, a CWT facility that accepts wastes in more than one CWT

subcategory may elect to comply with the appropriate set of limitations or standards for

Subcategory D. A facility, however, may only elect to comply with the Subcategory D

limitations or standards if it has established that it is providing “equivalent treatment.”

Providing equivalent treatment means that the facility is providing treatment for its mixed

wastewaterthat is designed to ensure pollutant removal that are essentially the same as would be

obtained from separate treatment of the different subcategory wastestreams. If a facility cannot

establish equivalent treatment then it must comply with each applicable subcategory’s limitations

or standards individually. This chapter provides guidance to CWT facilities on how to establish

equivalent treatment.

8.1 Introduction

Before a multi-subcategory CWT facility may elect to comply with effluent limitations or

standards from Subcategory D, it must first demonstrate equivalent treatment for each applicable

subcategory. The CWT rule defines equivalent treatment as “a wastewater treatment system that

achieves comparable pollutant removals to the applicable treatment technology selected as the

basis for the limits and standards.” The permitting or control authority makes the equivalent

treatment determination. The CWT facility needs to provide its permitting or control authority

with the information and data needed to make this determination. The CWT rule defines three

things a CWT facility must do to demonstrate equivalent treatment. The facility must:

1. submit an initial certification statement;

2. submit periodic certification statements; and 

3. maintain on-site compliance paperwork.

Each of these requirements are discussed in more detail below. 

8.2 Initial Certification Statement

8.2.1 What is an Initial Certification Statement?

The initial certification statement is a written

submission from a CWT facility to the appropriate

permitting authority certifying that its treatment train

includes all applicable equivalent treatment systems. It

must be signed by the responsible corporate officer as
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

1

Facilities need to submit the initial certification to their control authorities well in

advance of this date to ensure multiple wastestream pretreatment standards are in effect by

this date.

8 - 2

EPA suggests that an indirect CWT facility planning to

comply with the multiple wastestream subcategory

standards notify its control authority of this intent and

also state, based on its BMR submission, whether it can

or cannot comply with the standards currently.

defined in 40 CFR 403.12(l) or 40 CFR 122.22. It should also be kept on file at the CWT facility as

part of the required on-site compliance paperwork. 

8.2.2 When Does the Facility Have to Submit the Initial Certification Statement?

The CWT facility must notify its permitting or control authority of its desire to be subject

to Subcategory D limitations or

standards by submitting an initial

certification statement. Table 8-1

outlines when CWT facilities must

submit an initial certification statement.

Table 8-1 Initial Certification Dates 

Type of CWT Facility Required Initial Certification Statement Date Submission Must Be

Made to:

Existing Direct Discharger at the time of permit renewal or modification NPDES permit writer

Existing Indirect Discharger prior to December 22, 20031control authority

New Direct Discharger at the time of submitting its application for

permit

NPDES permit writer

New Indirect Discharger at the time of submitting its application for an

individual control mechanism

control authority

8.2.3 What Does a CWT Facility Have to Include in an Initial Certification Statement?

The CWT rule requires the initial certification to include three items:

1. A list and description of the subcategories of wastes accepted for treatment at the CWT

facility;

2. A list anddescription ofthe treatment systems atthe CWTfacility andthe conditions under

which the treatment systems are operated for the subcategories of wastes accepted for

treatment; and

3. Information and supporting data establishing that these treatment systems will achieve

equivalent treatment.

The following sections provide guidance to small entities that are CWT facilities on how

EPA envisions these materials should be submitted.
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 3

Item 1: List and description of the subcategories of wastes accepted for treatment at the facility

While not required, CWT facilities may use the guidance provided in Chapter 5 to aid in

determining what subcategories of wastes are accepted fortreatment/recovery at the facility. The

list of wastes accepted for treatment at the facility may be general (i.e., landfill leachate, used oil,

metal finishing wastewater) or may be more specific (i.e., broken down by RCRA codes or waste

codes). Based on information collected by EPA during development of this rule, CWT facilities

already collect this type of information as part of their waste acceptance procedures. Table 8-2 is

an example of the type of information EPA envisions facilities submitting to document the wastes

accepted for treatment at the facility.

Table 8-2 Types of Wastes Accepted at Acme CWT

oils subcategory metals subcategory

used oil 

lubricants

coolants

oil-water emulsions 

non-contact used glycols

spent electroplating sludges

metal finishing rinse waters

waste acids or bases with metals

Item 2: A list and description of the treatment systems at the facility and the conditions under which the

treatment systems are operated for the subcategories of wastes accepted for treatment

The facility should provide information on the treatment systems for each subcategory

identified in Step 1 above. This should include a listing of each treatment technology step that will

be used (not which is present at the facility) to treat the wastestreams. In EPA’s view, this should

include a flow diagram of each treatment system as well as a written discussion. This written

discussion should include pertinent information on the operation of each treatment step such as

the type of treatment chemicals included in a chemical precipitation step. Figure 8-1 is an example

of the level of detail envisioned by EPA.
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 4

Non-Emulsified

Oils Waste

Emulsified

Oils Waste

Metals

Waste

Emulsion

Breaking

Gravity 

Separation

Primary

Chemical

Precipitation

Clarification

Secondary

Chemical

Precipitation

M E M O R A N D U M

July 1, 20XX

FROM: Jane Doe, Plant Supervisor, Acme CWT

TO: Pretreatment Coordinator, City POTW

SUBJECT: Equivalent Treatment Determination for CWT Regulation

The Acme CWT facility treats both oils and metals subcategory wastes. As illustrated below,

some oily wastewater is sent directly to oil/water separation tanks where gravity oil/water separation

occurs. Others do not separate efficiently using gravity alone and are transferred to the emulsion breaking

tank where heat and/or treatment chemicals may be added to break the emulsions. The temperature and

treatment chemicals vary depending on the emulsion being treated. Treatment chemicals may include

polymer, sulfuric acid, and/or alum. The resulting wastewater from the oil/water separation phase is

then treated by dissolved air flotation. The DAF system consists of a 3,000 gallon slow-mix tank, a DAF

unit, chemical mix tanks, metering pumps for each chemical, and in-line mixers. The treatment chemicals

added to the DAF vary depending on the wastewater being treated and may include polymer or caustic. 

The total detention time of the DAF system is 50 to 100 minutes. Wastewater from the DAF is then

commingled with treated metals subcategory wastewater for final discharge.

Metals subcategory wastewaters are treated in a system which consists of primary and secondary

metals precipitation. Primary precipitation treatment occurs in the primary treatment tanks where lime is

added. The precipitation is carried out at ambient temperatures with pH ranging from 8 to 9.5. Caustic or

waste sulfuric acid may also be added to maintain pH. Other chemicals such as sodium sulfide or

potassium permanganate may also be added. The resulting wastewater is then sent to a clarifier. 

Following clarification, the wastewater is processed through a second precipitation step. Once again the

precipitation is carried out at ambient temperatures and the pH varies depending on the specific metals

being removed from the wastewater. Treatment chemicals may include caustic, sulfuric acid, lime, or

ferric chloride. The resulting wastewater is then clarified and commingled with treated oils subcategory

wastewater.

Clarification

Dissolved

Air Flotation

Figure 8-1 Sample Memorandum for Equivalent Treatment Determinations
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 5

The treatment technologies selected

as the basis for the limitations and

pretreatment standards are listed in

Table 3-1 in Chapter 3.

Item 3: Information and supporting data establishing that these treatment systems will achieve equivalent

treatment.

The CWT rule defines equivalent treatment as a “wastewater treatment system that

achieves comparable pollutant removals to the applicable technology selected as the basis for the

limitations and pretreatment standards. Comparable removals may be demonstrated through

references in technical and engineering treatises, journals or other literature, treatability tests, or

self-monitoring data.” The most common measurement of pollutant removals is percent removal

whichmeasures the amount of contaminantremovedfromthewastestream. Calculation of percent

removals is discussed in more detail in Chapter 7 of the technical development document and is:

(MASSinfluent - MASSeffluent)/MASSinfluent. EPA calculated

the percentremovals for each regulated pollutant using

the data included for developing the limitations and

standards in each subcategory. Tables 8-3 and 8-4 show

these pollutant removals. CWT facilities can use the

information in these tables to compare the pollutant

removals achieved by their selected technologies to

EPA’s technology basis.

Table 8-3 Removal Efficiencies for Indirect Discharging CWT Treatment Systems

Oils Subcategory

Pollutant Parameter

Oils Subcat.

Existing

Source

Removal (%)

Oils Subcat.

New 

Source

Removal (%)

Metals Subcategory

Pollutant Parameter

Metals Subcat.

Existing & New

Source

Removal (%)

Organics Subcategory

Pollutant Parameter

Organics Subcat.

Existing & 

New Source

Removal (%)

CLASSICALS CLASSICALS CLASSICALS

Total Cyanide 64.38 64.38 Hexavalent Chromium 98.01 Total Cyanide 33.46

Total Cyanide 99.30

METALS METALS METALS

Antimony 87.99 87.99 Antimony 94.30 Antimony 33.27

Arsenic 57.64 57.64 Arsenic 91.74 Cobalt 17.31

Barium 91.91 91.91 Cadmium 99.97 Copper 38.04

Cadmium 88.07 88.07 Chromium 99.91 Molybdenum 57.10

Chromium 80.54 86.24 Cobalt 98.47 Silicon 4.71

Cobalt 52.20 52.20 Copper 99.91 Strontium 59.51

Copper 91.09 90.02 Iridium 99.69 Zinc 60.51

Lead 92.64 88.26 Lead 99.95

Mercury 77.43 77.43 Lithium 66.83 ORGANICS

Molybdenum 53.73 53.73 Mercury 98.38 2-butanone 69.20

Nickel 41.24 41.24 Molybdenum 26.40 2-propanone 68.57

Selenium 36.94 36.94 Nickel 99.59 2,3-dichloroaniline 80.45

Silicon 54.16 54.16 Selenium 57.54 2,4,6-trichlorophenol 45.16
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

Table 8-3 Removal Efficiencies for Indirect Discharging CWT Treatment Systems

Oils Subcategory

Pollutant Parameter

Oils Subcat.

Existing

Source

Removal (%)

Oils Subcat.

New 

Source

Removal (%)

Metals Subcategory

Pollutant Parameter

Metals Subcat.

Existing & New

Source

Removal (%)

Organics Subcategory

Pollutant Parameter

Organics Subcat.

Existing & 

New Source

Removal (%)

8 - 6

Strontium 50.68 50.68 Silicon 98.58 Acetophenone 92.44

Tin 90.77 90.77 Silver 99.62 Aniline 92.88

Titanium 89.99 89.99 Strontium 95.89 Benzoic Acid 94.29

Zinc 80.33 83.48 Tin 99.94 n,nDimethylformamide 89.26

Titanium 99.84 o-Cresol 98.39

ORGANICS Vanadium 99.46 p-Cresol 85.38

2-Butanone 15.41 15.41 Yttrium 95.39 Pentachlorophenol 23.19

4-chloro-3-methylphenol* - 27.48 Zinc 99.93 Phenol 87.08

Acenapthene 96.75 96.75 Zirconium 42.13 Pyridine 61.69

Alpha-terpineol 94.77 94.77

Anthracene 97.07 96.67 ORGANICS

Benzo (a) anthracene 94.38 95.69 2-Butanone 74.72

Benzoic acid 6.54 19.32 2-Propanone 65.62

Bis(2- 93.22 93.66 Benzoic Acid 82.99

Butyl benzyl phthalate 92.19 92.19 n,nDimethylformamide54.81

Carbazole 81.09 81.09 Pyridine 48.49

Chrysene 96.93 97.22

Diethyl phthalate 77.01 63.97

Fluoranthene 96.24 95.21

Fluorene 95.32 92.86

n-Decane 97.36 94.98

n-Docosane 97.25 96.87

n-Dodecane 94.14 96.50

n-Eicosane 95.88 95.54

n-Hexadecane 97.38 96.53

n-Octadecane 97.32 97.20

n-Tetradecane 97.26 96.85

o-cresol* - 21.08

p-cresol* - 34.88

Phenol 53.68 14.88

Pyrene 97.10 97.63

Pyridine 21.45 21.45

* Not applicable for Existing Sources
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 7

Table 8-4 Removal Efficiencies for Direct Discharging CWT Treatment Systems

Oils Subcategory

Pollutant Parameter

Oils Subcat.

Existing & 

New Source 

Removal (%)

Metals Subcategory

Pollutant Parameter

Metals Subcat.

Existing Source

Removal (%)

Metals Subcategory

Pollutant Parameter

Metals Subcat.

New Source

Removal (%)

Organics

Subcategory

Pollutant Parameter

Organics Subcat.

Existing & 

New Source

Removal (%)

CLASSICALS CLASSICALS CLASSICALS CLASSICALS

Total Cyanide 64.38 Hexavalent Chromium 98.01 TSS 99.97 Total Cyanide 33.46

Total Cyanide 99.30

METALS

METALS METALS Antimony 99.76 METALS

Antimony 87.99 Antimony 94.30 Arsenic 99.87 Antimony 33.27

Arsenic 57.64 Arsenic 91.74 Cadmium 99.98 Cobalt 17.31

Barium 91.91 Cadmium 99.97 Chromium 99.98 Copper 38.04

Cadmium 88.07 Chromium 99.91 Cobalt 99.76 Molybdenum 57.10

Chromium 86.24 Cobalt 98.47 Copper 100.00 Silicon 4.71

Cobalt 52.20 Copper 99.91 Lead 99.79 Strontium 59.51

Copper 90.02 Iridium 99.69 Mercury 99.89 Zinc 60.51

Lead 88.26 Lead 99.95 Molybdenum 40.11

Mercury 77.43 Lithium 66.83 Nickel 99.86 ORGANICS

Molybdenum 53.73 Mercury 98.38 Selenium 94.33 2-butanone 69.20

Nickel 41.24 Molybdenum 26.40 Silver 99.61 2-propanone 68.57

Selenium 36.94 Nickel 99.59 Tin 99.89 2,3-dichloroaniline 80.45

Silicon 54.16 Selenium 57.54 Titanium 99.78 2,4,6-trichlorophenol 45.16

Strontium 50.68 Silicon 98.58 Vanadium 98.95 Acetophenone 92.44

Tin 90.77 Silver 99.62 Zinc 99.99 Aniline 92.88

Titanium 89.99 Strontium 95.89 Benzoic Acid 94.29

Zinc 83.48 Tin 99.94 n,nDimethylformamide89.26

Titanium 99.84 o-Cresol 98.39

ORGANICS Vanadium 99.46 p-Cresol 85.38

2-Butanone 15.41 Yttrium 95.39 Pentachlorophenol 23.19

4-chloro-3-

methylphenol*

27.48 Zinc 99.93 Phenol 87.08

Acenapthene 96.75 Zirconium 42.13 Pyridine 61.69

Alpha-terpineol 94.77

Anthracene 96.67 ORGANICS

Benzo (a) anthracene 95.69 2-Butanone 74.72

Benzoic acid 19.32 2-Propanone 65.62

Bis(2-ethylhexyl)

phthalate

93.66 Benzoic Acid 82.99

Butyl benzyl phthalate 92.19 n,n-Dimethylformamide 54.81

Carbazole 81.09 Pyridine 48.49

Chrysene 97.22

Diethyl phthalate 63.97

Fluoranthene 95.21

Fluorene 92.86

n-Decane 94.98

n-Docosane 96.87

n-Dodecane 96.50

n-Eicosane 95.54

n-Hexadecane 96.53

n-Octadecane 97.20

n-Tetradecane 96.85

o-cresol* 21.08
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

Table 8-4 Removal Efficiencies for Direct Discharging CWT Treatment Systems

Oils Subcategory

Pollutant Parameter

Oils Subcat.

Existing & 

New Source 

Removal (%)

Metals Subcategory

Pollutant Parameter

Metals Subcat.

Existing Source

Removal (%)

Metals Subcategory

Pollutant Parameter

Metals Subcat.

New Source

Removal (%)

Organics

Subcategory

Pollutant Parameter

Organics Subcat.

Existing & 

New Source

Removal (%)

8 - 8

An evaluation of equivalent

treatment should focus on

effective treatment of each

subcategory’s wastes in the

treatment train. The goal is not to

evaluate combined wastestreams

from different subcategories.

EPA included this

requirement so that pollutant

reductions would be through

treatment rather than dilution.

The National Risk Management

Research Laboratory’s (NRMRL)

Treatability Database can be accessed

on-line: www.epa.gov/tdbnrmrl

p-cresol* 34.88

Phenol 14.88

Pyrene 97.63

Pyridine 21.45

FortheAcme CWTfacilitydescribedin Figure 8-

1 above, the facility could simply state that it uses the

same treatment technologies selected as the basis forthe

limitations and standards for the oils and metals

subcategory, and has therefore demonstrated equivalent

treatment. However, a CWT facility does not need to

use the treatment systems selected as the basis of the

limitations and

standards to demonstrate equivalent treatment. As defined,

equivalent treatment may be demonstrated through

literature studies, treatability tests, or self-monitoring data,

or a combination of these. Each of these are discussed

further below.

Demonstrate equivalent treatment through literature

Effective treatment technologies can be

identified through a variety of sources including

technical literature, treatability databases, and

treatment vendors. Treatability testing on similar

wastewaters may provide clues on how to effectively

treat a particular wastewater. Treatment technology

vendors should have information on the capabilities of their treatment systems. A CWT facility

may use information from any of these sources, if available, to demonstrate that a particular

treatment systemwill achieve comparable removals to EPA’s model technologies. This option may

be particularly useful if a facility has actual removal data for a particular technology for some

regulated pollutants and not others, but can demonstrate through literature sources that the

pollutants should be treated in a similar manner.

Demonstrate equivalent treatment through treatability tests

Literature sources are a good method for evaluating various treatment technologies, but

treatability tests may also be required to demonstrate that a particulartechnology has comparable

removals to the model technologies selected as the basis for the rule. For example, a facility may

have literature information that carbon adsorption is effective for the removal of n-dodecane, but
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 9

does not have information on n-decane. Because these chemicals have similar structures, one

would expect them to behave similarly. However, a treatability test would provide the CWT

facility with the additional data which confirm the equivalent treatment demonstration. 

Many CWT facilities already perform treatability tests to obtain optimum pollutant

removals and identify alternative treatment schemes. A treatability test may also allow a facility

to identify surrogate parameters that may be used on an on-going basis to demonstrate equivalent

treatment. 

When conducting a treatability test, facilities may only test the individual treatment unit

operations. However, if a facility intends to implement an entire treatment train, testing the entire

train may reveal important information about how the wastewater characteristics change with each

treatment step. Testing the wastewater through the entire treatment train can help troubleshoot

the system and determine whether pretreatment steps are adequate to prevent malfunctioning of

other unit operations in the treatment train.

It is not always necessary to treat a large volume of wastewater in treatability tests, and

often valuable information can be acquired from smaller scale tests. Treatability tests are typically

categorized based on size as bench-, pilot- and full-scale test. A bench scale test is typically used

to screen treatment technologies or determine initial design and operating parameters, and is

typically conducted on one gallon or less of wastewater. Bench scale tests use laboratory

equipment (for example, beakers, hot plates, and stirring rods) and may be conducted on synthetic

wastewater(that is, distilled water spiked with a known concentration of contaminants). A bench

scale test requires less cost and effort because of the smaller volume of wastewater tested and the

basic equipment used. In addition, a bench scale treatability test may involve less sophisticated

sampling and analysis, and may use indicator parameters or visual appearance of the wastewater

instead of laboratory analysis to gauge test results.

A pilot scale test is conducted on actual wastewater, and is typically used to optimize

design and operating parameters and to troubleshoot treatment problems before constructing a

full-scale treatment system. Actual wastewater may contain surfactants, chelates, or impurities that

may interfere with treatment. The test is generally intermediate in size. Pilot scale tests typically

use smaller and simpler equipment than would be found in a full scale system, such as buckets and

drums instead of treatment tanks. These systems may also use temporary equipment that can be

disposed of after the test instead of permanently installed.

Afull scale treatability testis conductedon actual wastewater using the actual size andtype

of equipment to be used for routine treatment. 

If a CWT facility elects to demonstrate equivalent treatment through treatability tests, it

needs to submit a detailed description of its treatability tests as well as the results. The detailed

description should include the type of treatability test and the parameters used for evaluation.

Operating parameters and information on the wastes treated should also be submitted. Figure 8-2

is an example of a treatment test summary that may be submitted as part of an equivalent

treatment demonstration. The example shows treatability tests using oils subcategory wastes.
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 10

Caustic and

Lime Addition pH adjustment

Sulfuric Acid

and Polymer

Addition

Emulsified

Oils Waste

Treated

Effluent

pH = 7

T = 25 deg C

flow rate = 87 mL/min

empty bed residence time = 15 min

pH = 2

T = 60 deg C

24 hour settling time

pH = 9

T = 25 deg C

1 hour detention time

Emulsion

Breaking

Chemical

Precipitation

& Settling

Facility: Location: 

Date: Prepared by: 

Insert your optimal treatment train and operating parameters in the space provided below:

Technology Pollutant pH Temp,

deg. C

Treat

Time

Constituent

Concentration

Test

%

Rem

CWT

BAT

% 

Rem

Influent

(mg/L)

Effluent

(mg/L)

Emulsion

breaking

n-decane 2 60 24 hr. 1,000 700 30.0

carbazole 2 60 24 hr. 2500 2000 20.0

fluoranthene 2 60 24 hr. 3,000 2,000 33.3

chromium 2 60 24 hr. 230 150 34.8

Single stage

precipitation

chromium 9 25 1 hour 150 1 99.3

Carbon

n-decane 7 25 15 min 700 10 98.6

carbazole 7 25 15 min 2000 20 99.0

fluoranthene 7 25 15 min 2000 40 98.6

Figure 8-2 Sample Treatment Test Summary

For the parameters listed, this information indicates that the treatment systems evaluated

achieve comparable removals to the treatment systems selected as the basis for the CWT limitations

and pretreatment standards. Alternatively, if a treatment technology only removes 30 percent of

a parameter, butthat parameteris removed to below its detection limit orto the required discharge

limits or standards, this would also demonstrate comparable removals. 

Carbon

Adsorption
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 11

Self Monitoring Data

TheCWTfacilitymay alsoprovide thepermitting or control authority withself-monitoring

data to establish equivalent treatment. This is essentially the same as conducting a full-scale

treatability test discussed above. It is important to remember that this self-monitoring data must

demonstrate equivalent treatment for each individual subcategory and should not include

commingled wastewater from different subcategories or non-CWT wastewater such as stormwater.

The information submitted should be similar to that submitted for treatability tests and should

include a summary table similar to Table 8-3. Self-monitoring data from the treatment system as

employed on actual waste receipts is the most fool-proof method for demonstrating equivalent

treatment.

 

8.3 Periodic Certification Statement

8.3.1 What Is a Periodic Certification Statement?

The periodic certification statement is a written submission to the permitting or control

authority that certifies the facility is operating its treatment systems to provide equivalent

treatment as set forth in its initial certification. In the event that the facility has modified its

treatment systems, it must also include a justification to allow modification of the practices listed

in its initial certification. The rule provides that the statement must be signed by the appropriate

manager in charge of overall operations at the site to ensure that information provided is true,

accurate, and complete to the best of his/her knowledge. Again, this manager should be the same

person who signs compliance status reports required by 40 CFR 403.12(l) or 40 CFR 122.22. The

periodic certification statements should also be kept on file at the facility as part of the required onsite compliance paperwork. 

 

8.3.2 When Does a CWT Facility Have to File the Periodic Certification Statement?

The CWT rule requires the CWT facility to submit a periodic certification statement once

per year. The permit writer or control authority should determine the required month of

submission oftheperiodic certification statement andinclude this in the facility’s discharge permit

or control mechanism.

 

8.3.3 What Information Should Be Included in the Periodic Certification Statement?

Ifthe information containedinthe initial certification statement is still applicable, including

information on the subcategory type for wastes accepted fortreatment, a facility shall simply state

that in a letter to the permit writer or control authority, and the letter shall constitute the periodic

statement. However, if the facility has modified its treatment system or the subcategories of wastes

accepted for treatment, it shall submit the revised information in a manner similar to the initial

certification. In EPA’s view, a modification is a change in treatment technology or a major change

in operation. A CWT facility accepting different types of wastes within the same subcategory

previously identifiedisnot a major modification. EPA understands that CWT facilities may change

operating parameters as needed depending on the waste being treated. In EPA’s view, a major

change in operating parameters (such as pH, temperature, etc.) is one that is not listed in the

original certification that may reduce the effectiveness of the treatment. Similarly, a change in the

treatmenttechnology is any significant technology change that may reduce the effectiveness of the

overall treatment system. For example, it would not include the addition of a mixer to an existing
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

8 - 12

ACME CWT 

1234 Main Street 

Anytown, VA 12345 

March 1, 20XX 

Anytown POTW

1 Main Street

Anytown, VA 12345

Dear Sir/Madam:

Please be advised that our facility located at 1234 Main Street still accepts wastes in

both the CWT oils and metals subcategories. The information in our original certification

remains the same except that we now occasionally add a polymer to the DAF system. This

has not reduced the effectiveness of the system. 

Please feel free to contact me at (703) 555-5555 if you have any questions or

comments about this additional treatment chemical.

Sincerely,

John Doe

President

technology, but would include removing/changing an entire treatment step in a treatment train.

An example of a periodic certification statement in shown in Figure 8-3.

Figure 8-3 Sample Periodic Certification Statement
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

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8.4 On-Site Compliance Paperwork:

8.4.1 What Materials Must Be Included with the On-site Paperwork?

The CWT rule requires the following materials be included as part of the on-site paperwork:

1. A general list and description of the subcategory wastes being accepted for

treatment/recovery at the facility;

2. A list and description of the treatment systems at the facility and the conditions under

which the treatment systems are operated for the subcategories of wastes accepted for

treatment;

3. Information and supporting data establishing that these treatment systems will achieve

equivalent treatment.

4. A description of the procedures it follows to ensure that its treatment systems are well

operated and maintained; and

5. An explanation of why the procedures it has adopted will ensure its treatment system are

well-operated and maintained.

The first three items are included in the initial certification and periodic certification

statements. Therefore, the CWT facility should keep these certifications on file. Items 4 and 5 are

discussed in more detail below.

Treatment System Operation and Maintenance

CWT facilities that comply with Subcategory D limitations or standards must also choose

a method to demonstrate that their treatment system(s) are well operated and maintained. This

method should be stated and the rationale for choosing it should be discussed in the on-site

compliance paperwork, such as an environmental management system (EMS).

Proper operation and maintenance of a system includes a qualified person to operate the

system, use of correct treatment chemicals in appropriate quantities, and operation of the system

within stated design parameters (for example, temperature and pressure). Basically, the CWT

facility should keep records of its operating parameters for its treatment systems. Based on

information EPA collected during the development of this rule, most CWT facilities already

maintain these records on-site. For example, the CWT facility should keep records on the amount

and type of chemicals added to each step of its treatment systems. The facility should also

document flow rates and recycle rates on a regular basis (or whenever possible). Additionally,

facilities operatingsystems thatrequireperiodicmaintenance (suchas multimedia filters or carbon

adsorption systems) should keep records on this aspect of treatment system operation.

Alternatively, a facility could also monitor for specific parameters or a surrogate parameter. For

example, a facility may operate dissolved air flotation. The method for demonstrating that the

dissolved air flotation system is well operated can be as simple as maintaining records on the

temperature and pH, the chemicals added (including quantity), the duration of treatment, recycle

ratio, and physical characteristics of the wastewater before and after dissolved air flotation.

Conversely, the facility could monitor for selected parameters for the purpose of demonstrating

effective treatment. This could include any pollutant or a combination of pollutants. A CWT
EQUIVALENT TREATMENT DETERMINATION CWT SMALL ENTITY COMPLIANCE GUIDE

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facility should work with its permitting or control authority to determine whetherits current EMS

or alternative method for demonstrating that its treatment system(s) are well operated and

maintained

EPA notes that permitting or control authorities may inspect the CWT facility at any time

to confirm that the listed practices are being employed, that the treatment system is well operated

and maintained, and that the necessary paperwork provides sufficient justification for any

modifications.

8.5 Additional Considerations Permitting and Control Authorities May Use in Confirming

Equivalent Treatment Determinations

Permitting and control authorities will evaluate and review certification statements and

on-site compliance paperwork from CWT facilities for conformity with the rule requirements.

Factors that may influence their decisions include previous experience with the CWT facility, the

CWT facility management’s commitment to program implementation, and the thoroughness and

accuracy of the supporting documentation.

One area subject to interpretation is the determination of treatment system equivalency.

When reviewingtreatment systemperformancedata,thepermitting or control authority will likely

review the source of data, the time period during which it was collected, and the type of data

collected. 
9- 1

CHAPTER 9

COMPLIANCE ASSURANCE PROCESS

T

his chapter explains how EPA will determine compliance with the CWT rule, what happens

if you or EPA discovers noncompliance, and the legal status of this guide.

 9.1 How Will EPA Determine Compliance With the CWT Rule

EPA uses several approaches to monitor compliance with its environmental regulations,

including methods initiated by EPA and by facilities.

A. Compliance 

Monitoring – Each discharge permit or individual control mechanism includes

compliancemonitoringrequirements. These requirements typically specify

the frequency of monitoring required as well as the individual parameters

to be monitored and their respective discharge limits. Most permits (or

control mechanisms)include limits forthedaily maximum andthemonthly

average. The compliance monitoring must demonstrate that the discharge

complies with both.

B. Reporting – The permitting or control authority will monitor reports submitted by the

facility including discharge monitoring reports and periodic certification

statements. These are the key means by which your compliance will be

evaluated.

C. Inspections – Permitting authorities, control authorities, or EPA may conduct periodic

inspections at facilities subject to this regulation. Inspections may be

initiated by disclosures, random selection, or a variety of other targeting

methods. Inspections may be used to evaluate operations, records, or other

information at the facility. This will be an important component in assuring

equivalent treatment at facilities which have elected this option.

D. Self 

Disclosure – The CWT facility has the primary responsibility for ensuring that its

wastewater discharge complies continuously with its numerical discharge

requirements and, if applicable, its equivalent treatment demonstration.

EPA encourages CWT facilities to take advantage of EPA’s self disclosure

policies or small business policy. 
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 9.2 If I Discover a Violation, How Can I Work with EPA to Correct It?

EPAencourages self-disclosure of violations andhas implementedtwopolicies tomeetthis

goal. These policies meet the objectives of Section 223 of the Small Business Regulatory

Enforcement Fairness Act of 1996 (SBREFA), which provides for the reduction, and, under some

appropriate circumstances, the complete waiver of civil penalties for certain environmental

violations. The policies are:

! Small 

 Business Policy – The “Policy on Compliance Incentives for Small Businesses” applies to

companies with 100 or fewer employees and provides penalty waivers or

penalty reductions as incentives to participate in an on-site compliance

assistance program and to conduct self-audits to discover and correct

violations.

! Audit Policy – The “Incentives for Self-Policing: Disclosure, Correction, and Prevention of

Violations” policy applies to businesses of all sizes that meet the

applicability criteria and promptly disclose and correct violations.

 9.3 If EPA Discovers a Violation, What Might EPA’s Response Be?

To maximize compliance, EPA implements a balanced program of compliance assistance,

compliance incentives, and traditional law enforcement. EPA knows that CWT facilities owned

by small businesses that must comply with complicated new statutes orrules often want to do the

right thing, but may lack the requisite resources. Compliance assistance information and technical

advise helps small businesses to understand and meet their environmental obligations.

Compliance incentives, such as our Small Business Policy, encourage persons to voluntarily

discover, disclose, and correct violations before they’re identified by the government. EPA’s strong

law enforcement program protects all ofus by targetingpersons whoneither comply nor cooperate

to address their problems.

EPA uses a variety of methods to determine whether businesses are complying, including

inspecting facilities, reviewing records and reports, and responding to citizen complaints. If we

learn a person is violating the law, EPA (or State, if the program is delegated) may file an

enforcement action seeking penalties of up to $27,500 per violation, perday. The proposed penalty

in a given case will depend on many factors, including the number, length, and severity of the

violations, the economic benefit obtained by the violator, and its ability to pay. EPA has policies

in place to ensure penalties are calculated fairly. These policies are available to the public. In

addition, any company with a violation has the right to contest EPA’s allegations and proposed

penalty before an impartial judge or jury.

In summary, EPA recognizes that we can achieve the greatest possible protection by

encouraging small businesses to work with us to discover, disclose, and correct violations. That’s

why we’ve issued self-disclosure, small business, and small community policies to eliminate or

reduce penalties for small and large entities which cooperate with EPA to address compliance

problems. In addition, we’ve established compliance assistance centers to serve over a million
COMPLIANCE ASSURANCE PROCESS CWT SMALL ENTITY COMPLIANCE GUIDE

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small businesses. For more information on these and other EPA programs for small business,

please contact EPA’s Small Business Ombudsman, Karen Brown, at (202) 260-1390 or e-mail at

brown.karen@epa.gov.

 9.4 What is the Legal Status of This Guide?

A judge may review a compliance or implementation guide in determining what penalty

is appropriate and reasonable, although the content of the guide cannot otherwise by reviewed by

the court.

In this Compliance Guide, we have tried to make clear what you must do to comply with

the applicable law and regulation. This is the minimum required by SBREFA. You’ll notice,

however, that here and there we have also included suggestions for alternative approaches that

may make compliance easier and possibly even reduce costs. We hope you find this presentation

of regulatory requirements useful and the additional information helpful in reaching and

maintaining compliance.
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10 - 1

CHAPTER 10

QUESTIONS AND ANSWERS

T

his chapter provides questions commonly asked duringdevelopment ofthis rule andEPA’s

responses This information may serve to answer many questions which small entities may

have about the CWT rule.

 10.1 General

Q1. How many facilities are covered under the scope of this rule? How many discharge

wastewater?

A1. EPA estimates there are 223 centralized waste treatment facilities in the U.S., 165 of which

discharge wastewater.

Q2. My facility is a CWT, but it does not discharge wastewater. All wastewaters are shipped

off-site to another CWT. Do I need to meet the CWT discharge requirements prior to

shipping the wastewater off-site?

A2. The CWT rule applies to CWT facilities that discharge wastewater to surface waters or to

POTWs. This facility does neither and is not required to meet the CWT discharge

requirements before shipping the wastewater to another CWT.

Q3. Does the CWT rule include a de minimis exemption?

A3. No, the CWT rule does not include a de minimis exemption.

 10.2 Applicability

Q1. My facility accepts wastes from off-site, but we are not a treatmentfacility. RCRA classifies

us as a recycling facility. Are we subject to the CWT rule? 

A1. The CWT rule is not limited to facilities that perform treatment only. In general,

wastewater discharges from facilities that accept wastes from off-site for recycling are

subject to the CWT rule. However, wastewater discharges from some specific recycling

activities (such as solventrecovery) are not subject to the rule. Therefore, a recycler should

consult the applicability section of the rule for more information on its specific recycling

activity. If information is not included on its specific recycling activity, then its discharges

associated with these acetifies are subject to this rule.
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Q2. My facility only treats and discharges non-hazardous wastes. Is it subject to the CWT rule?

A2. The CWT rule applies to both hazardous and non-hazardous wastes. It does not

differentiate based on the RCRA status of the wastes accepted for treatment. 

Q3. My facilitydischarges wastewaters generatedin the treatment of solid wastes received from

off-site. Since the off-site wastes are not liquid, is the wastewater generated subject to the

CWT rule?

A3. The CWT rule applies to wastewater discharges associated with the treatment and/or

recovery of solid wastes, wastewater and used materials received from off-site.

Q4. My local POTW is my biggest competitor. Are POTWs subject to the CWT rule?

A4. POTWs are not CWT facilities and are not subject to the CWT rule. However, wastes that

are hauled, piped or shipped by rail to POTWs must comply with applicable pretreatment

standards and requirements, including categorical standards. 

Q5. I only accept non-industrial wastes (that is, sanitary wastes) from off-site. Am I a CWT

facility?

A5. No, the CWT rule only applies to discharges of industrial wastewaters. EPA does not

consider sanitary wastewater to be industrial. 

Q6. Are scrap metal yards and municipal waste transfer stations considered CWT facilities?

A6. No, scrap metal yards and municipal waste transfer stations are not subject to the CWT

rule. 

Q7. Is there a SIC Code which identifies the CWT industry?

A7. There is no SIC Code forthe CWT industry. However, many CWT facilities have identified

themselves with the SIC code for “Refuse systems,” 4953. 

 10.3 Pollutants Selected for Regulation

Q1. My facility’s permit does not currently limit all of the pollutants regulated in this rule.

How did you select the regulated pollutants? 

A1. EPA did not restrict its list of pollutants considered for regulation to the list of pollutants

limitedincurrentpermits. EPA examined data from influent wastewater samples collected

atmanyCWTfacilities todetermine the list ofpollutants consideredforregulation. Chapter

6 of the technical development document provides information on the methodology EPA

used to establish the pollutants considered for regulation and Chapter 7 of the technical
QUESTIONS AND ANSWERS CWT SMALL ENTITY COMPLIANCE GUIDE

10 - 3

development document details EPA’s decisions on which of these pollutants were selected

for regulation.

Q2. I discharge to a POTWand the regulated pollutantsdo not cause problems with my POTW.

Why do I have to monitor for these pollutants?

A2. The objective of the CleanWater Act is to “restore and maintain the chemical, physical, and

biological integrity of the Nation’s waters.” In order to achieve this objective, the CWA

establishes as a national goal the elimination of the discharge of all pollutants into the

nation’s waters. Congress mandated EPA to establish pretreatment standards that are

equivalent to standards for direct dischargers. These limitations for direct dischargers are

based on effluent reductions that can be achieved by best available technology

economically achievable (BAT)). However, Congress further mandated that EPA consider

and recognize the treatment capability and performance of the POTW in controlling

discharges for indirect dischargers. Consequently, EPA evaluated which pollutants to

regulate for indirect dischargers by comparing removals of the pollutants regulated for

direct dischargers with POTW removals to determine whether they “pass through” the

POTWto surface waters. All pollutants regulated for indirect dischargers were determined

to pass-through in EPA’s assessment. This pass-through assessment is detailed further in

Chapter 7 of the final technical development document and in the preamble to the final

rule. 

 10.4 Subcategorization Procedure

Q1. Who is responsible for determining the proper subcategories? The CWT facility or the

permit writer or control authority?

A1. EPA believes the CWT facility is in the best position to classify waste receipts into the

proper subcategory. For indirect dischargers, this responsibility is even clearer, as

categorical standards are self-implementing and do not depend necessarily on issuance of

a permit. 

Q2. My facility mainly accepts used oils. Occasionally, we also accept landfill leachate. The

leachate represents no more than 5% of the volume of waste discharged when present.

Based on yourrecommended subcategorization procedure, ourfacility would be classified

as an oils and organics facility. However, since the leachate is only periodic and such a

small percent of the wastewater discharged, can we simply classify ourselves as an oils

facility?

A2. No, your facility is both an oils and an organics facility. During development of this rule,

EPA considered an option for facilities that accept waste from different subcategories to

round to the nearest five percent. The final rule did not include this option. EPA clearly
QUESTIONS AND ANSWERS CWT SMALL ENTITY COMPLIANCE GUIDE

10 - 4

intends that the facility accurately accountfor all off-site wastes accepted– even ifthese offsite wastes are small in volume orrepresent a small percent of the wastewater discharged.

Q3. Are we required to use the subcategorization procedure outlined by EPA? For example,

our facility accepts a waste that has high levels of zinc, low levels of other metals, and low

levels of oil and grease. Using EPA’s hierarchy, it would fall into the organics subcategory,

but we believe it clearly belongs in the metals subcategory. Why do I have to classify it in

the organics subcategory?

A3. First, EPA stresses that the criteria and information on subcategory determination are

provided as guidance to permit writers, control authorities, and CWT facilities in properly

classifying their wastes by subcategory. EPA expects that facilities will also apply common

sense when using our suggested guides. Clearly, the waste described is a metals

subcategory waste and should be classified as such. If it is not explicitly listed in the waste

receipt classification table in Chapter 5, and the numerical hierarchy would otherwise

classify this unusual waste as an organics waste, despite the high concentration of zinc,

then the facility’s judgment couldoverride the classification procedure’s output and classify

this particular waste as needed.

Q4. We accept lubricants that sometimes contain nickel in concentrations in excess of the 37.5

mg/L listed in the waste hierarchy. Should this be classified as an oils waste, a metals

waste or both?

A4. Using EPA’s recommended subcategorization procedure, this waste would be classified in

the oils subcategory. Lubricants are included in the waste receipt classification table as an

oils subcategory waste. The subcategorization hierarchy (numerical criteria) should only

be consulted if the waste is not listed in the waste receipt classification table in Chapter 5.

Q5. Does the CWT rule require documentation for determining the proper classification of

wastes?

A5. TheCWTruledoesnotrequire anydocumentation for determining the proper classification

of wastes. However, permitting or control authorities may require such documentation.

In EPA’s view, however, most CWT facilities already collect and maintain sufficient

information during their waste acceptance procedures to classify their waste receipts

properly. In EPA’s view, permitting or control authorities should only request additional

documentation if a facility’s waste acceptance procedures are inadequate. Inadequate

support for classification could conceivably prevent a permitting or control authority from

confirming which subcategories apply, at which point the permitting or control authority

could choose to not issue a discharge permit.
QUESTIONS AND ANSWERS CWT SMALL ENTITY COMPLIANCE GUIDE

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Q6. I have been accepting used oils and coolants. I am now accepting bilge water. Do I need

to repeat the determination?

A6. No, since bilge wateris classified as an oils subcategory waste (see Table 5-1, Waste Receipt

Classification), a new round of subcategorization is unnecessary.

 10.5 Treatment

Q1. Does the CWT rule require facilities to use the model technologies?

A1. No, CWT facilities are not required to use the model technologies.

Q2. I installed the model technologies and still can’t meet the required limits? What am I doing

wrong?

A2. Installation of the model technology does not guarantee that you will be able to meet the

discharge requirements. You must also optimize the operation of your system. In addition,

many facilities improperly target the design and operation of their treatment systems to

actual numerical limits. This does not ensure that the facility will be in compliance. Rather,

a facility should target the design and operation of its system to the long-term averages.

The long-term average for each limit is included in Appendix A. Unless there is a major

upset of the system, this should ensure compliance with the discharge requirements.

Q3. How does this rule prevent the commingling of different types of wastestreams prior to

receipt at the CWT. For example, waste is represented as oily waste, but metals have been

mixed in during transport.

A3. As discussed in Chapter 5, waste generators initially furnish a CWT facility with a sample

of the wastestream to be treated. The CWT analyzes this sample to characterize the level

of pollutants in the sample and to determine what treatment is necessary. Then, generally,

for each truck load of waste received for treatment from the generator, the CWT facility

collects a sample and conducts “fingerprint” analysis to confirm it is similar to the initial

sample tested. In this manner, the CWT facility should be aware if the waste generator is

misrepresenting the wastestream characteristics. In the case of the example provided, the

facility could decline to accept the wastestream (if it is unable to treat it effectively orif the

wastestream is from a subcategory which would violate the facility’s discharge permit). 

10.6 Monitoring for Compliance

Q1. What monitoring frequency is required by the CWT rule?

A1. TheCWTruledoesnot establishnationally-applicable monitoring frequency requirements,

but rather, leaves the decision up to the permitting authority. The permitting or control

authority is in the best position to gauge the facilities potential for violations and establish
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monitoring frequencies accordingly. Permitting and control authorities generally use

factors such as raw waste variability, wastewater flow volume, type of treatment, and

compliance history, as well as self-developed IPPs to determine appropriate monitoring

frequencies. Section 403.12(e) of the pretreatment regulations requires IUs subject to

categorical pretreatment standards such as the CWT regulations to self-monitor and report

at least twice per year.

Q2. Can a permitting or control authority reduce or waive sampling requirements for a

particular pollutant after a history of sampling shows the pollutant to be absent? 

A2. EPAhas not established methods to waive sampling requirements for particular pollutants

under the CWT rule. In general, EPA does not believe sampling requirements for specific

pollutants should be waived entirely for the CWT industry because this industry accepts

a wide variety of wastestreams that can vary considerably from one batch to the next.

However, direct dischargers (those with NPDES permits) that demonstrate their

discharge is continually well within the limitations may have their monitoring

frequency reduced. The requirements and procedures for this are described in

detail in the EPA publication “Interim Guidance for Performance-Based Reduction

of NPDES Permit Monitoring Frequencies” (EPA-833-B-96-001, April, 1996). In

general, at least two years of monitoring data are needed and the modifications are

made during the re-issuance of the permit. The modifications are made on a

pollutant-by-pollutant basis.

Forindirect dischargers, EPA has proposed regulatory and administrative changes

that may reduce the burden on entities regulated under the National Pretreatment

Program. These proposed changes are referred to as the Pretreatment Streamlining

Proposal. One of the proposed changes is to allow control authorities to waive

industrial user (IU) sampling for pollutants that have been determined not to be

present. 

Q3. Does a CWT facility (electing to comply with the multiple wastestream limitations or

standards)that accepts cyanidehave tomonitor for cyanide immediately following cyanide

pretreatment? 

A3. The CWT rule requires a facility that accepts wastes containing cyanide in excess of 136

mg/L to monitor for cyanide after cyanide treatment and before commingling with other

waste streams. However, the permitting or control authority may allow the facility to

monitor after commingling with other waste streams if the permitting or control authority

adjusts the limit (or standard) using the building block approach (or combined waste

stream formula) and the adjusted limit (or standard) does not fall below the analytical

minimum level. 
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Q4. What if a wastewater matrix causes interference with the analytical method (and therefore

the detection limit is higher than the discharge limit)?

A4. Theprocedures outlinedin EPA’s Guidance on Evaluation, Resolution, and Documentation

of Analytical Problems Associated with Compliance Monitoring (EPA 821-B-93-001)

explain how to eliminate matrix or other interference with analysis. 

 10.7 Multiple Wastestream Subcategory

Q1. Can permitting or pretreatment authorities use the building block approach or combined

waste stream formula to determine the discharge requirements for a facility in lieu of the

multiple wastestream subcategory pretreatment standards?

A1. No, the building block approach and combined waste stream formula cannot be used to

establish discharge requirements for facilities subject to more than one CWT subcategory.

The facility must comply with each applicable subcategory’s limitations or standards

separately or with the applicable set of multiple wastestream subcategory limitations or

standards. 

Q2. Does a CWT facility need to know the percentage of wastes that would be in each of the

subcategories if it elects to comply with the multiple wastestream subcategory limitations?

A2. No, the CWT facility need not know the percentage of wastes that would fall into each of

the subcategories if it chooses to comply with the multiple wastestream subcategory

limitations. The multiple wastestream subcategory limitations consist of the most stringent

of the limitations from each subcategory for each pollutant.

 10.8 Initial Certification Paperwork for Equivalent Treatment

Q1. Who receives the initial certification?

A1. The permitting or control authority receives the certification from CWT facilities that wish

to comply with multiple wastestream limitations or standards. 

Q2. Does a CWT facility have to use the model technology to establish equivalent treatment?

A2. No, facilities electing to comply with the multiple wastestream subcategory limitations or

standards may use the model technology or any technology they can demonstrate will

achieve comparable removals.

Q3. What data requirements are necessary to establish equivalent treatment? For example, to

establish that my system achieves zinc removals equivalent to the model technology, how

many samples must I collect?

A3. The final CWT rule defines equivalent treatment, but gives CWT facilities the latitude to
QUESTIONS AND ANSWERS CWT SMALL ENTITY COMPLIANCE GUIDE

10 - 8

determine the appropriate manner in which to establish it. The rule does not specify a

particular “number” of samples that must be collected and submitted. In fact, the final rule

does not require CWT facilities to collect any samples. CWT facilities should work with

their respective permit writer or control authority to determine an appropriate and

reasonable manner to establish equivalent treatment for their particular circumstances.

Q4. When does the initial certification paperwork have to be completed?

A4. For existing indirect dischargers, the initial certification paperwork must be completed by

or before the compliance deadline. For existing direct dischargers, new direct dischargers

and new indirect dischargers, the initial certification must be completed by the time of

permit or control mechanism issuance, re-issuance or renewal. EPA suggests that an

indirect discharging CWT facility that plans to comply with the multiple wastestream

subcategory pretreatment standards notify its control authority ofthis intent andalso state,

in their BMRsubmission, whetherit can or cannot comply with theses standards currently.

Q5. Does the system have to be fully tested and operational at the time of the initial certification

statement is submitted?

A5. No,the treatment system may be tested afterthe initial certification statement is submitted,

but the system must be fully operational by the required date of compliance.

Q6. Do treatability tests require elaborate QA/QC procedures?

A6. No, the level of QA/QC conducted during EPA sampling is not necessary for facility

treatability testing.

 10.9 Periodic Certification Statement for Equivalent Treatment Certification

Q1. When is the periodic certification required?

A1. The periodic certification requirement begins after the facility has submitted its initial

certification and is required once per year. The timing of submittal can be coordinated with

the submittal of compliance paperwork required by the General Pretreatment Regulations

or the NPDES regulations.

Q2. Does a facility need to monitorforthe regulated pollutants when developing a relationship

for surrogateparametersusedtodemonstrate that a treatment system is well-operatedand

maintained?

A2. The CWT rule does not require monitoring or the establishment of a surrogate parameter

to demonstrate that a system is well-operated and maintained. However, if a facility

chooses to use a surrogate parameter to demonstrate that a treatment system is well
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operated and maintained, it should monitor for the specific regulated pollutant(s) to

establish the relationship between the surrogate and the regulated pollutants.

Q3. In the periodic certification statement, the CWT rule requires the facility to provide

information if it has modified its treatment system. What does EPA mean?

A3. In EPA’s view, a modification is any significant change in the equipment, treatment

chemicals, or operatingprocedures that couldnegatively affect the demonstrated removals.

For example,if a facilityhasdemonstrated equivalent treatment with a system that includes

chemical precipitation and dissolved air flotation, and decides to eliminate the chemical

precipitation step, this would be a modification that would require a re-demonstration

assuming the applicable subcategories have not changed. However, switching chemical

companies is an insignificant change.

Q4. Are CWT facilities required to submit monitoring data to the permitting or control

authority that they collect to demonstrate that a treatment system is well-operated and

maintained?

A4. No, such data should be kept with the facility’s on-site compliance paperwork and must

be available to the permitting or control authority as well as enforcement officials.

 10.10 On-Site Compliance Paperwork for Equivalent Treatment Certification

Q1. For on-site compliance paperwork, may a facility cross-reference other records at the

facility, or does a separate copy of those records need to exist in its CWT compliance file?

A1. Facilities may cross-reference records in other parts of the facility, but must be able to

produce those records when requested by their permitting or control authority.

Q2. How is confidential business information (CBI) that is included as part of compliance

paperwork (either initial or periodic certification or other on-site compliance paperwork)

handled? What can a facility claim as CBI? 

A2. The permitting or control authority is authorized to view CBI, but they must have

procedures inplace toprotectCBIfrom unauthorizedpublic access. Permitting and control

authorities have to allow access to the public at least to the extent that the EPA

confidentiality regulations allow public access. A facility cannot claim any effluent data

or data associated with the “point of compliance” as confidential.

 10.11 Costs

Q1. Is there any guidance on how much CWT facilities should spend on treatment of CWT

wastewater?
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A1. There is no guidance on the amount of money a facility should spend on wastewater

treatment; it depends on a number of factors that the facility should consider in making a

final compliance decision. These factors include the amount of wastewater treated, the

characteristics of the wastewater being treated, treatment in place currently at the facility,

the financial stability of the facility, and the market for waste treatment. For example, a

facility may be able to treat a wastewater adequately using available technologies.

However, if the amount of wastewater treated is very small, it may not be profitable for a

facility to treat and discharge this wastewater to comply with this rule.

Q2. My facility cannot currently afford the upgrades to our treatment system that will be

required to comply with this rule. Can we get a waiver of the requirements or an extension

on the date of compliance?

A2. No, a CWT facility can not obtain a waiver (or FDF) based on financial constraints. If the

facility is unable to comply with the regulation by the required date due to financial

considerations, it should cease discharge by the compliance date.

Q3. Can EPA make any recommendations on financing additional wastewater treatment

technologies for small businesses to comply with this rule?

A3. EPA has compiled a variety of sources to assist small businesses in applying for loans for

pollution control. See http://www.epa.gov/smallbusiness/money.htm.

 10.12 Baseline Monitoring Report

Q1. When is the baseline monitoring report due and to whom must it be submitted?

A1. For existing indirect dischargers, the baseline monitoring report is due on July 21, 2001. It

is submitted to the control authority. 

Q2. How many samples are required for the BMR?

A2. 40 CFR 403.12(b)(5)(iv) states, “The User shall take a minimum of one representative

sample to compile the data necessary to comply with the requirements of this paragraph.”

The type of sample will depend on the nature of the pollutant as described in 40 CFR

403.12(b)(5)(iii), which states “a minimum of four(4) grab samples must be used for pH,

cyanide, total phenols, oil and grease, sulfide, and volatile organics. For all other

pollutants, 24-hour composite samples must be obtained through flow-proportional

composite sampling techniques where feasible. The Control Authority may waive flowproportional composite sampling for any Industrial User that demonstrates that flowproportional sampling is infeasible. In such cases, samples may be obtained through timeproportional composite sampling techniques or through a minimum of four(4) grab

samples where the User demonstrates that this will provide a representative sample of the
QUESTIONS AND ANSWERS CWT SMALL ENTITY COMPLIANCE GUIDE

10 - 11

effluent being discharged.” If the process produces a discharge that is a homogeneous

batch, one grab sample may be taken.

 10.13 RCRA Permits

Q1. Our facility has a Federal RCRA permit because we accept hazardous wastes. We cannot

obtain a RCRA permit modification to alter our treatment system to meet the required

pretreatment standards by the required date of compliance. How can we get an extension?

A1. Many CWT facilities with Federal RCRA permits are under the impression that if they

modify their existing treatment system to comply with this regulation they will have to

obtain a RCRA permit modification. This is incorrect. RCRA contains a wastewater

treatment unit exemption from RCRA permit modification requirements for wastewater

treatment units that are subject to NPDES or pretreatmentrequirements established under

the CWA. Thus, CWT facilities with RCRA permits will not need to modify their RCRA

permits as a result of this rule.
(This Page Left Intentionally Blank)
11 - 1

CHAPTER 11

WHERE TO GET ADDITIONAL HELP

T

his chapter presents additional sources of information, as well as EPA contacts, that may

help small entities obtain additional information related to implementation of the CWT

effluent guidelines limitations andstandards fornew andexisting sources. Specifically, this

chapter presents a list of selected federal programs. These lists also include information on

how to reach EPA program personnel and how to access periodicals and directories.

 11.1 Where Can I Get Copies of Document Related to the CWT Rule?

Copies of documents directly related to the CWT effluent guidelines and standards, such

as theTechnicalDevelopmentDocument(EPA-821-R-00-020), the Economic Analysis (EPA-821-R00-024), the Cost Effectiveness Analysis (EPA-821-R-00-023), the Detailed Costing Document (EPA821-R-00-021), andtheEnvironmental Assessment Document (EPA-821-R-00-022) may be obtained

from our web site at: www.epa.gov/ost/guide/cwti.html. You may also obtain copies of these

documents by contacting the Office of Water Resource Center at (202) 260-7786 or by e-mail at:

waterpubs@epamail.epa.gov or fax: (202) 260-0386.

 11.2 Who Can Help Me at EPA with Specific Questions About the CWT Rule?

Questions specifically related to the effluent limitations guidelines and standards for the

CWT industry should be directed to:

A. Ms. Jan Matuszko (technical questions)

Engineering and Analysis Division

Washington, DC 

Tel: (202) 260-9126

Fax: (202) 260-7185

e-mail: matuszko.jan@epa.gov

B. Mr. Timothy Connor (technical questions)

Engineering and Analysis Division

Washington, DC 

Tel: (202) 260-3164

Fax: (202) 260-7185
WHERE TO GET ADDITIONAL HELP CWT SMALL ENTITY COMPLIANCE GUIDE

11 - 2

e-mail: connor.timothy@epa.gov

C. Dr. William Wheeler (economic questions)

Engineering and Analysis Division

Washington, DC 

Tel: (202) 260-7905

Fax: (202) 260-7185

e-mail: wheeler.william@epa.gov

 11.3 General Information

There are a number of web site resources for obtaining general information about the CWT

rule, related programs, and general EPA policies. The following table identifies some of the main

resources you may find helpful.

Table 11-1 General Resources Information

Resource Web Address Description

EPA web site www.epa.gov EPA’s web site includes press releases,

proposed and final EPA rules and

regulations, and updates to this manual.

Engineering and Analysis

Division website

www.epa.gov/ost/guide Federal Register notices of proposed and

final effluent limitations guidelines and

standard rules, supplemental notices,

pre-proposal documents, background

information, draft industry

questionnaires, public meeting notices,

development documents and other

supporting documents, updates to this

manual, and related documents. 

Federal Register Online via

GPO Access

www.access.gpo.gov/

su_docs/aces/

aces140.html

Official Federal Register documents,

including the published CWT regulation

(December 22, 2000)

EPA Small Business

Assistance Program (SBAP)

www.epa.gov/ttn/sbap State and local SBAP contacts, SBAP

materials, related web sites, meetings and

conferences

EPA Office of Enforcement

and Compliance Assurance:

Policy on Compliance

Incentives for Small Business

es.epa.gov/oeca/

smbusi.html

Applicability of EPA’s policy to promote

environmental compliance among small

businesses. Criteria for civil penalty

mitigation.
WHERE TO GET ADDITIONAL HELP CWT SMALL ENTITY COMPLIANCE GUIDE

Table 11-1 General Resources Information

Resource Web Address Description

11 - 3

EPA Office of Enforcement

and Compliance Assurance:

Audit Policy: Incentives for

Self-Policing

es.epa.gov/oeca/

auditpol.html

Applicability of EPA’s policy to enhance

protection of human health and the

environment by encouraging regulated

entities to voluntarily discover, and

disclose and correct, violations of

environmental requirements.
(This Page Left Intentionally Blank)
Appendix A - 1

APPENDIX A

FINAL EFFLUENT LIMITATIONS AND STANDARDS FOR

THE CWT INDUSTRY

T

his appendixpresents the final effluentlimitations andstandards fortheCWTindustry. The

limitations and standards are presented in tables starting on the next page. The limits are

accompanied by the long-term averages that CWT facilities ought to use as the basis for

design of their treatment systems. Note that the metals, oils, organics, and multiple wastestream

subcategories are labeled Subcategories A, B, C, and D, respectively. Note also that the multiple

wastestream effluent limitations and standards are presented for all possible subcategory

combinations.
Appendix A - 2

Table Appendix A-1. CWT design targets and BPT limitations by subcategory (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals - Subcategory A Oils - Subcategory B Organics - Subcategory C

Long-Term

Average

Design

Targets

Limitations Long-Term

Average

Design

Targets

Limitations Long-Term

Average

Design

Targets

Limitations

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

CONVENTIONAL PARAMETERS*

BOD5 C-003 41.0 163. 53.0

Oil & Grease C-007 34.3 205. 50.2 28.3 127. 38.0

TSS C-009 16.8 60.0 31.0 25.5 74.1 30.6 45.0 216. 61.3

METAL ANALYTES

Antimony 7440-36-0 0.170 0.249 0.206 0.103 0.237 0.141 0.569 0.928 0.679

Arsenic 7440-38-2 0.0839 0.162 0.104 0.789 2.95 1.33

Barium 7440-39-3 0.221 0.427 0.281

Cadium 7440-43-9 0.0580 0.474 0.0962 0.00746 0.0172 0.0102

Chromium 7440-47-3 1.67 15.5 3.07 0.183 0.746 0.323

Cobalt 7440-48-4 0.115 0.192 0.124 7.42 56.4 18.8

Copper 7440-50-8 0.744 4.14 1.06 0.157 0.500 0.242 0.704 0.865 0.757

Cyanide (in-plant) 136 500 178

Lead 7439-92-1 0.177 1.32 0.283 0.0986 0.350 0.160

Mercury 7439-97-6 0.000560 0.00234 0.000739 0.00309 0.0172 0.00647

Molybdenum 7439-98-7 1.54 3.50 2.09 0.943 1.01 0.965

Nickel 7440-02-0 1.16 3.95 1.45

Selenium 7782-49-2 0.280 1.64 0.408

Silver 7440-22-4 0.0264 0.120 0.0351

Tin 7440-31-5 0.0898 0.409 0.120 0.107 0.335 0.165

Titanium 7440-32-6 0.0569 0.0947 0.0618 0.0217 0.0510 0.0299

Vanadium 7440-62-2 0.0500 0.218 0.0662

Zinc 7440-66-6 0.413 2.87 0.641 3.14 8.26 4.50 0.382 0.497 0.420

ORGANIC ANALYTES

Acetone 67-64-1 2.06 30.2 7.97

Acetophenone 98-86-2 0.0359 0.114 0.0562

Aniline 62-53-3 0.0105 0.0333 0.0164

Bis(2-ethylhexyl) phthalate 117-81-7 0.0629 0.215 0.101

Butanone 78-93-3 0.878 4.81 1.85

Butylbenzyl phthalate 85-68-7 0.0550 0.188 0.0887

Carbazole 86-74-8 0.151 0.598 0.276

o-Cresol 95-48-7 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205

n-Decane 124-18-5 0.238 0.948 0.437

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.0173 0.0537 0.0268

n-Octadecane 593-45-3 0.203 0.589 0.302

Phenol 108-95-2 0.362 3.65 1.08

Pyridine 110-86-1 0.116 0.370 0.182

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106

* – The promulgated performance bounds for pH are 6-9 in standard units.
Appendix A - 3

Table Appendix A-2. CWT design targets and BPT limitations for Subcategory D mixed wastestream combinations (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals, Oils, Organics (A, B, & C) Metals, Oils (A & B) Metals, Organics (A & C) Oils, Organics (B & C)

Long-Term

Average

Design

Targets

Limitations Long-Term

Average

Design

Targets

Limitations Long-Term

Average

Design

Targets

Limitations Long-Term

Average

Design

Targets

Limitations

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

CONVENTIONAL PARAMETERS*

BOD5 C-003 41.0 163. 53.0 41.0 163. 53.0 41.0 163. 53.0

Oil & Grease C-007 28.3 127. 38.0 28.3 127. 38.0 34.3 205. 50.2 28.3 127. 38.0

TSS C-009 25.5 74.1 30.6 25.5 74.1 30.6 16.8 60.0 31.0 25.5 74.1 30.6

METAL ANALYTES

Antimony 7440-36-0 0.103 0.237 0.141 0.103 0.237 0.141 0.170 0.249 0.206 0.103 0.237 0.141

Arsenic 7440-38-2 0.0839 0.162 0.104 0.0839 0.162 0.104 0.0839 0.162 0.104 0.789 2.95 1.33

Barium 7440-39-3 0.221 0.427 0.281 0.221 0.427 0.281 0.221 0.427 0.281

Cadium 7440-43-9 0.00746 0.0172 0.0102 0.00746 0.0172 0.0102 0.0580 0.474 0.0962 0.00746 0.0172 0.0102

Chromium 7440-47-3 0.183 0.746 0.323 0.183 0.746 0.323 1.67 15.5 3.07 0.183 0.746 0.323

Cobalt 7440-48-4 0.115 0.192 0.124 0.115 0.192 0.124 0.115 0.192 0.124 7.42 56.4 18.8

Copper 7440-50-8 0.157 0.500 0.242 0.157 0.500 0.242 0.704 0.865 0.757 0.157 0.500 0.242

Cyanide (in-plant) 136 500 178 136 500 178 136 500 178

Lead 7439-92-1 0.0986 0.350 0.160 0.0986 0.350 0.160 0.177 1.32 0.283 0.0986 0.350 0.160

Mercury 7439-97-6 0.000560 0.00234 0.000739 0.000560 0.00234 0.000739 0.000560 0.00234 0.000739 0.00309 0.0172 0.00647

Molybdenum 7439-98-7 0.943 1.01 0.965 1.54 3.50 2.09 0.943 1.01 0.965 0.943 1.01 0.965

Nickel 7440-02-0 1.16 3.95 1.45 1.16 3.95 1.45 1.16 3.95 1.45

Selenium 7782-49-2 0.280 1.64 0.408 0.280 1.64 0.408 0.280 1.64 0.408

Silver 7440-22-4 0.0264 0.120 0.0351 0.0264 0.120 0.0351 0.0264 0.120 0.0351

Tin 7440-31-5 0.0898 0.409 0.120 0.0898 0.409 0.120 0.0898 0.409 0.120 0.107 0.335 0.165

Titanium 7440-32-6 0.0217 0.0510 0.0299 0.0217 0.0510 0.0299 0.0569 0.0947 0.0618 0.0217 0.0510 0.0299

Vanadium 7440-62-2 0.0500 0.218 0.0662 0.0500 0.218 0.0662 0.0500 0.218 0.0662

Zinc 7440-66-6 0.382 0.497 0.420 0.413 2.87 0.641 0.382 0.497 0.420 0.382 0.497 0.420

ORGANIC ANALYTES

Acetone 67-64-1 2.06 30.2 7.97 2.06 30.2 7.97 2.06 30.2 7.97

Acetophenone 98-86-2 0.0359 0.114 0.0562 0.0359 0.114 0.0562 0.0359 0.114 0.0562

Aniline 62-53-3 0.0105 0.0333 0.0164 0.0105 0.0333 0.0164 0.0105 0.0333 0.0164

Bis(2-ethylhexyl) phthalate 117-81-7 0.0629 0.215 0.101 0.0629 0.215 0.101 0.0629 0.215 0.101

Butanone 78-93-3 0.878 4.81 1.85 0.878 4.81 1.85 0.878 4.81 1.85

Butylbenzyl phthalate 85-68-7 0.0550 0.188 0.0887 0.0550 0.188 0.0887 0.0550 0.188 0.0887

Carbazole 86-74-8 0.151 0.598 0.276 0.151 0.598 0.276 0.151 0.598 0.276

o-Cresol 95-48-7 0.185 1.92 0.561 0.185 1.92 0.561 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205 0.0682 0.698 0.205 0.0682 0.698 0.205

n-Decane 124-18-5 0.238 0.948 0.437 0.238 0.948 0.437 0.238 0.948 0.437

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.0173 0.0537 0.0268 0.0173 0.0537 0.0268 0.0173 0.0537 0.0268

n-Octadecane 593-45-3 0.203 0.589 0.302 0.203 0.589 0.302 0.203 0.589 0.302

Phenol 108-95-2 0.362 3.65 1.08 0.362 3.65 1.08 0.362 3.65 1.08

Pyridine 110-86-1 0.116 0.370 0.182 0.116 0.370 0.182 0.116 0.370 0.182

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106 0.0858 0.155 0.106 0.0858 0.155 0.106

* – The promulgated performance bounds for pH are 6-9 in standard units.
Appendix A - 4

Table Appendix A-3. CWT design targets and NSPS standards by subcategory (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals - Subcategory A Oils - Subcategory B Organics - Subcategory C

Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

CONVENTIONAL PARAMETERS*

BOD5 C-003 41.0 163. 53.0

Oil & Grease C-007 34.3 205. 50.2 28.3 127. 38.0

TSS C-009 9.25 29.6 11.3 25.5 74.1 30.6 45.0 216. 61.3

METAL ANALYTES

Antimony 7440-36-0 0.0213 0.111 0.0312 0.103 0.237 0.141 0.569 0.928 0.679

Arsenic 7440-38-2 0.0112 0.0993 0.0199 0.789 2.95 1.33

Barium 7440-39-3 0.221 0.427 0.281

Cadium 7440-43-9 0.0819 0.782 0.163 0.00746 0.0172 0.0102

Chromium 7440-47-3 0.0398 0.167 0.0522 0.183 0.746 0.323

Cobalt 7440-48-4 0.0574 0.182 0.0703 7.42 56.4 18.8

Copper 7440-50-8 0.169 0.659 0.216 0.157 0.500 0.242 0.704 0.865 0.757

Cyanide (in-plant) 136 500 178

Lead 7439-92-1 0.177 1.32 0.283 0.0986 0.350 0.160

Mercury 7439-97-6 0.000201 0.000641 0.000246 0.00309 0.0172 0.00647

Molybdenum 7439-98-7 1.54 3.50 2.09 0.943 1.01 0.965

Nickel 7440-02-0 0.255 0.794 0.309

Selenium 7782-49-2 0.0563 0.176 0.0698

Silver 7440-22-4 0.0100 0.0318 0.0122

Tin 7440-31-5 0.0300 0.0955 0.0367 0.107 0.335 0.165

Titanium 7440-32-6 0.00500 0.0159 0.00612 0.0217 0.0510 0.0299

Vanadium 7440-62-2 0.0500 0.0628 0.0518

Zinc 7440-66-6 0.206 0.657 0.252 3.14 8.26 4.50 0.382 0.497 0.420

ORGANIC ANALYTES

Acetone 67-64-1 2.06 30.2 7.97

Acetophenone 98-86-2 0.0359 0.114 0.0562

Aniline 62-53-3 0.0105 0.0333 0.0164

Bis(2-ethylhexyl) phthalate 117-81-7 0.0629 0.215 0.101

Butanone 78-93-3 0.878 4.81 1.85

Butylbenzyl phthalate 85-68-7 0.0550 0.188 0.0887

Carbazole 86-74-8 0.151 0.598 0.276

o-Cresol 95-48-7 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205

n-Decane 124-18-5 0.238 0.948 0.437

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.0173 0.0537 0.0268

n-Octadecane 593-45-3 0.203 0.589 0.302

Phenol 108-95-2 0.362 3.65 1.08

Pyridine 110-86-1 0.116 0.370 0.182

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106

* – The promulgated performance bounds for pH are 6-9 in standard units.
Appendix A - 5

Table Appendix A-4. CWT design targets and NSPS standards for Subcategory D mixed wastestream combinations (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals, Oils, Organics (A, B, & C) Metals, Oils (A & B) Metals, Organics (A & C) Oils, Organics (B & C)

Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

CONVENTIONALS PARAMETERS*

BOD5 C-003 41.0 163. 53.0 41.0 163. 53.0 41.0 163. 53.0

Oil & Grease C-007 28.3 127. 38.0 28.3 127. 38.0 34.3 205. 50.2 28.3 127. 38.0

TSS C-009 9.25 29.6 11.3 9.25 29.6 11.3 9.25 29.6 11.3 25.5 74.1 30.6

METAL ANALYTES

Antimony 7440-36-0 0.0213 0.111 0.0312 0.0213 0.111 0.0312 0.0213 0.111 0.0312 0.103 0.237 0.141

Arsenic 7440-38-2 0.0112 0.0993 0.0199 0.0112 0.0993 0.0199 0.0112 0.0993 0.0199 0.789 2.95 1.33

Barium 7440-39-3 0.221 0.427 0.281 0.221 0.427 0.281 0.221 0.427 0.281

Cadium 7440-43-9 0.00746 0.0172 0.0102 0.00746 0.0172 0.0102 0.0819 0.782 0.163 0.00746 0.0172 0.0102

Chromium 7440-47-3 0.0398 0.167 0.0522 0.0398 0.167 0.0522 0.0398 0.167 0.0522 0.183 0.746 0.323

Cobalt 7440-48-4 0.0574 0.182 0.0703 0.0574 0.182 0.0703 0.0574 0.182 0.0703 7.42 56.4 18.8

Copper 7440-50-8 0.169 0.659 0.216 0.169 0.659 0.216 0.169 0.659 0.216 0.157 0.500 0.242

Cyanide (in-plant) 136 500 178 500 178 500 178

Lead 7439-92-1 0.0986 0.350 0.160 0.0986 0.350 0.160 0.177 1.32 0.283 0.0986 0.350 0.160

Mercury 7439-97-6 0.000201 0.000641 0.000246 0.000201 0.000641 0.000246 0.000201 0.000641 0.000246 0.00309 0.0172 0.00647

Molybdenum 7439-98-7 0.943 1.01 0.965 1.54 3.50 2.09 0.943 1.01 0.965 0.943 1.01 0.965

Nickel 7440-02-0 0.255 0.794 0.309 0.255 0.794 0.309 0.255 0.794 0.309

Selenium 7782-49-2 0.0563 0.176 0.0698 0.0563 0.176 0.0698 0.0563 0.176 0.0698

Silver 7440-22-4 0.0100 0.0318 0.0122 0.0100 0.0318 0.0122 0.0100 0.0318 0.0122

Tin 7440-31-5 0.0300 0.0955 0.0367 0.0300 0.0955 0.0367 0.0300 0.0955 0.0367 0.107 0.335 0.165

Titanium 7440-32-6 0.00500 0.0159 0.00612 0.00500 0.0159 0.00612 0.00500 0.0159 0.00612 0.0217 0.0510 0.0299

Vanadium 7440-62-2 0.0500 0.0628 0.0518 0.0500 0.0628 0.0518 0.0500 0.0628 0.0518

Zinc 7440-66-6 0.206 0.657 0.252 0.206 0.657 0.252 0.206 0.657 0.252 0.382 0.497 0.420

ORGANIC ANALYTES

Acetone 67-64-1 2.06 30.2 7.97 2.06 30.2 7.97 2.06 30.2 7.97

Acetophenone 98-86-2 0.0359 0.114 0.0562 0.0359 0.114 0.0562 0.0359 0.114 0.0562

Aniline 62-53-3 0.0105 0.0333 0.0164 0.0105 0.0333 0.0164 0.0105 0.0333 0.0164

Bis(2-ethylhexyl) phthalate 117-81-7 0.0629 0.215 0.101 0.0629 0.215 0.101 0.0629 0.215 0.101

Butanone 78-93-3 0.878 4.81 1.85 0.878 4.81 1.85 0.878 4.81 1.85

Butylbenzyl phthalate 85-68-7 0.0550 0.188 0.0887 0.0550 0.188 0.0887 0.0550 0.188 0.0887

Carbazole 86-74-8 0.151 0.598 0.276 0.151 0.598 0.276 0.151 0.598 0.276

o-Cresol 95-48-7 0.185 1.92 0.561 0.185 1.92 0.561 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205 0.0682 0.698 0.205 0.0682 0.698 0.205

n-Decane 124-18-5 0.238 0.948 0.437 0.238 0.948 0.437 0.238 0.948 0.437

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.0173 0.0537 0.0268 0.0173 0.0537 0.0268 0.0173 0.0537 0.0268

n-Octadecane 593-45-3 0.203 0.589 0.302 0.203 0.589 0.302 0.203 0.589 0.302

Phenol 108-95-2 0.362 3.65 1.08 0.362 3.65 1.08 0.362 3.65 1.08

Pyridine 110-86-1 0.116 0.370 0.182 0.116 0.370 0.182 0.116 0.370 0.182

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106 0.0858 0.155 0.106 0.0858 0.155 0.106

* – The promulgated performance bounds for pH are 6-9 in standard units.
Appendix A - 6

Table Appendix A-5. CWT design targets and PSES standards by subcategory (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals - Subcategory A Oils - Subcategory B Organics - Subcategory C

Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

METAL ANALYTES

Antimony 7440-36-0 0.170 0.249 0.206 0.103 0.237 0.141

Arsenic 7440-38-2 0.0839 0.162 0.104

Barium 7440-39-3 0.221 0.427 0.281

Cadium 7440-43-9 0.0580 0.474 0.0962

Chromium 7440-47-3 1.67 15.5 3.07 0.323 0.947 0.487

Cobalt 7440-48-4 0.115 0.192 0.124 7.42 56.4 18.8

Copper 7440-50-8 0.744 4.14 1.06 0.257 0.405 0.301

Cyanide (in-plant) 136 500 178

Lead 7439-92-1 0.177 1.32 0.283 0.149 0.222 0.172

Mercury 7439-97-6 0.000560 0.00234 0.000739

Molybdenum 7439-98-7 1.54 3.50 2.09 0.943 1.01 0.965

Nickel 7440-02-0 1.16 3.95 1.45

Selenium 7782-49-2 0.280 1.64 0.408

Silver 7440-22-4 0.0264 0.120 0.0351

Tin 7440-31-5 0.0898 0.409 0.120 0.107 0.249 0.146

Titanium 7440-32-6 0.0569 0.0947 0.0618

Vanadium 7440-62-2 0.0500 0.218 0.0662

Zinc 7440-66-6 0.413 2.87 0.641 3.45 6.95 4.46

ORGANIC ANALYTES

Bis(2-ethylhexyl) phthalate 117-81-7 0.116 0.267 0.158

Carbazole 86-74-8 0.151 0.392 0.233

o-Cresol 95-48-7 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205

n-Decane 124-18-5 2.37 5.79 3.31

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.253 0.787 0.393

n-Octadecane 593-45-3 0.793 1.22 0.925

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106
Appendix A - 7

Table Appendix A-6. CWT design targets and PSES standards for Subcategory D mixed wastestream combinations (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals, Oils, Organics (A, B, & C) Metals, Oils (A & B) Metals, Organics (A & C) Oils, Organics (B & C)

Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

METAL ANALYTES

Antimony 7440-36-0 0.103 0.237 0.141 0.103 0.237 0.141 0.170 0.249 0.206 0.103 0.237 0.141

Arsenic 7440-38-2 0.0839 0.162 0.104 0.0839 0.162 0.104 0.0839 0.162 0.104

Barium 7440-39-3 0.221 0.427 0.281 0.221 0.427 0.281 0.221 0.427 0.281

Cadium 7440-43-9 0.0580 0.474 0.0962 0.0580 0.474 0.0962 0.0580 0.474 0.0962

Chromium 7440-47-3 0.323 0.947 0.487 0.323 0.947 0.487 1.67 15.5 3.07 0.323 0.947 0.487

Cobalt 7440-48-4 0.115 0.192 0.124 0.115 0.192 0.124 0.115 0.192 0.124 7.42 56.4 18.8

Copper 7440-50-8 0.257 0.405 0.301 0.257 0.405 0.301 0.744 4.14 1.06 0.257 0.405 0.301

Cyanide (in-plant) 136 500 178 136 500 178 136 500 178

Lead 7439-92-1 0.149 0.222 0.172 0.149 0.222 0.172 0.177 1.32 0.283 0.149 0.222 0.172

Mercury 7439-97-6 0.000560 0.00234 0.000739 0.000560 0.00234 0.000739 0.000560 0.00234 0.000739

Molybdenum 7439-98-7 0.943 1.01 0.965 1.54 3.50 2.09 0.943 1.01 0.965 0.943 1.01 0.965

Nickel 7440-02-0 1.16 3.95 1.45 1.16 3.95 1.45 1.16 3.95 1.45

Selenium 7782-49-2 0.280 1.64 0.408 0.280 1.64 0.408 0.280 1.64 0.408

Silver 7440-22-4 0.0264 0.120 0.0351 0.0264 0.120 0.0351 0.0264 0.120 0.0351

Tin 7440-31-5 0.0898 0.409 0.120 0.0898 0.409 0.120 0.0898 0.409 0.120 0.107 0.249 0.146

Titanium 7440-32-6 0.0569 0.0947 0.0618 0.0569 0.0947 0.0618 0.0569 0.0947 0.0618

Vanadium 7440-62-2 0.0500 0.218 0.0662 0.0500 0.218 0.0662 0.0500 0.218 0.0662

Zinc 7440-66-6 0.413 2.87 0.641 0.413 2.87 0.641 0.413 2.87 0.641 3.45 6.95 4.46

ORGANIC ANALYTES

Bis(2-ethylhexyl)phthalate 117-81-7 0.116 0.267 0.158 0.116 0.267 0.158 0.116 0.267 0.158

Carbazole 86-74-8 0.151 0.392 0.233 0.151 0.392 0.233 0.151 0.392 0.233

o-Cresol 95-48-7 0.185 1.92 0.561 0.185 1.92 0.561 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205 0.0682 0.698 0.205 0.0682 0.698 0.205

n-Decane 124-18-5 2.37 5.79 3.31 2.37 5.79 3.31 2.37 5.79 3.31

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.253 0.787 0.393 0.253 0.787 0.393 0.253 0.787 0.393

n-Octadecane 593-45-3 0.793 1.22 0.925 0.793 1.22 0.925 0.793 1.22 0.925

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106 0.0858 0.155 0.106 0.0858 0.155 0.106
Appendix A - 8

Table Appendix A-7. CWT design targets and PSNS standards by subcategory (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals - Subcategory A Oils - Subcategory B Organics - Subcategory C

Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

METAL ANALYTES

Antimony 7440-36-0 0.170 0.249 0.206 0.103 0.237 0.141

Arsenic 7440-38-2 0.0839 0.162 0.104

Barium 7440-39-3 0.221 0.427 0.281

Cadium 7440-43-9 0.0580 0.474 0.0962

Chromium 7440-47-3 1.67 15.5 3.07 0.183 0.746 0.323

Cobalt 7440-48-4 0.115 0.192 0.124 7.42 56.4 18.8

Copper 7440-50-8 0.744 4.14 1.06 0.157 0.500 0.242

Cyanide (in-plant) 136 500 178

Lead 7439-92-1 0.177 1.32 0.283 0.0986 0.350 0.160

Mercury 7439-97-6 0.000560 0.00234 0.000739

Molybdenum 7439-98-7 1.54 3.50 2.09 0.943 1.01 0.965

Nickel 7440-02-0 1.16 3.95 1.45

Selenium 7782-49-2 0.280 1.64 0.408

Silver 7440-22-4 0.0264 0.120 0.0351

Tin 7440-31-5 0.0898 0.409 0.120 0.107 0.335 0.165

Titanium 7440-32-6 0.0569 0.0947 0.0618

Vanadium 7440-62-2 0.0500 0.218 0.0662

Zinc 7440-66-6 0.413 2.87 0.641 3.14 8.26 4.50

ORGANIC ANALYTES

Bis(2-ethylhexyl)phthalate 117-81-7 0.0629 0.215 0.101

Carbazole 86-74-8 0.151 0.598 0.276

o-Cresol 95-48-7 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205

n-Decane 124-18-5 0.238 0.948 0.437

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.0173 0.0537 0.0268

n-Octadecane 593-45-3 0.203 0.589 0.302

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106
Appendix A - 9

Table Appendix A-8. CWT design targets and PSNS standards for Subcategory D mixed wastestream combinations (mg/L)

Pollutant Parameters

CAS

Registry

Number

Metals, Oils, Organics (A, B, & C) Metals, Oils (A & B) Metals, Organics (A & C) Oils, Organics (B & C)

Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards Long-Term

Average

Design

Targets

Standards

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

Daily

Maximum

 Monthly

Average

Maximum

METAL ANALYTES

Antimony 7440-36-0 0.103 0.237 0.141 0.103 0.237 0.141 0.170 0.249 0.206 0.103 0.237 0.141

Arsenic 7440-38-2 0.0839 0.162 0.104 0.0839 0.162 0.104 0.0839 0.162 0.104

Barium 7440-39-3 0.221 0.427 0.281 0.221 0.427 0.281 0.221 0.427 0.281

Cadium 7440-43-9 0.0580 0.474 0.0962 0.0580 0.474 0.0962 0.0580 0.474 0.0962

Chromium 7440-47-3 0.183 0.746 0.323 0.183 0.746 0.323 1.67 15.5 3.07 0.183 0.746 0.323

Cobalt 7440-48-4 0.115 0.192 0.124 0.115 0.192 0.124 0.115 0.192 0.124 7.42 56.4 18.8

Copper 7440-50-8 0.157 0.500 0.242 0.157 0.500 0.242 0.744 4.14 1.06 0.157 0.500 0.242

Cyanide (in-plant) 136 500 178 136 500 178 136 500 178

Lead 7439-92-1 0.0986 0.350 0.160 0.0986 0.350 0.160 0.177 1.32 0.283 0.0986 0.350 0.160

Mercury 7439-97-6 0.000560 0.00234 0.000739 0.000560 0.00234 0.000739 0.000560 0.00234 0.000739

Molybdenum 7439-98-7 0.943 1.01 0.965 1.54 3.50 2.09 0.943 1.01 0.965 0.943 1.01 0.965

Nickel 7440-02-0 1.16 3.95 1.45 1.16 3.95 1.45 1.16 3.95 1.45

Selenium 7782-49-2 0.280 1.64 0.408 0.280 1.64 0.408 0.280 1.64 0.408

Silver 7440-22-4 0.0264 0.120 0.0351 0.0264 0.120 0.0351 0.0264 0.120 0.0351

Tin 7440-31-5 0.0898 0.409 0.120 0.0898 0.409 0.120 0.0898 0.409 0.120 0.107 0.335 0.165

Titanium 7440-32-6 0.0569 0.0947 0.0618 0.0569 0.0947 0.0618 0.0569 0.0947 0.0618

Vanadium 7440-62-2 0.0500 0.218 0.0662 0.0500 0.218 0.0662 0.0500 0.218 0.0662

Zinc 7440-66-6 0.413 2.87 0.641 0.413 2.87 0.641 0.413 2.87 0.641 3.14 8.26 4.50

ORGANIC ANALYTES

Bis(2-ethylhexyl)phthalate 117-81-7 0.0629 0.215 0.101 0.0629 0.215 0.101 0.0629 0.215 0.101

Carbazole 86-74-8 0.151 0.598 0.276 0.151 0.598 0.276 0.151 0.598 0.276

o-Cresol 95-48-7 0.185 1.92 0.561 0.185 1.92 0.561 0.185 1.92 0.561

p-Cresol 106-44-5 0.0682 0.698 0.205 0.0682 0.698 0.205 0.0682 0.698 0.205

n-Decane 124-18-5 0.238 0.948 0.437 0.238 0.948 0.437 0.238 0.948 0.437

2,3-Dichloroaniline 608-27-5 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361 0.0230 0.0731 0.0361

Fluoranthene 206-44-0 0.0173 0.0537 0.0268 0.0173 0.0537 0.0268 0.0173 0.0537 0.0268

n-Octadecane 593-45-3 0.203 0.589 0.302 0.203 0.589 0.302 0.203 0.589 0.302

2,4,6-Trichlorophenol 88-06-2 0.0858 0.155 0.106 0.0858 0.155 0.106 0.0858 0.155 0.106