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

Environmental Protection (4303) June 2001 Agency Version 3.0 

# S MALL 

# E NTITY 

# C OMPLIANCE 

# G UIDE



# Centralized Waste Treatment

Effluent Limitations Guidelines

and Pretreatment Standards (40 CFR 437)

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# D ISCLAIMER



# T he Engineering and Analysis Division of EPA’s Office of Water prepared this guide pursuant

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

Public Law 104-121. EPA intends t h is g uide to aid small regulated entities that are direct or indirect industrial dischargers in complying with recently p ublished national regulations, “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, it d oes not impose legally-binding requirements on EPA, States, or the regulated
community, and the general description provided here may not apply to a part icular 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 mad e 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

NPDES permit and EPA’s regulations or in the case of indirect dischargers 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 woul d 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 admini strative action against a small business for violation of the effluent limitations guidelines, pretreatment standards or new source performance standards for the 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.

EPA may decide 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

, or to 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 gu ide by accessing the document at: www.epa.gov/ost/guide/cwti.html

.

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## C HAPTER 

## 1



# I NTRODUCTION



# T his document is published by the U.S. Environmental Protection Agency (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 pu blished on December 22, 2000. EPA is continually improving and up grading its rules, policies, compliance programs and outreach efforts.

You can determine whether EPA has revised or supplemented any of th e 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,

p ages 81242

- 81313) on December 22, 2000 under the authority of the Clean Wat er Act (CWA).

EPA has prepared this small en tity compliance guide because Section 212 of the Small Business Regulatory Enforcement 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 t

hat 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 (based on Small Business Administration 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 50,0 00; and (3) a small organization

that is any n ot-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. I f 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.I NTRODUCTION CWT S MALL E NTITY C OMPLIANCE G UIDE

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 p e rmit and

control authorities need to have a thorough understanding o f a CWT facility’s operations to implement this rule properly. Likewise, CWT facilities must maintain close communication with

the generators and sources of the wa stes 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. T he entities that are subject to this rule include small entities that are CWT facilities that

either discharge wastewater directly into surface water or that introduce wastewater into publicly

owned treatment works.

Because the regulation establishes the sa me requirements for all affected facilities, 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 for the CWT industry. This guidance also enables

the reader to determ

ine 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 gui delines and pretreatment standards. EPA

d eveloped 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 o f 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 o n determining what subcategories apply to a facility’s

operations.I NTRODUCTION CWT S MALL E NTITY C OMPLIANCE G UIDE

1 - 3 Chapter 6 provides in formation 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 for facilities 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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## C HAPTER 

## 2



# O VERVIEW OF 

# E FFLUENT 

# L IMITATIONS 

# G UIDELINES AND



# P RETREATMENT 

# S

TANDARDS



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

pretreatment standards (ELGs). EPA has simplified t h e 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 t he 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 discha rged from various industrial,

commercial, and public sources of wastewater. Among these are restrictions on the direct discharge of effluent, i.e. wastewater, into navigable waters (“ effluent limitations”) and restrictions

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

their int roduction 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 efflue

nt 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 requ ired 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) thanO VERVIEW OF ELG S CWT S MALL E NTITY C OMPLIANCE G UIDE

1 Conventional 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 p ollutants 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 was tewater -- 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

Te chnology, Best Available Technology Economically Achievable, and New Source Performance Standards, respectively.
Existing direct discharging CWT facilities

are required to co

m ply with BPT for

conventional pollutants 1 (BOD 5 , TSS, oil and

grease, pH) and BAT for all other regulated pollutants. New source direct dischargers

must comply w ith 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 indir ect discharger is a facility that discharges pollutants to surface water indirectly by introducing pollutants into a publically owned treatme nt 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

.O VERVIEW OF ELG S CWT S MALL E NTITY C OMPLIANCE G UIDE

2 - 3 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.” For CWT indi rect discharging facilities, EPA

has established two o

verall 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 CWT facilities do not discharge process wastewater into waters of the U.S. or a POTW.

These facilities are referred to as zero or alternative dischargers

. Zero or alternative discharging CWT

facilitie s dispose of their process wastewater through

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

facilities do not ha

ve to meet the restrictions established by this rule (these facilities may have to meet restrictions

establis hed 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 contin ue to apply to that wastewater (this would not be true if the CWT

wastewater is 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 rest rictions. A CWT facility which is currently a direct or indirect dischargi n g facility and alters its wastewater disposal method to become a zero or alternative discharger would no longer be regulated under this rule.

## (This Page Left Intentionally Blank)3 - 1 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. 

## C HAPTER 

## 3



# T HE 

# CWT I NDUSTRY AND THE 

# CWT R ULE



# T his chapter provides a general overview of the CWT in dustry and the CWT rule. It also

includes genera

l 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 informat ion 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 for treatment and/or recovery 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 facili ties 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 w a

stes exclusively while others

treat hazardous and non-hazardous wastes. Some primarily treat

concentrated wastes while others primarily treat dilute wastes. Some primarily perform w astewater treatment or materials recovery and recycling, while others perform both.

EPA estimates there are 223 centr alized

waste trea

tment 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. F e wer than

10% are direct dischargers. The average volume of wastewater discharged on an annual basis by

an indirect discharging CWT facility is 9.3 million gallons while a direct discharging CWT fa cility

averages 38 million gallons/year. EPA estimates

that sixty-three small companies own discharging facilities that are subje ct to the requirements of this rule.T HE CWT I NDUSTRY AND THE CWT R ULE CWT S MALL E NTITY C OMPLIANCE G UIDE

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 CWT rule contains effluent limitations guidelines and standards for the CWT industry.

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 limit a tions 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 or recover metal from metal-bearing waste, wastewater,

or used material received from off-site;

• Subcategory B: Facilities t hat 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 meta l-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 restricti ons 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.T HE CWT I NDUSTRY AND THE CWT R ULE CWT S MALL E NTITY C OMPLIANCE G UIDE

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 t

he 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 metals 1 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.T HE CWT I NDUSTRY AND THE CWT R ULE CWT S MALL E NTITY C OMPLIANCE G UIDE

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 w astewater discharges covered by this

rule i n clude some or all discharges related to

materials received from off-site (waste receipts)

and on-site

CWT wastewater generated as a
result of CWT opera

tions. Examples of off-site

w aste receipts include metal finishing rinse

waters and sludges, used oils, and leachate or groundwater cleanup. On-site CWT wastewater include:

solubilization wastewater, emulsi on breaking/gravity

separa t ion 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 Facility 1 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, 2000T HE CWT I NDUSTRY AND THE CWT R ULE CWT S MALL E NTITY C OMPLIANCE G UIDE

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 authorized States under Section 402 of the CWA and local pretreatment programs under

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 or rules 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 inhi bit sludge

management pract

ices. 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 req u irements (RCRA, EPCRA), waste

management planning requirements (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 t o the CWT rule. Chapter 4 describes the applicability of the CWT rule to various CWT operations.

2. If a fa

cility 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 gene r al pretreatment reporting
requirements which includes submission of a baseline

monitoring

report within 180 days of the effect

ive date of the

CWT rule, or July 21, 2001. This baseline monitoring reportT HE CWT I NDUSTRY AND THE CWT R ULE CWT S MALL E NTITY C OMPLIANCE G UIDE

3 - 6 You can obtain 40 CFR § 403.12 through EPA’s web site: www.epa.gov (BMR) must include results of samp ling and analysis identifying

the concentr

ation of all regulated pollutants in its discharges.

Additional information on this requirement can be found in 40 CFR
§ 403.12(b).

3.8 What Compliance Monitoring Is Required by the CWT Rule?

The CWT rule 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, suchas the CWT regulations, to selfmonit or and report at least twice per year. Additionally, pursuant to 40 CFR 403, POTWs, or

control authorities, have developed in dustrial pretreatment programs (IPPs). IPPs generally contain guidelines for determining monitoring frequencies. Permitting and control authorities look

towards these rules, IPPs, and guidelines to determine monitoring frequencies. They also consider

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

factors.4 - 1 See also Section V of the preamble and Chapter 3 of the Development Document. 

## C HAPTER 

## 4



# A PPLICABILITY



# T his chapter provides guidance on the types of facilities and CWT operations tha t 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 or to a POTW from a facility defined by the

rule as a CWT facility unless specificall y excluded. As previously noted, the rule does not establish different

requirements for CWT that are small entities. The rule definesa 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 allA PPLICABILITY CWT S MALL E NTITY C OMPLIANCE G UIDE

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 withproduct 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 allA PPLICABILITY CWT S MALL E NTITY C OMPLIANCE G UIDE

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.’ 

## C HAPTER 

## 5



# D ETERMINING THE 

# A PPLICABLE 

# S UBCATEGORIES



# 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 fac

i lities 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 facilit ies have already established waste acceptance procedures. The CWT rule does not establish waste acceptance procedures. However, in EPA’s

view, th ese 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 of f-site wastes. Consequently, EPA has included information on waste acceptance procedures as the first step in

its guidance for determ ining 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 perf orms a pre-approval review of the proposed wastestream. This pre-approval process may

include screening the waste for treatability 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 accep tance. 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

for treatment. 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.D ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 FormD ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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



### . Further more, 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 CWT rule does not require waste segregation, CWT facilities should encourage

their waste generators to segregate their wastestreams (i.e., keep metal beari ng 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

Based on information provided by CWT facilities during the de velopment 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 i f 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 subcate gories 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 fi rst 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 classifyD ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 wast es 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 sourcesD ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 t

hat 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

use data collected during the waste acceptance procedures 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 con tains oil and grease <100 mg/L, and has any of the pollutants list

ed 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 gre ase < 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 ma

de, the facility will not need t o repeat this determination process where its

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

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

from a subcategory outside its permit (or to 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

n otification 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.D ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

5 - 6 5.4 Subcategory Determination Procedures for New CWT Facilities

New CWT facilities should estimate the percentage of was te 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 limitatio n s 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 fac ilities. 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 approa ch classifying its o

ff-site

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

4 (for example, contaminated stormwater, emulsion bre a king 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 s hould apportion the on-site generated wastewater to the appropriate subcategory. Certain waste streams may be associated

with more than one subcateg ory 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 subcat egory based on the appropriateness of the selected subcategory treatment technologies. E PA notes that this is only necessary for multiple

s ubcategory facilities which elect not to comply with the Multiple Wastestream Subc ategory

limitations or standards.D ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 t hen

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

based on 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 also discharges on-site generated waste waters – emulsion breaking wastewater

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

to the CWT rule (that is, defined as “C WT 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 locati o n, the limits would be adjusted
using the combined wastestream fo rmula or building block approach to account for the

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

stormwater come

s in contact with this waste handling area, it is c ontact stormwater and is CWT process wastewater subject to this rule.

If this facility elects to comply with the mixed waste subcategory, it does not ne ed 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 classif y the on–site CWT process wastewaters into the

met als or oils subcategory. Clearly, the emulsion breaking

wastewater and any wastewater associated wit h cleaning the treatment equipment for these

wastewaters will be classified in the oils subcategory. Likewise, any wastewater associated with cleaning the treatment equipment for the metals subcategory wastes will be classified in the metals subcategory. If the stormwater is contact stormwater and the facility collects the contact

stormwater from dedicated areas of the facility for each sub category, then these wastewaters would

be classified accordingly. If these contact stormwaters are not collected from dedicated areas, theD ETERMINING THE A PPLICABLE S UBCATEGORIES CWT S MALL E NTITY C OMPLIANCE G UIDE

5 - 8 facility could sample the wastewater to 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 nondetect 20

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

classi fication 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 c riteria hierarchy. Notice, however, that if the

wastewater from customer 6 was an unknown waste type, this facility would need to 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



## C HAPTER 

## 6



# S INGLE 

# S UBCATEGORY 

# F ACILITIES



# 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 importan t ingredient of a successful

wastewater treatment system at CWT facilities. The permitting or 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

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

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

Form ula (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 singl e 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 for the 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 th e CWT facility monitor for cyanide when the

wast ewater 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 “com bined waste stream formula,” assuming the cyanide6 - 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 Documen t 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. 

## C HAPTER 

## 7



# M ULTIPLE 

# S UBCATEGORY 

# F ACILITIES



# E PA e

stimates 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?

A n adequate waste management program is an important ingredient of a successful

wastewater treatment system at CWT facilities. The first step in such a system is identification and
segregation of wastestreams. By i dentify ing 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 for treating concentrated metals waste streams like

those found in the metals subcategory or wastestreams with oil and grease comp ositions 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 se p aration, and/or dissolved air flotation is typically

insufficient for treating concentrated metals wastewaters or wastewaters containing organic

p ollutants 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.M ULTIPLE S UBCATEGORY F ACILITIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 subca tegory (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 m ust monitor for compliance with each subcategory’s effluent limitations or standards prior to 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 and monitor for 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 f

acilities that do not want to complete the paperwork required to demo nstrate equivalent treatment. However, compliance
monitoring costs for this option will be more expensive s

ince it requires monitoring at more than one sample point.

Figure 7-1 and the example 7-1 below illustrate this option.M ULTIPLE S UBCATEGORY F ACILITIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 C WT subcategories with separate subcategory

treatment systems and has el ected 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 requires that the facility comply with the metals subcategory 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 e ach 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 establis h 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 p ermitting 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, the permitting or control a uthority 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.M ULTIPLE S UBCATEGORY F ACILITIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 thr ee 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 equiva lent 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.M ULTIPLE S UBCATEGORY F ACILITIES CWT S MALL E NTITY C OMPLIANCE G UIDE

7 - 5 Oils Waste Metals Waste

Oils

Treatment Discharge

Metals

Treatment Monitoring

Point Example 7-3
Facility C accepts waste in the oils and metals subcategory. The total volume of wastewater

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

me tals 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 subcatego ry 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 de

struction process rather than after mixing with other process wastewater.
Alternatively, the facility ma y 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 b elow the minimum analytical

detectio n limit. F or further information on the “building block approach” or “combined waste stream formula”, see Section 14 of the TDD. Example 7-4 illustrates this approach.M ULTIPLE S UBCATEGORY F ACILITIES CWT S MALL E NTITY C OMPLIANCE G UIDE

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 subcat e gory pretreatment standards for a combination of metals and oils wastes, this facility would be
required to monitor for compliance with cyanide pretreatment standards. Alternatively, the

control authority may allow the facility to monitor for complian ce 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 b elow the minimum
analytical detection limit.8 - 1 The initial certification statement should be signed by the same person who signs the compliance status reports. 

## C HAPTER 

## 8



# E QUIVALENT 

# T REATMENT 

# D ETERMINATION



# A s described in Chapte r 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

Subca tegory D. A facility, however, may o nly elect to comply with the Subcategory D

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

treatment means that the facility is providing treatment for its mixed

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

obtained from separate treatment of the different subcategory wastestrea ms. 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 appro priate permitting authority certifying that its treatment train

includes a

ll applicable equivalent treatment systems. It

m ust be signed by the responsible corporate offi cer asE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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

stand ards by submitting an initial

c e rtification 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, 2003 1 control 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 wa stes accepted for treatment at the CWT facility;

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

which the treatment system s 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.E QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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 for treatment/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.E QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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

F igure 8-1 Sample Memorandum for Equivalent Treatment DeterminationsE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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

limita tions 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

which measures the amount of contaminant removed from the was testream. Calculation of percent

removals is discussed in more detail in Chapter 7 of the technical development document and is:
(M ASS influent - M ASS effluent )/M ASS influent . EPA calculated

the percent removals 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 (%)

C LASSICALS C LASSICALS C LASSICALS

Total Cyanide 64.38 64.38 Hexavalent Chromium 98.01 Total Cyanide 33.46

Total Cyanide 99.30

M ETALS M ETALS M ETALS

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 O RGANICS

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 45.16E QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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

O RGANICS 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 O RGANICS
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,nDimethylformamide 54.81

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 SourcesE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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 (%)

C LASSICALS C LASSICALS C LASSICALS C LASSICALS Total Cyanide 64.38 Hexavalent Chromium 98.01 TSS 99.97 Total Cyanide 33.46
Total Cyanide 99.30

M ETALS

M ETALS M ETALS Antimony 99.76 M ETALS
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 O RGANICS 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-trichlorop henol 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,nDimethylformamide 89.26

Titanium 99.84 o-Cresol 98.39

O RGANICS 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 O RGANICS
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* 21.08E QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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

For the Acme CWT facility described in Figure 8-

1 above, the

facility could simply state that it uses the

same treatment technologies selected as the basis for the

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 th e 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

Effecti ve treatment technologies can be

identified through

a variety of sources including

te chnical 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 capabilit ies of their treatment systems. A CWT facility

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

treatment system will ach ieve comparable removals to EPA’s model technologies. This option may

be particularly useful if a facility has act ual 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 particular technology 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, butE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

8 - 9 does not have info

rmation 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 opti mum 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 n ot 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 be fore 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.

A full scale treatability test is conducted on actual wastewater using the actual size and type of equipment to be used for routine treatment.

If a CWT facility elects to demonstrate equivalent treatment through treatabili ty 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.E QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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, but that parameter is removed to below its detection limit or to the required discharge limits or standards, this would also demonstrate comparable removals. Carbon AdsorptionE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

8 - 11 Self Monitoring Data

The CWT facility may also provide the permitting or control authority with self-monitoring

data to establish equivalent treatme nt. 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 commingl ed wastewater from different subcategories or non-CWT wastewater such as stormwater.

The information submitted should be simil ar 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 emplo yed 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 p eriodic certification statement is a written submission to the permitting or control authority that certifies the facility is operating its treatment systems to provide e quivalent

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 t h e statement must be signed by the appropriate

manager in charge of over all 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 of the periodic certification statement and include this in the facility’s discharge permit

or control mechanism.

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

If the information contained in the initial certification statem ent is still applicable, including

information on the subcategory type for wastes accepted for treatment, 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 info rmation 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 identified is n ot a major modification. EPA understands that CWT facilities may change
operating parameters as needed depending on the waste bein g treated. In EPA’s view, a major change in operating parameters (such as pH, temperature, etc.) is one tha t is not listed in the original certification that may reduce the effectiveness of the treatment. Similarly, a change in the

treatment technology 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 existingE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

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 StatementE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

8 - 13 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 su bcategory 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 t hese treatment systems will achieve equivalent treatment.

4. A description of the p r ocedures 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 incl uded 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

a nd 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 possib le). Additionally,

facilities operating systems that require periodic maintenance (such as multimedia filters or carbon adsorption systems) should keep records on this aspect o f treatment system operation. Alternatively, a facility could also monitor for specific parameters or a surrogate parameter. For exampl e, a facility may operate dissolved air flotation. The method for demonstrating that the

dissolv ed 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

r atio, 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 treat

ment. This could include any pollutant or a combination of pollutants. A CWTE QUIVALENT T REATMENT D ETERMINATION CWT S MALL E NTITY C OMPLIANCE G UIDE

8 - 14 facility should work with its permitting or control authority to determine whether its current EMS

or alternative method for demonstrating that its treatment system(s) are well operat ed 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 paper w ork provides sufficient justification for any
modifications.

8.5 Additional Considerations Permitt ing and Control Authorities May Use in Confirming Equivalent Treatment Determinations

Permitting and cont

rol 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 reviewing treatment system performance data, the permit ting or control authority will likely

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

collected.9- 1



## C HAPTER 

## 9



# C OMPLIANCE 

# A SSURANCE 

# P ROCESS



# 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 co mpliance with its environmental regulations, including methods initiated by EPA and by facilities.

A. Compliance
Monitoring – Each discharge permit or individual control mechanism includes

compliance monitoring requi rements. These requirements typically specify

the frequency of monitoring required as well as the individual parameters

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

control mechanisms) include limits for the daily maximum and the monthly

average. The compliance monitoring must demonstrate that the discharge complies with both.

B. Reporting – Th e 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 authoritie s, or EPA may

conduct periodic

inspections at facilities subject to this regu lation. Inspections may be

i nitiated 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 encourage

s CWT facilities to take advantage of EPA’s self disclosure policies or small business policy.C OMPLIANCE A SSURANCE P ROCESS CWT S MALL E NTITY C OMPLIANCE G UIDE

9- 2 9.2 If I Discover a Violation, How Can I Work with EPA to Correct It?

EPA encourages self-disclosure of violations and has im p lemented two policies to meet this 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 f or certain environmental violations. The policies are:

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

companies with 100 or fewer emp loyees and provides penalty waivers or penalty r

eductions as incentives to participate in an on-site compliance

assis tance program and to conduct self-audits to discover and correct

violations.

! A udit Policy

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

Violatio ns” 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 or rules 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 th eir environmental obligations. Compliance incentive

s, 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 of us by targeting persons who neither 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, per day. The proposed penalty

in a given case will depend on many factors, including the number, lengt h, 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 a llegations 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 millionC OMPLIANCE A SSURANCE P ROCESS CWT S MALL E NTITY C OMPLIANCE G UIDE

9- 3 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 suggesti ons 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.

## (This Page Left Intentionally Blank)10 - 1



## C HAPTER 

## 10



# Q UESTIONS AND 

# A NSWERS



# T his chapter provides questions commonly asked during development of this rule and EPA’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 treatment facility. 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 tha t accept wastes from off-site for recycling are
subject to the CWT rule. However, wastewater discharges from some s pecific recycling

activities (such as solvent recovery) 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.Q UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 2 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 facility discharges wastewaters generated in 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 a ssociated 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 dischar ges 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 for the 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

limited in current permits. EPA examined data from influent wastewater samples collected

at many CWT facilities to determine the list of pollutants considered for regulat ion. Chapter

6 of the technical development document provides information on the methodology EPA

used to est

ablish the pollutants considered for regulation and Chapter 7 of the technicalQ UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 3 development document details EPA’s decisions on which of these pollutants were selected
for regulation.

Q2. I discharge to a POTW and the regulated pollutants do not cause problems with my POTW.
Why do I have to monitor for these pollutants?

A2. The objective of the Clean Water 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 co ntrolling
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 re movals to determine whether they “pass through” the

POTW to 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 t

he CWT facility is in the best position to classify waste receipts into the

proper sub category. 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 vol ume of waste discharged when present.

Based on your recommended subcategorization procedure, our facility 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 clearlyQ UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 4 intends that the facility accurately account for all off-site wastes accepted

– even if these offsite wastes are small in volume or represent a small percent of the wastewater discharged.

Q3. Are we require

d 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 info rmation 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 un

usual waste as an organics waste, despite the high concentration of zinc,

then the facility’s

judg ment could override the clas sification 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. The CWT rule does not require any documentation fo r determining the proper classification

of wastes. However, permitting or control authorities may require such documentation.

In EPA’s view, however, most CWT facilities already collec t and maintain sufficient

information during their waste acceptance procedures to c lassify 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.Q UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 5 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 water is 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-te rm 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 w astestreams 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 or if 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. The CWT rule does not establish nationally- 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 establishQ UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 6 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 appropri ate 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 requir ements for a particular pollutant after a history of sampling shows the pollutant to be absent?

A2. EPA has 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 with in 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.

For indirect 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 det ermined not to be

present.

Q3. Does

a CWT facility (electing to comply with the multiple wastestream limitations or

standards) that accepts cyanide have to mo nitor for cyanide immediately following cyanide

pretreatment?

A3. The CWT rule requires a facility that accepts w astes 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 standa rd) does not fall below the analytical

minimum level.Q UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 7 Q4. What if a wastewater matrix causes interference with the analytical method (and therefore
the detection limit is higher than the discharge limit)?

A4. T he proc edures outlined in EPA’s Guidance on Evaluation, Resolution, and Documentation

of Analytical Problems Associate d 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 b e used to

establish discharge requirements for facilities subject to more than one CWT subcategory.

The facility must comply with each app l icable 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 subcateg ories 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

s tandards may use the model technology or any technology they can demonst rate 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 trea tment, but gives CWT facilities the latitude toQ UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 8 determine the appropriate manner in whic h 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 per

mit 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

p ermit 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 of this intent and also state,

in their BMR submission, whether it 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 after the 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 it s 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 monitor for the regulated pollutants when developing a relationship

for surrogate parameters used to demonstrate that a treatment system is well -operated and

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 par ameter to demonstrate that a treatment system is wellQ UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 9 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 operating procedures that could negative ly affect the demonstrated removals.

For example, if a facility has demonstrated 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 s ubmit 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 p aperwork, 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. H ow is confidential business information (CBI) that is included as part of compli ance 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 in place to protect CBI from unauthorized public 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?Q UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

10 - 10 A1. Ther

e 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 a dequately 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 sy stem 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 Use r 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 d epend 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 forany Industrial User that demonstrates that flowproportional sampling is infeasible. In such cases, samples may be obtained through timeproportional composite sampling techniques or through a m inimum of four(4) grab
samples where the User demonstrates that this will provide a representative sample of theQ UESTIONS AND A NSWERS CWT S MALL E NTITY C OMPLIANCE G UIDE

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 sys tem to meet the required

pretreatment standards by the required date of compliance. How can we get an extension?

A1. Many CWT facilities with Federal RC RA permits are under the impression that if they
modify t heir 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 p ermit modification requirements for wastewater

treatment units that are subject to NPDES or pretreatment requirements established under

the CWA. Thus, CWT facilities with RCRA permits will not need to modify their RCRA
permits as a result of this rule.

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## C HAPTER 

## 11



# W HERE TO 

# G ET 

# A DDITIONAL 

# H ELP



# 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 and standards for new and existing 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 the Technical Development Document (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), and the Envir onmental 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 Ce nter 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) 260-7185W HERE TO G ET A DDITIONAL H ELP CWT S MALL E NTITY C OMPLIANCE G UIDE

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.W HERE TO G ET A DDITIONAL H ELP CWT S MALL E NTITY C OMPLIANCE G UIDE

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



## A PPENDIX 

## A



# F INAL 

# E FFLUENT 

# L IMITATIONS AND 

# S TANDARDS FOR

THE 

# CWT I NDUSTRY



# T his appendix presen

t s the final effluent limitations and standards for the CWT industry. 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 standar ds 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

C ONVENTIONAL P

ARAMETERS *

BOD 5 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

M ETAL A NALYTES 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

O RGANIC A NALYTES

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

C ONVENTIONAL P

ARAMETERS *

BOD 5 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

M ETAL A NALYTES 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

O RGANIC A NALYTES

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

C ONVENTIONAL P

ARAMETERS *

BOD 5 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

M ETAL A NALYTES 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

O RGANIC A NALYTES

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

C ONVENTIONALS P

ARAMETERS *

BOD 5 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

M ETAL A NALYTES 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

O RGANIC A NALYTES

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

M ETAL A NALYTES 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

O RGANIC A NALYTES 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 0.106Appendix 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

M ETAL A NALYTES 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

O RGANIC A NALYTES 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 0.106Appendix 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

M ETAL A NALYTES
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

O RGANIC A NALYTES 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 0.106Appendix 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

M ETAL A NALYTES
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

O RGANIC A NALYTES 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