Transcript INDUSTRIAL PRETREATMENT PROGRAM

State and Federal IPP
Regulations
Grace Scott
Pretreatment Coordinator
Water Bureau
517-335-4107
[email protected]
Disclaimer: The information provided in the following slides is an overview
only. The actual rules and regulations should be consulted for complete
requirements.
Wanted: Industrial Pretreatment
Coordinator
Chemist
Biologist
Engineer
Technician
Lawyer
Data Clerk
Public Relations Specialist
Regulator
Teacher
Inspector
Part 23 Michigan Rules vs
Federal 40 CFR Part 403
In 1983, Michigan received delegation from USEPA to
manage and enforce the Industrial Pretreatment
Program.
40 CFR Part 403 General Pretreatment Regulations
http://cfpub.epa.gov/npdes/home.cfm?program_id=3
R323.2303 of the Michigan Administrative Code
http://www.state.mi.us/orr/emi/admincode.asp?Admin
Code=Single&Admin_Num=32302301&Dpt=EQ&Rng
High=
INDUSTRIAL
PRETREATMENT PROGRAM
R323.2301 (403.2)
prevent discharge of
metals, solvents &
other pollutants
prevent POTW
interference/passthrough
prevent worker
health and safety
problems
enhance biosolids
character
Interference
You know it’s going to
be a bad day when:
(IPP) Prohibited Discharges
R323.2303 (403.5)
Fire or Explosion
(Flashpoint <140ºF)
Corrosive (pH<5)
Block Flow
Interference or Pass
through
Heat (<104ºF at WWTP)
Oil
Toxic Gases
Trucked Wastewater
(unless at designated
points)
(IPP) Local Limits
R323.2303(4)
Local limits are site specific and environmentally
protective of the local conditions
Evaluate Ten Pollutants (Minimum)
– Arsenic, Cadmium, Chromium, Copper, Lead,
Mercury, Nickel, Silver, Zinc and Cyanide
– Other Pollutants of Concern
Influent, Effluent & Biosolids
Sanitary (Background)
Other locations as appropriate
When is an IPP required?
R323.2305 (403.8)
If > 5MGD design and non-domestic users with
potential to cause pass through or interference or
categorical industrial user a Federal IPP
If <5MGD design and non-domestic users with
potential to cause pass through or interference or
categorical industrial user a Michigan IPP, unless
Federal IPP
If a state permit (groundwater) with non-domestic
users with potential to cause interference or permit
violations or categorical industrial user a Michigan
IPP
Programs must be developed within one year of
written notification
Legal Authority
R323.2306 (403.8)
The authority may be contained in:
– a statute
– ordinance
– series of contracts
– or interjurisdictional agreements
Require compliance with pretreatment standards and
requirements
Control through permit the contribution to the POTW
by each Significant Industrial User (SIU)
Require installation of technology to meet standards
and requirements, and self monitoring and reporting
Legal Authority (cont.)
Carry out all inspection, surveillance and monitoring
procedures necessary to determine compliance
independent of information supplied by nondomestic
users
Enforce and seek injunctive relief and penalties
Immediately halt (after informal notice) a discharge that
may endanger persons, the environment, or threatens to
interfere with the operation of the POTW
Comply with confidentiality requirements
All local units of government that collect wastewater from
nondomestic sources, shall be responsible for the
development and implementation of an IPP consistent
with the POTW’s program
Legal Authority (cont.)
Permits Requirements
Statement of Duration (not more than 5 yrs.)
Statement of nontransferability without prior notification
to the POTW and provision of a copy to the new owner
or operator
Effluent limits based upon applicable general
pretreatment standards, categorical pretreatment
standards, local limits, and state and local law.
Self monitoring, sampling, reporting, notification and
recordkeeping requirements
Pollutants to be monitored, sampling location, frequency,
and type
Criminal and Civil Penalties and any applicable
compliance schedule
Future streamlining addition: Slug Control Plan
Requirement and Notification of Changes which impact
spill/slug potential
Procedures
R323.2306 (403.8)
Identify and locate all possible nondomestic
users that might be subject to the POTW’s IPP
Identify the character and volume of pollutants
contributed to the POTW
Notify nondomestic users identified of applicable
pretreatment standards, 204(b) and 405 of the
CWA, and subtitles C&D of the Resource
Conservation and Recovery Act (except MIPPs
don’t have to notify users of RCRA)
Within 30 days of the approval of a list of
Significant Industrial Users, notify each SIU of its
status and all requirements as a result of its
status
Procedures (cont.)
Receive and analyze self-monitoring reports
Randomly sample and analyze the effluent from
nondomestic users.
Inspect and sample all SIUs at least once per
year.
Evaluate whether SIU needs a slug control plan
every two years (not required for MIPPs)
Investigate instances of non-compliance.
Procedures (cont.)
Sample taking and analysis and the collection of
other information shall be performed with
sufficient care to produce evidence admissible in
enforcement proceedings or in judicial actions
Annually public notice nondomestic users in
significant noncompliance (6 month rolling
quarter)
Develop an Enforcement Response Plan
Prepare and maintain a list of SIUs
Submittal and Approval Process
R323.2307 and R323.2308
(403.9 & 403.11)
Submissions for Approval
– Original Program
– Modifications
Modifications
R323.2309 (403.18)
Substantial Modifications
Non-Substantial Modifications
Reporting
R323.2310 (403.12)
Industrial User – Periodic Compliance
Reports
Sampling and Analysis in accordance with
40 CFR 136
POTW Annual Reporting
Certification statements and signatory
requirements
Categorical Standards and
Dilution Prohibition
R323.2311 (403.6)
New or Existing Source
Dilution Prohibition
Combined Wastestream Formula
Alternative Categorical Standards
R323.2313 (403.6, 403.7, 403.13, 403.15)
Removal Credits – When POTW agrees to treat
a categorical pollutant for the CIU
Fundamentally Different Factors – When a user
applies to be included or exempt from
categorical regulations. Claim must be applied
for within 180 days of regulation.
Net/Gross – When an allowance is granted for
pollutants in intake water
Equivalent Mass
Combined Wastestream Formula
Confidentiality
R323.2314 (403.14)
Trade Secrets may be
claimed as
confidential, if so
marked at the time of
submission.
Discharge information
shall be available to
the public without
restriction.
Upset
R323.2315 (403.16)
An upset is an affirmative defense for a
categorical pretreatment standard if:
– user can establish an upset occurred and can
identify the cause;
– the facility was operated in a prudent and
workmanlike manner and in compliance with
applicable O&M procedures; and,
– required information is submitted within 24
hours.
Bypass
R323.2316 (403.17)
A routine bypass for essential
maintenance that will not cause violations
does not require advance notice
If potential for violation – If planned, notice must be given 10 days in
advance.
– If unplanned, a user must notify within 24
hours of becoming aware, followed by a
wriitten report.
Categorical Regulations
R323.2317
(40 CFR 405-471)
40 CFR Subpart N – Parts 405-471 (adoption by
reference)
Some pretreatment standards only refer to 40
CFR 403 or do not have limits or requirements.
These IUs are not considered categorical
industrial users (e.g. Plastics Forming)
Pretreatments Standards for Existing Sources
(PSES)
Pretreatment Standards for New Sources
(PSNS)
No discharge requirement
Some are production based, others are
concentration based
Streamlining Requirements
Flow proportional sampling or documentation
that time proportional is representative
Slug Control Plan and notification of change in
Permit
Notification of violation and resampling
requirement when POTW monitors
Documentation and recordkeeping of BMPs
Submission of ALL monitoring data in periodic
compliance reports
Questions?