Pretreatment Streamlining Rule Overview of Changes to the Federal Pretreatment Regulations.

Pretreatment Streamlining RulePretreatment Streamlining Rule

Overview of Changes to the Federal Overview of Changes to the Federal Pretreatment RegulationsPretreatment Regulations

22

Objectives of BriefingObjectives of Briefing Provide history and background of the RuleProvide history and background of the Rule

Review all changes adopted in the final rule Review all changes adopted in the final rule

33

History of Streamlining RuleHistory of Streamlining Rule 1995 – Office of Wastewater Management (OWM) initiates evaluation 1995 – Office of Wastewater Management (OWM) initiates evaluation

streamlining opportunities in Part 403 regulationsstreamlining opportunities in Part 403 regulations

May 1996 – OWM circulates issue papers to stakeholders for feedbackMay 1996 – OWM circulates issue papers to stakeholders for feedback

September 1996 – Association of Metropolitan Sewerage Agencies September 1996 – Association of Metropolitan Sewerage Agencies (AMSA)/Water Environment Federation (WEF) present report (AMSA)/Water Environment Federation (WEF) present report summarizing multi-stakeholder experts workshopssummarizing multi-stakeholder experts workshops

July 1999 – Environmental Protection Agency (EPA) proposes Streamlining July 1999 – Environmental Protection Agency (EPA) proposes Streamlining RuleRule

August 2003 – Streamlining Workgroup reconstitutedAugust 2003 – Streamlining Workgroup reconstituted

March 2005 – Office of Management and Budget’s (OMB) Thompson March 2005 – Office of Management and Budget’s (OMB) Thompson Report publishedReport published

June 2005 – EPA formally submits final rule to OMBJune 2005 – EPA formally submits final rule to OMB

September 26, 2005 – Administrator Johnson signs final ruleSeptember 26, 2005 – Administrator Johnson signs final rule

October 14, 2005 – Final Streamlining Rule Published in the Federal October 14, 2005 – Final Streamlining Rule Published in the Federal RegisterRegister

44

Key StakeholdersKey Stakeholders National Association of Clean Water Agencies, Water National Association of Clean Water Agencies, Water

Environment Federation and Other POTWsEnvironment Federation and Other POTWs

Industrial UsersIndustrial Users Metal FinishersMetal Finishers Synthetic Organic Chemical Manufacturers Synthetic Organic Chemical Manufacturers

Assoc. (SOCMA)Assoc. (SOCMA) Food IndustryFood Industry Auto/Shipbuilding/Leather TanningAuto/Shipbuilding/Leather Tanning Small Business AdministrationSmall Business Administration

Approval Authorities (Regions/States)Approval Authorities (Regions/States)

Natural Resources Defense CouncilNatural Resources Defense Council

55

Glossary of PT TermsGlossary of PT Terms PretreatmentPretreatment-the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of -the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of

the nature of pollutant properties in wastewater prior to or in lieu of discharging into a POTW.the nature of pollutant properties in wastewater prior to or in lieu of discharging into a POTW. POTWPOTW-Publicly Owned Treatment Works, includes any devices and systems used in the storage, -Publicly Owned Treatment Works, includes any devices and systems used in the storage,

treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature.treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature. Approval Authority Approval Authority – the Director in an NPDES State with an Approved Program and the appropriate – the Director in an NPDES State with an Approved Program and the appropriate

Regional Administrator in a non-NPDES State or NPDES State without an approved State pretreatment Regional Administrator in a non-NPDES State or NPDES State without an approved State pretreatment program.program.

Control Authority-Control Authority- The POTW, if there is an approved pretreatment program or the Approval Authority The POTW, if there is an approved pretreatment program or the Approval Authority if there is not an approved pretreatment program. Also referred to as a CA.if there is not an approved pretreatment program. Also referred to as a CA.

BMPBMP-Best Management Practices-Best Management Practices SIUSIU- All industrial users subject to Categorical Pretreatment Standards, and any other industrial user that - All industrial users subject to Categorical Pretreatment Standards, and any other industrial user that

discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, non-contact cooling, and boiler blow-down wastewater); contributes a process wastestream which sanitary, non-contact cooling, and boiler blow-down wastewater); contributes a process wastestream which makes up to 5% or more of the average dry weather hydraulic or organic capacity of the POTW treatment makes up to 5% or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant, or is designated as such by the Control Authority on the basis the industrial user has the reasonable plant, or is designated as such by the Control Authority on the basis the industrial user has the reasonable potential for adversely affecting the POTW’s operation or for violating any pretreatment standard.potential for adversely affecting the POTW’s operation or for violating any pretreatment standard.

CIUCIU- Categorical Industrial User- All industrial users subject to Categorical Pretreatment Standards- Categorical Industrial User- All industrial users subject to Categorical Pretreatment Standards Pass-ThroughPass-Through- a discharge that exits the POTW into the waters of the United States in quantities or - a discharge that exits the POTW into the waters of the United States in quantities or

concentrations which, alone or inconjunction with a discharge or discharges from other sources, is a cause concentrations which, alone or inconjunction with a discharge or discharges from other sources, is a cause of a violation of any requirement of the POTW’s NPDES permit.of a violation of any requirement of the POTW’s NPDES permit.

InterferenceInterference- a discharge which, alone or in conjunction with a discharge or discharges from other sources, - a discharge which, alone or in conjunction with a discharge or discharges from other sources, both inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or both inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal.disposal.

66

Glossary of PT Terms (cont’d)Glossary of PT Terms (cont’d) SNC SNC – Significant Non-Compliance-An Industrial User is in SNC, if one or more of the following occur:– Significant Non-Compliance-An Industrial User is in SNC, if one or more of the following occur:

a.) Chronic violations of wastewater discharge limits, defined here as those in which 66% or more of the a.) Chronic violations of wastewater discharge limits, defined here as those in which 66% or more of the measurements taken within a six month period exceed (by any magnitude) the daily maximum limit or the measurements taken within a six month period exceed (by any magnitude) the daily maximum limit or the average limit for the same pollutantaverage limit for the same pollutant

b.) Technical Review Criteria (TRC) violations, defined here as those in which 33% or more of all of the b.) Technical Review Criteria (TRC) violations, defined here as those in which 33% or more of all of the measurements for each pollutant parameter taken during a six-month period equal or exceed the product of measurements for each pollutant parameter taken during a six-month period equal or exceed the product of the daily maximum limit or the average limit multiplied by the applicable TRC (TRC=1.4 for BOD, TSS, & the daily maximum limit or the average limit multiplied by the applicable TRC (TRC=1.4 for BOD, TSS, & O+G, and 1.2 for all other pollutants except pH.)O+G, and 1.2 for all other pollutants except pH.)

c.) Any other violation of a pretreatment effluent limit (daily maximum or longer-term average) that the c.) Any other violation of a pretreatment effluent limit (daily maximum or longer-term average) that the Control Authority determines has caused, alone or in combination with other discharges, interference or Control Authority determines has caused, alone or in combination with other discharges, interference or pass-through.pass-through.

d.) Any discharge of a pollutant that has caused imminent endangerment to human health, welfare, or to the d.) Any discharge of a pollutant that has caused imminent endangerment to human health, welfare, or to the environment.environment.

e.) Failure to meet within 90 days of after the schedule date, a compliance schedule milestone contained in a e.) Failure to meet within 90 days of after the schedule date, a compliance schedule milestone contained in a local control mechanism or enforcement order for starting construction, completing construction, or local control mechanism or enforcement order for starting construction, completing construction, or attaining final compliance.attaining final compliance.

f.) Failure to provide, with in 45 days after the due date, required reports such as baseline monitoring f.) Failure to provide, with in 45 days after the due date, required reports such as baseline monitoring reports, 90 day compliance reports, and reports on compliance with compliance schedules.reports, 90 day compliance reports, and reports on compliance with compliance schedules.

g.) Failure to accurately report noncompliance g.) Failure to accurately report noncompliance

h.) Any other violation or group of violations which the Control Authority determines will adversely affect h.) Any other violation or group of violations which the Control Authority determines will adversely affect the operation or implementation of the local pretreatment program.the operation or implementation of the local pretreatment program.

Control Mechanism-permit issued to SIU/CIU by CA if approved pretreatment program or by AA if not.Control Mechanism-permit issued to SIU/CIU by CA if approved pretreatment program or by AA if not.

77

Summary of Final Rule ChangesSummary of Final Rule ChangesIssueIssue Rule ChangeRule Change

Pollutants not presentPollutants not present CAs can grant sampling waivers where CIU demonstrates that a CAs can grant sampling waivers where CIU demonstrates that a regulated pollutant is neither present nor expected to be presentregulated pollutant is neither present nor expected to be present

General control General control mechanismsmechanisms

CAs may issue general control mechanisms to groups of SIUs that CAs may issue general control mechanisms to groups of SIUs that are substantially similarare substantially similar

BMPs as local limitsBMPs as local limits BMPs may be used in lieu of numeric local limitsBMPs may be used in lieu of numeric local limits

Slug control plansSlug control plans 1)1) POTWs may determine how often they evaluate SIUs for the POTWs may determine how often they evaluate SIUs for the need for slug control plans or other requirementsneed for slug control plans or other requirements

2)2) Any requirements must be reflected in control mechanism or Any requirements must be reflected in control mechanism or permit.permit.

Equivalent Conc. Equivalent Conc. LimitsLimits

CAs can use existing concentration-based standards instead of CAs can use existing concentration-based standards instead of converting to flow-based mass limits for CIUs in Organic converting to flow-based mass limits for CIUs in Organic Chemical, Plastics, and Synthetic Fibers, Petroleum Refining, and Chemical, Plastics, and Synthetic Fibers, Petroleum Refining, and Pesticide ChemicalsPesticide Chemicals

Grab and Composite Grab and Composite SamplingSampling

Clarifies and updates application of sampling requirements; Clarifies and updates application of sampling requirements; Provides flexibility to CA in certain sampling protocolsProvides flexibility to CA in certain sampling protocols

SNC – PublicationSNC – Publication POTW can publish SNC violations in any paper of general POTW can publish SNC violations in any paper of general circulationcirculation

88

Summary of Final Rule Changes (cont’d)Summary of Final Rule Changes (cont’d)IssueIssue Rule ChangeRule Change

SNC – ApplicabilitySNC – Applicability SNC criteria apply only to SIUs and to those IUs that have SNC criteria apply only to SIUs and to those IUs that have adversely affected pretreatment programadversely affected pretreatment program

SNC – Daily Max. or SNC – Daily Max. or Avge. LimitsAvge. Limits

Broadens scope of violations covered by chronic, TRC, and Broadens scope of violations covered by chronic, TRC, and other violationsother violations

SNC – Late ReportsSNC – Late Reports SNC violation occurs when reports submitted more than 45 SNC violation occurs when reports submitted more than 45 days after deadlinedays after deadline

SNC – TRC, Rolling SNC – TRC, Rolling Quarters, pHQuarters, pH

No changes made to current rulesNo changes made to current rules

Removal Credits - Removal Credits - OverflowsOverflows

Retains and updates current formula to adjust removal credits Retains and updates current formula to adjust removal credits by number of hours of sewer overflows per yearby number of hours of sewer overflows per year

Removal Credits – Removal Credits – Sewage SludgeSewage Sludge

Advanced Notice of Proposed Rulemaking (ANPRM) asks for Advanced Notice of Proposed Rulemaking (ANPRM) asks for comment on adding pollutants to list of chemicals eligible for comment on adding pollutants to list of chemicals eligible for removal credits, and on potential ways to streamline consistent removal credits, and on potential ways to streamline consistent removal requirementsremoval requirements

Miscellaneous ChangesMiscellaneous Changes Updates or corrects provisions re: to signatory requirements, Updates or corrects provisions re: to signatory requirements, net/gross calculations, requirement to report all monitoring net/gross calculations, requirement to report all monitoring data, and notification of changesdata, and notification of changes

99

Summary of Final Rule Changes (cont’d)Summary of Final Rule Changes (cont’d)IssueIssue Rule ChangeRule Change

Equivalent Mass LimitsEquivalent Mass Limits CIUs can request, and Control Authorities have discretion to CIUs can request, and Control Authorities have discretion to approve, the conversion of concentration-based categorical approve, the conversion of concentration-based categorical standards to equivalent mass limitsstandards to equivalent mass limits

CIU OversightCIU Oversight 1)1) Establishes Non-Significant CIU (NSCIU) category Establishes Non-Significant CIU (NSCIU) category (discharges < 100 gpd)(discharges < 100 gpd)

CIU reporting can be reduced to yearly compliance CIU reporting can be reduced to yearly compliance certificationcertification

CA oversight can be reduced to annual evaluation of the CA oversight can be reduced to annual evaluation of the CIU’s certificationCIU’s certification

2)2) Establishes “Middle Tier” CIU category (discharges don’t Establishes “Middle Tier” CIU category (discharges don’t exceed (a) the smaller of 5,000 gpd or 0.01 % of POTW exceed (a) the smaller of 5,000 gpd or 0.01 % of POTW design dry weather hydraulic capacity; (b) 0.01 % of POTW design dry weather hydraulic capacity; (b) 0.01 % of POTW design organic treatment capacity; and (c) 0.01 % of the design organic treatment capacity; and (c) 0.01 % of the Maximum Allowable Headworks LoadingsMaximum Allowable Headworks Loadings

CIU reporting can be reduced to once annuallyCIU reporting can be reduced to once annually CA oversight can be reduced to one inspection and sampling CA oversight can be reduced to one inspection and sampling

event every other yearevent every other year

1010

Pollutants Not PresentPollutants Not PresentCurrent RulesCurrent Rules

CIUs must sample for all pollutants covered by the categorical standard, CIUs must sample for all pollutants covered by the categorical standard, regardless of whether pollutant is present (unless the categorical standard regardless of whether pollutant is present (unless the categorical standard allows for surrogate pollutant sampling or alternative certifications)allows for surrogate pollutant sampling or alternative certifications)

Proposed RuleProposed Rule

If CIU can demonstrate a pollutant is not present in its process waste If CIU can demonstrate a pollutant is not present in its process waste stream or is present only in background levels in intake water, the CA stream or is present only in background levels in intake water, the CA may authorize a sampling waiver for that pollutantmay authorize a sampling waiver for that pollutant Must still comply with categorical standards Must still comply with categorical standards OCPSF (Organic Chemicals, Plastics, and Synthetic Fibers) facilities OCPSF (Organic Chemicals, Plastics, and Synthetic Fibers) facilities

not eligiblenot eligible

1111

Pollutants Not PresentPollutants Not PresentFinal RuleFinal Rule

Adopted proposed rule, with the following modifications:Adopted proposed rule, with the following modifications:

OCPSF facilities are eligible for waiverOCPSF facilities are eligible for waiver

At least one representative process wastewater sample must be taken prior to At least one representative process wastewater sample must be taken prior to treatmenttreatment

CIU must notify CA if pollutant found, and must immediately resume CIU must notify CA if pollutant found, and must immediately resume monitoringmonitoring

CA must:CA must: include waiver and notification requirement in control mechanism, include waiver and notification requirement in control mechanism, document reasons for granting waiver and maintain information for 3 years after document reasons for granting waiver and maintain information for 3 years after

control mechanism expirescontrol mechanism expires

Waiver valid for one term of control mechanism (like NPDES provision)Waiver valid for one term of control mechanism (like NPDES provision)

Waiver Waiver does notdoes not replace any certification requirements established in specific replace any certification requirements established in specific categorical standardscategorical standards

Waiver may be granted where pollutant present solely due to sanitary Waiver may be granted where pollutant present solely due to sanitary wastewater except if covered by categorical standardwastewater except if covered by categorical standard

1212

Pollutants Not PresentPollutants Not PresentWhere to find rule changes?Where to find rule changes?

40 CFR 403.8(f)(2)(v)40 CFR 403.8(f)(2)(v) 40 CFR 403.12(e)(2)40 CFR 403.12(e)(2)

1313

General Control MechanismsGeneral Control MechanismsCurrent RulesCurrent Rules

SIUs must be controlled through permits or equivalent SIUs must be controlled through permits or equivalent mechanisms mechanisms

EPA has emphasized the importance of evaluating each SIU EPA has emphasized the importance of evaluating each SIU individually individually


Allow POTWs to control SIUs through general permits where Allow POTWs to control SIUs through general permits where the necessary legal authority exists and the SIUs meet the the necessary legal authority exists and the SIUs meet the criteria for being substantially similarcriteria for being substantially similar SIU must file a Notice of Intent or similar application deviceSIU must file a Notice of Intent or similar application device Coverage by general control mechanism doesn’t relieve SIU of Coverage by general control mechanism doesn’t relieve SIU of

reporting requirementsreporting requirements Coverage not allowed for SIUs subject to mass limitsCoverage not allowed for SIUs subject to mass limits CA may choose to make coverage optional or requiredCA may choose to make coverage optional or required

1414

General Control MechanismsGeneral Control MechanismsFinal RuleFinal Rule

Adopted proposed rule, with the following modifications:Adopted proposed rule, with the following modifications: Coverage available for CIUs granted a monitoring waiver for Coverage available for CIUs granted a monitoring waiver for

pollutants not presentpollutants not present

POTW must maintain the following for 3 years after expiration of POTW must maintain the following for 3 years after expiration of general control mechanism:general control mechanism: Copy of the general control mechanismCopy of the general control mechanism Documentation to support POTW’s determination that the group Documentation to support POTW’s determination that the group

of SIUs meets the criteria for coverageof SIUs meets the criteria for coverage Copies of all written requests for coverageCopies of all written requests for coverage

Still exempts SIUs subject to mass limits, but allows coverage for Still exempts SIUs subject to mass limits, but allows coverage for facilities subject to the same mass-based local limitsfacilities subject to the same mass-based local limits

1515

General Control MechanismsGeneral Control Mechanisms

Where to find rule changes?Where to find rule changes?

40 CFR 403.8(f)(1)(iii)40 CFR 403.8(f)(1)(iii)

1616

BMPs as Local LimitsBMPs as Local LimitsCurrent RulesCurrent Rules

Pretreatment rules are silent on whether POTWs can use Pretreatment rules are silent on whether POTWs can use BMPs (rather than numeric limits) to satisfy their requirement BMPs (rather than numeric limits) to satisfy their requirement to develop local limitsto develop local limits

Pretreatment rules Pretreatment rules do notdo not explicitly require reporting explicitly require reporting compliance data for Industrial Users subject to BMPs as local compliance data for Industrial Users subject to BMPs as local limits or categorical standardslimits or categorical standards


Clarify that:Clarify that: BMPs developed by POTWs may serve as local limits, andBMPs developed by POTWs may serve as local limits, and Full CIU reporting required where BMPs required for categorical Full CIU reporting required where BMPs required for categorical

standardsstandards

1717

BMPs as Local LimitsBMPs as Local LimitsFinal RuleFinal Rule Adopted proposed rule, with the following Adopted proposed rule, with the following

modifications:modifications: Specify the necessity for POTWs to document the supporting Specify the necessity for POTWs to document the supporting

rationale for specific BMPsrationale for specific BMPs

Include definition of BMPsInclude definition of BMPs

Clarify in the preamble what EPA considers to be minimum Clarify in the preamble what EPA considers to be minimum elements that make BMPs enforceableelements that make BMPs enforceable

Specific notice to IUs of requirementsSpecific notice to IUs of requirements Equipment specificationsEquipment specifications O&M requirementsO&M requirements Timeframes for key activitiesTimeframes for key activities Compliance certification, reporting and recordkeepingCompliance certification, reporting and recordkeeping Re-opener for revoking or modifyingRe-opener for revoking or modifying

1818

BMPs as Local LimitsBMPs as Local Limits


40 CFR 403.540 CFR 403.5 40 CFR 403.8(f)40 CFR 403.8(f) 40 CFR 403.12(b), (e), (h)40 CFR 403.12(b), (e), (h)

1919

Slug Control PlansSlug Control PlansCurrent RulesCurrent Rules

Slug discharges are prohibited Slug discharges are prohibited POTWs must evaluate, at least once every two years, POTWs must evaluate, at least once every two years,

whether each SIU needs a plan to control slug dischargeswhether each SIU needs a plan to control slug discharges EPA has historically emphasized that a plan is not requiredEPA has historically emphasized that a plan is not required


Provide POTWs the flexibility to review the need for a slug Provide POTWs the flexibility to review the need for a slug control plan or other action as necessary control plan or other action as necessary

Clarifies that plan is not required outcome of evaluationClarifies that plan is not required outcome of evaluation

Requirements must be included in control mechanismRequirements must be included in control mechanism

2020

Slug Control PlansSlug Control PlansFinal RuleFinal Rule

Adopted proposed rule, with the following modifications:Adopted proposed rule, with the following modifications: POTWs must evaluate need for a plan at least one time for each POTWs must evaluate need for a plan at least one time for each

SIU, by the following deadline:SIU, by the following deadline: Within 1 year of the effective date of the rule if the IU was identified as Within 1 year of the effective date of the rule if the IU was identified as

“significant” prior to rule’s effective date“significant” prior to rule’s effective date Within 1 year of being designated as “significant”, if the IU is designated as Within 1 year of being designated as “significant”, if the IU is designated as

“significant” after the rule’s effective date“significant” after the rule’s effective date

SIUs must immediately notify POTW of any changes at their SIUs must immediately notify POTW of any changes at their facilities, not already addressed in their slug control plan or other facilities, not already addressed in their slug control plan or other slug requirements, affecting slug discharge potentialslug requirements, affecting slug discharge potential

Clarify annual slug-related inspections should continue as per Clarify annual slug-related inspections should continue as per existing guidanceexisting guidance

2121

Slug Control PlansSlug Control Plans


40 CFR 403.8(f)(1)(iii)(B)(6)40 CFR 403.8(f)(1)(iii)(B)(6) 40 CFR 403.8(f)(2)(vi)40 CFR 403.8(f)(2)(vi)

2222

Equivalent Concentration LimitsEquivalent Concentration Limits

Current RulesCurrent Rules

No allowance for equivalent concentration limits No allowance for equivalent concentration limits where categorical standard requires a mass limit to where categorical standard requires a mass limit to be calculated based on the facility’s flowbe calculated based on the facility’s flow


For CIUs subject to OCPSF, Petroleum Refining (Cr For CIUs subject to OCPSF, Petroleum Refining (Cr an Zn), and Pesticide Chemicals allow POTW to use an Zn), and Pesticide Chemicals allow POTW to use concentration limit in categorical standard where concentration limit in categorical standard where flow from facility is so variable that use of mass flow from facility is so variable that use of mass limits is impracticallimits is impractical

2323

Equivalent Concentration LimitsEquivalent Concentration LimitsFinal RuleFinal Rule

Adopted proposed rule, with the following Adopted proposed rule, with the following modifications:modifications: Eliminate condition requiring variable flowsEliminate condition requiring variable flows

Require CA to document that dilution is not Require CA to document that dilution is not being substituted for treatment as prohibited by being substituted for treatment as prohibited by 40 CFR 403.6(d)40 CFR 403.6(d)


40 CFR 403.6(c)(6)40 CFR 403.6(c)(6)

2424

Use of Grab/Composite SamplesUse of Grab/Composite SamplesCurrent RulesCurrent Rules

Pretreatment regulations specify:Pretreatment regulations specify: Type of sampling method for baseline monitoring Type of sampling method for baseline monitoring

reports and 90-day compliance reports, but not reports and 90-day compliance reports, but not for periodic compliance reportsfor periodic compliance reports

Minimum of 4 grab samples for pH, cyanide, total Minimum of 4 grab samples for pH, cyanide, total phenols, oil & grease, sulfides, and volatile phenols, oil & grease, sulfides, and volatile organic compoundsorganic compounds

Composite samples must be flow-proportional Composite samples must be flow-proportional unless the Industrial User demonstrates that this unless the Industrial User demonstrates that this is “infeasible”is “infeasible”

2525

Use of Grab/Composite SamplesUse of Grab/Composite SamplesProposed RuleProposed Rule

Clarify when different types of sampling methods may be Clarify when different types of sampling methods may be used:used: Extend sampling requirements to periodic reportsExtend sampling requirements to periodic reports

Give POTWs flexibility to determine appropriate number of grab Give POTWs flexibility to determine appropriate number of grab samples to measure pH, CN, total phenols, oil and grease, sulfides samples to measure pH, CN, total phenols, oil and grease, sulfides and Volatile Organic Compounds (VOCs)and Volatile Organic Compounds (VOCs)

Clarify composite samples for CN and VOCs may be done prior to Clarify composite samples for CN and VOCs may be done prior to analysisanalysis

Remove requirement that flow-composite sampling must be Remove requirement that flow-composite sampling must be “infeasible” in order to allow time-composite sampling (sampling “infeasible” in order to allow time-composite sampling (sampling must be “representative”)must be “representative”)

2626

Use of Grab/Composite SamplesUse of Grab/Composite SamplesProposed RuleProposed Rule (cont’d) (cont’d)

Clarify when different types of sampling methods Clarify when different types of sampling methods may be used:may be used: Clarify that although “24-hour composite sample” must be taken Clarify that although “24-hour composite sample” must be taken

within a 24-hour period, this period only covers period during within a 24-hour period, this period only covers period during which IU is dischargingwhich IU is discharging

Final RuleFinal Rule

Adopted proposed rule, with minor editorial Adopted proposed rule, with minor editorial changeschanges


40 CFR 403.12(b), (d), (e), (g), (h)40 CFR 403.12(b), (d), (e), (g), (h)

2727

SNC - PublicationSNC - PublicationCurrent RuleCurrent Rule

Pretreatment regulations require SNC violations to be Pretreatment regulations require SNC violations to be published in largest daily newspaperpublished in largest daily newspaper


Allow publication in any paper of general circulation Allow publication in any paper of general circulation within the jurisdiction that provides meaningful public within the jurisdiction that provides meaningful public noticenotice


Adopted proposed ruleAdopted proposed rule


40 CFR 403.8(f)(2)(viii)40 CFR 403.8(f)(2)(viii)

2828

SNC – Application to SIUs OnlySNC – Application to SIUs OnlyCurrent RulesCurrent Rules

SNC can apply to any IUSNC can apply to any IU


Apply SNC to Significant Industrial Users onlyApply SNC to Significant Industrial Users only


Adopted proposed rule, with the following modifications:Adopted proposed rule, with the following modifications: Apply SNC to other IUs if they cause pass through, Apply SNC to other IUs if they cause pass through,

interference, imminent endangerment, or adversely affect interference, imminent endangerment, or adversely affect pretreatment programpretreatment program


40 CFR 403.8(f)(2)(viii)40 CFR 403.8(f)(2)(viii)

2929

SNC – Daily Maximum or Avg. LimitsSNC – Daily Maximum or Avg. LimitsCurrent RuleCurrent Rule

SNC determinations for chronic violations, technical review SNC determinations for chronic violations, technical review criteria violations, and pass through or interference criteria violations, and pass through or interference violations limited to daily maximum or average limitsviolations limited to daily maximum or average limits


Include broader array of numeric or narrative violationsInclude broader array of numeric or narrative violations


Adopted proposed ruleAdopted proposed rule


40 CFR 403.8(f)(2)(viii)(A), (B), (C)40 CFR 403.8(f)(2)(viii)(A), (B), (C)

3030

SNC – Late ReportsSNC – Late ReportsCurrent RuleCurrent Rule

SNC applies if a required report is submitted more than SNC applies if a required report is submitted more than 30 days late30 days late


No changes were proposed due to the wide variety of No changes were proposed due to the wide variety of suggestionssuggestions

EPA solicited comments on recommended approaches EPA solicited comments on recommended approaches


Extended 30-day deadline to 45 daysExtended 30-day deadline to 45 days


40 CFR 403.8(f)(2)(viii)(F)40 CFR 403.8(f)(2)(viii)(F)

3131

SNC – Technical Review CriteriaSNC – Technical Review CriteriaCurrent RulesCurrent Rules

TRC are numeric thresholds used to define a subcategory of SNC based TRC are numeric thresholds used to define a subcategory of SNC based on the magnitude of an effluent violationon the magnitude of an effluent violation

TRC violation occurs when 33 percent or more of all measurements TRC violation occurs when 33 percent or more of all measurements taken for the same pollutant during a 6-month period equal or exceed taken for the same pollutant during a 6-month period equal or exceed the product of the applicable limit multiplied by the TRCthe product of the applicable limit multiplied by the TRC


No changes proposed, but solicited comment on workable alternatives to No changes proposed, but solicited comment on workable alternatives to current TRC current TRC


Retained current TRC, with slight wording changesRetained current TRC, with slight wording changes

3232

pHpHCurrent RulesCurrent Rules

IUs prohibited from discharging at pH < 5.0 w/o exceptionIUs prohibited from discharging at pH < 5.0 w/o exception


Allow temporary excursions for discharges with pH < 5.0 to Allow temporary excursions for discharges with pH < 5.0 to POTWs provided POTW first conducts a technical evaluation POTWs provided POTW first conducts a technical evaluation to support lower pHto support lower pH


EPA did not take action due to insufficient data on relationship EPA did not take action due to insufficient data on relationship between pH and corrosionbetween pH and corrosion

Clarified current enforcement flexibilityClarified current enforcement flexibility

3333

Removal Credits - OverflowsRemoval Credits - OverflowsCurrent RuleCurrent Rule

POTWs may grant removal credit to a CIU which equals or is less POTWs may grant removal credit to a CIU which equals or is less than the consistent removal of the pollutant provided by the than the consistent removal of the pollutant provided by the treatment planttreatment plant

Where annual overflows occur, the amount of consistent removal Where annual overflows occur, the amount of consistent removal claimed by the POTW is reduced by a mathematic formula that claimed by the POTW is reduced by a mathematic formula that takes into account the number of hours of overflows in a yeartakes into account the number of hours of overflows in a year

As a condition of using this overflow formula, the POTW must be in As a condition of using this overflow formula, the POTW must be in compliance with certain guidance documents related to combined compliance with certain guidance documents related to combined sewer overflows, which are now obsoletesewer overflows, which are now obsolete


Delete the current overflow formulaDelete the current overflow formula CIUs that are upstream from overflows are ineligible for removal CIUs that are upstream from overflows are ineligible for removal

credits unless they can establish that their discharges are consistently credits unless they can establish that their discharges are consistently treatedtreated

3434

Removal Credits - OverflowsRemoval Credits - OverflowsFinal RuleFinal Rule

Retains current overflow formulaRetains current overflow formula Updates references to obsolete guidance, and replaced with Updates references to obsolete guidance, and replaced with

requirement for POTWs to be in compliance with all NPDES requirement for POTWs to be in compliance with all NPDES permit requirements and other requirements in any orders or permit requirements and other requirements in any orders or decrees issued pursuant to the decrees issued pursuant to the CSO Control PolicyCSO Control Policy

Makes one technical correction to a footnote in Appendix Makes one technical correction to a footnote in Appendix G, Table 1G, Table 1

THC or carbon monoxide concentrations can be used to represent THC or carbon monoxide concentrations can be used to represent organic compounds in exit gas from incineratorsorganic compounds in exit gas from incinerators


40 CFR 403.7(h)40 CFR 403.7(h)

3535

Removal Credits – Sewage SludgeRemoval Credits – Sewage SludgeCurrent RuleCurrent Rule

Removal credits can be granted to a CIU where:Removal credits can be granted to a CIU where: The POTW demonstrates its ability to “consistently remove” The POTW demonstrates its ability to “consistently remove”

the pollutant at issue, the pollutant at issue,

The Pollutant is among those listed in Appendix G, Table I or The Pollutant is among those listed in Appendix G, Table I or Table II,Table II, If the pollutant isn’t listed in Table I or Table II, it isn’t If the pollutant isn’t listed in Table I or Table II, it isn’t

eligible for removal creditseligible for removal credits

Potential additions to Appendix GPotential additions to Appendix G EPA has identified 15 pollutants for refined risk assessments EPA has identified 15 pollutants for refined risk assessments

will be conducted, which could result in part 503 amendmentswill be conducted, which could result in part 503 amendments

EPA has concluded that an additional 20 pollutants did not fail EPA has concluded that an additional 20 pollutants did not fail the Agency’s exposure and hazard screening process, and could the Agency’s exposure and hazard screening process, and could be considered for inclusion in the Appendix G, Table II list if be considered for inclusion in the Appendix G, Table II list if upper concentrations are developedupper concentrations are developed

3636

Removal Credits – Sewage SludgeRemoval Credits – Sewage SludgeProposed RuleProposed Rule No specific revisions to the Appendix G list or the No specific revisions to the Appendix G list or the

consistent removal provisions proposedconsistent removal provisions proposed

Public comments on the overflow provision indicated Public comments on the overflow provision indicated support changes to the removal credit provisions to make support changes to the removal credit provisions to make them available for a broader range of pollutantsthem available for a broader range of pollutants

Several public comments highlighted in the Office of Several public comments highlighted in the Office of Management & Budget’s 2004 Report to Congress on Management & Budget’s 2004 Report to Congress on costs and benefits of Federal regulations supported costs and benefits of Federal regulations supported revisions to the “consistent removal” provisions to more revisions to the “consistent removal” provisions to more accurately reflect total removal by POTWs accurately reflect total removal by POTWs

3737

Removal Credits – Sewage SludgeRemoval Credits – Sewage Sludge

Advance Notice of Proposed Rulemaking (ANPRM)Advance Notice of Proposed Rulemaking (ANPRM)

EPA requests comment on options to amend the EPA requests comment on options to amend the consistent removal provisions to simplify the consistent removal provisions to simplify the process for obtaining removal creditsprocess for obtaining removal credits

EPA requests comment on whether the addition EPA requests comment on whether the addition of the 20 pollutants to Appendix G, Table II of the 20 pollutants to Appendix G, Table II would be helpful to POTWs and IUswould be helpful to POTWs and IUs

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Miscellaneous ProvisionsMiscellaneous ProvisionsSignatory Requirements for IU and POTW ReportsSignatory Requirements for IU and POTW Reports (40 CFR (40 CFR

403.12(l) and (m))403.12(l) and (m)) Changes numeric criteria for designating an appropriate Changes numeric criteria for designating an appropriate

“responsible corporate officer” signer to more flexible “responsible corporate officer” signer to more flexible narrative criteria (same as adopted by NPDES rules)narrative criteria (same as adopted by NPDES rules)

Specifies general POTW or pretreatment personnel who Specifies general POTW or pretreatment personnel who can sign as a “duly authorized” employeecan sign as a “duly authorized” employee

Net / Gross CalculationsNet / Gross Calculations (40 CFR 403.15) (40 CFR 403.15)

Corrects unintended error in net/gross procedures which Corrects unintended error in net/gross procedures which appeared to make the test for using such procedures appeared to make the test for using such procedures more difficult to meet (mirrors the NPDES provision)more difficult to meet (mirrors the NPDES provision)

3939

Miscellaneous ProvisionsMiscellaneous ProvisionsRequirement to Report All Monitoring DataRequirement to Report All Monitoring Data (40 CFR (40 CFR

403.12(g)(6))403.12(g)(6)) Corrects omission from earlier addition of reporting Corrects omission from earlier addition of reporting

requirements (1990) for non-categorical SIUs to require requirements (1990) for non-categorical SIUs to require such Users to report all monitoring data [this is a such Users to report all monitoring data [this is a required change to approved pretreatment program]required change to approved pretreatment program]

Notification by IUs of Changed DischargeNotification by IUs of Changed Discharge (40 CFR 403.12(j)) (40 CFR 403.12(j)) Clarifies that when IU provides notification, notice must Clarifies that when IU provides notification, notice must

be given to the CA or to the AA where the POTW does be given to the CA or to the AA where the POTW does not have an approved pretreatment programnot have an approved pretreatment program

4040

Equivalent Mass LimitsEquivalent Mass LimitsCurrent RulesCurrent Rules

40 CFR 403.6(d) allows CA to impose equivalent mass limits 40 CFR 403.6(d) allows CA to impose equivalent mass limits in addition to concentration-based standards where the IU is in addition to concentration-based standards where the IU is using dilution to meet standards or where the imposition of using dilution to meet standards or where the imposition of mass limits is appropriatemass limits is appropriate

Current rules do not allow the equivalent mass limit to Current rules do not allow the equivalent mass limit to replace the concentration-based standardreplace the concentration-based standard

Some POTWs and CIUs argue that use of concentration-Some POTWs and CIUs argue that use of concentration-based standards discourages the adoption of water based standards discourages the adoption of water conservation measuresconservation measures

4141

Equivalent Mass LimitsEquivalent Mass LimitsProposed RuleProposed Rule

Allow POTW to set equivalent mass limits Allow POTW to set equivalent mass limits as an as an alternative toalternative to concentration limits where CIU has concentration limits where CIU has:: Installed treatment equivalent to model technology, Installed treatment equivalent to model technology, Is employing water conservationIs employing water conservation

POTW would need to determine an appropriate POTW would need to determine an appropriate flow from a CIU to set the alternative mass limitflow from a CIU to set the alternative mass limit Flow based upon a reasonable estimate of the flow Flow based upon a reasonable estimate of the flow

required to achieve the facility’s production goals using required to achieve the facility’s production goals using BAT and in the absence of water conservation technologyBAT and in the absence of water conservation technology

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Equivalent Mass LimitsEquivalent Mass LimitsFinal RuleFinal Rule - Adopt proposed rule, with following modifications: - Adopt proposed rule, with following modifications:

Emphasized that CIU may request equiv. mass limits, and CA has discretion to Emphasized that CIU may request equiv. mass limits, and CA has discretion to authorizeauthorize

To be eligible for use of equiv. mass limits, CIU must:To be eligible for use of equiv. mass limits, CIU must: Implement water conservation measures that substantially reduce water use,Implement water conservation measures that substantially reduce water use,

Use control and treatment technologies adequate to achieve compliance with Use control and treatment technologies adequate to achieve compliance with categorical standards, and demonstrate that dilution not used,categorical standards, and demonstrate that dilution not used,

Provide monitoring data to establish its actual average daily flow rate through Provide monitoring data to establish its actual average daily flow rate through the use of a continuous effluent flow monitoring device and its baseline long-the use of a continuous effluent flow monitoring device and its baseline long-term average production rate,term average production rate,

Demonstrate that it doesn’t have daily flow rates, production rates, or Demonstrate that it doesn’t have daily flow rates, production rates, or pollutant levels that fluctuate so significantly that establishing equiv. mass pollutant levels that fluctuate so significantly that establishing equiv. mass limits would not be appropriate, andlimits would not be appropriate, and

Have consistently complied with applicable categorical standardsHave consistently complied with applicable categorical standards

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Equivalent Mass LimitsEquivalent Mass LimitsFinal RuleFinal Rule (cont’d) (cont’d)

If CA approves eligible CIU’s request, CA then calculates the equiv. mass If CA approves eligible CIU’s request, CA then calculates the equiv. mass limits:limits: Concentration-based categorical standard × CIU’s actual average Concentration-based categorical standard × CIU’s actual average

daily flow rate × unit conversion factordaily flow rate × unit conversion factor

Once equiv. mass limit is effective in the CIU’s control mechanism, CIU Once equiv. mass limit is effective in the CIU’s control mechanism, CIU must do the following to retain coverage:must do the following to retain coverage:

Maintain and effectively operate control and treatment technologies Maintain and effectively operate control and treatment technologies adequate to achieve compliance with the equiv. mass limits,adequate to achieve compliance with the equiv. mass limits,

Record the facility’s flow rates through use of a continuous effluent Record the facility’s flow rates through use of a continuous effluent flow monitoring device,flow monitoring device,

Continue to record facility’s production rates and notify CA if rates Continue to record facility’s production rates and notify CA if rates vary by more than 20 percent from production rates used as basis for vary by more than 20 percent from production rates used as basis for equiv. mass limitsequiv. mass limits

Employ same or comparable water conservation measures used in Employ same or comparable water conservation measures used in setting the equiv. mass limitssetting the equiv. mass limits

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Equivalent Mass LimitsEquivalent Mass LimitsFinal RuleFinal Rule (cont’d) (cont’d)

After calculating equiv. mass limit, CA must reassess the limit and After calculating equiv. mass limit, CA must reassess the limit and recalculate as necessary to reflect changed conditions, where the CIU recalculate as necessary to reflect changed conditions, where the CIU notifies it of a revised production ratenotifies it of a revised production rate

CA may retain the initial equiv. mass limits in subsequent control CA may retain the initial equiv. mass limits in subsequent control mechanism terms if:mechanism terms if: CIU’s actual average daily flow rate reduced solely as a result of water CIU’s actual average daily flow rate reduced solely as a result of water

conservation methods and technologies,conservation methods and technologies,

Actual average daily flows used for calculating limit weren’t based on Actual average daily flows used for calculating limit weren’t based on use of dilution as substitute for treatment, anduse of dilution as substitute for treatment, and

CIU doesn’t bypass treatment control and treatment technologiesCIU doesn’t bypass treatment control and treatment technologies

Equiv. mass limits are not authorized for pollutants such as pH, Equiv. mass limits are not authorized for pollutants such as pH, temperature, radiation, or other pollutants which cannot be appropriately temperature, radiation, or other pollutants which cannot be appropriately expressed as massexpressed as mass

4545

Equivalent Mass LimitsEquivalent Mass Limits


40 CFR 403.6(c)(5)40 CFR 403.6(c)(5)

4646

Non-Significant CIUNon-Significant CIUCurrent RulesCurrent Rules

SIUs include all IUs subject to categorical pretreatment standardsSIUs include all IUs subject to categorical pretreatment standards POTW may exclude a non-categorical IU if demonstrates that it has POTW may exclude a non-categorical IU if demonstrates that it has

no reasonable potential to adversely affect the plant or violate a no reasonable potential to adversely affect the plant or violate a standardstandard

No flexibility currently to exclude categorical IUs from SIU statusNo flexibility currently to exclude categorical IUs from SIU status


Define Define non-significant CIU non-significant CIU (NSCIU) using 100 gpd flow cutoff(NSCIU) using 100 gpd flow cutoff Prohibited untreated, concentrated wastewater Prohibited untreated, concentrated wastewater

Requested comments on whether to allow averaging over 5-day Requested comments on whether to allow averaging over 5-day periodperiod

An NSCIU would be exempt from certain inspection and sampling An NSCIU would be exempt from certain inspection and sampling requirements, and POTW can set appropriate frequenciesrequirements, and POTW can set appropriate frequencies

4747

Non-Significant CIUNon-Significant CIUFinal RuleFinal Rule - - Adopted proposed rule, with modifications:Adopted proposed rule, with modifications:

Clarified that 100 gpd cutoff is measured accurately to the amount of Clarified that 100 gpd cutoff is measured accurately to the amount of “total categorical wastewater” as opposed to “total process wastewater”“total categorical wastewater” as opposed to “total process wastewater”

Where categorical and non-categorical wastewaters are commingled, Where categorical and non-categorical wastewaters are commingled,

measure categorical wastewaters to the extent they can be reliably measure categorical wastewaters to the extent they can be reliably distinguished from non-categorical wastewater)distinguished from non-categorical wastewater)

If categorical and non-categorical wastewaters can’t be reliably If categorical and non-categorical wastewaters can’t be reliably distinguished, measure the combined flowdistinguished, measure the combined flow

100 gpd is a daily maximum threshold, which cannot be met through 100 gpd is a daily maximum threshold, which cannot be met through averagingaveraging

4848

Non-Significant CIUNon-Significant CIU To be eligible, the CIU must:To be eligible, the CIU must:

Have consistently complied w/ all applicable standards and Have consistently complied w/ all applicable standards and requirementsrequirements

Annually submit certification statement indicating that it Annually submit certification statement indicating that it continues to meet the NSCIU definitional criteria and that it continues to meet the NSCIU definitional criteria and that it complied w/ applicable standards and requirementscomplied w/ applicable standards and requirements

Requires annual certification statement to be signed in Requires annual certification statement to be signed in accordance w/ 403.12 requirementsaccordance w/ 403.12 requirements

CA required to annually list out which CIUs are considered CA required to annually list out which CIUs are considered NSCIUsNSCIUs

CA required to annually evaluate whether each NSCIU has CA required to annually evaluate whether each NSCIU has submitted its certification statement and continues to meet the submitted its certification statement and continues to meet the definitional criteria definitional criteria

4949

Non-Significant CIUNon-Significant CIU

Where to find rule changes?Where to find rule changes? 40 CFR 403.3(v)(2)40 CFR 403.3(v)(2) 40 CFR 403.8(f)(2)(v), (6)40 CFR 403.8(f)(2)(v), (6) 40 CFR 403.12(e)(1), (g), (i),40 CFR 403.12(e)(1), (g), (i), (q)(q)

5050

Middle Tier CIUMiddle Tier CIUProposed RuleProposed Rule

In section discussing NSCIUs, EPA requested comment on “alternative In section discussing NSCIUs, EPA requested comment on “alternative criteria for determining non-significant status … [such as] the percentage criteria for determining non-significant status … [such as] the percentage of POTW’s total flow discharged by a particular CIU.”of POTW’s total flow discharged by a particular CIU.”

18 POTW commenters suggested adoption of 3-tier system for CIUs18 POTW commenters suggested adoption of 3-tier system for CIUs 11stst tier – categorical SIUs tier – categorical SIUs

22ndnd tier – non-significant CIUs: discharge less than a percentage of tier – non-significant CIUs: discharge less than a percentage of POTW’s design dry weather treatment capacity, design dry weather POTW’s design dry weather treatment capacity, design dry weather organic treatment capacity, and MAHL for any pollutant detected organic treatment capacity, and MAHL for any pollutant detected at headworks for which CIU is regulatedat headworks for which CIU is regulated

33rdrd tier – tier – de minimisde minimis CIUs: discharge less than 100 gpd CIUs: discharge less than 100 gpd

EPA approved Metropolitan Water Reclamation District of Greater EPA approved Metropolitan Water Reclamation District of Greater Chicago’s pilot project for the 3-tier system (no longer active)Chicago’s pilot project for the 3-tier system (no longer active)

5151

Middle Tier CIUMiddle Tier CIUFinal RuleFinal Rule

Adopts concept similar to 3-tier systemAdopts concept similar to 3-tier system 11stst tier – categorical CIUs tier – categorical CIUs

22ndnd tier – “Middle Tier” CIUs tier – “Middle Tier” CIUs

33rdrd tier – NSCIUs tier – NSCIUs

If designated “Middle Tier”:If designated “Middle Tier”: CIU can reduce reporting to one time per yearCIU can reduce reporting to one time per year

POTW can reduce inspections/samplings to one time every other yearPOTW can reduce inspections/samplings to one time every other year

““Middle Tier” CIUs discharge no greater than:Middle Tier” CIUs discharge no greater than: 0.01% of POTW’s design dry weather hydraulic capacity, or 5,000 gpd, 0.01% of POTW’s design dry weather hydraulic capacity, or 5,000 gpd,

whichever is smaller (measured by continuous effluent flow monitor unless whichever is smaller (measured by continuous effluent flow monitor unless CIU is batch discharger)CIU is batch discharger)

0.01% of POTW’s design dry weather treatment capacity0.01% of POTW’s design dry weather treatment capacity 0.01% of MAHL for any pollutant for which CIU regulated0.01% of MAHL for any pollutant for which CIU regulated

5252

Middle Tier CIUMiddle Tier CIUFinal RuleFinal Rule

Additional eligibility criteria:Additional eligibility criteria: CIU has not been in SNC for any time in past 2 yearsCIU has not been in SNC for any time in past 2 years

CIU does not have daily flow rates, production levels, or pollutant levels CIU does not have daily flow rates, production levels, or pollutant levels that vary significantly that reduced reporting would be non-representative that vary significantly that reduced reporting would be non-representative of operating conditionsof operating conditions

Middle Tier CIU must notify CA immediately of any changes that cause Middle Tier CIU must notify CA immediately of any changes that cause it to no longer meet eligibility conditionsit to no longer meet eligibility conditions

If CIU no longer meets Middle Tier criteria, it must immediately being If CIU no longer meets Middle Tier criteria, it must immediately being complying w/ minimum reporting requirements for categorical SIUscomplying w/ minimum reporting requirements for categorical SIUs

CA must retain documentation to support CA’s determination that CA must retain documentation to support CA’s determination that specific CIU qualifies as a Middle Tier CIU for 3 years after expiration specific CIU qualifies as a Middle Tier CIU for 3 years after expiration of control mechanismof control mechanism

5353

Middle Tier CIUMiddle Tier CIUWhere to find rule changes?Where to find rule changes?

40 CFR 403.8(f)(2)(v)(C)40 CFR 403.8(f)(2)(v)(C) 40 CFR 403.12(e)(3), (i)40 CFR 403.12(e)(3), (i)

5454

NSCIU v. Middle Tier CIUNSCIU v. Middle Tier CIU

Control Control Mechanism Mechanism Required?Required?

Minimum CIU Minimum CIU Reporting Reporting RequirementsRequirements

Minimum Minimum POTW POTW Inspection / Inspection / Sampling Sampling RequirementsRequirements

NSCIUsNSCIUs NoNo Certification only Certification only (no reporting), (no reporting), one time per yearone time per year

Not requiredNot required

Middle Tier CIUsMiddle Tier CIUs YesYes One time per year One time per year (if representative (if representative of operating of operating conditions)conditions)

One time every One time every other yearother year

Categorical SIUsCategorical SIUs YesYes Two times per Two times per year (at a year (at a minimum)minimum)

One time per One time per yearyear

5555

EPA Webpage to read Final RuleEPA Webpage to read Final Rule

http://cfpub.epa.gov/npdes/homehttp://cfpub.epa.gov/npdes/home

5656

Questions ??? Call Dan or me at Questions ??? Call Dan or me at 502-564-3410502-564-3410

Pretreatment Streamlining Rule Overview of Changes to the Federal Pretreatment Regulations.

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