Pretreatment Review of TPDES Permit Applications How to

Pretreatment Review of TPDES Permit Applications & How to Identify Industrial Users Jessica Alcoser May 14, 2019 Water Quality Division Texas Commission on Environmental Quality

Introduction All publicly owned treatment works (POTWs) that discharge to a waterbody of Texas, must apply for a Texas Pollutant Discharge Elimination System (TPDES) permit. The application to discharge wastewater goes through a series of administrative and technical reviews before a permit is written and issued.

TPDES Permitting Process Application Received by TCEQ Draft Permit Sent for Comments Administrative Review Pretreatment Review Technical Review Standards and Assessment Review

Pretreatment Review – Domestic Worksheet 6. 0 ØAll POTWs must complete Worksheet 6. 0 as part of their TPDES permit application ØInclude Significant Industrial Users (SIUs), Categorical Industrial Users (CIUs), and other IUs discharging to the POTW ØBased on total number, average process flow, and other information

Pretreatment Review – Worksheet 6. 0 Section 1. A: Use results from water billing records or IU surveys CIUs, SIUs, or Other IUs: Enter “ 0” or “None” if none are discharging. Do not enter “N/A” Any issues in the sanitary sewer system or WWTP? Include dates, duration, description of issue, and sources

Pretreatment Review – Worksheet 6. 0 Section 3: Include required information for all SIUs and CIUs B. Process Information: Provide as much detail as possible

Pretreatment Review – Worksheet 6. 0 Section 3, Items C-E: Describe the product, provide flows, and applicable pretreatment standards Section 3: Industrial Interruptions Describe any problems caused by IUs, i. e. interference or pass through

TPDES Permit Pretreatment Options

TPDES Pretreatment Permit Language Option 1 POTWs not required to have an approved pretreatment program Option 2 POTWs are required to conduct an industrial user survey (IUS) and may be required to develop a pretreatment program

TPDES Pretreatment Permit Conditions Option 1 • No approved pretreatment program • No development of a pretreatment program • No formal IUs Permit Language Requirements • General and Specific Prohibitions • 40 CFR § 403. 5 • POTW notification requirements • New introduction of pollutants • Substantial changes in volume or character of pollutants • Require any indirect discharger to: • Comply with the reporting requirements of Sections 204(b), 307, and 308 of the Clean Water Act

TPDES Pretreatment Permit Language POTWs that are (or may) be required to develop a pretreatment program Submit an IUS Option 2 Activity No. 1 Due within 60 days of issued permit Based on results, TCEQ will determine if program development is required or not

TPDES Pretreatment Permit Language Option 3 Option 4 POTWs within an approved pretreatment program SIUs are discharging to the specific WWTP No SIUs are discharging to the specific WWTP

TPDES Pretreatment Permit Language – Options 3 & 4 WWTPs: Option 3 • Have an approved TPDES pretreatment program • 40 CFR Part 403 requirements • Technically based local limits (TBLLs) • Annual Report • Notification Requirements Option 4 • Covered under approved TPDES pretreatment program • No SIUs in the service area of the plant • WWTP Influent/effluent sampling not required • Notification requirements still apply

Industrial Users Identification and Survey

How to Identify Industrial Users Water billing records POTW treatment plant operators Applications for sewer service Industrial Users POTW collection system personnel Building permits Property tax records

How to Identify Industrial Users (cont. ) ØBusiness and telephone directories Texas Manufacturer’s Directory ØChamber of Commerce records ØEconomic Development organizations ØDirect observation (drive-by) ØInternet searches Toxic Release Inventory (TRI) www. epa. gov/TRI/ EPA Envirofacts www. epa. gov/enviro/

Facility Types – Commonly Missed ØSmall metal plating facilities Metal Finishing (40 CFR Part 433) ØTruck washing facilities Transportation & Equipment Cleaning (40 CFR Part 442) ØGrease & Grit Processing facilities Centralized Waste Treatment (40 CFR Part 437) ØFacilities with no categorical pretreatment standards Hospitals (40 CFR Part 460) Meat and Poultry Products (40 CFR Part 432) Plastic Molding and Forming (40 CFR Part 463) And several others

Industrial User or Waste Survey COMPILE MASTER LIST OF POTENTIAL IUs IN SERVICE AREA – CONSIDER… ØIUs with high water usage ØIUs that might impact the POTW ØStandard Industrial Classification (SIC) code ØNorth America Industrial Classification System (NAICS) code ØCompare SIC or NAICS codes to categories: 40 CFR Parts 405 -471

Industrial User Survey (cont. ) ØSurvey each IU to collect information ØConduct follow-up inspections ØConduct follow-up telephone calls ØSummarize data ØMaintain and update IU list

How to Identify HW Generators in Your Area http: //www. epa. gov/enviro/facts/rcrainfo/search. html 1. Select Geography Search and enter information for: “Zip Code” or “City, ” “County, ” and “State. ” Use 5 -digit Zip Code Use state abbreviation (AR, LA, OK, NM, or TX)

HW Generator Search 1. Select Search Value to use RCRAInfo only. 2. Select Search Box to generate the report.

How to Identify TRI Transfers to POTWs Use TRI Transfers to POTW Tool

TRI Waste Transfers to POTWs https: //iaspub. epa. gov/triexplorer/tri_transfer. chemical 1. Select “Waste Transfer Reports” then “Facility” tabs. 2. Click on Geographic Location and then select ZIP Code or State or a County in the pop-up menu that will appear. 4. Click Generate Report tab to create list. 3. Only select the 2 “Transfers to POTWs…” Click on each box to select or deselect. Note that Total Transfers Off-site for further Waste Management remains selected.

Who reports TRI Waste Transfers to POTWs? This particular facility transferred 30, 804 pounds of NITRATE COMPOUNDS to a POTW in 2015. Click on the Name of the Facility. Then click on TRI Reporting Forms link. Scroll down to Section 6 to find out which POTW. This Waste Transfer Facility Report shows the list of facilities in Travis County, TX that transferred wastes to a POTW in 2015

QUESTIONS? Pretreatment Team (512) 239 -4671 WQPRET@tceq. Texas. gov