Al Garcia. CIPCA October 12, 2018

Transcription

1 Al Garcia CIPCA October 12, 2018

2 Final 2016 Effluent Limitation Guidelines Plan Published for Public Comment May 2, /pdf/ pdf

3 Final 2016 ELG Plan Petroleum Refining Industry Review Electrical and Electronic Components Manufacturing Continued Study of the CWT Facilities oil and gas Conventional Extraction - Oil and Gas Industry Produced Water Discharges in the Oil and Gas Industry (well treatment, workover fluids)

4 Final 2016 ELG Plan New Rulemaking Potentially Revise Requirements in the 2015 Steam Electric Rule PSES November 2018 Bottom Ash Transport Water and Flue Gas Desulfurization (FGD) wastewater

5 National Rulemaking Process and Local Program Input Local Program Implementation New Pretreatment Standards IUs in Service Area Existing SIUs

6 National Studies Oil and Gas, EEC, Petroleum Refining Local Program Interpretation New Pretreatment Standards IUs in Service Area Existing SIUs

7 Metal Finishing Study /documents/metal-finishing_prelimreview_april-2018.pdf Etching vs. Cleaning (use of citric acid, acetic acid, weak acids on metal) Ancillary Processes

8 Published on June 14, 2017 with correction June 26, 2017 and corrections, *sigh* - July 5, CFR Part 441 Effective Date July 14, 2017

9 New Source Date July 14, 2017 Applicability Provisions: Installation of an ISO compliant Amalgam Separator (or equivalent device) Compliance with 2 BMPs Line cleaners Waste amalgam must be treated

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11 Dental Facilities, including institutions, temporary offices, clinics, home offices and dental facilities owned by Federal, State or Local governments.

12 Oral pathology/radiology/surgery, orthodontics, periodontics, prosthodontics Mobile Units Dental dischargers that do not discharge amalgam process wastewater to the POTW Dentists that transfer waste to a CWT facility

13 Do not place or remove amalgam, except in limited emergency or unplanned, unanticipated circumstances, and Certify to the control authority to the effect that they do not and will not use or remove amalgam

14 Unless otherwise designated by the Control Authority, dental dischargers subject to this part are not Significant Industrial Users as defined in 40 CFR part 403, and are not Categorical Industrial Users as a result of applicability of this rule.

15 Successful Sector Control Programsbased on BMPs: Requirement to install Treatment Technology Requirement for Adequate Sizing Requirement to Operate and Maintain Treatment Requirement to Maintain Records

16 Installation of an adequately sized amalgam separator Meets ISO certification standards Removal efficiency of at least 95%

17 Installation of an adequately sized amalgam separator What is an amalgam separator? Solids collector Capture Hg by default Avg Annual Costs -$800.00

18 Operation and Maintenance Inspected in accordance with manufacturers operating manual Must be repaired within 10 business days, if discovered to be not functional Maintained by replacing the cartridge, canister or unit collector of retained solids when the design capacity is reached.

19 Prohibition of oxidizing line cleaners, including but not limited to bleach, chlorine, iodine or peroxide that have a ph lower than 6 or greater than 8. Ensure all amalgam process wastewater, including chair side traps, screens, vacuum pump filters, dental tools, cuspidors, or collection devices are treated through the amalgam separator.

20 Recordkeeping Maintain for three years: Inspection records/logs Maintenance of Separator Manifest/shipping records of cartridge replacement Documentation of repairs or replacement

21 Existing Source: Compliance with Rule by July 14, 2020 Provide a one-time compliance report- October 12, 2020 New Source Compliance with Rule upon startup Provide a one-time compliance report within 90 days

22 Grandfather Clause: Separators installed prior to June 14, 2017 (publication date in FR) Separator meets requirements until it is replaced or for 10 years (June 14, 2027) whichever is sooner.and If they continue to meet the requirements in the Rule

23 One time Compliance Report Contact information Characterize Dental office Amalgam Separator information O + M certifications BMP certifications

24 Legal authority Procedures Funding/Resources Local Limits Enforcement Response Plan (Compliance Evaluation) IU inventory

25 IU inventory You need to identify the universe of dental dischargers in your service area.

26 Coordinated with State ADA offices Provided the EPA Region 8 One-time Compliance report Receiving reports from dentists in nonapproved program Phase II IU inventory in 2019 Gather list of dentist offices

27 Every report but 1 is incomplete; Outreach to every dental office to ensure interpretation of compliance Do I have to complete the report? (Orthodontists, oral surgeon, etc.) If more than one dentist in the practice do we each have to complete the form? What about multiple practices in one building?

28 EPA Effluent Limitations Guidelines Electronic CFR

29 Federal Register October 22, 2015 Final Rule-NPDES E-Reporting Rule-FR Vol 80, No 204-pp Effective Date December 21, 2015 Reduces burden of existing paper-based reporting from regulated facilities and reduces third-party data entry errors by instead requiring electronic data submissions;

30 30 Phase 1 DMR Submissions & Biosolids Reports (21 Dec 2016) Phase 2 General Permit and Program Reports (21 Dec 2020)

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32 32 Cross Media Electronic Reporting Rule 40 CFR 403.8(g) A POTW that chooses to receive electronic documents must satisfy the requirements of 40 CFR part 3. les/ /documents/cromerr_potw_1.pdf

33 33 System Standards to ensure Integrity and Enforceability of electronic received data Criteria for establishing a copy of record; Integrity of the electronic document; Validity of the electronic signature; Determination of the identity of the individual uniquely entitled to use a signature device; and Opportunity to review and repudiate the copy of record. PDFs do not meet these data integrity elements

34 34 Guidance issued May /documents/cromerr_potw_1.pdf

35 35 May 2018 Roles and Responsibilities of Pretreatment Programs: Verify Legal Validity of Electronic Signatures Prepare CROMMER system documentation Review and Update Pretreatment Program Requirements

36 Legal authority Procedures Funding/Resources Local Limits Enforcement Response Plan IU inventory

37 40 CFR 403.8(f)(2)(iv) : Receive[s] and analyze[s] self-monitoring reports and other notices submitted by Industrial Users in accordance with the self-monitoring requirements in CFR 403.8(f)(5) and 403.9(b) - Identify POTW organizational duties 40 CFR 403.8(f)(3) and 403.9(b): Ensure that the POTW has sufficient resources (funding) and qualified personnel

38 EPA s Public Access Website ECHO EPA s public access tool for NPDES program information. Updated on a weekly basis with the latest information from states. ECHO uses a search, sort, and drill approach to provide public access. Provides data with a dashboard and in bulk for more technical users. Improved Access to Pretreatment Data

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40 Results are displayed on a map and sortable and downloadable for additional processing by the user

41 Users can drilldown to a facility and get more details information. The DFR will eventually include information on individual Significant Industrial Users (SIUs) as well as the POTW pretreatment program.

42 Al Garcia EPA Region 8 Pretreatment Coordinator garcia.al@epa.gov