TPDES Pretreatment Program & Updates Texas Commission on Environmental Quality Water Quality/Stormwater Seminar Water Quality/Stormwater Seminar September 23, 2015 Adam Shumate & Zandra Castaneda Stormwater & Pretreatment Team Water Quality Division

Today’s Presentation  Pretreatment History, Objectives, and Introduction  TPDES Permit Application – Domestic Worksheet 6.0  TPDES Pretreatment Permit Options 1 & 2  Industrial Users Identification and Survey  Categorical Industrial Users (CIUs)  Pretreatment Program Development  TPDES Pretreatment Permit Options 3 & 4  TPDES Updates  Resources and Contacts

Pretreatment History, Objectives, and Introduction

HistoryHistory   Early 20 th century to mid-century   High levels of pollution   Fish kills, burning rivers, thick black smog   Philosophy was “the solution to pollution is dilution”!

The Federal Clean Water Act Goals  Eliminate the discharge of pollutants  Support "the protection and propagation of fish, shellfish, and wildlife and recreation in and on the water"  Prohibit the discharge of toxic pollutants in toxic amounts Photo credit: tautologous.com/ Objective Restore and maintain the chemical, physical, and biological integrity of the Nation’s waters

National Pretreatment Program Goals and Objectives  Prevent Interference and Pass Through  Protect Worker Health and Safety  Encourage Recycling/Reuse

Pretreatment Standards to Achieve Objectives General Prohibitions Discharges that cause Interference or Pass Through

Pretreatment Standards to Achieve Objectives Specific Prohibitions  Fire or explosion hazard  Corrosive structural damage  Solid or viscous pollutants obstructing flow  Flow rate causing interference  Heat inhibiting biological activity  Oils causing interference/pass through  Toxic gases causing worker health problems  Trucked/hauled pollutants unless designated

Wastewater Collection and Treatment

 Significant Industrial Users (SIUs)  Categorical Industrial Users (CIUs)  Other Industrial Users (IUs) Based on character and volume of wastewater discharged to the POTW The Pretreatment Program regulates:

What is a Significant Industrial User (SIU)? 40 CFR Part §403.3(v)  Discharges 25,000 gallons per day (gpd) or more of process wastewater  Subject to categorical pretreatment standards (CIUs)  Contributes 5% or more of the hydraulic or organic capacity of the WWTP  Reasonable potential to adversely impact the POTW or for violating any standard

What is a Categorical Industrial User (CIU)?  Industrial categories in 40 CFR Parts  Subparts according to processes or manufactured products or raw material used  Existing Source or New Source in 40 CFR §403.3(m)  National technology based limits that apply at the CIU’s “end-of-process”

CIUs SIUs IUs Non-CIUs Non-SIUs Domestic

Categorical Pretreatment Standards  National standards  Apply to specific industrial categories  Emphasis on toxic pollutants  Technology-based  Apply at the “end-of-process” Local Limits  Developed individually by each POTW  Based on local, site-specific data  Protect WWTP, workers, sludge quality and water body  Apply at the IU’s “end-of-pipe”

TPDES Permit Application Domestic Worksheet 6.0

TPDES Domestic Wastewater Permit Application Worksheet 6.0 of the Technical Report  All POTWs must complete Worksheet 6.0 as part of their TPDES permit application  Include SIUs, CIUs, & other IUs discharging to the WWTP  Based on total number, average process flow, & other information

TPDES Domestic Permit Application Worksheet 6.0  Use water billing records or survey results in Table 1a  Be sure to enter “0” or “none” if there are no CIUs, SIUs, non- categorical, or Other IUs  Do NOT enter “N/A”

TPDES Domestic Permit Application Worksheet 6.0  Include required information for all SIUs and CIUs in Number 3  Provide as much detail as possible for Process Description

TPDES Domestic Permit Application Worksheet 6.0  3b-e: Describe the product and process  3f: Describe any problems, i.e. interference or pass through

TPDES Pretreatment Permit Options 1 and 2

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

TPDES Pretreatment Option 1 No approved pretreatment program No development of a pretreatment program No formal IU survey Permit Language Requirements  General and Specific Prohibitions 40 CFR §403.5  Notification requirements New introduction of pollutants New introduction of pollutants Changes in volume or character of pollutants Changes in volume or character of pollutants

 POTWs that are (or may) be required to develop pretreatment program  Activity No. 1 Submit an industrial User (IU) surveySubmit an industrial User (IU) survey Due within 60 days of issued permitDue within 60 days of issued permit Based on results, TCEQ will determine if program development continues or terminates.Based on results, TCEQ will determine if program development continues or terminates. TPDES Pretreatment Option 2

Industrial Users Identification and Survey

Problems and Discharges to Consider Collection System:   Stoppages or Overflows?   Corrosion of lines? Wastewater Treatment Plant:   Exceeding permit discharge limits?   Biomonitoring failures?   Exceeding sludge criteria for its disposal method?   Unusual or noxious odors? Industrial users (IUs):   Excessive amounts of pollutants or hydraulic loads?   Excessive fats, oils or grease (FOG)?   Wastewater with a high or low pH?

How to Identify Industrial Users?  Water billing records  Applications for sewer service  Building permits  Property tax records  POTW collection system personnel  POTW treatment plant operator(s)

How to Identify Industrial Users?  Business & telephone directories  Chamber of commerce records  Economic Development Board records  Direct observation (drive-by)  Internet searches  Toxic Release Inventory  Envirofacts

Facility Types Commonly missed facilities:  Small metal plating facilities  Truck washing facilities  Facilities that don’t have categorical standards  Meat and Poultry Products (40 CFR 432)  Plastic Molding & Forming (40 CFR 463)

Industrial User Survey Compile master list of potential IUs in service area Compile master list of potential IUs in service area  IUs with high water usage  IUs that might impact the POTW  Standard industrial classification (SIC) code  North America Industry Classification System (NAICS) codes  Compare categories 40 CFR Part

Industrial User Survey  Survey each IU to collect information  Send a questionnaire  Conduct follow-up inspections & phone calls  Summarize data  Maintain and update IU list Industrial User Survey

Categorical Industrial Users (CIUs) Discharging to POTWs without an approved pretreatment program

CIUs discharging to POTWs without an approved TPDES pretreatment program  TCEQ is the Control Authority  Send semi-annual self-monitoring reports to: TCEQ Stormwater & Pretreatment Team (MC-148) Water Quality Division TCEQ Stormwater & Pretreatment Team (MC-148) Water Quality Division  TCEQ’s guidance Reporting Requirements for CIUs Discharging Wastewater to POTWs Without Approved Pretreatment Programs (RG-401) Reporting Requirements for CIUs Discharging Wastewater to POTWs Without Approved Pretreatment Programs (RG-401) wastewater/pretreatment/rg401.pdf wastewater/pretreatment/rg401.pdf  CIUs and the POTWs may be inspected by the TCEQ’s Pretreatment Compliance Investigators

Pretreatment Program Development

POTWs with:  Combined design flow of ≥ 5 MGD, and Receive wastewater contributions from CIUsReceive wastewater contributions from CIUs Receive pollutants which cause pass through or interference at the WWTPReceive pollutants which cause pass through or interference at the WWTP  Program development required by TCEQ Who Must Develop Pretreatment Program? 40 CFR §403.8

Pretreatment Program Elements 40 CFR §   Legal Authority (ordinance)   Enforcement response plan and guide   Standard operating procedures   Adequate funding & resources   Local Limits   List of IUs, SIUs, CIUs

TPDES Pretreatment Permit Options 3 and 4

TPDES Pretreatment Permit Language  Option 3: POTWs within an approved pretreatment programs POTWs within an approved pretreatment programs With SIUs discharging to that specific WWTP With SIUs discharging to that specific WWTP  Option 4: POTWs within an approved pretreatment program POTWs within an approved pretreatment program Without SIUs discharging to that specific WWTP Without SIUs discharging to that specific WWTP

Option 3 WWTPs: Option 3 WWTPs:  An approved TPDES pretreatment program  40 CFR Part 403 with Streamlining Rule requirements  Technically based local limits (TBLLs): Reassessment certification of existing TBLLs Reassessment certification of existing TBLLs Notification to redevelop existing TBLLs Notification to redevelop existing TBLLs Either due 60 days after permit issuance Either due 60 days after permit issuance TPDES Pretreatment Permit Language

Option 3 WWTPs:  Annual report - due a specific month WWTP influent and effluent monitoring WWTP influent and effluent monitoring 40 CFR Part 122, Appendix D & 30 TAC Chapter CFR Part 122, Appendix D & 30 TAC Chapter 307 List of SIUs in SNC and newspaper publication List of SIUs in SNC and newspaper publication  Notification requirements New introduction of pollutants New introduction of pollutants Changes in volume or character of pollutants Changes in volume or character of pollutants TPDES Pretreatment Permit Language

Option 4 WWTPs:  Covered under approved TPDES pretreatment program  No SIUs in the service area of the plant  Influent/effluent sampling not required  Notification requirements still apply TPDES Pretreatment Permit Language

TPDES Pretreatment Program Universe  73 Approved TPDES Pretreatment Programs  Includes approximately 1,250 SIUs  150 WWTPs  160 municipalities  6 Developing Pretreatment Programs  32 CIUs Discharge to POTWs without an approved pretreatment program Discharge to POTWs without an approved pretreatment program

TPDES UPDATES

TPDES Updates  TCEQ’s Minimum Analytical Limits (MALs)  Wastewater Potable Reuse  OIG’s Hazardous Waste Notification Evaluation  EPA Proposed Rules Dental Amalgam Rule Dental Amalgam Rule Management for Hazardous Waste Pharmaceuticals Management for Hazardous Waste Pharmaceuticals

 On July 12, EPA partially approved The 2010 version of the Implementation Procedures (IPs) The 2010 version of the Implementation Procedures (IPs)  Implementation began July 14, 2014  More than 50 MALs were updated Lowered due to EPA’s lowered Minimum Quantification Limits (MQLs) Lowered due to EPA’s lowered Minimum Quantification Limits (MQLs) New MALs for additional pollutants were added New MALs for additional pollutants were added  Download 2010 IPs at: standards/WQ_stds standards/WQ_stds standards/WQ_stds standards/WQ_stds Minimum Analytical Levels (MALs)

 The lowest concentration at which a particular substance can be quantitatively measured with a defined accuracy and precision level, using approved analytical methods  It is not the published method detection limit (MDL) for an EPA approved analytical method  MDL is based on a single laboratory analysis of the substance in reagent (distilled) water  MAL is based on analyses of the analyte in the matrix of concern (i.e. wastewater effluent) Minimum Analytical Levels (MALs) Defined Defined

 Industrial, Municipal, and Stormwater permits 2003 MALs or previously authorized MALs in existing permits stay in effect until permit is renewed or amended 2003 MALs or previously authorized MALs in existing permits stay in effect until permit is renewed or amended  Permits issued to POTWs with approved pretreatment programs Contributing Industries and Pretreatment Requirements Section Contributing Industries and Pretreatment Requirements Section Effective July 14, use 2010 MALs, found in Tables E-1 & E-2 Effective July 14, use 2010 MALs, found in Tables E-1 & E-2 TPDES Permits & MALs

 The 2010 MALs are required for new developing and approved pretreatment programs, including: WWTP effluent test results submitted with pretreatment annual reports WWTP effluent test results submitted with pretreatment annual reports TBLLs reassessments TBLLs reassessments Sampling plans for TBLLs development Sampling plans for TBLLs development Monitoring for IUs discharging into these WWTPs, as applicable – for example: Monitoring for IUs discharging into these WWTPs, as applicable – for example: TBLLs based on industrial contribution allocation methodTBLLs based on industrial contribution allocation method Determine if a pollutant is not present to waive a pollutantDetermine if a pollutant is not present to waive a pollutant Pretreatment Programs & MALs

Indirect & Direct Potable Water Reuse Projects   Entities with projects: Colorado River MWD at Big Spring (Start date: April 2013) City of Wichita Falls (Start date: July 2014; terminated July 2015) City of Brownwood (DPR, on hold) El Paso Water Utilities (IPR & DPR pilot project underway)   Entities considering City of Houston North Texas MWD (IPR) Abilene (IPR) Laguna Madre Water District ( DPR) San Angelo (DPR) Gulf Coast Water Authority (IPR)

See Texas Water Development Board DPR Resource Document Vol.1 & 2 See Texas Water Development Board DPR Resource Document Vol.1 & 2 Vol. 1, Chapter 4 – Enhanced Source Control for DPR tions/reports/contracted_reports/d oc/ _Vol1.pdf tions/reports/contracted_reports/d oc/ _Vol1.pdf tions/reports/contracted_reports/d oc/ _Vol1.pdf Vol. 2, Appendix D – Source Control blications/reports/contracted_ reports/doc/ _Vol 2.pdf blications/reports/contracted_ reports/doc/ _Vol 2.pdf Direct Potable Water Reuse Resource Document

  Pretreatment objectives to control sources of pollutants Protect POTW from interference including uses of sludge Protect POTW from pass through of pollutants Improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges   Enhanced Source Control Regulated pollutants (CWA and SDWA) Unregulated pollutants (i.e., contaminants of concern)   Regulated SIUs and CIUs   Regulate Ius not typically regulated   Public education and outreach   Improve chances of public acceptance of DPR and IDPR Role of Pretreatment

Hazardous Waste Notification Requirements for IUs and POTWs

Hazardous Waste Notification 40 CFR §403.12(p)  Office of the Inspector General (OIG) evaluated hazardous waste (HW) discharges to and from POTWs  Research starting May 2013  Fieldwork Phase considered: Effectiveness of notification in preventing and addressing contamination of surface water from HW passing through POTWs?Effectiveness of notification in preventing and addressing contamination of surface water from HW passing through POTWs? EPA, States’, and POTWs’ role and oversightEPA, States’, and POTWs’ role and oversight Toxic Release Inventory (TRI)Toxic Release Inventory (TRI) Discharge Monitoring Reports (DMRs)Discharge Monitoring Reports (DMRs)

EPA OIG HW Report Findings  Report No. 14-P-0363  September 29, 2014  Findings: EPA can improve to identify and regulate HW discharges from WWTPs EPA can improve to identify and regulate HW discharges from WWTPs WWTPs monitor for a small portion of known toxic chemicals WWTPs monitor for a small portion of known toxic chemicals

Proposed Dental Amalgam Rule

 Effluent Limitations Guidelines for the Dental Category Published in Federal Register – October 22, 2014 Published in Federal Register – October 22, 2014 Comments to EPA extended to February 20, 2015 Comments to EPA extended to February 20, 2015  EPA proposes to: Create 40 CFR Part 441 Create 40 CFR Part 441 Dental Industrial User (DIU) category Dental Industrial User (DIU) category Amend 40 CFR Parts and Amend 40 CFR Parts and EPA Proposed Dental Amalgam Rule

 Would apply to all dental facilities  Excludes facilities practicing exclusively: oral pathologyoral pathology oral and maxillofacial radiology and surgeryoral and maxillofacial radiology and surgery orthodontics, periodontics, and prosthodonticsorthodontics, periodontics, and prosthodontics  Dentists who do not place or remove dental amalgam may comply by certifying to their Control Authority If this status changes, the facility would have toIf this status changes, the facility would have to comply with the discharge limit. EPA Proposed Dental Amalgam Rule

 Requires > 99.0% removal of total mercury (Hg) from amalgam process wastewater  Numeric limit could be met by using a separator that is: 2008 ISO11143 certified to remove > 99.0% of total Hg2008 ISO11143 certified to remove > 99.0% of total Hg Receives all process wastewaterReceives all process wastewater Inspected monthly to ensure proper functioningInspected monthly to ensure proper functioning Regularly maintained/serviced as per manufacturer’s instructions or annually, whichever comes firstRegularly maintained/serviced as per manufacturer’s instructions or annually, whichever comes first Annual certification, no wastewater monitoringAnnual certification, no wastewater monitoring EPA Proposed Dental Amalgam Rule

 Would also require best management practices (BMPs) Bleach free line cleaners with a neutral pHBleach free line cleaners with a neutral pH No flushing of scrap metalNo flushing of scrap metal  Effective date: Three years after the effective date of the final ruleThree years after the effective date of the final rule EPA Proposed Dental Amalgam Rule

List of Dentists and Dental Offices Texas State Board of Dental Examiners Select “Mailing Lists” to download “Dentist.csv” file Select “Mailing Lists” to download “Dentist.csv” file Filter to remove non-active and practices not subject to the rule Filter to remove non-active and practices not subject to the rule Click on “Licensing Information” then “Dentist” to get a list of Texas Dental and Dental Hygiene Schools Click on “Licensing Information” then “Dentist” to get a list of Texas Dental and Dental Hygiene Schools U.S Census Bureau 2012 County Business Patterns for Dental Offices (NAICS ) Search by County: Search by County: Go to View Data in Tables and select Texas in Select Area box Go to View Data in Tables and select Texas in Select Area box

Dental Amalgam Resources American Dental Association Best Management PracticesAmerican Dental Association Best Management Practices health-topics/amalgam-waste-best- management health-topics/amalgam-waste-best- management health-topics/amalgam-waste-best- management health-topics/amalgam-waste-best- management EPA Mercury in Dental AmalgamEPA Mercury in Dental Amalgam health-topics/amalgam-waste-best- management health-topics/amalgam-waste-best- management health-topics/amalgam-waste-best- management health-topics/amalgam-waste-best- management

  Proposed rule signed by EPA on August 31, 2015   Proposes sector-specific set regulations to ensure the management of HWP   Healthcare facilities, pharmacies, and reverse distributors   Help make drinking and surface water healthier by reducing the amount of HWP entering the waterways   Comment Period: comments due 60 days following publication in the Federal Register Management Standards for Hazardous Waste Pharmaceuticals (HWP) standards-hazardous-waste-pharmaceuticals

Training and Resources

Pretreatment Training & Resources TCEQ – Pretreatment  32st Annual EPA Region VI Pretreatment Workshop Date: August 2016Date: August 2016 Location: TBDLocation: TBD  Environmental Trade Fair Date: May 2016Date: May 2016 Location: Austin Convention CenterLocation: Austin Convention Center  training_seminars.html EPA – Pretreatment webcasts Including archived presentationsIncluding archived presentations

TPDES Pretreatment Program Contacts  Rebecca L. Villalba, Team Leader  Ryan Bucek  Zandra Castaneda  Lana D’Souza  David James  Yamunalinie Pathmanathan  Adam Shumate  Santiago Velez-Garcia Water Quality Division (512)

TCEQ Regional Contacts North Central and West Texas Eric Agnew Pretreatment Compliance Investigator Fort Worth Office (817) Coastal and East Texas Gary Fogarty Pretreatment Compliance Investigator Houston Office (713) North Central and West Texas Eric Agnew Pretreatment Compliance Investigator Fort Worth Office (817) Coastal and East Texas Gary Fogarty Pretreatment Compliance Investigator Houston Office (713)

Questions and Discussion? Thank You!