PRETREATMENT PERFORMANCE MEASURES (Draft) 24 th EPA REGION 6 ANNUAL PRETREATMENT WORKSHOP OKLAHOMA CITY 8/14/08 Allen Gilliam ADEQ State Pretreatment Coordinator

WHY Pretreatment Program Performance Measures NOW? OFFICE OF INSPECTOR GENERAL “Evaluation Report” (September 28, 2004) EPA Needs to Reinforce Its National Pretreatment Program I. Better Information and Analysis Needed EPA does not have the information systems necessary to effectively measure, analyze, demonstrate, and improve Program performance. Without sufficient data to show the gains made by its Pretreatment Program, EPA leaves this program vulnerable to future budget cuts.

EPA Needs to Reinforce Its National Pretreatment Program II. Performance Measures Need to Be Results Based Measuring the impact of a Program is essential to documenting Program performance to support continued funding and identify future needs. The Pretreatment Program is at risk of losing the gains it has made if EPA does not become more vigorous in setting national policy and developing Program measures that can adequately document the Program’s progress.

9 PROPOSED MEASUREMENTS 6 BASIC Pretreatment Program (POTW is in compliance) and 3 “Enhanced” Measures THE 6 BASIC 1. Explosions & Hazardous Atmosphere(s) 2. pH Violations and Observed Corrosion 3. Sewer Collection System Overflows 4. Interference or Pass Through 5. Correct Permits & Representative Sampling 6. Full Compliance

9 PROPOSED MEASUREMENTS THE 3 “ENHANCED” 7. Biosolids Voluntarily Meet EQ Limits 8. # of Zero Discharging SIUs 9. Controls on Emerging Pollutants

1. Explosions & Hazardous Atmosphere(s) # or % of POTW fires, explosion hazards, or other type of hazardous atmosphere at plant or in collection system attributable to SIUs? Fires & explosions - Rare and should be an easy count? Is it standard procedures to use gas/vapor detection or explosi-meters before entering confined spaces to determine the # of “hazardous” conditions that were found in a year? No collection system alarms?

2. pH Violations and Observed Corrosion # or % of SIUs that violated a local limit or categorical standard for pH? # or % of SIUs that were in SNC for pH violations? # or % of pH related “issues” (corrosion, odor, inhibition, pass-through, worker health & safety) caused by SIUs? Difficult to determine source(s)? Was pH even the problem? No communication with collection system folks? Problems with grabs vs continuous?

3. Sewer Collection System Overflows # or % of POTWs with active FOG programs? # of POTWs that consider their FOG program to be part of their Pretreatment program? # or % of POTW blockages, spills, or overflows due to solidified grease or other (not including linens, rags, diapers, etc) not attributed to non- domestic dischargers (NDUs)? # or % of blockages, spills, overflows in the collection system attributable to non-domestic dischargers? No communication with collection system folks?

4. Interference or Pass Through # of POTW limit violations attributable to: a) operational problems at the plant, b) interference or pass thru by SIUs, or c) source is undetermined but not due to operational problems at plant? OR JUST # of incidents of pass through or interference attributable to SIUs causing POTW to violate its NPDES permit limits or be unable to dispose of biosolids by intended means? Going to have to have excellent communications with the O&M folks at your POTW(s)!!

5. Correct(?) Permits and Representative Sampling(?) % of SIU permits that contain all required 40 CFR 403 components, % of SIU permits that require representative sampling, # of POTWs that ensure representative samples are taken of their SIUs’ process wastewater. YOU better know ALL your permitted IUs’ processes, batch discharge frequencies and their plumbing! Your production based & CWF IUs’ limits have to be “correct”!

6. SIUs in Full Compliance # or % of POTWs’ SIUs in 100% compliance with local limits, categorical standards, general & specific prohibitions, and reporting requirements Verified(?) via more detailed, time consuming audits & PCIs. Are your enforcement actions timely & effective? Do you allow your SIUs to reach SNC? Good measurement for small programs?

7. Biosolids Meet EQ Limits 7. Biosolids Meet EQ Limits # of POTWs producing biosolids that meet limits in Tables 1 & 3 of 40 CFR # of POTWs disposing of biosolids by type of practice. Measure doesn’t differentiate how biosolids are disposed (landfill, incinerated or lagoon storage vs land app.) And doesn’t include those meeting Class A or Exceptional Quality as defined in CFR 503 (but could) Aren’t most Cities meeting 503, Tables 1 or 3 anyway? Where or who has the “authority” to require you to analyze your biosolids if you’re landfilling, incinerating or storing it in a waste lagoon?

8. # of Zero Discharging SIUs # or % of POTWs’ CIUs and non- categorical SIUs at zero-discharge voluntarily (AND/OR ?) # or % Due to NPDES or enforcement requirement? Doesn’t include those IUs that are hauling their wastes off-site Looking for IUs that have made process changes, incorporated P2 and other innovative approaches in managing and using water.

9. Controls on Emerging Pollutants # of POTWs with programs addressing “emerging” pollutants or sources: (a) not subject to categorical standards, (b) not traditionally evaluated, (c) not typically regulated, or (d) recently identified of potential concern to the environment, or public health such as Pharmaceuticals & Personal Care Products (PPCPs)

Collection of Data? The “who” and “hows” 1. Explosions & Hazardous Atmosphere(s) 2. pH Violations and Observed Corrosion 3. Sewer Collection System Overflows 4. Interference or Pass Through YOU Provide #s on your Annual Reports –More administrative burden for you –MUST have Effective communication between collection system and Pretreatment personnel –#s Verified via Pretreatment Audits and Compliance Inspections Better Have the Paperwork Documented

Collection of Data? The “who” and “hows” 5. Correct Permits & Representative Sampling 6. Full Compliance #s Discovered via Pretreatment Audits and Compliance Inspections More administrative burden on the State –More scrutiny on file reviews –More “friendly discussions” between you and I on what representative sampling is? –More “nit-picking” than usual?

THE 3 “ENHANCED” MEASUREMENTS 7. Biosolids Voluntarily Meet EQ Limits YOU Provide #s on your Annual Report –“Voluntarily” being the active term –Aren’t most Cities meeting CFR 503 tables 1 & 3 limits without local limit requirements? –Some cities are landfilling and/or “not generating” and not land applying Where’s your requirement to supply data? Where’s your requirement to supply data? Can EPA or the State force analyticals? Can EPA or the State force analyticals? Verified via Pretreatment Audits and Compliance Inspections

8. # of Zero Discharging SIUs YOU Provide #s on your Annual Report –More administrative burden for you –Does the # or % of your SIUs achieving a “no discharge” status regardless of reason mean your Program is going beyond what is minimally required and is “enhanced”? Have some of your SIUs achieved “no discharge” voluntarily for cost effectiveness? Have some of your SIUs achieved “no discharge” voluntarily for cost effectiveness? How many of your SIUs have YOU required to have “no discharge” of process wastewater? How many of your SIUs have YOU required to have “no discharge” of process wastewater? #s Verified via Pretreatment Audits and Compliance Inspections

9. Controls on Emerging Pollutants YOU Provide #s on your Annual Report –More administrative burden for you BMPs for businesses not considered SIUs (restaurants, dentists, auto repair, machine shops, etc) BMPs for businesses not considered SIUs (restaurants, dentists, auto repair, machine shops, etc) P2 implementation requirements in permits P2 implementation requirements in permits –Requirements to report progress (lbs, $$, energy, water) Ordinance prohibitions against flushing pharmaceuticals Ordinance prohibitions against flushing pharmaceuticals –Hope you’ve started gathering your “baseline” data to show progress in the future! #s Verified via Pretreatment Audits and Compliance Inspections

ORIGINAL PERFORMANCE MEASURES “TASK FORCE” (AMSA) ATTEMPTS WERE SUBMITTED TO EPA IN ’ These Measurements were basically ignored by the EPA but some are essentially the same Since EPA’s Inspector General’s Office has now, in essence, placed the Office of Water on a compliance schedule with milestone dates to be met: “WE” HAVE TO COME UP WITH SOMETHING!!!!! Do these 9 measures seem good performance measures to you?