CENTRALIZED WASTE TREATMENT 40 CFR 437 Lessons Learned

LESSONS LEARNED: The goal of this presentation is to share our CWT compliance strategies with you based on our experiences.

THE MESSAGE IS: Understand the CWT treatment process as it relates to your process and compliance requirements. Confirm that Dilution of Wastestreams at the CWT is NOT occurring.

WHO IS GULF COAST WASTE DISPOSAL AUTHORITY (GCA)? GCA has an approved Pretreatment Program in the Houston, Texas area. GCA operates several industrial wastewater treatment plants and receives wastewater from Centralized Waste Treatment Facilities.

WHAT IS A CENTRALIZED WASTE TREATMENT FACILITY? A CWT Facility is one that accepts for treatment and/or recovery used industrial materials generated off-site (at another location). Treatment means any method, technique, or process designed to change the physical, chemical or biological character or composition of any metal-bearing, oily, or organic waste so as to neutralize such wastes, to render such wastes amendable to discharge or to recover energy or recover metal, oil or organic content from the wastes.

Application to Discharge Affluent Permit to CWT Facility Reviewing CWT Incoming Wastestreams Inspecting the CWT Facility Continuous Evaluation of Analytical Data

Lessons Learned: Application to Discharge Determine what subcategories your POTW can treat and still be in compliance with your POTW’s permits and applicable regulations. The CWT Subcategories are facilities that treat or recover from off-site: Subcategory A: metal-bearing waste, wastewater, or used material received from off-site - GCA does not accept this subcategory. POTWs are not really designed to treat metals. Subcategory B: oil from oily waste, wastewater, or used material Subcategory C: organics from organic waste, wastewater, or used material Subcategory D: combination of above - GCA does not accept this subcategory because it is too difficult to verify compliance with our customers.

Lessons Learned: Application to Discharge Key Questions: Do you agree that the Facility is actually subject to CWT and their Subcategory Determination? Do they describe a treatment process appropriate to the subcategory being treated?

Lessons Learned: Application to Discharge Key Questions: Review the pollutant loadings and evaluate if your POTW: has the capacity to treat the wastewater and will still be in compliance with your POTW permits and other regulations.

Lessons Learned: Affluent Permit to CWT Facility CONTROL WHAT COMES INTO YOUR POTW Under Specific Prohibitions in the Affluent Permit make sure to describe in detail the type of incoming wastestreams that the CWT Facility can accept for subsequent transfer into your POTW.

Lessons Learned: Affluent Permit to CWT Facility To accurately evaluate compliance with each Subcategory Have: Separate sampling points for each subcategory, Sampling points strategically located within the process, and Carefully review the analytical results for compliance.

Lessons Learned: Affluent Permit to CWT Facility Fact Sheet for Each Affluent Permit that documents items such as: Permit Action Summary, Pass Through and Interference Evaluations and Special Conditions and Rationale.

Lessons Learned: Reviewing CWT Incoming Wastestreams CONTROL WHAT COMES INTO YOUR POTW Insert into your permit specific elements such as Documentation of Authorizations: In the event the Permittee intends to accept for treatment, storage and/or recovery any wastes that are hazardous, prior to Permittee’s acceptance of such waste, Permittee’s shall provide to the Authority this information in writing.

Lessons Learned: Reviewing CWT Incoming Wastestreams CONTROL WHAT COMES INTO YOUR POTW Insert into your permit specific elements such as: Customer / Generator / Transporter Information and Regulatory Identification Numbers Identification of organic, oily and metal-bearing wastes and waste codes General description of waste and process generating waste, and A description of the treatment that the Permittee conducts on the waste.

Lessons Learned: Reviewing CWT Incoming Wastestreams CONTROL WHAT COMES INTO YOUR POTW Insert into your permit specific elements such as Additional CWT Monthly Reporting Requirements. If Permittee accepts wastes that are regulated under 40 CFR 437 whose compliance is not expressly described in the Permittee’s Application to Discharge the CWT Monthly Report shall describe specific information.

Lessons Learned: Affluent Permit to CWT Facility CONTROL WHAT COMES INTO YOUR POTW Insert into your permit specific elements such as: Prior to the Permittee’s acceptance of a new or changed waste from an existing or new customer or generator, the Permittee must provide to the Authority: Waste profiles; All the informational details referenced in the CWT Monthly Report; and GCA must approve the acceptance, in writing, prior to Permittee’s receipt of said waste.

Lessons Learned: Inspecting the CWT Facility Check On-Site Records to Confirm: Consistency with Application to Discharge Consistency with Approved Wastestreams Future Wastestreams Being Considered

Lessons Learned: Inspecting the CWT Facility Walk the Site: Follow Pipelines to Ensure Treatment is Actually Being Undertaken Confirm the Treatment being Implemented is Appropriate for the Subcategory Make sure that Dilution of the Wastestream is NOT Occurring (i.e., Evaluate Boiler Blowdown Pipelines)

Lessons Learned: Inspecting the CWT Facility Inspect the On-Site Laboratory to Ensure that: Appropriate Testing is Being Undertaken to Ensure Incoming Wastestreams are Accurately Being Identified, Compliance with any Affluent Permit Limits are Being Evaluated and Analytical Documentation is Acceptable.

Lessons Learned: Continuous Evaluation of Analytical Data It is an Ongoing Process to: Confirm Compliance Check Data and Compare with Wastestream Profiles Cross Reference Process Events that Might Be Occurring at the POTW with Wastestream Profiles at the CWT (i.e., Metals at POTW Outfall or Sludge) Adjust Approval Process to Accommodate Outcome

TO SUMMARIZE LESSONS LEARNED: Understand the CWT treatment process as it relates to your process and compliance requirements. Confirm that Dilution of Wastestreams at the CWT is NOT occurring.

Thank You