indust. pretreatment program 7/8/1983�J.`t. to Of Xi 137SGS . . . John Carlin, Governor r
Barbara J. Sabol , Secretary Forbes F*W
jQ,=):X.xl1A1Ql Mx$Q x Topeka. Kansas 66620
973-1162-9360
July 8, 1983
Wilson & Company
P. 0. Box 1648
Salina, KS 67401
ATTN: Jim Dowell
Re: Industrial Pretreatment Program
Salina, KS
Dear Jim:
As per our June 6, 1983, phone conversation,,we are providing the following
review comments for the referenced project. Your efforts in submitting
this program document for our consideration and comment by the designated
deadline was appreciated. Overall the program submittal contained the
basic elements necessary for the City to run an effective pretreatment pro-
gram complying with objectives of the general pretreatment regulations 40
CFR, Part 403.
However, in order for the program to be in approved form, we request the
City submit a one-page implementation schedule. This schedule should con-
tain a series of estimated implementation dates for future program events.
One such event should include the date the City is expecting to adopt the
proposed amendments to their sewer use ordinance. Another date would be
when the City expects to implement their proposed permit system to monitor
industries subject to categorical and prohibited discharge standards. The
submission dates of baseline reports and other monitoring reports also
needs to be addressed in the schedule. The final date of the schedule
should not extend beyond July 1, 1984.
Report
In addition to the above requirements, we request the following comments
and/or recommendations be considered to allow the City to administer and
implement the program in a more effective manner.
Please note in a September 28, 1982, Federal Register, the effective
date of the general (Part 403) regulations of January 31, 1982, has
been changed to March 31, 1981. The January date is mentioned on
Page II -1 of the report.
Mr. Jim Dowell
July 8, 1983
Page 2
2. According to the information provided on Page III -6 of the report, it
is evident Tony's Pizza is an industry contributing a waste, exhibiting
excessive oil and grease, BOD, and TSS loading characteristics. Despite
efforts made by Tony's to reduce their waste loading to the treatment
system, effluent pollutant limitations are being exceeded at Plant No. 2.
As noted on Page IV -3 of the report, limited loading capacity currently
exists at the plant. We recommend the City address this problem by
enforcing their existing sewer use ordinance and applicable amendments
when enacted. Specifically those sections pertaining to the control of
"prohibited" discharges which adversely affect treatment plant operations.
The City has various options in which to control "prohibited" wastes.
One means is establishing loading limitations as described on Page II -2
and VII -2 of the report and incorporating those limits in the City's
permit program. If the City decides not to limit the influent waste
loading, additional capacity and/or modifications to plant equipment
may be needed at Plant No. 2 to prevent further NPOES permit violations.
3. Please note only two standard industrial classification (SIC) codes apply
to the electroplating standard (Part 413). They are 3471 and 3479.
Either the SIC code of 3721 mentioned on Pages II -4 and III -6 of the
report is incorrect or Beech is not an electroplater. It is possible
Beech has electroplating processes but is a "captive shop" so, there-
fore, will be subject to the proposed metal finishing standard (Part
433). We hope the problem in determining whether such industries are
electroplaters or metal finishers will be resolved when the final metal
finishing standard is promulgated. The reason this determination is
difficult to make is because both standards regulate similar metal
treating processes.
4. The January 28, 1984, date provided on Page III -6 has been extended
to April 27, 1984, as of January 21, 1983. Refer to 40 CFR 2774,
published on January 21, 1982.
5. A summary of the "priority" categorical standards is attached for your
information. This list updates the information presented.in Appendix
A. Only nineteen of the thirty-four standards remain as a result of
recent EPA actions excluding and deferring certain categorical standards
from regulation under Paragraph 8 of the NRDC vs. Castle Consent Decree.
This list of nineteen "priority" standards is subject to change by EPA.
6. We recommend an example self-monitoring report be included in the final
report for the City's use. This report is discussed on Page VI -1 of
the report. Copies of questionnaires of the eleven industries identified
as being subject to the program should also be provided in the final
report.
7. Based on the industrial survey results, we recommend a list of parameters
be developed for each of the eleven industries in Tables D-1 and D-2,
specifying pollutants which should be added to the City's existing roni-
toring program if needed (Table D-3). These pollutants would include
both compatible and noncompatible pollutants.
Mr. Jim Dowell
July 8, 1983
Page 3
8. A statement regarding the POTW's legal authority should be included
in Appendix E or the final report, when submitted.
Ordinance
1. The definition of "approval authority" should be amended by adding the
following words;
"and/or Director of the Division of Environment of the Kansas
Department of Health and Enviornment."
2. Due to expected changes regarding the removal credit requirements
referenced in Section 35-119 of the ordinance and 40 CFR, Part 403,
Section 403.7 of the regulations, we suggest the verbiage in the
ordinance be revised to reference any amendments to Section 403.7.
The requirements and/or section numbers may be changed by EPA as a
result of the promulgation of proposed revisions to Section 403.7.
(Refer to FR 42698-42707, dated September 28, 1982.)
3.. The City should notify all industries affected by reporting requirements
under 40 CFR Section 403.12, as mentioned in Section 35-118 of the
ordinance.. This would include any industries subject to promulgated
categorical pretreatment standards. Nine priority categorical standards
currently have established due dates for the submission of baseline
reports.
4. The term "Administrator" was used in Sections 35-134(2) and 35-134(3)
of the ordinance and was not defined 'in the ordinance definitions.
In this case, using the term "EPA" would be more appropriate.
As agreed in our conversation, we will expect to receive three copies of the
final program containing any necessary additions and/or corrections.
Even though the general concepts have been established for a successful pro-
gram, the City should continue to expand and improve this program in the
future. In particular, the City should further develop their permit system
to include eleven industries and satisfy the reporting requirements specified
in 403.12 of the general pretreatment regulations.
We invite you and the City to discuss an acceptable implementation schedule
with us and any other concerns regarding State requirements necessary for
the City of Salina to obtain an approvable program.
Sincerely yours,
Division of Environment
Steve Caspers
Pretreatment Specialist
;later Pollution Control
jaw
cc: Dean Soyer, City of Salina
Dave bialdo, :DHE
SUMMARY OF DATES FOR
INDUSTRIAL CATEGORIES W/PRETREATMENT STDS
As of May 1, 1983
Number SIC Industrial Cat
Date
ve Compliance
1. 467 ---- Aluminum Forming 11-2-82 (07-00-83) ---- (07-00-86)
7 AGl _:__ D-«�-.. u--..F-�a..w:�� ii-in-oo nc-nn-caI _--- nG-nn-RRl
4. 468 ---- Co er Formin 11-12-82 U/-UU-83 ---- lu-vu-6b
. 469 3600 Electric & Electronic 08-24-82 03-09-83 ---- 07-00-84_
C ncn TM u-+�l u -1A4-- 0_ 0 —+4 --11-ic-013 nn-nn-cv ---_ nR-nn-ARl
cars
2813
b. 4zu 3612
iron & bteel Mg.
ul-u/-01
un -z/ -oz U/ -IU -04 ui-iu-oo
3315
3316
3317
3325
9. 425 3111
Leather Tanning &
07-02-79
11-23-82 01-06-83 11-26-8
Finishi2
10. 433 3400
Metal Finishing
08-31-83
06-00-83 ---- 04-00-
-00-3500
3500
3630
3700
3800
11. 421 ----
Non Ferrous Metals
02-17-83
01-00-84 ---- ----
Urganic Chemicals�n U3-21-Ui (U3-UU-d4) ---- ----
416
3469
3479
3631
3632
3633
431 2621
2631
2646
2647
18. 125 & 4911 Steam Electric 10-14-80 11-19-82 01-02-83 07-01-84
3479 (01-28-81)
* Foundries ( ) = Estimated Date
** Combined with Plastics and Synthetics Category
*** Proposed Amendment (August 31, 1982)
SLC (5/19/83) 33-N
State of Kansas
Baseline Reports and (FDF) Variance Requests
CATEGORICAL STANDARDS IN FINAL FORM
Baseline Reports FDF Requests*
CATEGORICAL STANDARDS IN PROPOSED FORM
1.
Category
Due
Date
Due Date
_-.:. — 0seember 1983)
1.
Coil Coating
July 16,
1983
June
25,
1983
2a.
Electroplating (integrated)
June 25,
1983
June
25,
1983
2b.
Electroplating (nonintergrated)
September
26,
1981 June
25,
1983
3.
Inorganic Chemicals Manufacturing
May 9, 1983
June
25,
1983
4.
Iron & Steel Manufacturing
April 6,
1983
June
25,
1983
5.
Leather Tanning & Finishing
July 5,
1983
June
25,
1983
6.
Petroleum Refining
May 30,
1983
June
25,
1983
7.
Porcelain Enameling
July 6,
1983
June
25,
1983
8.
Pulp & Paper Mills
July 2,
1983
June
25,
1983
9.
Steam Electric Power Plants
July 1,
1983
June
25,
1983
*180
days after Effective Date of standard
or 30 days
after
Categorical
Determination
CATEGORICAL STANDARDS IN PROPOSED FORM
1.
Electrical & Electronic Comp.
(September 1983)
2.
Metal Finishing
_-.:. — 0seember 1983)
3.
Pesticides
(June 1984)
4.
Battery Mfg.
(December 1983)
5.
Copper Forming
(February 1984)
6.
Metal Moulding & Casting
(February 1984)
7.
Aluminium Forming
(January 1984)
8.
Pharmaceuticals Mfg.
(March 1984)
9.
Nonferrous Metals, Phase I
(July 1984)
(Proposed Date)
SLC (5/19/83) 33-N-2
DEFERRED CATEGORICAL STANDARDS
1.
4bb
Coll Coating (Lan Making Segment) (Phase 11)
Z -1U-83
(10-83)
2.
469
Electrical & Electronic (Phase II)
3-11-83
(11-83)
3.
415
Ingoranic Chemicals (Phase II)
(9-83)
(6-84)
4.
421
Nonferrous Metals (Phase II)
(9-83)
(6-84)
5.
421
Nonferrous Metals Forming
(9-83)
(6-84)
6.
416
Plastics Molding & Forming
(10-83)
(6-84)
7.
456
Adhesives & Sealants
(10-83)
(12-83)
EXCLUDED CATEGORICAL STANDARDS
Part No.
Industrial Category (SIC)
Coal Mining
1.
444
Auto & Other Laundries ---
2.
457
Explosives ---
3.
454
Gum & Wood Chemicals ---
4.
447
Ink Manufacturing ---
5.
446
Paint Manufacturing ---
6.
443
Paving & Roofing ---
7.
459
Photographic Equipment 3861
8.
448
Printing & Publishing ---
9.
428
Rubber Processing ---
10.
417
Soaps & Detergents ---
Promulgation Promulgation'
Industrial Date of Date of Effective
1.
434
Coal Mining
01-13-81
LU-13-dz
11-82
2.
440
Ore Mining
06-14-82
12-03-82
01-83
3.
429
Timber Products
10-31-79
01-26-81
03-30-81
4.
410
Textile Mills
10-29-79
09-02-82
10-82
* These four industries are subject to prohibited discharge standards in 40
CFR Part 403.5 only. The standards do not contain numerical limits for
pollutants for PSES or PSNS.
SLC (5/19/83) 33-N-3