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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