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Gossman Consulting, Inc

GCI TECH NOTES©


Volume 4, Number 06                  A Gossman Consulting, Inc. Publication                   June, 1998

Effluent Limitations Guidelines, Pretreatment Standards and NSPS for Industrial Waste Combustors

(FR-63, pages 6392-6423)

David Constans and Jim Woodford

Effluent Limitations Guidelines, Pretreatment Standards and NSPS for Industrial Waste Combustors (FR-63, pages 6392-6423) is a proposed rule released for comment in February 1998 with comments to the EPA to be received by May 7, 1998. Upon first reading, the proposed regulation would appear to focus on a very narrow segment of industrial waste combustors that utilize wet scrubbing systems as air pollution control devices. Indeed, the rule appears almost innocuous. Briefly, the proposed regula-tion applies to commercial industrial waste combustors that receive industrial waste from off-site and discharge industrial waste combustor wastewater. This wastewater discharge, per this rule, must meet the BPT Effluent Limitations limits in the table below. Interpreting the rule in this narrow fashion would result in a rule that applies to perhaps as many as eleven facilities. This is the interpretation EPA used in their economic analysis. However, the rule can be more broadly interpreted to include virtually every cement kiln, whether they use hazardous waste fuels or not, and for a broader range of pollutants than those listed.

BPT Effluent Limitation (mg/l)

Pollutant or Pollutant Parameter

Conventional Pollutants

Maximum of any one day Monthly Average
Total Suspended Solids
24.3
7.46
pH

>6.0 <9.0

Priority and non-conventional Pollutants





Arsenic
0.0166
0.016
Chromium
0.137
0.049
Copper
0.0205
0.013
Lead
0.0957
0.061
Mercury
0.00409
0.003
Silver
0.0102
0.006
Titanium
0.0442
0.016
Zinc
0.0532
0.035

Significant Details of the Rule and Comments

Recommendations:

At this point nothing can be done about EPA's possible expansion of this rule to include more facilities, more effluent streams or more pollutants. Comments have been submitted to the EPA regarding the above points, and hopefully some clarification and narrowing of the rule will result. However, there is some indication that state agencies will utilize this proposed regulation in formulating permit conditions for wastewater releases from facilities which are subject to RCRA permitting. In any event, it would seem prudent that any facility which utilizes industrial wastes should examine their process and determine if there are any effluent discharges which might be subject to these regulations, and then analyze those discharges to determine what pollutants are present and in what concentrations.