CENTRALIZED WASTE TREATMENT40 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.

Application to DischargeAffluent Permit to CWT FacilityReviewing CWT Incoming WastestreamsInspecting the CWT FacilityContinuous 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 FacilityCONTROL 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 FacilityTo 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 FacilityFact 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 WastestreamsCONTROL 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 POTWInsert 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; andGCA must approve the acceptance, in writing, prior to

Permittee’s receipt of said waste.

Lessons Learned:Inspecting the CWT FacilityCheck On-Site Records to Confirm:

Consistency with Application to Discharge

Consistency with Approved Wastestreams

Future Wastestreams Being Considered

Lessons Learned:Inspecting the CWT FacilityWalk 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 FacilityInspect 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 DataIt 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