State and Federal IPP State and Federal IPP Regulations Regulations Grace Scott Grace Scott Pretreatment Coordinator Pretreatment Coordinator Water Bureau Water Bureau 517- -335 335- -4107 4107 517 scottg@michigan.gov scottg@michigan.gov Disclaimer: The information provided in the following slides is an overview only. The actual rules and regulations should be consulted for complete requirements.
Wanted: Industrial Pretreatment Wanted: Industrial Pretreatment Coordinator Coordinator Chemist Chemist Biologist Biologist Engineer Engineer Technician Technician Lawyer Lawyer Data Clerk Data Clerk Public Relations Specialist Public Relations Specialist Regulator Regulator Teacher Teacher Inspector Inspector
Part 23 Michigan Rules vs vs Part 23 Michigan Rules Federal 40 CFR Part 403 Federal 40 CFR Part 403 In 1983, Michigan received delegation from USEPA to In 1983, Michigan received delegation from USEPA to manage and enforce the Industrial Pretreatment manage and enforce the Industrial Pretreatment Program. Program. 40 CFR Part 403 General Pretreatment Regulations 40 CFR Part 403 General Pretreatment Regulations http://cfpub.epa.gov/npdes/home.cfm?program_id cfpub.epa.gov/npdes/home.cfm?program_id=3 =3 http:// R323.2303 of the Michigan Administrative Code R323.2303 of the Michigan Administrative Code http://www.state.mi.us/orr/emi/admincode.asp?Admin www.state.mi.us/orr/emi/admincode.asp?Admin http:// Code= =Single&Admin_Num Single&Admin_Num=32302301&Dpt= =32302301&Dpt=EQ&Rng EQ&Rng Code High= = High
INDUSTRIAL INDUSTRIAL PRETREATMENT PROGRAM PRETREATMENT PROGRAM R323.2301 (403.2) R323.2301 (403.2) prevent discharge of prevent discharge of metals, solvents & metals, solvents & other pollutants other pollutants prevent POTW prevent POTW interference/pass- - interference/pass through through prevent worker prevent worker health and safety health and safety problems problems enhance biosolids enhance biosolids character character
Interference Interference You know it’ ’s going to s going to You know it be a bad day when: be a bad day when:
(IPP) Prohibited Discharges (IPP) Prohibited Discharges R323.2303 (403.5) R323.2303 (403.5) Fire or Explosion Fire or Explosion (Flashpoint <140º ºF) F) (Flashpoint <140 Corrosive (pH<5) Corrosive (pH<5) Block Flow Block Flow Interference or Pass Interference or Pass through through Heat (<104º ºF at WWTP) F at WWTP) Heat (<104 Oil Oil Toxic Gases Toxic Gases Trucked Wastewater Trucked Wastewater (unless at designated (unless at designated points) points)
(IPP) Local Limits (IPP) Local Limits R323.2303(4) R323.2303(4) Local limits are site specific and environmentally Local limits are site specific and environmentally protective of the local conditions protective of the local conditions Evaluate Ten Pollutants (Minimum) Ten Pollutants (Minimum) Evaluate – Arsenic, Cadmium, Chromium, Copper, Lead, Arsenic, Cadmium, Chromium, Copper, Lead, – Mercury, Nickel, Silver, Zinc and Cyanide Mercury, Nickel, Silver, Zinc and Cyanide – Other Pollutants of Concern Other Pollutants of Concern – Influent, Effluent & Biosolids Biosolids Influent, Effluent & Sanitary (Background) Sanitary (Background) Other locations as appropriate Other locations as appropriate
When is an IPP required? When is an IPP required? R323.2305 (403.8) R323.2305 (403.8) If > 5MGD design and non- -domestic users with domestic users with If > 5MGD design and non potential to cause pass through or interference or potential to cause pass through or interference or categorical industrial user a Federal IPP categorical industrial user a Federal IPP If < <5MGD design and non 5MGD design and non- -domestic users with domestic users with If potential to cause pass through or interference or potential to cause pass through or interference or categorical industrial user a Michigan IPP, unless categorical industrial user a Michigan IPP, unless Federal IPP Federal IPP If a state permit (groundwater) with non- -domestic domestic If a state permit (groundwater) with non users with potential to cause interference or permit users with potential to cause interference or permit violations or categorical industrial user a Michigan violations or categorical industrial user a Michigan IPP IPP Programs must be developed within one year of Programs must be developed within one year of written notification written notification
Legal Authority Legal Authority R323.2306 (403.8) R323.2306 (403.8) The authority may be contained in: The authority may be contained in: – a statute a statute – – ordinance ordinance – – series of contracts series of contracts – – or or interjurisdictional interjurisdictional agreements agreements – Require compliance with pretreatment standards and Require compliance with pretreatment standards and requirements requirements Control through permit the contribution to the POTW Control through permit the contribution to the POTW by each Significant Industrial User (SIU) by each Significant Industrial User (SIU) Require installation of technology to meet standards Require installation of technology to meet standards and requirements, and self monitoring and reporting and requirements, and self monitoring and reporting
Legal Authority (cont.) Legal Authority (cont.) Carry out all inspection, surveillance and monitoring Carry out all inspection, surveillance and monitoring procedures necessary to determine compliance procedures necessary to determine compliance independent of information supplied by nondomestic nondomestic independent of information supplied by users users Enforce and seek injunctive relief and penalties Enforce and seek injunctive relief and penalties Immediately halt (after informal notice) a discharge that Immediately halt (after informal notice) a discharge that may endanger persons, the environment, or threatens to may endanger persons, the environment, or threatens to interfere with the operation of the POTW interfere with the operation of the POTW Comply with confidentiality requirements Comply with confidentiality requirements All local units of government that collect wastewater from All local units of government that collect wastewater from nondomestic sources, shall be responsible for the sources, shall be responsible for the nondomestic development and implementation of an IPP consistent development and implementation of an IPP consistent with the POTW POTW’ ’s s program program with the
Legal Authority (cont.) Legal Authority (cont.) Permits Requirements Permits Requirements Statement of Duration (not more than 5 yrs.) Statement of Duration (not more than 5 yrs.) Statement of nontransferability nontransferability without prior notification without prior notification Statement of to the POTW and provision of a copy to the new owner to the POTW and provision of a copy to the new owner or operator or operator Effluent limits based upon applicable general Effluent limits based upon applicable general pretreatment standards, categorical pretreatment pretreatment standards, categorical pretreatment standards, local limits, and state and local law. standards, local limits, and state and local law. Self monitoring, sampling, reporting, notification and Self monitoring, sampling, reporting, notification and recordkeeping requirements recordkeeping requirements Pollutants to be monitored, sampling location, frequency, Pollutants to be monitored, sampling location, frequency, and type and type Criminal and Civil Penalties and any applicable Criminal and Civil Penalties and any applicable compliance schedule compliance schedule Future streamlining addition: Slug Control Plan Future streamlining addition: Slug Control Plan Requirement and Notification of Changes which impact Requirement and Notification of Changes which impact spill/slug potential spill/slug potential
Procedures Procedures R323.2306 (403.8) R323.2306 (403.8) Identify and locate all possible nondomestic nondomestic Identify and locate all possible users that might be subject to the POTW POTW’ ’s s IPP IPP users that might be subject to the Identify the character and volume of pollutants Identify the character and volume of pollutants contributed to the POTW contributed to the POTW Notify nondomestic nondomestic users identified of applicable users identified of applicable Notify pretreatment standards, 204(b) and 405 of the pretreatment standards, 204(b) and 405 of the CWA, and subtitles C&D of the Resource CWA, and subtitles C&D of the Resource Conservation and Recovery Act (except MIPPs MIPPs Conservation and Recovery Act (except don’ ’t have to notify users of RCRA) t have to notify users of RCRA) don Within 30 days of the approval of a list of Within 30 days of the approval of a list of Significant Industrial Users, notify each SIU of its Significant Industrial Users, notify each SIU of its status and all requirements as a result of its status and all requirements as a result of its status status
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