14    HOW WILL INDUSTRIAL PRETREATMENT BE IMPACTED
BY EPA'S TECHNICAL SLUDGE REGULATIONS?
Robert G. O'Dette, Environmental Engineer
Tennessee Department of Health and Environment
Nashville, Tennessee 37219
INTRODUCTION
The Federal Water Quality Control Act of 1987 (P.L. 100-4) made several significant amendments
to the Clean Water Act (The Act). One of these amendments pertained to municipal (sewage) sludge in
Section 405(d). The overall intent of this particular amendment was to insure that municipal wastewater treatment plant sludges would be controlled by regulations promulgated under the authority of
the Act.
On February 6, 1989, EPA's technical sludge regulations, 40 CFR Part 503 were proposed. These
regulations will affect every municipality in these United States as well as the majority of industrial
indirect discharges to public owned treatment works (POTW's). The 503 regulations are perhaps the
agency's most controversial set of regulations to date. However, the ink had hardly dried on the paper
before the scientific sludge experts from around the country were saying the proposed rule was
technically flaw. EPA's lack of peer review is the main reason for this, and although the agency says it
wants to promote the beneficial reuse of sludge, the proposed regulations are counter to this policy.
Mr. Bob Perry representing the Water Pollution Control Federation (WPCF) made this point in his
public hearing statement on July 6, 1989, in Washington, D.C. Bob said EPA's proposed regulations,
if implemented, would result in the elimination of beneficial reuse as a viable sludge disposal alternative. This of course would be in direct conflict with the goals of the Act and EPA's own 1984 Policy on
Municipal Sludge Management.
Bob further pointed out that in light of this policy, it was ironic that EPA would propose regulations which could result in the curtailment or elimination of several projects recognized by the agency
as model reuse programs. These include composting facilities operated by Los Angeles County
(California), Washington Suburban Sanitary Commission in Montgomery (Maryland), and Sussex
County (Delaware). All three of these facilities received awards in EPA's 1988 Beneficial Reuse of
Sludge Award Program. If the proposed regulations are put into effect, these facilities and many
others like them could be out of business. (A fact which is not included in EPA's analysis of the cost
impact of the regulations.)
Why is this issue important to industries discharging to POTWs? For the answer all one has to do is
look at Section 307(b) of the Act and the General Pretreatment Regulations (40 CFR Part 403). The
stated purposes of pretreatment programs are to fulfill three primary objectives. First, to prevent the
introduction of pollutants into POTWs that will interfere with the operation of the POTW, including
interference with the use or disposal of municipal sludge. Second, to prevent the introduction of
pollutants into POTWs that will pass through the treatment works or be otherwise incompatible with
such works. Third, to improve opportunities to recycle and reclaim municipal and industrial wastewater and sludges.1
In addition to the general prohibition of interference or pass through, EPA has established several
specific prohibitions on the introduction of pollutants that create a fire or explosion hazard, are
excessively corrosive, may obstruct flow, are slug loads, or are excessively hot. Although categorical
restrictions are established for certain types of indirect industrial discharges, such as electroplaters,
the basic framework of the pretreatment program relies heavily on each municipality identifying its
own problems and proposing solutions. EPA promotes the development of local limits to account for
site-specific factors that may concern the performance of a POTW or the disposal of its sludge.
The rationale behind this three-part strategy is, first, that categorical standards provide nationally
uniform effluent limits affording a technology-based degree of environmental protection for discharges from particular categories of industry. Second, the prohibited discharge standards recognize
45th Purdue Industrial Waste Conference Proceedings, © 1991 Lewis Publishers, Inc., Chelsea, Michigan 48118.
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