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The public hearing gave interested parties the opportunity to present oral comments on the proposed regulation. EPA provided each of the small entity representatives and panel members many materials related to the development of this reproposal. As such, the small entity representatives had the opportunity to comment on many aspects of this reproposal in addition to those specified above.
EPA has reviewed these comments and is proposing a revised scope for this rule. The vast majority of these issues are discussed in the following chapter. Applicability 3. First, EPA is proposing to establish limitations and pretreatment standards for stand- alone waste treatment and recovery facilities receiving materials from off-site - classic "centralized waste treaters.
The wastewater flows which EPA is proposing to regulate include some or all off-site waste receipts and on-site wastewater generated as a result of centralized waste treatment operations. A detailed discussion of CWT wastewaters is provided in Chapter 4. Non-commercial facilities were defined as facilities that accept off-site wastes from facilities under the same ownership. These facilities are generally manufacturers who treat wastes generated as a result of their on-site manufacturing operations and whose wastewater discharges are already subject to existing effluent guidelines and standards.
Many of these facilities also accept off-site generated wastes for treatment. In other instances, the off-site waste streams originate from a company under a different ownership, an intercompany transfer. Since most of these facilities are already covered by an existing effluent guideline, coverage of these wastestreams is redundant. Monitoring, record keeping, etc. Currently, many companies operate a single, central treatment plant and transport waste from "satellite" facilities to the central treatment facility.
This allows for effective treatment while controlling costs. Additionally, many facilities transfer a specific wastestream to other company owned treatment systems intracompany that are designed for the most efficient treatment of that type of wastestream.
Only a small percentage of wastes treated are from off- site. EPA's database contains information on 17 manufacturing facilities which commingle waste generated by on-site manufacturing activities for treatment with waste generated off-site and one manufacturing facility which does not commingle waste generated by on-site manufacturing activities for treatment with waste generate off- site.
Nine of these facilities treat waste on a non- commercial basis only and nine treat waste on a commercial basis. Of the eighteen facilities, eight facilities only accept and treat off-site wastes which are from the same categorical process as the on-site generated wastestreams. Ten of the facilities, however, accept off-site wastes which are not subject to the same categorical standards as the on-site generated wastewater.
The percentage of off-site wastewaters being commingled for treatment with on-site wastewater varies from 0. The guidelines, as proposed in , would have included both types of facilities within the scope of this rule. EPA agrees that, for off-site wastes which are generated by the same categorical process as on-site generated wastes, intracompany and intercompany transfers are a viable and often preferable method to treat wastestreams efficiently at a reduced cost.
EPA does not want to discourage these management practices. EPA is still concerned, however, that the effluent limitations and categorical standards currently in place may not ensure adequate treatment in circumstances where the off-site generated wastes are not from the same categorical group as the on-site generated wastes.
Additionally, even though the primary business at these facilities is not the treatment of off-site wastes, EPA does not believe that the burden to these facilities exceeds that of the facilities whose primary business is the treatment of off-site wastes. EPA has included these facilities in all of its economic analyses. For purposes of developing its effluent limitations and pretreatment standards, EPA has included manufacturing facilities which accept off-site waste for treatment in all of its analyses unless the above mentioned conditions were met.
EPA contemplates that this approach would be implemented in the following manner. A facility that is currently subject to an ELG receives wastewater from off-site for treatment. The wastewater is commingled for treatment with wastewater generated on-site. If the off-site wastewater is subject to the same ELG as the onsite wastewater or would be if treated where generated , the CWT limitations would not apply to the discharge associated with the off-site wastewater flows.
In that case, another guideline or standard applies. If, however, the off-site wastewater is not subject to the same ELG or if none exist or if the off-site wastewater is not commingled with on-site wastewater for treatment, that portion of the discharge associated with off-site flow would be subject to CWT requirements.
The portion of the commingled or non-commingled wastewater associated with on- site generated wastewater remains subject to applicable limitations and standards for the facility. Alternatively, EPA is considering an option that requires manufacturing facilities that treat off-site wastes to meet all otherwise applicable categorical limitations and standards. This approach would determine limitations and standards for the off-site wastewater using the "combined waste stream formula" or "building block approach" see Chapter EPA envisions the second alternative would be preferable for facilities which only receive continuous flows of process wastewaters with relatively consistent pollutant profiles from no more than five customers.
The decision to base limitations in this manner would be at the permit writers discretion only. In addition, there are manufacturing facilities that may not currently be subject to any effluent limitations guidelines or pretreatment standards. Some of these may accept off-site wastewater that is commingled for treatment with on-site process wastewater.
The portion of the discharge resulting from the treatment of off-site flows would be subject either to CWT limitations and standards or to the same BPJ requirements as on-site flows. CWT limitations would apply if the off-site wastes treated at the facility were different from those generated on-site, whether or not the wastes were subject to existing guidelines and standards or would be, if treated at the site where generated. Alternatively, applying either a building block or combined wastestream formula approach, on-site wastewater would be subject to BPJ limits or standards and the off-site categorical wastewater subject to categorical limits for the industry generating the wastewater.
Pipeline Transfers Fixed Delivery Systems 3. At that time, EPA had concluded that facilities which receive all their wastes through a pipeline or trench fixed delivery systems from the original source of waste generation are receiving continuous flows of process wastewater with relatively consistent pollutant profiles.
As such, EPA concluded that these wastes differ fundamentally from those received at centralized waste treatment facilities it had studied as part of this rulemaking. The Agency received many comments on the proposal to limit the applicability of the proposed limits to wastewaters received other than by pipelines or fixed delivery systems.
Many commented that this approach is arbitrary and that the mode of transportation should not be the determining factor as to whether or not a facility is included in the scope of the rule. Commenters asserted that the character of the waste remains unchanged regardless of whether it is trucked or piped to another facility for treatment. Many also questioned EPA's conclusion that piped waste is more consistent in strength and treatability from typical CWT wastewaters studied for this proposal.
EPA has reevaluated the database for this rule. EPA received questionnaire responses from four centralized waste treatment facilities which receive their wastestreams solely via pipeline. Based on the OCPSF database, 16 additional facilities are treating wastewater received solely via pipeline from off-site for treatment. A review of the CWT and OCPSF databases supplemented by telephone calls to selected facilities reveals that one facility no longer accepts wastes from off-site, one facility is now operating as a POTW, and 11 facilities only accept off-site wastes that were generated by a facility within the same category as on-site generated waste.
The latter facilities, under the criteria explained above, would no longer be within the scope of the proposed rule because they are already subject to existing effluent guidelines and standards. Therefore, EPA identified 7 facilities which receive off-site wastes solely via pipeline which may be subject to this rulemaking.
Of these seven facilities, one is a dedicated treatment facility which is not located at a manufacturing site. The other six pipeline facilities are located at manufacturing facilities which are already covered by an existing ELG. All of the facilities are direct dischargers and all receive waste receipts from no more than five customers many receive waste receipts from three or fewer customers. Information collected during these site visits confirmed EPA's original conclusion that wastes received by pipeline are more consistent in strength and treatability than "typical" CWT wastewaters.
These wastewaters are traditional wastewaters from the applicable industrial category that generally remain relatively constant from day to day in terms of the concentration and type of pollutant parameters. Unlike traditional CWTs, their customers and wastewater sources do not change and are limited by the physical and monetary constraints associated with pipelines. EPA has also reviewed the discharge permits for each of these pipeline facilities. EPA found that, in all cases, permit writers had carefully applied the "building block approach" in establishing the facility's discharge limitations.
Therefore, in all cases, the treating facility was required to treat each of the piped wastewaters to comply with otherwise applicable effluent guidelines and standards. Consequently, based on the information it has obtained to date, EPA continues to believe that except as discussed below wastes that are piped to waste treatment facilities should be excluded from the scope of the CWT rule and covered by otherwise applicable effluent guidelines and standards.
The Agency has concluded that effluent limitations and pretreatment standards for centralized waste treatment facilities should not apply to pipeline treatment facilities. EPA believes that it is more appropriate for permit writers to develop limitations for treatment facilities that receive wastewater by pipeline on an individual basis by applying the "combined waste stream formula" or "building block" approach.
The one exception to this approach is for facilities which receive waste via conduit that is, pipeline, trenches, ditches, etc. These wastewaters would be subject to CWT. EPA has not identified any pipeline facility that is receiving waste from waste consolidators, but has received public comment that these facilities exist.
In the case of a pipeline treatment system, this may require that the permit writer include conditions in a permit issued to the pipeline treatment system and its users, as co- permittee, if necessary for the pipeline facility to comply with the applicable limitations. Alternatively, EPA may need to issue permits both to the private treatment works and to the users or require the user to file a permit application.
Product Stewardship 3. Many commenters on the proposal have defined "product stewardship" in this way: "taking back spent, used, or unused products, shipping and storage containers with product residues, off- specification products and waste materials from use of products. Manufacturing companies that cannot reuse the spent, used, or unused materials returned to them treat these materials in their wastewater treatment plant.
EPA received no specific information on these product stewardship activities in the responses to the Waste Treatment Industry Questionnaire. EPA obtained information on this program from comment responses to the CWT proposal and in discussions with industry since the proposal. As part of their comment to the proposal, the Chemical Manufacturer's Association CMA provided results of a survey of their members on product stewardship activities.
Based on these survey results, which are shown in Table 3. A small amount is classified as residual recycling and an even smaller amount is classified as drum take backs. Of the materials received, the vast majority is reused in the manufacturing process. With few exceptions, all of the materials which are not reused in the manufacturing process that are treated in the on- site wastewater treatment systems, appear to be from the same categorical group as the on-site manufactured materials.
Of these 33 members, 13 reported information concerning more than one product type, or activity. Therefore, the percentage of the total is based on 58 separate entries on the survey. In most of the instances stated in the product stewardship definition, manufacturing facilities are essentially taking back product which has not been utilized or has not been chemically altered.
In these cases where the treatment of these wastes would be subject to current guidelines or pretreatment standards, under the approach discussed in Section 3. EPA remains concerned, however, that there are circumstances in which used materials or waste products may not be compatible with the otherwise existing treatment system.
Therefore, EPA is not proposing to remove all product stewardship activities from the scope of this rulemaking. Those activities that involve used products or waste materials that are not subject to effluent guidelines or standards from the same category as the on-site generated wastes are subject to today's proposal.
Based on the information provided by manufacturing facilities, EPA believes that very few product stewardship activities would be subject to this rule. EPA's approach will not curtail product stewardship activities, in general, but will ensure that all wastes are treated effectively. Solids, Soils, and Sludges 3. EPA's sampling program also included facilities which accepted both aqueous and solid wastes for treatment. In fact, the facility which formed the technology basis for the metals subcategory limitations selected at the time of the original proposal treats both liquid and solid wastes.
Therefore, wastewater generated in the treatment of solids received from off-site would be subject to the CWT rule. As a further point of clarification, the main concern in the treatment or recycling of off-site "solid wastes" is that pollutants contained in the solid waste may be transferred to a process or contact water resulting in a wastewater that may require treatment.
The treatment or recovery of solids that remain in solid form when contacted with water and which do not leach any chemicals into the water are necessarily not subject to this rule. Examples of excluded solids recovery operations are the recycling of aluminum cans, glass and plastic bottles. Sanitary Wastes 3. Sanitary wastes such as chemical toilet wastes and septage are not covered by the provisions of the proposed CWT rule.
EPA would expect that, permit writers would develop Best Professional Judgment limitations or local limits to establish site-specific permit requirements for any commercial sanitary waste treatment facility. Similarly, sanitary wastes received from off- site and treated at an industrial facility or a centralized waste treatment facility are not covered by provisions of the CWT rule.
If these wastes are mixed with industrial wastes, EPA would expect that, as is the case now with ancillary sanitary waste flows mixed for treatment at categorical facilities, the pennit writer would establish Best Professional Judgment, site-specific pennit requirements. A facility which accepts a tank truck, rail tank car, or barge not considered to be empty for cleaning or treatment is not subject to the TEC Point Source Category, and may be subject to the provisions established for this rule.
There are some facilities which are engaged in traditional CWT activities and also engaged in traditional TEC activities. If the wastewaters from the two operations are commingled, under the approach adopted for the TEC proposal, the commingled TEC wastewater flow would be subject to CWT limits when promulgated. Therefore, a facility performing transportation equipment cleaning as well as other centralized waste treatment services that commingles these wastes is a centralized waste treatment facility.
All of the wastewater discharges are subject to provisions of this rule. If, however, a facility is performing both operations and the wastestreams are not commingled that is, transportation equipment cleaning wastewater is treated in one system and CWT wastes are treated in a second, separate system , both the TEC rule and CWT rules apply to the respective wastewaters. As a further point of clarification, the CWT proposal would subject transportation equipment cleaning wastes received from off-site to its provisions.
Transportation equipment cleaning wastes received from off-site that are treated at CWTs along with other off-site wastes are subject to provisions of this rule. As such, the CWT operation may be subject to provisions of this rule.
It is not a POTW itself even if the facility is located at the same site. In this case, the facility is operating as a centralized waste treatment facility and all discharges are subject to provisions of this rule. Based on the fundamental difference in technology used to recover silver at facilities devoted exclusively to treatment of photographic and x-ray wastes, the Agency has decided to defer proposing regulations for these facilities.
The precipitation processes to recover silver used as the basis for its metal limits including silver is different from that most widely used to recover silver at facilities that treat only silver bearing wastes -- electrolytic plating followed by metallic replacement.
Facilities which only perform centralized waste treatment silver recovery operations electrolytic plating followed by metallic replacement would not fall within the scope of today's proposal. Permit writers would use Best Professional Judgement or local limits to establish site-specific permit requirements.
Many commenters to the CWT proposal expressed concern over the inclusion in the metals subcategory of CWT operations that recover metals from used photographic materials and solutions and x-ray materials and solutions. Commenters were particularly concerned that they would be unable to meet the limitations established for silver in the metals subcategory.
In general, commenters stated that the scope of the proposed rule should not include these operations. Silver recovery facilities typically use electrolytic plating followed by metallic replacement with iron. This BAT treatment system does not reflect performance of facilities which solely treat silver-bearing wastes.
Many facility discharge permits are based on Part , effluent guidelines for non-ferrous metals manufacturing, Subpart L secondaiy silver subcategory. Based on information provided by the industry, EPA estimates that there are , photographic and image processing facilities which generate silver bearing wastes. Many of these facilities generate very small volumes of silver bearing waste which would not be economical or efficient to recover on site.
Thus, there exists a large potential for facilities to consolidate and treat silver bearing photographic waste from various sources. EPA believes that the off-site shipment of silver bearing photographic wastestreams for the purpose of consolidation and recovery is beneficial and does not wish to discourage this practice. EPA encourages the segregation of wastestreams as this leads to more efficient recovery.
EPA is aware that some of these consolidated wastestreams are treated at typical CWTs and some are treated at facilities which treat photographic wastestreams only. While EPA has promulgated effluent guidelines for non- ferrous metals manufacturing and the photographic point source categories 40 CFR , Subpart L and 40 CFR , respectively , the majority of these centralized silver recovery facilities are not currently subject to any effluent guideline. EPA agrees with proposal commenters that the BAT system selected at the time of the original proposal does not reflect performance of facilities which solely treat silver-bearing wastes.
Although the facility which formed the technology basis for the proposed BAT limitations was engaged in recovering silver from photographic wastestreams, EPA does not have information in its database on facilities which perform centralized waste treatment of photographic wastestreams only.
High Temperature Metals Recovery 3. EPA is aware of three facilities in the U. High temperature metals recovery facilities generally take solid forms of various metal containing materials and produce a remelt alloy which is then sold as feed materials in the production of metals. Based on questionnaire responses and industry comments, the HTMR process does not generate wastewater. For these reasons, the high temperature metals recovery operations have been excluded from provisions of the CWT rule.
Facilities which only perform high temperature metals recovery are not subject to this rule. Accordingly, EPA is also considering whether this rule, when promulgated, should include a subcategory for HTMR operations with a zero discharge requirement. There, EPA explains how it proposed to treat categorical facilities that mix and treat categorical wastewater with wastewater from on-site landfills.
EPA proposed to subject the mixed wastewater to the applicable categorical limits and not the proposed landfill limits. In the C WT industry, there are some facilities which are engaged both in CWT activities and in operating an on-site landfill s. EPA is proposing to evaluate the mixture of CWT wastewater and landfill wastewater in the same way considered for the proposed landfill guidelines. Therefore, a facility performing landfill activities as well as other centralized waste treatment services that commingles the wastewaters would be a centralized waste treatment facility and all of the wastewater discharges would be subject to the provisions of this rule when promulgated.
If a facility is performing both operations and the wastestreams are not commingled that is, landfill wastewaters are treated in one treatment system and CWT -wastewaters are treated in a second, separate, treatment system , the provisions of the Landfill rule and CWT rule would apply to their respective wastewaters.
Additionally, under the approach proposed for the Landfills rulemaking, centralized waste treatment facilities which are dedicated to landfill wastewaters only, whether they are located at a landfill site or not, would be subject to the effluent guidelines limitations and pretreatment standards for landfills when promulgated. These dedicated landfill centralized waste treatment facilities would not be subject to provisions of the centralized waste treatment rulemaking.
As a further point of clarification, landfill wastewaters are not specifically excluded from provisions of this rule. Landfill wastewaters that are treated at CWTs along with other off-site wastestreams are subject to provisions of this rule. Furthermore, a landfill that treats its own landfill wastewater and off-site landfill wastewater would be subject to the proposed Landfill limits when promulgated in the circumstance described in 3.
Industrial Waste Combustors 3. There, EPA explains how it proposed to treat categorical facilities that mix and treat categorical wastewater with wastewater from on-site industrial waste combustion. EPA proposed to subject the mixed wastewater to the applicable categorical limits and not the proposed industrial waste combustors limits.
In the CWT industry, there are some facilities which are engaged both in CWT activities and in industrial waste combustion. EPA is proposing to evaluate the mixture of CWT wastewater and industrial waste combustion wastewater in the same way considered for the proposed industrial waste combustors guidelines. Therefore, a facility performing industrial waste combustion activities as well as other centralized waste treatment services that commingles the wastewaters would be a centralized waste treatment facility and all of the wastewater discharges would be subject to the provisions of this rale when promulgated.
If a facility is performing both operations and the wastestreams are not commingled that is. Industrial waste combustor wastewaters that are treated at CWTs along with other off-site wastestreams are subject to provisions of this rule. Furthermore, an industrial waste combustor that treats off-site industrial waste combustor wastewater would be subject to the proposed Industrial Waste Combustor limits when promulgated in the circumstances described in 3.
This document defines solvent recovery as "the recycling of spent solvents that are not the byproduct or waste product of a manufacturing process or cleaning operation located on the same site. Traditional solvent recovery involves pretreatment of the wastestream in some cases and separation of the solvent mixtures by specially constructed distillation columns.
Wastewater discharges resulting from this process are subject to effluent limitations guidelines and standards for the organic chemicals industry 40 CFR As such, wastewaters resulting from traditional solvent recovery operations as defined above are not subject to this effluent guideline. Fuel blending is the second main operation which falls under the definition of solvent recovery.
Fuel blending is the process of mixing wastes for the purpose of regenerating a fuel for reuse. At the time of the proposal, fuel blending operations were excluded from the CWT rule since EPA believed the fuel blending process was "dry" that is, no wastewaters were produced.
Based on comments to the original proposal and the Notice of Data Availability, EPA has concluded that this is valid and that true fuel blenders do not generate any process wastewaters and are therefore zero dischargers. EPA is concerned, however, that the term "fuel blending" may be loosely applied to any process where recovered hydrocarbons are combined as a fuel product. Such operations occur at nearly all used oil and fuel recovery facilities. Therefore, fuel blending operations as defined above would be excluded from the CWT rule providing that the operations do not generate a wastewater.
In the event that wastewater is generated at a fuel blending facility, the facility is most likely performing some pretreatment operations usually to remove water. These pretreatment wastewaters would be subject to this rule. Re-refining 3. Consequently, the re-refining wastewater is included within the scope of this proposal.
The used oil reclamation and re-refining industry was studied by EPA in the s. Minor processors reclaimers generally separate water and solids from the used oil using simple settling technology, primarily in-line filtering and gravity settling with or without heat addition. Major processors reclaimers generally use various combinations of more sophisticated technology including screen filtration, heated settling, centrifugation, and light fraction distillation primarily to remove water.
Re-refiners generally use the most sophisticated systems which generally include, in addition to the previous technology, a vacuum distillation step to separate the oil into different components. This proposal applies to the process wastewater discharges from used oil re-refining operations. Used Oil Filter Recycling 3. However, in response to the September Notice of Data Availability, EPA received comments from facilities which recycle used oil filters.
In addition, EPA also visited several used oil reprocessors that recycle used oil filters as part of their operations. Used oil filter recycling processes range from simple crushing and draining of entrained oil to more involved processes where filters are shredded and the metal and filter material are separated.
In all cases, the oil is recycled, the crushed filters and separated metal are sent to smelters, and the separated filter material is recovered as solid fuel. Also, in all cases observed, the operations generate no process wastewater.
Therefore, based on this characterization, used oil filter recycling operations would be not be subject to the provisions of the CWT rule as proposed today. EPA is also considering whether this rule, when promulgated, should include a subcategory for used oil filter recycling with a zero discharge requirement for such operation. Marine Generated Wastes 3.
Since these wastes are often generated while a ship is at sea and subsequently off-loaded at port for treatment, the treatment site could arguably be classified as a CWT due to its acceptance of "off site wastes. If only the small portion of bilge water contained in the ship upon docking is subject to regulation, it would be expensive and inefficient to monitor only that small portion for compliance with the CWT rule.
EPA reexamined its database concerning these wastes as well as additional data on the characteristics of these types of wastes provided through comments to the proposal. Based on data provided by industry on bilge and ballast water characteristics, bilge and ballast water can vary greatly in terms of the breadth of analytes and the concentration of the analytes from one ship to another.
For purposes of this rule, EPA is defining a marine generated waste as waste generated as part of the normal maintenance and operation of a ship, boat, or barge operating on inland, coastal or open waters. Such wastes include wash water from equipment and tank cleaning, ballast water, bilge water, and other wastes generated as part of routine ship maintenance.
EPA has determined that a waste off-loaded from a ship shall be considered as being generated on-site at the point where it is off-loaded provided that the waste is generated as part of the routine maintenance and operation of the ship on which it originated.
The waste will not be considered an off-site generated waste as long as it is treated and discharged at the ship servicing facility where it is off-loaded. Therefore, these facilities would not be considered centralized waste treatment facilities. If, however, marine generated wastes are off- loaded and subsequently sent to a centralized waste treatment facility at a separate location, these facilities and their wastestreams would be subject to provisions of this rule.
Stabilization 3. The reason stated for EPA's conclusion was that these operations are "diy" and do not generally produce a wastewater. EPA reexamined its database and concluded that this assessment remains valid. EPA is also considering whether this rule, when promulgated, should include a subcategory for stabilization operations with a zero discharge requirement. Some of these wastes are from non- industrial sources and some are from industrial sources. Such facilities include restaurants, cafeterias, and caterers.
Wastewater discharges from the centralized treatment of wastes produced from oil interceptors, which are designed to collect petroleum-based oils, sand, etc. Several factors have contributed to the growth of this industry. A manufacturing facility's options for managing wastes include on-site treatment or sending them off-site. Because a large number of operations both large and small have chosen to send their wastes off-site, specialized facilities have developed whose sole commercial operation is the handling of wastewater treatment residuals and industrial process by-products.
Many promulgated effluent guidelines also encouraged the creation of these central treatment centers. Inconsistent treatment of facilities which send their waste off-site to CWTs in the guidelines program has resulted in wastewater that is treated off-site being subject to inconsistent standards. EPA acknowledges that this may have created a loop-hole for dischargers to avoid treating their wastewater to standards comparable to categorical standards before discharge.
Additionally, RCRA regulations, such as the used oil management requirements 40 CFR significantly influenced the size and service provided by this industry. Industry Size 4. As shown below in Table , the major concentration of centralized waste treatment facilities is in EPA Regions 4, 5 and 6 due to the proximity of the industries generating the wastes undergoing treatment. At the time of the original proposal, EPA estimated there were 85 centralized waste treatment facilities in the United States.
EPA, however, greatly underestimated the number of facilities in the proposed oily waste and recovery subcategory. Through additional data gathering activities see discussion in Chapter 2 , EPA obtained information on additional oils facilities. EPA is aware that facilities in the metals and organics subcategories have entered or left the centralized waste treatment market also.
This is expected in a service industry. Even so, EPA believes its initial estimate of facilities in the other subcategories is reasonable and no adjustments, other than those resulting from the redefined scope of the industry, have been made.
In preparing this reproposal, EPA conducted its analysis with the known facility specific information and then used the actual data to develop additional information to represent the Chapter 4 Description of the Industry Development Document for the CWT Point Source Category entire population. Unless otherwise stated, information presented in this document represents the entire population. Table provides an example where data is only presented for the facilities for which EPA has facility-specific information.
General Description 4. Some treat wastes from a few generating facilities while others treat wastes from hundreds of generators. Some treat only certain types of waste while others accept many wastes. Some treat non-hazardous wastes exclusively while others treat hazardous and non- hazardous wastes.
Some primarily treat concentrated wastes while others primarily treat more dilute wastes. For some, their primary business is the treatment of other company's wastes while, for others, centralized waste treatment is ancillary to their main business. At the time of the original proposal, a few of the facilities in the industry database solely accepted wastes classified as non-hazardous under RCRA.
The remaining facilities accepted either hazardous wastes only or a combination of hazardous and non-hazardous wastes. The vast majority of the newly identified oils facilities accept non-hazardous materials only. As such, EPA believes the market for centralized waste treatment of non-hazardous materials has increased during the s. EPA has detailed waste receipt information for the facilities in the Waste Treatment Industry Questionnaire data base.
As such, most of these facilities were able to use information reported in the Biennial Hazardous Waste Report to classify the waste accepted for treatment by the appropriate Waste Form and RCRA codes. Some questionnaire respondents, especially those that treat non-hazardous waste, did not report the Waste Form Code information due to the variety and complexity of their operations. EPA does not have detailed RCRA code and waste code information on waste receipts for the facilities identified after the original proposal.
It is known that the majority of these facilities accept non-hazardous wastes. Centralized waste treatment facilities service a variety of customers. A CWT generally receives a variety of wastes daily from dozens of customers. Some customers routinely generate a particular wastestream and are unable to provide effective on-site treatment of that particular wastestream.
Some customers utilize CWTs because they generate wastestreams only sporadically for example tank removal, tank cleaning and remediation wastes and are unable to economically provide effective on-site treatment of these wastes. Others, many which are small businesses, utilize CWTs as their primary source of wastewater treatment. Table Waste generators initially furnish the treatment facility with a sample of the waste stream to be treated.
The sample is analyzed to characterize the level of pollutants in the sample and bench-scale treatability tests are performed to determine what treatment is necessary to treat the waste stream. After all analyses and tests are performed, the treatment facility determines the cost for treating the waste stream.
If the waste generator accepts the cost of treatment, shipments of the waste stream to the treatment facility will begin. Generally, for each truck load of waste received for treatment, the treatment facility collects a sample from the shipment and analyzes the sample to determine if it is similar to the initial sample tested.
If the sample is similar, the shipment of waste will be treated. If the sample is not similar but falls within an allowable range as determined by the treatment facility, the treatment facility will reevaluate the estimated cost of treatment for the shipment.
Then, the waste generator decides if the waste will remain at the treatment facility for treatment. If the sample is not similar and does not fall within an allowable range, the treatment facility will decline the shipment for treatment. Treatment facilities and waste generators complete extensive amounts of paperwork during the waste acceptance process.
Most of the paperwork is required by Federal, State, and local regulations. The amount of paperwork necessary for accepting a waste stream emphasizes the difficulty of operating centralized waste treatment facilities. Water Use and Sources of Wastewater 4. It is difficult to determine the quantity of wastes attributable to different sources because facilities generally mix the wastewater prior to treatment.
EPA has, as a general matter, however, identified the sources described below as contributing to wastewater discharges at CWT operations that would be subject to the proposed effluent limitations and standards. Waste Receipts. Most off-site waste received by CWT facilities is aqueous.
These aqueous off- site waste receipts comprise the largest portion of the wastewater treated at C WTs. Typical waste receipts for the metals subcategory include but are not limited to: spent electroplating baths and sludges; spent anodizing solutions; metal finishing rinse water and sludges; and chromate wastes. Types of waste accepted for treatment in the oils subcategory include but are not limited to: lubricants, used petroleum products, used oils, oil spill clean-up, bilge water, tank clean out, off- specification fuels, and underground storage tank remediation waste.
Types of wastes accepted for treatment in the organics subcategory include, but are not limited to: landfill leachate; groundwater clean-up; solvent-bearing waste; off-specification organic products; still bottoms; used antifreeze; and wastewater from chemical product operations and paint washes. Solubilization Water.
A portion of the off-site waste receipts is in a solid form. Water may be added to the waste to render it treatable. Waste Oil Emulsion-Breaking Wastewater. The wastewater generated as a result of the emulsion breaking or gravity separation process from the processing of used oil constitutes a major portion of the wastewater treated at oils facilities. Water is used to clean the equipment used for transporting wastes. The amount of wastewater generated was difficult to assess because the wash water is normally added to the wastes or used as solubilization water.
Equipment Washes, Water is used to clean waste treatment equipment during unit shut downs or in between batches of waste. Water or acidic or basic solution is used in air emission control scrubbers to control fumes from treatment tanks, storage tanks, and other treatment equipment. Laboratory-Derived Wastewater. Water is used in on-site laboratories which characterize incoming waste streams and monitor on-site treatment performance.
Wastewater is generated at some CWT facilities as a result of on-site landfilling or incineration activities. Contaminated Stormwater. This is storm water which comes in direct contact with the waste or waste handling and treatment areas. If this contaminated CWT stormwater is introduced to the treatment system, its discharge is subject to the proposed limitations. The Agency is proposing not to regulate under the CWT guideline non-contact stormwater or contaminated stormwater not introduced to the treatment system.
Such flows may, in certain circumstances, require permitting under EPA's existing permitting program under 40 CFR CWTs that introduce non-contaminated stormwater into their treatment system will need to identify this as a source of non-CWT wastewater in their treatment system in their permit applications. This is necessary in order that the permit writer may take account of these flows in developing permit limitations that reflect actual treatment.
Volume by Type of Discharge 4. Some facilities utilize more than one option for example, a portion of their wastewater is discharged to a surface water and a portion is evaporated. Direct dischargers are facilities which discharge effluent directly to a surface water. Indirect dischargers are facilities which discharge effluent to a publicly-owned treatment works POTW.
Zero or alternative dischargers do not generate a wastewater or do not discharge to a surface water or POTW. The types of zero or alternative discharge identified in the CWT industry are underground injection control UIC , off-site transfer for further treatment or disposal, evaporation, and no wastewater generation. Table lists the number of facilities utilizing each discharge option. Average facility wastewater discharge information is presented in Table for the indirect and direct discharge options.
The proposed effluent limitations guidelines and standards for the CWT industry do not apply to facilities with a zero or alternative discharge. Major contributors to the growth of this industry include EPA decisions about how to structure its CWA effluent limitations guidelines program as well as the manner in which manufacturing facilities have elected to comply with CWA and RCRA requirements.
The CWA requires the establishment of limitations and standards for categories of point sources that discharge into surface waters or introduce pollutants into publicly owned treatment works. Such facilities include manufacturing or service facilities that generate no process wastewater, facilities that recycle all contaminated waters, and facilities that use some kind of alternative disposal technology or practice for example, deep well injection, incineration, evaporation, surface impoundment, land application, and transfer to a centralized waste treatment facility.
Thus, for example, in implementing CWA and RCRA requirements in the electroplating industry, many facilities made process modifications to conserve and recycle process wastewater, to extend the lives of plating baths, and to minimize the generation of wastewater treatment sludges.
As the volumes of wastewater were reduced, it became economically attractive to transfer electroplating metal-bearing wastewater to off-site centralized waste treatment facilities for treatment or metals recovery rather Chapter 4 Description of the Industry Development Document for the CWT Point Source Category than to invest in on-site treatment systems. In the case of the organic chemicals, plastics, and synthetic fibers OCPSF industry, many facilities transferred selected process residuals and small volumes of process wastewater to off- site centralized waste treatment facilities.
When estimating the engineering costs for the OCPSF industry to comply with the OCPSF regulation, the Agency assumed, based on economies of scale, in the case of facilities with wastewater flows less than gallons per day, such plants would use off-site rather than on-site wastewater treatment. The Agency believes that any wastes transferred to an off-site CWT facility should be treated to at least the same level as required for the same wastes if treated on-site at the manufacturing facility.
In the absence of appropriate regulations to ensure at least comparable or adequate treatment, the CWT facility may inadvertently offer an economic incentive for increasing the pollutant load to the environment. One of the Agency's primary concerns is the potential for a discharger to reduce its wastewater pollutant concentrations through dilution rather than through appropriate treatment.
This proposal is designed to ensure that wastes transferred to centralized waste treatment facilities would be treated to the same levels as on-site treatment or to adequate levels. This is illustrated by the information the Agency obtained during the data gathering activities for the proposal. EPA visited 27 centralized waste treatment facilities in an effort to identify well-designed, well-operated candidate treatment systems for sampling. Two of the principal criteria for selecting plants for sampling were based on whether the plant applied waste management practices that increased the effectiveness of the treatment system and whether the treatment system was effective in removing pollutants.
This effort was complicated by the level of dilution and co-dilution of one type of waste with another. For example, many facilities treated metal-bearing and oily wastes in the same treatment system and many facilities mixed non- CWT wastewater with CWT wastewater.
Of the 27 plants visited, many were not sampled because of the problems of assessing CWT treatment efficiencies due to dilution of one type of wastewater with another. This proposal would ensure, to the extent possible, that metal-bearing wastes are treated with metals control technology, that oily wastes are treated with oils control technology, and that organic wastes are treated with organics control technology. In developing this proposal, EPA identified a wide variation in the size of CWT facilities and the level of treatment provided by these facilities.
Often, pollutant removals were poor, and, in some cases, significantly lower than would have been required had the wastewaters been treated at the site where generated. In particular, EPA's survey indicated that some facilities were employing only the most basic pollution control equipment and, as a result, achieved low pollutant removals relative to that easily obtained through the use of other, readily available pollutant control technology.
Further, as explained below, EPA had difficulty in identifying more than a handful of facilities throughout the CWT industry that were achieving optimal removals. During consideration of this proposal, EPA looked at whether it should limit the scope of national regulation to facilities above a certain size or flow level because of information before the Agency suggesting, that, in the case of certain smaller facilities, the costs of additional controls would represent a significant increase in their costs of operation.
For the reasons explained Chapter 4 Description of the Industry Development Document for the CWT Point Source Category above, however, EPA has decided not to limit the scope of this proposal, based either on the size of a facility or the volume of wastewater flows. The effect of such an approach, given the structure of the industry and treatment level currently observed, would be effectively to encourage the movement of wastewater to some of the very facilities that are not providing treatment that is equivalent to that which would be expected and required if the wastewater were treated at the point of origin.
Since this proposal would ensure adequate controls for wastewater discharges from CWT facilities that accept waste and wastewater that would otherwise be controlled by other guidelines, all members of the CWT industry should comply with the national CWT standards regardless of size or potential economic impacts. Among others, these include the age of the equipment and facilities in the category, manufacturing processes employed, types of treatment technology to reduce effluent discharges, and the cost of effluent reductions Section b 2 b of the CWA, 33 U.
The statute also authorizes EPA to take into account other factors that the Agency deems appropriate. One way in which the Agency has taken some of these factors into account is by breaking down categories of industries into separate classes of similar characteristics. This recognizes the major differences among companies within an industry that may reflect, for example, different manufacturing processes or other factors.
One result of subdividing an industry by subcategories is to safeguard against overzealous regulatory standards, increase the confidence that the regulations are practicable, and diminish the need to address variations between facilities through a variance process Weyerhaeuser Co. Costle, F.
The centralized waste treatment industry, as previously explained, is not typical of many of the industries regulated under the CWA because it does not produce a product. Therefore, EPA considered certain additional factors that specifically apply to centralized waste treatment operations in its evaluation of how to establish appropriate limitations and standards and whether further subcategorization was warranted.
Additionally, EPA did not consider certain other factors typically appropriate when subcategorizing manufacturing facilities as relevant when evaluating this industry. EPA concluded that certain of these factors did not support further subcategorization of this industry. The Agency concluded that the age of a facility is not a basis for subcategorization as many older facilities have unilaterally improved or modified their treatment process over time.
EPA also decided that facility size was not an appropriate basis for subcategorizing. Where is the commission in forex trading? Investors who trade stocks, futures or options typically use a broker, who acts as an agent in the transaction. The broker takes the order to an exchange and attempts to execute it as per the customer's instructions. For providing this service, the broker is paid a commission when the customer buys and sells the tradable instrument.
The FX market does not have commissions. Unlike exchange-based markets, FX is a principals-only market. FX firms are dealers, not brokers. This is a critical distinction that all investors must understand. Unlike brokers, dealers assume market risk by serving as a counterparty to the investor's trade.
They do not charge commission; instead, they make their money through the bid-ask spread. In FX, the investor cannot attempt to buy on the bid or sell at the offer like in exchange-based markets. On the other hand, once the price clears the cost of the spread, there are no additional fees or commissions.
Every single penny gain is pure profit to the investor. Do and Don't in Forex Trading Forex trading is generally referred to as an exchange of currencies or what is commonly known as Foreign Exchange. It is not a game of bet like that of balls gaming or pony racing.
In no time traders can reap the fruits of good trade by timing their trade wisely. A new forex trader who is all set to begin trading in the market should be ready with a trading plan. The pillars of successful forex lies with sound knowledge and understanding of the entire Foreign Exchange Trade Lifecycle. In order to give a smooth start to their trade business, one should keep in mind the present monetary market scenario and study the dynamics and conduct basic research related to forex trade.
A new trader should always begin his trade at a time when the market shows a progressively growing or down 4. Prior to beginning a currency trade, he should always keep in mind the gain and loss ratio. Having a sound knowledge on the Fibonacci Analysis will help a trader to choose the best time of his entry or exit for starting a trade as it enables them to foresee the market fluctuations.
A detailed technical and fundamental study of the current trading patterns by using charts, continuation patterns or trend reversal will be beneficial for a new forex trader. A trader should be patient and should avoid impulsive decisions. They should not make hasty decisions in order to earn profits, but instead should gradually learn the trick of trading.
A forex trader who is not sure about the market trends should not risk their present capital 3. A trader should avoid indulging in trades during inactive market hours as this may incur heavy loss. It will be unwise for a new trader to trade with all his deposit,particularly when he does not have proper understanding of Forex trade. Even a small movement of the market will make him loose all the money on his deposit.
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Having plans for every likely scenario increases your chances of closing your trades without losses. Money is secondary. Concentrate on being a good trader and the money will follow. This is to warn himself not to add to a losing position, especially since you can always get back in.
Focusing on making money exposes you greed. Focus instead on keeping what you have while developing your trading skills. Simply put, making money in forex trading involves taking risks. The best you can do is to control your risk by placing strict risk management tools and by being flexible in your execution. The profitable trading methods and correlations today may not be what gets you pips next week.
Profitable traders know how to adapt to any trading environment. You could lose some or all your initial investment; do not invest money that you cannot afford to lose. Educate yourself on the risks associated with foreign exchange trading and seek advice from an independent financial or tax advisor if you have any questions. Clients and prospects are advised to carefully consider the opinions and analysis offered in the blogs or other information sources in the context of the client or prospect's individual analysis and decision making.
None of the blogs or other sources of information is to be considered as constituting a track record. Any news, opinions, research, data, or other information contained within this website is provided as general market commentary and does not constitute investment or trading advice.
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