NC0001899_correspondence_20161212

NcD1
Belnick, Tom
From: Belnick, Tom
Sent: Monday, December 12, 2016 6:11 PM
To: 'Styles, Laura'
Cc: Poupart, Jeff; Grzyb, Julie
Subject: RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Laura- still no news on this permit. Per DEQ directive, NPDES staff have continued to prioritize Duke Energy coal ash
permitting, with one remaining public hearing in 2016. Te?°re expiredis ponrJuly 3it au2016 est rlrenewal
recommend afrom
meeting
OCPSF to CWT operation will not occur until 2017. This permittional
to review your client's current plans in early 2017. Giventhe complexity
operate andTmapntai eratiosuch tdrleatme t system would
who will be operating the CWT facility and financial qualifications o
be beneficial. Please note that NC adopted dissolved metals water quality standards in 2016, and this change may have
a bearing on potential metals limits.
Finally, since I am retiring soon, I am copying Jeff Poupart and Julie Grzyb on this email, as they will be leads on this
permit request in 2017.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
[e-mail]
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
1111911
,„4. '...60,
MI IIP
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
lathing Compares.•..' -
From: Styles, Laura[mailto:[e-mail]]
Sent: Thursday, December 08, 2016 3:54 PM
To: Belnick, Tom <[e-mail]>
Cc: Bryant, Chan <[e-mail]>
Subject: RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Good afternoon Tom,
I just left you a voicemail but wanted to follow up with an e-mail If
it coo be provideeatly appreciated.nupdate
on the estimated
timeframe anticipated for the NPDES NC0001899 to be reviewed,

Regards,
Laura M. Styles, P.E.
414
WithersRavenet
Qvr People. Your Succcfs.
115 MacKenan Drive I Cary, NC 27511
Office: 919.469.3340 I Direct: 919.238.0377
lsh 1es:iilwithersravenel.com
MUDD
CONFIDENTIALITY AND NONDISCLOSURE
From: Styles, Laura
Sent: Monday, September 26, 2016 11:50 AM
To: 'Belnick, Tom' <[e-mail]>
Subject: RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
I appreciate your prompt response.
Laura
From: Belnick, Tom [ma ilto:[e-mail]]
Sent: Monday, September 26, 2016 11:48 AM
To: Styles, Laura <IstylesPwithersravenel.com>
Subject: RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Unfortunately it will likely be months. We are currently scheduled for 8 public hearings over the next 2 months.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
tom. belnick(a7ncdenr.gov
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
Nothing Compares, --
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Styles, Laurajmailto:[e-mail])
Sent: Monday, September 26, 2016 9:06 AM
To: Belnick, Tom <[e-mail]>
Cc: Wicker, Michael <MWickerPwithersravenel.com>; Bryant, Chan <[e-mail]>
Subject: RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Good morning Tom,
understand that you are currently backlogged, but would you be able to provide a rough timeline on when this permit
might be reviewed? Are we looking at a number of weeks or months? Any guesstimate would be appreciated. Thanks,
Laura M. Styles, P.E.
1
115 MacKenan Drive I Cary, NC 27511
Office: 919.469.3340 I Direct: 919.238.0377
1ttyles r withersravenel.cai
CONFIDENTIALITY AND NONDISCLOSURE
From: Belnick, Tom [mailto:[e-mail]]
Sent: Thursday, September 8, 2016 9:44 AM
To: Styles, Laura <[e-mail]>
Subject: RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Laura- due to staff shortages and other priorities, this permit request has not been started. Currently all staff are
working on Duke coal ash permits to meet imminent deadlines. Since this permit expired July 31, 2016, we will need to
incorporate the modification request (change from OCPSF to CWT operation) into the permit renewal. Let me know if
any questions.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
tom.belnickncdenr.gov
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669

ng
p
res
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Styles, Laurajmailto:[e-mail]]
Sent: Thursday, September 08, 2016 8:17 AM
To: Belnick, Tom <[e-mail]>
Subject: FW: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Good morning Tom,
Could you please provide an update on the above referenced permit review? Thanks,
Laura M. Styles, P.E.
115 MacKenan Drive I Cary, NC 27511
Office: 919.469.3340 I Direct: 919.238.0377
1stvles ri•withersravenel.com
CONFIDENTIALITY AND NONDISCLOSURE
From: Styles, Laura
Sent: Thursday, June 2, 2016 8:44 AM
To: '[e-mail]' <[e-mail]>
Cc: Wicker, Michael <[e-mail]>; 'Jason Kaplan' <[e-mail]>; Bryant, Chan
<[e-mail]>
Subject: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Good morning Tom,
Please find attached a request from Moncure Holdings West, LLC for an NPDES Permit Modification for the former
DFTDuraFiber Technologies, Inc. industrial site (formerly Performance Fibers, Inc.) near Moncure in Chatham County,
NC. Further explanation of the request can be found in the attached "160531 WithersRavenel Cover Letter." I have also
attached the project narrative for the permit modification request, a cover letter from Moncure Holdings West, LLC and
a copy of the check. Hard copies are to follow. Please do not hesitate to contact myself or Michael Wicker with any
questions you may have.
Regards,

NC of 1'' fl1ICM1 f-tiJJ
Belnick, Tom
/40 I A,
From:
Sent:
To:
Subject:
Belnick, Tom
Thursday, September 08, 2016 9:43 AM
'Styles, Laura'
RE: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Laura- due to staff shortages and other priorities, this permit request has not been started. Currently all staff are
working on Duke coal ash permits to meet imminent deadlines. Since this permit expired July 31, 2016, we will need to
incorporate the modification request (change from OCPSF to CWT operation) into the permit renewal. Let me know if
any questions.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
[e-mail]
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
isfothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Styles, Laura[mailto:[e-mail]]
Sent: Thursday, September 08, 2016 8:17 AM
To: Belnick, Tom <[e-mail]>
Subject: FW: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Good morning Tom,
Could you please provide an update on the above referenced permit review? Thanks,
Laura M. Styles, P.E.
115 MacKenan Drive I Cary, NC 27511
Office: 919.469.3340 I Direct: 919.238.0377
lstvles(ci withersravenel.com

CONFIDENTIALITY AND NONDISCLOSURE
From: Styles, Laura
Sent: Thursday, June 2, 2016 8:44 AM
To: '[e-mail]' <[e-mail]>
Cc: Wicker, Michael <[e-mail]>; 'Jason Kaplan' <[e-mail]>; Bryant, Chan
<[e-mail]>
Subject: NPDES NC0001899 Permit Modification - Moncure Holdings West, LLC
Good morning Tom,
Please find attached a request from Moncure Holdings West, LLC for an NPDES Permit Modification for the former
DFTDuraFiber Technologies, Inc. industrial site (formerly Performance Fibers, Inc.) near Moncure in Chatham County,
NC. Further explanation of the request can be found in the attached "160531 WithersRavenel Cover Letter." I have also
attached the project narrative for the permit modification request, a cover letter from Moncure Holdings West, LLC and
a copy of the check. Hard copies are to follow. Please do not hesitate to contact myself or Michael Wicker with any
questions you may have.
Regards,
Laura M. Styles, P.E.
115 MacKenan Drive I Cary, NC 27511
Office: 919.469.3340 I Direct: 919.238.0377
lstvles a lwithersravenel.com
CONFIDENTIALITY AND NONDISCLOSURE

NC0001899 Performance Fibers
Updated Historical TN/TP Loading for 2009-2012
mgd mg/I mg/I Ib/d Ib/d
Date Flow TN TP TN TP
Apr-09 0.098 6.1 0.5 4.99
Oct-09 0.057 3 0.7 1.43
Apr-10 0.049 3.8 0.4 1.55
Jul-10 0.075 6.4 1.4 4.00
0ct-10 0.06 10.1 0.5 5.05
Jan-11 0.04 2.7 0.3 0.90
Apr-11 0.049 9.5 1 3.88
Jul-11 0.071 8.5 1.4 5.03
Oct-11 0.034 4 0.3 1.13
Jan-12 0.035 1.5 0.9 0.44
Apr-12 0.035 10.1 0.7 2.95
JuI-12 0.031 9.8 1.8 2.53
Oct-12 0.011 2.6 0.4 0.24
0.05 AVG
20-N --eurot3 ofiCi
VG��u�� Ian S,i
001
0.41
0.33
0.16
0.88
0.25
0.10
0.41
0.83
0.09
0.26
0.20
0.47
0.04
rg 004
/ V4Iws pit Jevil 1 a0, /
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Berry; Ron
S A Utz° ciFr , use w
From: Langley, Shannon <[e-mail]>
Sent: Tuesday, August 30, 2016 4:23 PM
To: Weaver, John
Cc: Chernikov, Sergei; Baker, Richard E Jr; Wylie, Robert R; Cahoon, Steve; Berry, Ron; Grzyb,
Julie
Subject: Stream Flow characteristic request
Attachments: FW: Response from USGS concerning...Fwd: 7Q10 information
Curtis,
Thanks for chatting with me briefly this afternoon about a requests for low flow stream characteristics near a couple of
our facility's. There are a few additional points (3) that we want to obtain flow characteristics for to complete NPDES
permit activities with DEQ. I have asked Sergei Chernikov with NC DEQ (cc'd on this email) to be available to discuss
timing if you need to discuss that.
The locations we are requesting information for are as follows::
Suck creek in Cleveland County at point N 35°12' 36.82" W -81° 45' 15.10" . Request 7Q10(summer) and QA.
Shaddox Creek in Chatham County at point N 35° 35' 46.73" W -79° 02' 38.32" Need QA only. You provided 7Q10
data for this location two years ago (attached).
Cape Fear River in Chatham County at point N 35° 35' 31.61" w -79° 03' 06.21" Request 7Q10(summer) and QA for this
point if possible.
Thanks. I appreciate any assistance you can provide.
Shannon Langley
ef: eAcumon ut�le#
Lead Environmental Specialist
Duke Energy Corporation
Office: [phone]
Cell: [phone]
410 South Wilmington 15th floor, Raleigh, NC 27601
.., DUKE
ENERGY
From: Weaver, John [mailto:[e-mail]]
Sent: Friday, July 08, 2016 12:00 PM
To: Langley, Shannon
Cc: Dishmon, Joyce Martin; Baker, Richard E Jr; Newcomb, Dana H; John Weaver
Subject: Response from USGS concerning...Re: Stream Flow request
Mr. Langley,
1

In response to your inquiry about the low -flow characteristics for Railroad Branch in the vicinity of Eden in
northern Rockingham County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) does not indicate previous low -
flow detenninations for the lat/long coordinates (36.493 //-79.711, just above the mouth at the confluence with the Deep
River) provided via your email dated June 28, 2016. No USGS discharge records are likewise known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at ungaged locations
are determined by assessing a range in the low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby sites where
estimates have previously been determined.
A basin delineation completed for the point of interest using the USGS. StreamStats application for North Carolina
(http://water.usos.gov/osw/streamstats/north carolina.html) resulted in a drainage area at 0.83 sqmi.
For streams in Rockingham County, low -flow characteristics published by the USGS are provided in three reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow characteristics of streams
in North Carolina" (Giese and Mason, 1993). An online version of the report is available at http://pubs.usgs.gov/wsp/2403/report.pdf. The
report provides the low -flow characteristics (based on data through 1988) via regional relations and at -site values for sites with drainage
basins between 1 and 400 sqmi and not considered or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Roanoke River basin published in 1996. It is USGS Water -Resources
Investigations Report 96-4154, "Low -flow characteristics and profiles for selected streams in the Roanoke River Basin, North
Carolina" (Weaver, 1996). An online version of the report is available
through http://pubs.er.usos.gov/publication/wri964154. The report provides the low -flow characteristics (based on data through
1994) for continuous -record gaging stations and partial -record sites within the Roanoke basin. The report also provides low -flow
discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the reaches of Dan River and Roanoke River in North Carolina as
well as selected tributaries within the basin.
(3) The third is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001, "Low -flow
characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in North Carolina through 2012"
(Weaver, 2015). The report is available online at http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics
and flow -duration statistics for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum
of 10 climatic years discharge records were available for flow analyses.
Because the site is underlain by the Triassic basin geologic unit, the reports were examined for basins in Rockingham County and
southeastern Stokes County where a majority of the upstream basin was similarly underlain by the Triassic basin. Inspection of the second
report indicates the presence of four selected USGS partial -record sites in general vicinity of the point of interest where low -flow
characteristics were published. Among these 4 sites, the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 discharge ==> zero cfsm at all four index sites
Annual 30Q2 discharge ==> from 0.17 to 0.29 cfsm (average about 0.24 cfsm)
Annual W7Q10 discharge ==> from 0.17 and 0.27 cfsm (average about 0.22 cfsm)
Average annual discharge ==> 1.2 cfsm at all four index sites
Application of the above range in yields to the drainage area (0.83 sqmi) for the point of interest results in the following estimated low -flow
discharges:
Annual 7Q10 discharge ==> zero flow
Annual 30Q2 discharge ==> from 0.14 to 0.24 cfs (average about 0.20 cfs)
Annual W7Q10 discharge ==> from 0.14 to 0.22 cfs (average about 0.18 cfs)
Average annual discharge ==> estimated at 1 cfs
During our phone conversation, I commented to you that an estimate of the l Q10 would not be available because it requires an additional
analysis not typically completed as part of the low -flow requests received by the USGS in North Carolina. However, because the 7Q10
estimate for this point of interest is zero flow, the l Ql0 discharge would correspondingly be zero flow for the same point of interest.
Please understand the information provided in this message is based on a preliminary assessment and considered provisional, subject to
revision pending further analyses.
Hope this information is helpful.
2

Thank you.
Curtis Weaver
3. Curtis Weaver, Hydrologist, PE Email: jcweaver(dusas.gov
USGS South Atlantic Water Science Center Online: http://nc.water.usgs.gov/
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
On Tue, Jun 28, 2016 at 9:41 AM, Langley, Shannon <Shannon.Langleyaduke-energv.com> wrote:
Curtis,
Thanks for giving me a call back this morning. The email below contains the request we received from our NC
DEQ NPDES permit writer for flow characteristics of Railroad Branch in Rockingham County. The specific
point requested is very near the confluence of Railroad Branch and the Dan River. Specifically, the latitude and
longitude we are requesting flow characteristics for are 36.493, -79.711.
As indicated below, we would like to obtain 7Q10 (summer and winter), 30Q2 and QA for this point. I would
also like to obtain the 1 Q 10 if possible.
Please advise if any of those are not attainable.
Thanks for your assistance. I understand from our discussion that it may be the end of next week before you
can provide the information. That is fine.
Please let me know if there are any questions.
Thanks.
Shannon
3

eAaanon otaa0lee
Lead Environmental Specialist
Duke Energy Corporation
Office: [phone]
Cell: [phone]
410 South Wilmington 15th floor, Raleigh, NC 27601
DUKE
ENERGY
From: Chernikov, Sergei [mailto:[e-mail]]
Sent: Monday, June 27, 2016 9:15 AM
To: Langley, Shannon
Subject: question
*** Exercise caution. This is an EXTERNAL email. DO NOT open
attachments or click links from unknown senders or unexpected
email. ***
Shannon,
I received a Staff Report indicating that Seep 1, Seep 2, and Seep 3 at the Dan River station discharges to the
Railroad Branch. Please send a request to USGD to obtain 7Q10s, 7Q10w, 30Q2, and QA for this stream.
Thank you!
Sergei
Sergei Chernikov, Ph.D.
4

Berry, Ron
From: Ogallo, LeToya Fields <[e-mail]>
Sent: Tuesday, August 30, 2016 3:52 PM
To: Langley, Shannon
Subject: FW: Response from USGS concerning...Fwd: 7Q10 information
From: Weaver, John [mailto:[e-mail]]
Sent: Wednesday, August 27, 2014 11:36 AM
To: Ogallo, Letoya
Cc: Douglas Smith; John Weaver
Subject: Response from USGS concerning...Fwd: 7Q10 information
*** This is an EXTERNAL email. Exercise caution. DO NOT open attachments or click links from
unknown senders or unexpected email. ***
Ms. Ogallo,
In response to your inquiry about the 7Q10 low -flow discharge for an unspecified location on Shaddox Creek in Chatham
County, the following information is provided:
A check of the low -flow files here at the USGS North Carolina Water Science Center indicates previous determinations of
low -flow characteristics at various locations within the Shaddox Creek basin, and 7Q10 estimates for these sites were
estimated at zero flow.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square mile
drainage area, of cfsm) at nearby sites where estimates have been determined.
A drainage -area delineation completed at the mouth of Shaddox Creek using the USGS StreamStats application for North
Carolina(http://water.usgs.gov/osw/streamstats/north carolina.html) indicates the drainage area is 15.1 sqmi.
The most recent low -flow information published for streams within the Shaddox Creek basin in Chatham County is in a
basinwide low -flow report completed in 2001. It is USGS Water -Resources Investigations Report 01-4094, "Low -flow
characteristics and discharge profiles for selected streams in the Cape Fear River Basin, North Carolina, through 1998 "
(Weaver and Pope, 2001). An online version of the report is available
through http:/Inc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The report
also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and selected
tributaries within the basin.
When we receive a request for low -flow estimates, we ask the requester to provide information concerning the
specific location on the stream. Knowing the specific location on the stream allows us to determine the
drainage area, which is a variable used in the computations.
However, please be aware that my initial assessment of Shaddox Creek in vicinity of Moncure indicates the
entire basin is underlain by the Triassic basin geologic unit. From a hydrologic perspective, streams underlain
i

by this geologic unit have very little to no potentials for sustained base flows during extended dry periods. °At sites
underlain by the Triassic basin and where the USGS has collected sufficient records for low -flow analyses, the low -flow
characteristics for sites having drainage areas that would typically be expected to have sustained flows actually have
some of the lowest low -flow estimates in the state.
As stated above, previous 7Q10 estimates for sites in the Shaddox Creek basin have all been zero
flow. These observations are supported by the publication of zero -flow 7Q10 estimates in the above -referenced low -flow
report for six sites on nearby streams (with drainage areas ranging from 0.5 to 24 sqmi) in southwestern Wake County
also underlain by the Triassic basin.
Consideration of the above information results in a conclusion that the 7Q10 discharge for Shaddox
Creek is likely zero flow as far downstream as the mouth (station id 02098281, drainage area 15.1 sqmi).
Please understand the information provided in this message is based on a preliminary assessment and considered
provisional, subject to revision pending further analyses.
Hope this information is helpful.
Thank you.
Curtis Weaver
*************************************************************
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
E-mail address -- icweaver@'usgs.gov
Internet address -- http://nc.water.usgs.gov/
*************************************************************
Forwarded message
From: Smith, Douglas <[e-mail]>
Date: Tue, Aug 26, 2014 at 9:58 AM
Subject: Fwd: 7Q10 information
To: John Weaver <[e-mail]>
Curtis,
Would you please help answer this request from Duke Energy? Let me know if you need more info from me.
Thanks.
Doug
Forwarded message
From: Ogallo, Letoya <Letoya.Ogallo(ai,,duke-energv.com>
Date: Tue, Aug 26, 2014 at 9:02 AM
2

Subject: 7Q1Q information
To: "dgsmith(ausgs.gov" <[e-mail]>
Hi Doug,
.. i
Thanks for returning my phonecall. I have been trying to call you back but your voicemail box is full, so I
figured I would send you an email instead. I am trying to obtain 7Q10 statistics for Shaddox Creek in the Cape
Fear River basin. Please let me know if you need a map of the location or any other information.
Thanks in advance for your assistance,
Toya
Toya Ogallo Environmental Specialist
Duke Energy NPDES Permitting and Compliance
410 South Wilmington Street. Raleigh NC 27601
o: 919.546.6647 c: 919.608.1793 1 f: 919.546.4409
3

6/23/2016
Centralized Waste Treatment Effluent Guidelines I Effluent Guidelines I US EPA
Aytrn[y
Effluent Guidelines
Centralized Waste Treatment Effluent Guidelines
Rule Summary
EPA promulgated the Centralized Waste Treatment (CWT) Effluent Guidelines
and Standards (40 CFR Part 437) in 2000 and amended the rule in 2003. The
regulations cover discharges from facilities that treat or recover metal -bearing,
oily, and organic wastes, wastewater, or used material received from off -site. The
CWT Effluent Guidelines and Standards are incorporated into NPDES (National
Pollutant Discharge Elimination System) permits for direct dischargers, and
permits or other control mechanisms for indirect dischargers (see Pretreatment
Program).
On this page:
• What is Centralized Waste Treatment?
• Facilities Covered
• Compliance Assistance
• Study of CWT and Oil & Gas Wastewater — 2014-16
• Rulemaking History
• Additional Information
What is Centralized Waste Treatment?
The centralized waste treatment industry handles wastewater treatment residuals
and industrial process by-products that come from other industries. CWT facilities
receive a wide variety of hazardous and non -hazardous industrial wastes for
treatment. Many of the wastes contain very high pollutant concentrations and are
unusually difficult to treat.
CWT facilities typically fall within NAICS (North American Industrial
Classification System) codes 562211 (hazardous waste treatment and disposal),
562219 (other nonhazardous waste treatment and disposal) and 562920 (materials
recovery facilities).
Facilities Covered
The CWT Effluent Guidelines apply to facilities in four subcategories:
https://www.epa.gov/eg/centralized-waste-treatment-effluent-guidelines 1/4

6/23/2016 Centralized Waste Treatment Effluent Guidelines l Effluent Guidelines US EPA
A. Metals Treatment and Recovery
B. Oils Treatment and Recovery
C. Organics Treatment and Recovery
D. Multiple Wastestreams
Examples of discharges covered by the regulation:
• Discharges from stand-alone waste treatment and recovery facilities
receiving materials from off site. These facilities may treat hazardous or
non -hazardous waste, hazardous or non -hazardous wastewater, and/or used
material from off site, for disposal, recycling or recovery.
• Certain discharges from waste treatment systems at facilities primarily
engaged in other industrial operations. Thus, industrial facilities which
process their own, on -site generated, process wastewater with hazardous or
non -hazardous wastes, wastewaters, and/or used material received from off
site, in certain circumstances, may be subject to this category with respect
to a portion of their discharge.
Covered wastestreams include materials received from off -site, solubilization
water, used oil/emulsion breaking wastewater, tanker truck/drum/roll-off box
washes, equipment washes, air pollution control waters, laboratory -derived
wastewater, wastewater from on -site industrial waste combustors, landfills, and
contaminated stormwater.
The CWT category does not apply to:
.16
• operations at facilities which are subject to other effluent guidelines
categories and which receive wastes from off -site for treatment or recovery
that are subject to the same effluent guidelines as the on -site generated
wastes
• operations at facilities which receive off -site wastes whose nature and
treatment are compatible with the treatment of on -site non-CWT wastes
perations engaged exclusively in landfilling and/or the treatment of
andfill wastewaters, whether generated on- or off -site (See also the
Landfills Effluent Guidelines, 40 CFR Part 445)
Facilities that treat wastewater that results from cleaning tanker trucks, rail tank
cars, or barges may be subject to the CWT effluent guidelines if not subject to the
Transportation Equipment Cleaning Effluent Guidelines (40 CFR Part 442).
See the applicability and definitions sections in 40 CFR Part 437 for complete
descriptions of coverage and exclusions.
Compliance Assistance
• Small Entity Compliance Guide (2001)
A plain language explanation of how to comply with the CWT regulation;
with Frequently Asked Questions (2003 and 2006)
https://www.epa.gov/eg/central ized-waste-treatm ent-effl uent-gui deli nes
2/4

6/23/2016
Centralized Waste Treatment Effluent Guidelines I Effluent Guidelines I US EPA
Study of CWT and Oil & Gas Wastewater — 2014-
16
EPA is conducting a study of CWT facilities accepting oil and gas extraction
wastewater. EPA solicits data and information related to the extent to which CWT
facilities accept such wastewater, available treatment technologies (and their
associated costs), discharge characteristics, financial characteristics of CWT
facilities, the environmental impacts of discharges from CWT facilities, as well as
any other information believed to be relevant to EPA's study of this issue.
Rulemaking History
You will need Adobe Reader to view some of the files on this page. See EPA's
About PDF page to learn more.
• 2003 Amendment
Deleted limitations for several pollutants; revision to BOD limitation.
o Final Rule - Federal Register Notice (PDF) (13 pp, 208K)
(12/22/2003)
• Fact Sheet
o Proposed rule - Federal Register Notice (PDF) (14 pp, 201K)
(9/10/2003)
• 2000 Initial Rulemaking
o Final rule - Federal Register Notice (PDF) (72 pp, 571K)
(12/22/2000)
• Support documents, including:
• Fact sheet
• Development Document
Describes industry processes, pollutants generated,
available control & treatment technologies, the technical
basis for the final rule, and costs of the rule
• Environmental Assessment
Evaluates environmental effects, human health impacts
and impacts on publicly owned treatment works from
wastewater discharges by CWT facilities, and estimates
the benefits associated with the final rule
o Proposed Rule - Federal Register Notice (PDF) (78 pp, 665K)
(1/13/1999)
Additional Information
For additional information regarding the CWT Effluent Guidelines, please contact
Jesse Pritts, [e-mail] or 202-566-1038.
https://www.epa.gov/eg/centralized-wastetreatm ent-effluent-gui del i nes
3/4

Oil Skimmers - Oil Water Separators - Industrial Wastewater Treatment
Page 1 of 1
Caring for the Environment
...Today and Tomorrow
OIL/WATER SEPARATORS
The SKIMSTER® OWS
THE SKIMSTER®
FLOATING OIL SKIMMER
INDUSTRIAL WASTEWATER
TREATMENT EQUIPMENT
SOIL VAPOR EXTRACTION
SYSTEMS
LIQUID HANDLING EQUIP._
& REPLACEMENT PARTS
♦ WASTEWATER TREATMENT/
SOLIDIFICATION PROGRAM
CWT Permit
CWT Wastewater Guide
Waste Material Profile
PRODUCT DESTRUCTION
SERVICES
CONTACT US
CWT Permit
meter Treatment Solutions
336.727.4644
On July 1, 2002, HOH Corporation located at 1701 Vargrave Street, Winston-Salem, NC was issued a Centralized
Waste Treatment (CWT) Permit. We believe HOH Corporation is one of only a few commercial industrial
pretreatrnent facilities in the Mid -Atlantic United States to receive this required permit set forth by US EPA / CLEAN
WATER ACT of December 2000. (All existing and new wastewater facilities must comply with these new CWT
guidelines by December 22, 2003.)
What is a CWT Facility?
A CWT facility is one that accepts for treatment and/or recovery used industrial materials generated off -site (at
another location). These used materials may be hazardous, non -hazardous, solid, or liquid. (Note: HOH
Corporation accepts non -hazardous waste only at its Winston-Salem, NC facility.)
What is the CWT Rule and What Does It Require?
The CWT Rule contains effluent limitations guidelines and standards for the CWT industry. These are numerical
restrictions that are applied to the discharge of wastewaters from CWT facilities to waters of the U.S. or into a
local POTW. HOH Corporation is authorized to discharge treated wastewater meeting the CWT /local municipality
effluent limitations to the City of Winston-Salem, NC sanitary sewer and municipal wastewater system.
US EPA developed different effluent limitations and standards for the CWT operations depending on the type of
waste received by the CWT. There are four types, or subcategories of wastewater:
Subcategory A: Facilities that treat or recover metal from metal -bearing waste, wastewater, or used material
received from off -site;
Subcategory B: Facilities that treat or recover oil form oily waste, wastewater, or used material received from
off -site;
Subcategory C: Facilities that treat or recover organics from organic waste, wastewater, or used material
received from off -site;
Subcategory D: Facilities that treat or recover some combination of metal -bearing, oily, or organic waste,
wastewater, or used material received from off -site.
HOH Corporation elected to comply with the Subcategory D limitations (metal -bearing, oily, and organic
wastewater). CWT rule requires the facility (HOH) to demonstrate equivalent treatment for all subcategories of
wastewater. HOH has the equipment at its Winston-Salem facility to treat Subcategory D waste streams. HOH's
treatment system includes the following:
Physical/Chemical Treatment (Batch System & Flow-Thru)
Carbon Filtration
Bag Filtration
Oil / Water Separation
Ultra Filtration
Nano Filtration
Alar Rotary Vacuum System
Filter Press
As you can see, HOH Corporation with its many treatment options and capabilities listed above has invested time
and money over the past few years to qualify and earn this CWT Permit. We have prepared ourselves more than
any other wastewater facility in the area to handle all your Non -Hazardous wastewater treatment needs.
Please don't hesitate to call HOH [phone] with any questions or comments you may have regarding our
wastewater treatment services or your own facility wastewater treatment concerns. (HOH also designs,
manufactures and installs wastewater systems & oil / water separators.) We have the knowledge and experience
to assist you with all your wastewater service and equipment needs.
Home :: Company :: Oil/Water Separators :: The SKIMSTER® Floating oil Skimmer
Industrial WastewaterTreatment Equipment :: Soil Vapor Extraction Systems
Liquid Handling Equip. & Replacement Parts :: Wastewater Treatment/Solidification Program
Product Destruction Services :: Contact Us
HOH Corporation :: 1701 Vargrave St. :: Winston-Salem, NC 27107 :: v. 336.727.4644 :: f. 336.727.8840
© 2011 HOH Corporation. All Rights Reserved. Web Services by iComDeslan.com
http://www.hohcorp.com/wastewater treatment solidification cwt_permit.php 6/29/2016

'-yrro 1 "EPA I'Nitk -•jo l CW r"
1Jniicd States ()Bice EPA 821-R410-020
EuvironniceLtl l'rot c o❑ (4303) August 2000
Agency
aEPA Development Document for
Effluent Limitations
Guidelines and Standards for
the Centralized Waste
Treatment Industry — Final

EXECUTIVE SUMMARY
This technical development document
describes the technical bases for the final
Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance
Standards for the Centralized Waste Treatment
(CWT) Industry Point Source Category. The
regulation (40 CFR Part 437) establishes
technology -based effluent limitations guidelines
and standards to reduce the discharge of
pollutants into waters of the United States and
into publicly owned treatment works (POTWs)
by existing and new facilities that treat or recover
hazardous or non -hazardous industrial waste,
wastewater, or used material from off- site.
Although the numerical effluent limitations and
standards are based on specific processes or
treatment technologies to control pollutant
discharges, EPA does not require dischargers to
use these technologies. Individual facilities may
meet the numerical requirements using whatever
types oftreatment technologies, process changes,
and waste management practices they choose.
The regulation controls discharges from the
treatment and recovery of metal -bearing waste
receipts, oily waste receipts, and organic waste
receipts. The wastewater flows covered by the
rule include both off -site and on -site generated
wastewater. This includes materials received
from off -site, solubilization water, used
oil/emulsion breaking wastewater, tanker
truck/drum/roll-off box washes, equipment
washes, air pollution control waters, laboratory -
derived wastewater, wastewater from on -site
industrial waste combustors and landfills, and
contaminated stormwater.
EPA developed different limitations and
standards for the CWT operations depending on
the type of waste received for treatment or
recovery. EPA established four subcategories
for the CWT industry:
• Subcategory A: Facilities that treat or
recover metal from metal -bearing waste,
wastewater, or used material received from
off -site ("metals subcategory");
• Subcategory B: Facilities that treat or
recover oil from oily waste, wastewater, or
used material received from off -site ("oils
subcategory");
• Subcategory C: Facilities that treat or
recover organics from organic waste,
wastewater, or used material received from
off -site ("organics subcategory");
• Subcategory D: Facilities that treat or
recover some combination of metal -bearing,
oily, and organic waste, wastewater, or used
material received from off -site ("multiple
wastestream subcategory").
The multiple wastestream subcategory simplifies
implementation of the rule and compliance
monitoring for CWT facilities that treat wastes
subject to more than one of Subcategories A, B,
and C. These facilities may elect to comply with
the provisions of the multiple wastestream
subcategory rather than the applicable provisions
of subcategories A, B, or C. However, these
facilities must certify that an equivalent treatment
system is installed and properly designed,
maintained, and operated.
Executive Summary-1

Executive Summary Development Document for the CWT Point Source Category
BEST PRACTICABLE CONTROL
TECHNOLOGY CURRENTLY AVAILABLE
(BPT)
Est
The technology basis for the metals
treatment and recovery subcategory BPT
limitations is primary chemical precipitation,
liquid -solid separation, secondary chemical
precipitation, clarification, and sand filtration.
For facilities that accept concentrated cyanide,
metal -bearing wastestream, the rule is based on
in -plant cyanide removal prior to metals
treatment. The technology basis for in -plant
cyanide control is alkaline chlorination in a two-
step process.
The technology basis for the oils treatment
and recovery subcategory BPT limitations is
emulsion breaking/gravity separation, secondary
gravity separation and dissolved air flotation.
The technology basis for the organics
treatment and recovery subcategory BPT
limitations is equalization and biological treatment
(sequential batch reactor).
The BPT model technology long-term
averages and effluent limitations for the metals,
oils, and organics subcategories are listed in
Table 1. The model technology long-term
averages should be considered as design and
operating targets — presented for informational
purposes only. They are not effluent limitations
and do not appear in 40 CFR Part 437. The
long-term averages used in developing the
effluent limitations are values that plants should
design and operate to achieve on a consistent
average basis. Plants that do this and maintain
reasonable control over their operating and
treatment system variability should have no
difficulty in meeting the limitations. Plants that
operate above the long-term averages must
achieve good control of their treatment system
variability to meet the limitations.
The BPT limitations for the multiple
wastestream subcategory are subdivided into
four segments. Each segment applies to one of
the possible combinations of the first three
subcategories of wastestreams. The multiple
wastestream subcategory limitations were
derived by combining BPT pollutant limitations
from each possible combination of subcategories
and selecting the most stringent pollutant value
where they overlap'. Therefore, the technology
bases for the multiple wastestream subcategory
limitations reflect the technology basis for each
applicable subcategory as detailed above. These
limits may only apply to those facilities that
accept wastes in multiple subcategories and elect
to comply with the requirements of the multiple
wastestream subcategory.
The BPT multiple wastestream long-term
averages and limitations are listed in Table 2 for
mixtures of:
• metal -bearing, oils, and organics waste
receipts,
• metal -bearing and oils waste receipts,
• metal -bearing and organics waste receipts,
and
• oils and organics waste receipts.
BEST CONVENTIONAL POLLUTANT
CONTROL TECHNOLOGY (BCT) Es 2
The BCT effluent limitations for the
conventional pollutant parameters (BOD5, O&G,
and TSS) are equivalent to the BPT limitations
listed in Tables 1 and 2 for all subcategories.
BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE (BAT) Es.3
The BAT effluent limitations for the priority
and non -conventional pollutants are equivalent to
the BPT limitations listed in Tables 1 and 2 for
all subcategories.
1EPA selected the most stringent maximum
monthly average limitations and its corresponding
maximum daily limitation.
Executive Summary-2

Executive Summary Development Document for the CWT Point Source Category
NEW SOURCE PERFORMANCE STANDARDS
(NSPS) Es 4
For the oils and the organics subcategories,
NSPS standards for the conventional, priority,
and non -conventional pollutants are equivalent to
the BPT/BCT/BAT limitations.
For the metals subcategory, NSPS standards
are based on the recovery of metals for reuse
through selective metals chemical precipitation,
liquid -solid separation, secondary chemical
precipitation, liquid -solid separation, and tertiary
chemical precipitation and clarification. For in -
plant cyanide control of concentrated cyanide
wastes, the in -plant technology basis is alkaline
chlorination in a two-step process. The NSPS
long-term averages and standards for the metals,
oils, and organics subcategories are listed in
Table 3.
As was the case for BPT/BCT/BAT, the
NSPS standards for the multiple wastestream
subcategory are subdivided into four segments.
The technology basis for the NSPS standards for
the multiple wastestream subcategory reflect the
technology bases for the applicable
subcategories. The NSPS multiple wastestream
long-term standards are listed in Table 4.
PRETREATMENT STANDARDS FOR EXISTING
SOURCES (PSES) • Es.5
PSES standards are established for those
BAT pollutants that are determined to pass
through or otherwise interfere with the
operations of publicly owned treatment works
(POTWs). For the metals and organics
subcategories the priority and non -conventional
pollutant PSES standards are based on the same
technology as the BPT/BAT limitations for those
pollutants that pass through POTWs..
For the oils subcategory, the technology
basis for PSES is emulsion breaking/gravity
separation, and dissolved air flotation. The
PSES long-term averages and standards for the
metals, oils, and organics subcategories are listed
in Table 5.
The PSES standards for the multiple
wastestream subcategory are also subdivided into
four segments. The technology basis for
pretreatment standards for the multiple
wastestream subcategory reflect the technology
bases for the applicable subcategories. The
PSES multiple wastestream long-term averages
and standards are listed in Table 6.
PRETREATMENT STANDARDS FOR NEW
SOURCES (PSNS) ES. 6
For the metals and organics subcategories,
the technology bases for PSNS are equivalent to
PSES. For the oils subcategory, the technology
basis is equivalent to BPT/BAT. The PSNS
long-term averages and standards for those
pollutants that are determined to pass through
POTWs are listed in Table 7 for the metals, oils,
and organics subcategories .
The PSNS standards for the multiple
wastestream subcategory are subdivided into
four segments. The technology bases for the
multiple wastestream subcategory new source
standards reflect the technology bases for the
applicable subcategories. The PSNS multiple
wastestream long-term averages and standards
are listed in Table 8.
Executive Summary-3

Chapter 14 Implementation Development Document for the CWT PointSource Category
ESTABLISHING LIMITATIONS AND
STANDARDS FOR FACILITY DISCHARGES 14.8
In establishing limitations and standards for
CWT facilities, the permit writer or control
authority must ensure that the CWT facility has
an optimal waste management program. First,
the permit writer or control authority should
verify that the CWT facility is identifying and
segregating waste streams to the extent possible
since segregation of similar waste streams is the
first step in obtaining optimal mass removals of
pollutants from industrial wastes. Next, the
permit writer or control authority should verify
that the CWT facility is employing treatment
technologies designed and operated to optimally
treat all off -site waste receipts. For example,
biological treatment is inefficient for treating
concentrated metals waste streams like those
found in the metals subcategory or wastestreams
with oil and grease compositions and
concentrations like those found in the oils
subcategory. In fact, concentrated metals
streams and high levels of oil and grease
compromise the ability of biological treatment
systems to function. Likewise, emulsion
breaking/gravity separation, and/or dissolved air
flotation is typically insufficient for treating
concentrated metals wastewaters or wastewaters
containing organic pollutants which solubilize
readily in water. Finally, chemical precipitation
is insufficient for treating organic wastes and
waste streams with high oil and grease
concentrations.
Once the permit writer or control authority
has established that the CWT facility is
segregating its waste receipts and has appropriate
treatment technologies in place for all off -site
waste receipts, the permit writer or control
authority can then establish limitations or
standards which ensure that the CWT facility is
operating its treatment technologies optimally.
Available guidance in calculating NPDES
categorical limitations for direct discharge
facilities can be found in the U.S. EPA NPDES
Permit Writers' Manual (December 1996, EPA-
833-B-96-003). Sources of information used for
calculating Federal pretreatment standards for
indirect discharge facilities include 40 CFR Part
403.6, the Guidance Manual for the Use of
Production -Based Pretreatment Standards and
the Combined Waste Stream Formula
(September 1985), and EPA's Industrial User
Permitting Guidance Manual (September 1989).
The CWT limitations and standards for each
subcategory are listed in Tables 1 through 8 of
the Executive Summary at the beginning of this
document.
Implementation for Facilities in
Multiple CWT Subcategories 14.8.1
EPA estimates that many facilities in the
CWT industry accept wastes in two or more
subcategories (a combination of wastes in
Subcategory A, B or C). This situation is
different from the case in which metal -bearing
waste streams may include low-level organic
pollutants or that oily wastes may include low
level metal pollutants due to the origin of the
waste stream accepted for treatment.
For these multi -subcategory CWT facilities
which combine subcategory wastes prior to
discharge, guidance provided during development
of this rule required that control authorities
apply either the building block approach (see
Section 14.8.4.1) or the combined waste stream
formula (see Section 14.8.4.2) as appropriate to
develop combined limitations or standards.
As promulgated, however, neither the
building block approach nor the combined waste
stream formula apply in developing limitations or
standards for multi -subcategory CWT facilities.
Rather, multiple subcategory facilities may
comply with this rule in one of two ways: 1)
facilities may elect to comply with the limitations
or standards for each applicable subcategory
directly following treatment (before commingling
with different subcategory wastes); or 2) facilities
may certify equivalent treatment and comply
14-18

Chapter 14 Imp1ementation Development Document for the CWT Point Source Category
with one of the four sets of limitations or
standards for the multiple wastestream
subcategory (Subcategory D). Each of these
options is discussed further below.
Comply with Limitations or Standards
for Subcategory A, B or C 14.8.1.1
If a CWT facility elects to comply with each
applicable subcategory's limitations or standards
individually, the permit writer or control
authority should establish compliance monitoring
for each applicable subcategory directly following
treatment of each subcategory's waste steam
(and apply the appropriate limitations or
standards at that point). As a further point of
clarification, the permit writer or control
authority should not allow CWT facilities to
commingle waste streams from different
subcategories prior to monitoring for compliance
with each subcategory's limitations or standards.
Example 14-1 illustrates this approach. EPA
notes that multiple subcategory facilities which
elect to comply with each applicable
subcategory's limits or standards individually do
not have to demonstrate equivalent treatment
(see Section 14.8.1.2).
Example 14-1
FacilityA accepts wastes in all three CWT subcategories with separate subcategory
treatment systems and has elected to comply with each set ofpretreatment standards
separately. This facility treats 20,000 1/day of metal -bearing wastes, 10,000 1/day
of oily wastes, and 45,000, 1/day of organic wastes and discharges to its local
POTW.
Metals Waste
20,000 L/day
Metals
Treatment
Sample
Point 1
Oils Waste
10,000 L/day
Sample
Point 2
Organics Waste
45,000 L/day
Organics
Treatment
Sample
Point 3
Figure 14-2. Facility Accepting Waste in All Three Subcategories With Treatment in Eaci
14-19

Chapter 14 Implementation Development Document for the CWT Point Source Category
For this example, the control authority establishes monitoring points 1, 2, and 3. The control
authority requires that the facility comply with the metals subcategory pretreatment standards
at Sample Point 1, the oils subcategory pretreatment standards at Sample Point 2, and the
organics subcategory pretreatment standards at Sample Point 3. Note that the specific analytes
requiring compliance monitoring vary at each sampling point since the pollutants regulated vary
among subcategories.
Comply with Limitations or Standards
for Subcategory D 14.8.1.2
If a multi -subcategory CWT facility elects to
comply with the limitations or standards for
Subcategory D, then the permit writer or control
authority establishes a single monitoring point
prior to discharge and applies the appropriate set
of limitations or standards from Subcategory D
(for example, if a CWT facility accepts wastes in
both the metals and oils subcategory, the permit
writer or control authority establishes limits or
standards for Subcategory D facilities which
commingle wastes from Subcategories A and B).
Examples 14-2 and 14-3 illustrate this approach.
EPA notes that under this approach, the permit
writer or control authority must allow a multi -
subcategory facility to commingle wastestreams
prior to discharge. Also, facilities which select
this compliance method must first establish
equivalent treatment as detailed in Section
14.8.1.2.1 below.
14-20

Chapter 14 Implementation Development Document for the CWTPoint Source Cate • ori•
Example 14-2
Facility B accepts wastes in all three CWT subcategories with separate subcategory
treatment systems and has elected to comply with Subcategory D pretreatment standards
at a combined outfall. This facility treats 20,000 l/day of metal -bearing wastes, 10,000
1/day of oily wastes, and 45,000 1/day of organic wastes and discharges to its local
POTW.
Metals Waste
2 ft000lfday
Mils
Treatment
Olds Wad
10;000Zlday
Os
Ti anent
Organics Waste
43, 0001,/day
Organics
Treatment
v
75,000 L/day
Figure 14-3. Factlt4v Accepting Warta in All Three &ubcatagortar With Treatment in. Feel
And G"oneb ed Outfafi
For this example, the control authority establishes a single monitoring point as indicated. The
control authority requires the facility to comply with Subcategory D pretreatment standards for
facilities which commingle wastes from Subcategory A, B, and C.
14-21

Chapter 14 Implementation Development Document for the CWT Point Source Category
Example 14-3. Facility Which Accepts Wastes in Multiple Subcategories and Treats the
Wastewater Sequentially
Facility C accepts waste in the oils and metals subcategory. The total volume of
wastewater discharged to the local POTW is 100,000 liters per day. The facility
segregates oils and metals waste receipts and first treats the oils waste receipts
using two stage emulsion breaking/gravity separation and dissolved air flotation
(see Figure 14-4). The facility then commingles this wastewater with metal
subcategory waste receipts and treats the combined wastestreams using primary and
secondary chemical precipitation and solid/liquid separation followed by
multimedia filtration.
ails Waste
i
t7tis
IYxent
Metals Waite
Metals
Siaatrant
lischsage
F!@LQ 14-4. Fad*, Which Accepts Wastes ti ale Subcategories rearrests
For this example, like example 14-2, the control authority establishes a single monitoring point.
This monitoring point follows the metals treatment. The control authority requires that the
facility comply with Subcategory D pretreatment standards for facilities which commingle
wastes from Subcategories A and B.
EQUIVALENT TREATMENT
DETERMINATION FOR
SUBCATEGORY D
14.8.1.2.1
Before a multi -subcategory CWT facility can
elect to comply with limitations or standards
from Subcategory D, it must first demonstrate
equivalent treatment for each applicable
wastestream. The CWT rule defines equivalent
treatment as "a wastewater treatment system that
achieves comparable pollutant removals to the
applicable treatment technology selected as the
basis for the limits and standards." The
following outlines the procedure for
demonstrating equivalent treatment.
14-22
First, facilities which desire this option must
submit an initial request to their permit writer or
control authority certifying that their treatment
train includes all applicable equivalent treatment
systems. This initial certification would include,
at a minimum, the applicable subcategories (i.e.,
metals, oils, organics), a listing of and
descriptions of the treatment technologies and
operating conditions used to treat wastes in each
subcategory, and the justification for making an
equivalent treatment determination. For
example, a facility which accepts metals
subcategory and oils subcategory wastewaters
could show that its treatment train includes two -
stage oil/water separation, two -stage chemical

Chapter 14 Implementation DevelopmentDocumentfor the CWT Point Source Category
precipitation, and dissolved air flotation operated
in a similar manner to the model technology
costed by EPA. Since these are the treatment
technologies selected as the basis for this rule,
the equivalent treatment determination could be
established. However, EPA is not defining
"equivalent treatment" as specific treatment
technologies or the technology bases, but rather
as a "wastewater treatment system that is
demonstrated in literature, tractability tests, or
self -monitoring data to remove a similar level of
the appropriate pollutants as the applicable
treatment technology selected as the basis for the
applicable regulations." While EPA is leaving the
decision as to whether a particular treatment train
is "equivalent treatment" to the permit writer or
control authority's best professional judgement,
the Small Entity Compliance Guide for this rule
provides several examples of cases where EPA
believes equivalent treatment is demonstrated.
EPA notes that the requesting facility is
responsible for providing the permit writer or
control authority with enough information and/or
data to make the equivalent treatment
determination. This initial certification statement
must be signed by the responsible corporate
officer as defined in 40 CFR 403.12(1) or 40
CFR 122.22. If the permit writer or control
authority determines that equivalent treatment is
demonstrated, then the permit writer or control
authority will issue discharge requirements based
on one of the four subsets of limitations or
standards promulgated for the mixed waste
subcategory. If the facility has not demonstrated
equivalent treatment, then the permit writer or
control authority will not allow the CWT facility
to comply with limitations or standards from
Subcategory D. Rather, the permit writer or
control authority will issue discharge
requirements based on the appropriate limitations
or standards from Subcategory A, B or C and
require that these requirements be met prior to
commingling (See Section 14.8.1.1).
Once the facility has established equivalent
treatment, the facility shall submit an annual
14-23
certification statement which indicates that the
treatment technologies are being utilized in the
manner set forth in its original certification or a
justification to allow modification ofthe practices
listed in its initial certification. If the information
contained in the initial certification statement is
still applicable, a facility shall simply state that in
a letter to the permit writer or control authority,
and the letter shall constitute the periodic
statement. However, if the facility has modified
its treatment system in any way, it shall submit
the revised information in a manner similar to the
initial certification. Once again, the permit writer
or control authority will use BE/B.J. in reviewing
any modifications.
Finally, the facility shall be required to
maintain on -site compliance paperwork. The on -
site compliance paperwork should include
information from the initial and periodic
certifications, but must also include: (1) the
supporting documentation for any modifications
that have been made to the treatment system; (2)
a method for demonstrating that the treatment
system is well operated and maintained; and (3)
a discussion of the rationale for choosing the
method of demonstration. Proper operation and
maintenance of a system includes a qualified
person to operate the system, use of correct
treatment chemicals in appropriate quantities,
and operation of the system within the stated
design parameters. For example, a facility may
operate dissolved air flotation. The method for
demonstrating the dissolved air flotation system
is well operated can be as simple as maintaining
records on the temperature and pH, the
chemicals added (including quantity), the
duration of treatment, recycle ratio, and physical
characteristics ofthe wastewater before and after
dissolved air flotation. Alternatively, the facility
could monitor for selected parameters for the
purpose of demonstrating effective treatment.
This could include any pollutant or a
combination of pollutants. The implementation
manual for the CWT rule provides additional
examples.

Chapter 14 Implementation Development Document for the CWT P oint Source Category
Permit writers and control authorities may
inspect the CWT facility at any time to confirm
that the listed practices are being employed, that
the treatment system is well operated and
maintained, and that the necessary paperwork
provides sufficient justification for any
modifications.
Implementation for Facilities with
Cyanide Subset 14.8.2
Whenever a CWT facility accepts a waste
receipt that contains more than 136 mg/L of total
cyanide, the CWT facility must monitor for
cyanide when the wastewater exits the cyanide
destruction process rather than after mixing with
other process wastewater. Alternatively, the
facility may monitor for compliance after mixing
if the cyanide limitations are adjusted using the
"building block approach" or "combined waste
stream formula," assuming the cyanide
limitations do not fall below the minimum
analytical detection limit. For further information
on the "building block approach" or "combined
waste stream formula", see section 14.8.4.
CWT Facilities Also Covered By
Another Point Source Category 14.8.3
As detailed in Chapter 3, some
manufacturing facilities, which are subject to
existing effluent guidelines and standards, may
also be subject to provisions of this rule. In all
cases, these manufacturing facilities accept waste
from off -site for treatment and/or recovery
which are generated from a different categorical
process as the on -site generated wastes. EPA is
particularly concerned that these facilities
demonstrate compliance with all applicable
effluent guidelines and pretreatment standards --
including this rule.
Direct Discharging Facilities 14.8.3.1
For determination of effluent limits where
there are multiple categories, the effluent
14-24
guidelines are applied using a flow -weighted
combination of the appropriate guideline for each
category(i.e., "the building block approach").
Where a facility treats a CWT wastestream and
process wastewater from other non-CWT
industrial operations, the effluent guidelines
would be applied by using a flow -weighted
combination of the BPT/BAT limitations for the
CWT and the other non-CWT industrial
operations to derive the appropriate limitations.
Example 14-4, on the next page, illustrates the
daily maximum limitations calculations for a
CWT facility which is also subject to another
effluent guideline.

Chapter 14 Implementation Development Document for the CWT Point Source Category
Example 14-4 Categorical Manufacturing Facility Which Also Operates as a CWT
Facility
Facility D is a manufacturing facility currently discharging wastewater to the local
river under the OCPSF point source category. Facility D also performs CWT operations
and accepts off -site metal -bearing wastes for treatment. Facility D commingles the on -site
wastewater and the off -site wastewater together for treatment in an activated sludge system.
The total volume of wastewater discharged at Facility D is 100, 000 liters per day. The total
volume of wastewater contributed by the off -site wastewater is 10,000 liters per day.
r)a-SYta :X'.'RVF
Wastes
9 .0C19 L/i y
off-Stre CG✓T
Metals Wrsstts
1 Q COO L/dny
D•gman-s
?r2ritin=n.t
Duch wig
I Oe LOCC/a►ay
Figure 1 r5. Crtegnncul.Mmwfactn.ruxgFac:lrty nick Also rates as a CWf
Facility D will be required to monitor and demonstrate that it has complied with the CWT
metals BAT limitations. Since Facility D commingles the wastestreams and has no treatment
in place for the metals wastestreams, Facility D will be unable to demonstrate compliance with
the BAT limits through treatment rather than dilution. Therefore, Facility D can not
commingle the CWT metals wastestreams and on -site OCPSF wastestreams for treatment.
If Facility D chose to install metals treatment for the off -site wastewater and wanted to
commingle the effluent from the metals treatment and the biological treatment at a single
discharge point (See Figure 14-6 on the next page), the permit writer would use the building
block approach to determine the limitations. Using lead and chromium as examples, for the
metals subcategory, EPA has promulgated BAT monthly average limits of 3.07 mg/L for
chromium and 0.283 mg/L for lead. Since the OCPSF facility has no limits for chromium
and lead, the contribution for the OCPSF wastewaters would be zero. Therefore, the
chromium monthly average limit would be ( 0.1 x 3.07) + (0.9 x 0) = 0.307 mg/1 and the lead
monthly average limit would be (0.1 x 0.283) x (0.9 x 0) = 0.0283 mg/1. Since the monthly
average limit for lead is below the minimum analytical detection level (.050 mg/1), the facility
would be required to demonstrate compliance with the lead limit for the CWT metals
subcategory prior to commingling at the outfall. The monthly average and daily maximum
limitations for other pollutants would be calculated in a similar manner. Since EPA has not
proposed any BAT limits for organic pollutants under the metals subcategory of the CWT
point source category, the contribution for these pollutants would be zero.
14-25

Chapter 14 Implementation Development Document lar the CWTPointSource Category
Off -Site
CWT Metals Wastes
10,000 L/day
Metals
Treatment
On Site OCPSF
Wastes
90,000 L/day
Organics
Treatment
V
Discharge
100,000 L/day
Figure 14-6. Facility That Commingles Wastestreams After Treatment
Indirect Discharging Facilities
14.8.3.2 Therefore, as described in 40 CFR 403, the
combined waste stream formula is
For determination of pretreatment standards
where there are multiple categories, the
pretreatment standards are applied using the
"combined waste stream formula" as defined in
40 CFR § 403.6(e). The combined wastestream
formula (CWF) is based on three types of
wastestreams that can exist at an industrial
facility: regulated, unregulated, and dilute. As
defined (40 CFR 403), a regulated wastestream
is a wastestream from an industrial process that
is regulated by a categorical standard for
pollutant x. An unregulated wastestream is a
wastestream that is not covered by categorical
pretreatment standards and not classified as
dilute, or one that is not regulated for the
pollutant in question although it is regulated for
others. A dilute wastestream is defined to
include sanitary wastewater, noncontact cooling
water and boiler blowdown, and wastestreams
listed in Appendix D to 40 CFR 403.
CT
IV
C;
7.1• x
N
. F.
where
14-26
iv 1
CT =
C, _
F; _
Fd
FT =
FT ' FD
FT
(14-1)
the alternate concentration
limit for the combined
wastestream;
the categorical pretreatment
standard concentration limit
for a pollutant in the regulated
stream i;
the average daily flow of
stream i;
the average daily flow from
dilute wastestreams as defined
in 40 CFR 403; and
the total daily average flow
including regulated,

Chapter 14 Implementation Development Document for the CWT PointSource Category
unregulated, and dilution
wastestreams.
Using example 14-4 above, but assuming the
facility discharges to the local POTW, there are
no dilution flows. Therefore, the CWF equation
reduces in the following manner:
N
C. F.
F • 0
C • t• l X T
T FT
T
Cr
i• 1
N
. C. F.
i• 1
N
i• 1
, (14-2)
Using chromium and lead as examples again,
EPA has promulgated monthly average
pretreatment standards of 3.07 mg/L for
chromium and 0.283 mg/L for lead. Since the
OCPSF facility has no pretreatment standards
for chromium and lead, these wastestreams are
defined as "unregulated." Therefore, for this
example, the only regulated wastestream is the
oils subcategory flow and the chromium monthly
average limit would be (10,000 x 3.07)/10,000
= 3.07 mg/1 and the lead monthly average limit
would be (10,000 x 0.283)/10,000 = 0.283 mg/1.
The monthly average and daily maximum
pretreatment standards for other pollutants would
be calculated in a similar manner. Since EPA
has not proposed any pretreatment standards for
organic pollutants under the metals subcategory
of the CWT point source category, for organic
pollutants the CWT wastestreams would be
unregulated and would not effect the allowable
discharge concentration of organic pollutants as
required by OCPSF. For additional information
on the application of the combined waste stream
formula, see the Guidance Manual for the Use of
14-27
Production -Based Pretreatment Standards and
the Combined Waste Stream Formula.
However, as discussed on pages 3-2 to 3-3
of this guidance manual, unregulated streams are
presumed, for purposes of using the CWF, to
contain pollutants of concern at a significant
level. In effect, the CWF "gives credit" for
pollutants which might be present in the
unregulated wastestream. Rather than treating
the unregulated flow as dilution, which would
result in lowering the allowable concentration of
a pollutant, the CWF allows thepollutant to be
discharged in the unregulated wastestream at the
same concentration as the standard for the
regulated wastestream that is being discharged.
This is based on the assumption that if pollutants
are present in the unregulated wastestream, they
will be treated to the same level as in the
regulated wastestream. In some cases,
unregulated wastestreams may not actually
contain pollutants of concern at a significant
level. Even if this is the case, they are still
considered unregulated when applying the
formula. However, if the control authority is
concerned that an unregulated stream is actually
acting as dilution, a local or state control
authority can use its own legal authority to
establish a limit more stringent than would be
derived using the formula in the manner
prescribed by the Federal regulations.
Therefore, the control authority could apply its
best professional judgment to derive the same
chromium and lead limits as those derived in
Example 14-4 for the direct discharge example.
In the case of chromium the BPJ pretreatment
standard could be 0.307 mg/1 rather than the
CWF result of 3.07 mg/1. Similarly for lead, the
BPJ pretreatment standard could be 0.283 mg/1
rather than the CWF result of 0.283 mg/1.

Chapter 14 Implementation Development Document for the CWT Point Source Category
Exceptions to Guidance Provided for
CWT Facilities Also Covered By
Another Point Source Category 14.8.3.3
The only exceptions to the guidance
provided in sections 14.8.4.1 and 14.8.4.2 are
for facilities also subject to effluent guidelines
and preatreatment standards for Transportation
Equipment Cleaning (40 CFR 442) and effluent
guidelines for Landfills (40 CFR 445). The
application of the CWT rule to each of these
types of facilities is discussed below.
TRANSPORTATION EQUIPMENT
CLEANING (TEC) 14.8.3.3.1
There are some facilities which are engaged
in both traditional CWT activities and traditional
TEC activities. If the wastewaters from the two
operations are commingled, under the approach
adopted for TEC, the commingled wastewater
flow from the transportation equipment cleaning
activities would be subject to CWT limits.
Therefore, a facility performing transportation
equipment cleaning as well as other CWT
services that commingles these wastes is a CWT
facility and all of the wastewater discharges are
subject to provisions of this rule. If, however, a
facility is performing both operations and the
waste streams are not commingled (that is,
transportation equipment cleaning process
wastewater is treated in one system and CWT
wastes are treated in a second, separate system),
both the TEC rule and CWT rule apply to the
respective wastewaters. If, however, the
wastewaters from the two separate treatment
systems are combined after treatment but prior
to discharge monitoring, discharge requirements
would be calculated by applying the "building
block approach" or the "combined waste stream
formula" as detailed in Sections 14.8.4.1 and
14.8.4.2.
14-28.
LANDFILLS 14.8. 3.3. 2
In the CWT industry, there are some
facilities which are engaged both in CWT
activities and in operating landfills. For the CWT
fmal rule, EPA's approach to facilities which
treat mixtures of CWT wastewater and landfill
wastewater is consistent with that established for
the landfill guideline. Therefore, a facility
performing landfill activities, as well as other
CWT services, and commingles the wastewater
is a CWT facility only, and all of the wastewater
discharges are subject to the provisions of this
rule. If a facility is performing both operations
and the waste streams are not commingled (that
is, landfill wastewater is treated in one treatment
system and CWT wastewater is treated in a
second, separate treatment system), the
provisions of the Landfill rule and CWT rule
apply to its respective wastewaters. If, however,
the wastewaters from the two separate treatment
systems are combined after treatment, but prior
to discharge monitoring, discharge requirements
would be calculated by applying the "building
block approach" or the "combined waste stream
formula" as detailed in Sections 14.8.4.1 and
14.8.4.2.

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