2014 Industrial Waste and Pretreatment Seminar Charlottesville, VA March 3, 2014 Deborah L. DeBiasi Virginia Coordinator for Pretreatment and WET Office of VPDES Permits, Virginia DEQ http://www.deq.virginia.gov/Locations.aspx VRO – Valley Regional Office NRO – Northern Regional Office BRRO – Blue Ridge Regional Office PRO – Piedmont Regional Office SWRO – Southwest Regional Office CO TRO – Tidewater Regional Office http://www.deq.virginia.gov/Locations.aspx VRO – Bev Carver NRO – Anna Westernik BRRO-R - Lynn Wise BRRO-L – Kevin Crider PRO – Adam Eller SWRO – Willard Keene CO CO – Deborah DeBiasi TRO – Melinda Woodruff Central Office, Richmond Deborah L. DeBiasi 804-698-4028 [email protected] Northern Regional Office, Woodbridge Anna Westernik 703-583-3837 [email protected] Tidewater Regional Office, Virginia Beach Melinda Woodruff 757-518-2174 [email protected] Blue Ridge Regional Office-L, Lynchburg Kevin Crider 434- 582-6212 [email protected] Blue Ridge Regional Office-R, Roanoke Lynn Wise 540-562-6787 [email protected] Southwest Regional Office, Abingdon Willard Keene 276- 676-4847 [email protected] Valley Regional Office, Harrisonburg Beverley Carver 540-574-7805 [email protected] Piedmont Regional Office, Glen Allen Adam Eller 804-527-5046 [email protected] 46 Approved Pretreatment programs in VA 36 more POTWs under the CAs - Total 82 POTWs 1 Developing program, 5 “Partial programs” VRO – 1 at 5% NRO – 1 at 25% PRO – 1 at 5% 1 at 5% 1 at 2 % BRRO-R - 1 at 50% BRRO-L – 1 at 10% 9 SWRO – 1 at 20% 12 6 CO – 1 at 40% CO 14 3 2 TRO – 1 at 20% 1 at 15% EPA delegated Pretreatment Program to VA 1989 Originally did annual frequency, then biennial frequency 1982 1983 1984 1985 1987 1988 1991 1995 1996 1999 2001 2002 2003 2006 2009 2012 1 2 11 5 1 1 3 3 4 1 2 1 1 4 1 1 Audits are now a risk-based frequency, with minimum frequency of every 5 years for established programs New Pretreatment Programs should be audited within 2 years of program approval date Audit can cover activities of POTW back to previous audit Changes with, or loss of POTW personnel that could affect Pretreatment Program operation. VPDES compliance issues Violations of other DEQ or EPA issued permits Addition of SIU to Pretreatment Program that has potential for pass-through or interference Other concerns with Pretreatment Program at POTW Part I – Background information Part II – Program overview and modifications Part III – Changes to Legal Authority or Control Mechanisms (SIU permits) Part IV – Application of Pretreatment Standards Part V – Compliance Monitoring Part VI – Non Compliance, Enforcement Part VII – Data Management and Public Participation Part VIII – Program Resources Part IX - SIU File Review (SIUs inspected at other times) Part X – Evaluation: Required Improvements needed and Recommended Improvements Part XI – WENDB Data for EPA reporting Summary Report At conclusion of audit, discussion of findings with POTW More information/clarification may be needed Audit finalized and sent to POTW staff and DEQ CO Any action items on audit should be completed and reported by POTW to DEQ staff within 30 days Annual reports are due January 31 each year Annual report covers activities from Jan 1 – Dec 31 of previous year Requirements listed in VPDES permit List of SIUs, with differences (additions, deletions, name change, status change, etc.) from previous list explained. Hard copy with “wet” signature must be submitted. Electronic copy may also be provided for enhanced visibility. Electronic reporting rule still not final. Latest note from EPA: …some people are receiving the “wet Ink” paper and then scanning them to reduce storage needs. Whomever is the keeper of the “official record” must keep the hard copy with the “wet ink” signature for the requisite 3 years per 40 CFR 122.41(j) and 403.12(o). Originally inspected SIUs with POTW personnel annually. Reduced inspections to annually for CIUs, and biennial for non-CIUs Further reduced to biennial for CIUs and every 5 years for non-CIUs Now, risk-based frequency for all previously inspected SIUs (CIUs and non-CIUs) that go to POTWs with approved programs SIUs previously inspected by DEQ now inspected on risk-based frequency Newly added SIUs will be inspected within 2 years of notification to determine risk potential ****** Annual inspections continue for CIUs that go to POTWs without Pretreatment programs Non-CIUs that go to POTWs without Pretreatment programs inspected every 5 years • 382 SIUs total – 146 CIUs, 234 non-CIUs VRO – 38 SIUs (15 CIUs) BRRO – 100 SIUs (48 CIUs) NRO – 36 SIUs (13 CIUs) PRO – 132 SIUs (39 CIUs) SWRO – 18 SIUs (10 CIUs) TRO – 58 SIUs (21 CIUs) 140 120 Non-CIUs 100 CIUs 93 80 52 60 40 37 48 20 0 8 10 SWRO BRRO 23 23 15 13 VRO NRO 39 21 PRO TRO DEQ staff usually perform announced inspections with POTW staff Inspection reports may be done by DEQ and POTW, or as a collaboration and shared DEQ will primarily inspect for Pretreatment concerns, but may do multi-media (air, water, waste) inspection too Concerns outside of DEQ purview should be given to POTW staff to address in their locality (ie. building or fire issues) Pollution Prevention (P2) suggestions may be offered SIUs “in the news” for financial problems, downsizing, spills, having potential to cut corners on environmental compliance Citizen complaints Data submitted to POTW may indicate concerns SIU with frequent violations or Significant NonCompliance (SNC) Violations of other DEQ or EPA issued permits SIU inspection should be done is assistance is requested by POTW staff DEQ Pretreatment staff who are often multi-tasking and still doing a great job with the program POTW Pretreatment Program staff who are knowledgeable and thorough, keeping their POTWs compliant SIU staff who are more environmentally conscientious these days. A clean, healthy environment is good for all of us. THANK YOU !! 26th
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