Kansas Environmental Conference

1. Kansas Environmental Conference

2. Pretreatment Program Update • 17 Cities in Kansas with an approved Pretreatment Program Chanute Lawrence Coffeyville Manhattan Emporia McPherson Great Bend Olathe Hutchinson Pittsburg Independence Salina Iola Topeka Johnson County Wichita Kansas City

3. Pretreatment Program Update • Recent Events/Hot Topics • EPA finalized the Dental Amalgam Rule. • Several City Pretreatment Ordinances (previously approved) will be reviewed and updated. • Minor changes are being made to most Enforcement Response Plans (ERPs). • Local limits for most programs are being updated. • EPA is offering free training this coming fall, to all cities.

4. Pretreatment Program Update EPA’s Dental Amalgam Rule • This final rule became effective July 14, 2017. • Existing sources must be in compliance by July 14, 2020. • New sources must be in compliance immediately.

5. Pretreatment Program Update EPA’s Dental Rule applies to: Dental Offices, including large institutions such as Dental schools and clinics, where dentistry is practiced, amalgam is removed and there is a discharge of wastewater to the city sanitary sewer. It does not apply to mobile units or dental offices where the practice of dentistry consists only of the following dental specialties: • oral pathology, • oral and maxillofacial radiology, • oral and maxillofacial surgery, • orthodontics, • periodontics, or • prosthodontics.

6. Pretreatment Program Update Dental Office Requirements Kansas State University (SBEAP) has been contracted to help KDHE notify dentists outside of pretreatment program cities that they need to submit a “One Time Compliance Report”. Statewide, about 30% of dentists have responded and over half already have amalgam separators in place.

7. Pretreatment Program Update Pretreatment Ordinance Reviews – Streamlining Regulations • EPA and KDHE will review Pretreatment Ordinances for all 17 cities in Kansas this year, as directed by EPA HQs. • Even though no cities are adopting any streamlining provisions. • Changes should be minor. • We are suggesting other changes be incorporated into the Ordinances, if needed.

8. Pretreatment Program Update • EPA’s Streamlining Rule Rule became effective on November 14, 2005 • Allowed for BMP’s to be used as local limits • Allowed cities to issue general permits, not just individual permits • Allowed industries to only sample for pollutants present in their discharge

9. Pretreatment Program Update • EPA’s Streamlining Rule - Impact • These regulations were written with good intentions but it took too many waivers and certifications to make the provisions practical. • Cities and industries must provide certifications to KDHE and EPA, in order to use the streamlining provisions. • Cities must provide/maintain considerable documentation, once any waivers are granted. • Few cities in the US adopted the streamlining provisions.

10. Pretreatment Program Update • EPA’s Streamlining Rule – Bottom Line • None of the cities in Kansas even elected to adopt any of the optional streamlining provisions. • However, minor additions to definitions (like interference, pass through, authorized representative) in the regulations will need to be incorporated into City Ordinances. • EPA will let cities know what minor changes are needed.

11. Pretreatment Program Update • Enforcement Response Plans – ERP’s • ERP’s are written documents (procedures) cities follow when taking enforcement actions. • ERP’s give cities a way to be consistent, when following up industrial violations • Only minor changes to approved ERP’s are expected. • Changes will hopefully improve the EPA model ERP.

12. Pretreatment Program Update • Local Limit Updates • Local limits give cities a way to enforce pollutant limits, where Federal limits do not exist. • Local limits vary from city to city. • Limits need to be updated if a city upgrades their treatment plant or receive new industries. • Changes to local limits need to be approved by KDHE and EPA.

13. Pretreatment Program Update Pretreatment Training • EPA and KDHE will be providing free training to anyone interested in Kansas, in October. • A training site will be in Cowtown in Wichita. • Basic fundamentals will be covered over two days. • Hands on local limit calculations will be also be provided.

14. Pretreatment Program Update Thank you/Questions