Regulatory review and comment by KCIW

The King County Industrial Waste Program reviews and comments on proposed local, state and federal regulations that may affect King County's ordinances pertaining to the pretreatment of industrial wastewater and the program's regulated industrial waste dischargers.

2009 - EPA Proposal to add pharmaceuticals to the universal waste rule

The December 2, 2008 Federal Register (73 Fed. Reg. 232) included a proposal by the EPA to add pharmaceuticals to the universal waste rule. In response King County's Wastewater Treatment Division filed comments supporting EPA's proposal primarily because it simplifies the regulation of unused and expired medications, and makes it easier for hospitals, clinics, nursing homes, and governmental programs to divert pharmaceutical products away from sewer systems.

2008 - EPA Preliminary 2008 Effluent Guidelines

EPA establishes national, technology-based regulations known as effluent guidelines and pretreatment standards to reduce pollutant discharges from categories of industry discharging directly to waters of the United States or discharging indirectly through Publicly Owned Treatment Works (POTWs) The Clean Water Act (CWA) requires EPA to annually review these effluent guidelines and pretreatment standards.
Every two years the CWA requires EPA to identify any new or existing industrial categories selected for effluent guidelines rulemaking and to publish a plan to implement these after public notice and comment.
In December 2007 KCIW reviewed the Preliminary 2008 Effluent Guidelines Program Plan for the health services sector: dental offices and pharmaceuticals.
Dental mercury: KCIW's comments emphasized the effectiveness of its non-permit approach in reducing mercury loading in the county's biosolids. The program noted that, in its experience a voluntary program had not worked, whereas mandatory controls with follow-up inspections did. Based on KCIW's experience the program argued that the additional resources that would be required to implement categorical standards were not justified.
Unused pharmaceuticals: KCIW pointed out that the Washington State Department of Ecology recently developed an Interim Enforcement Policy for Pharmaceutical Waste and that KCIW has advised local hospitals to employ it. KCIW's conclusion is that the methods being used to control the disposal of unused pharmaceuticals to the sewer can be as effective as, or even more effective than the use of categorical standards.

2005 - EPA's Preliminary Effluent Guidelines Program plan for 2006

KCIW commented on the EPA's Preliminary Effluent Guidelines Program plan for 2006, stating its support for EPA's findings that four of the industrial sectors being considered for categorical standards ( food service; industrial laundries; photo processing, and printing and publishing) do not have pass-through potential. ("Pass-though" means that any pollutants are present in the wastewater could be adequately treated by the treatment plants.)

2002 - proposed effluent limits and guidelines for the Metal Products and Machinery Point Source Category

KCIW commented on proposed effluent limits and guidelines for the Metal Products and Machinery Point Source Category, requesting that the EPA either revise or eliminate its proposed regulations for the category (40 CFR 438). KCIW presented data showing that the proposed rule would not be beneficial to the environment and that enforcement would result in higher costs for industry and sewage agencies. The resulting EPA rule, issued in 2003, limited its scope to direct dischargers of oily wastewater and did not affect any dischargers within King County's sewage system.