UNDERSTANDING THE SETTING OF PASS-THROUGH FOR ACETONE PRETREATMENT STANDARDS UNDER FEDERAL EFFLUENT GUIDELINES

The U.S. Environmental Protection Agency (EPA) promulgated revised pretreatment standards for existing sources (PSES) and pretreatment standards for new sources (PSNS) for the pharmaceutical manufacturing category on September 21, 1998. The pharmaceutical PSES and PSNS for Subparts A, B, C, and D regulate 2-propanone (acetone) and other volatile organic compounds because EPA determined that this chemical passes through publicly owned treatment works (POTW).EPA has recently determined, in two final and one proposed rulemakings, that acetone does not pass-through POTWs. In addition, a one-year study conducted by a pharmaceutical company for a removal credits study demonstrated that more than 99.8% of the influent acetone is removed by the well-operated POTW equipped with secondary treatment. Air emissions modeling demonstrated that only 1.8% of the acetone was emitted to air during this treatment. Therefore, EPA should revise its pass-through analysis for the pharmaceutical manufacturing point source category to remove acetone as a regulated chemical in the PSES and PSNS, because acetone does not pass-through POTWs.