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Pretreatment 101

Pretreatment 101. IWEA/IWWSG Pretreatment Dinner February 18,2010. History. Clean Water Act passed in 1972. Required the elimination of pollutants into the nation’s waters.

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Pretreatment 101

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  1. Pretreatment 101 IWEA/IWWSG Pretreatment Dinner February 18,2010

  2. History • Clean Water Act passed in 1972. • Required the elimination of pollutants into the nation’s waters. • EPA’s National Pollution Discharge Elimination System (NPDES) Permitting Program is a key component to accomplish this feat. • The National Pretreatment Program is a component of the NPDES Permitting Program .

  3. Who Needs a Pretreatment Program? POTW’s designed to treat more than five million gallons per day are required to have a program. Smaller POTW’s that have significant industrial discharges coming to them. If a POTW is required to have a program it will be listed with in its NPDES permit under Special Conditions.

  4. Objectives of a Pretreatment Program

  5. Louisville Kentucky, February 13, 1981

  6. EPA EPA EPA NPDES State NPDES State NPDES State NPDES Permit NPDES Permit NPDES Permit Pretreatment Program Pretreatment Program Pretreatment Program Industrial User Industrial User Delegation

  7. POTWPretreatment Programs • The requirement to develop and implement a pretreatment program is a condition of the POTW’s NPDES permit. Fox Metro’s program was approved in 1985. • Required components of a pretreatment program are: • Legal Authority - Ordinance • Local Limits • Adequate funding • Procedures to determine compliance of IU’s (sampling, analysis, inspections) • Control through permits • Enforcement Response Plan

  8. General Pretreatment Regulations 40 CFR Part 403 • Apply to all indirect “nondomestic” discharges of Industrial Users (IU’s). • EPA created four criteria that define a Significant Industrial User (SIU). • IU that discharges 25,00 gpd of process waste water. • IU that contributes 5% or more of the hydraulic capacity of the POTW. • IU is subject to federal categorical standards. • IU has reasonable potential to adversely affect the POTW.

  9. Objectives of Program Met by Enforcing Discharge Standards • Three types: • Prohibited discharge standards • Pollutants that cause a fire or explosion. • Pollutants causing corrosive structural damage. • Pollutants causing obstruction. • Pollutants which will cause an interference with the POTW. • Discharges of heat that will inhibit biological activity. • Discharge of petroleum oil, no biodegradable cutting oil, mineral oil that will cause interference or pass through. • Discharges that result in the presence of toxic gases. • Trucked or hauled pollutants. • Categorical standards-Technology based standards that apply to specific industrial categories. • Local limits- Developed for pollutants that may cause interference, pass-through, sludge contamination and/or health and safety issues.

  10. How do you enforce your Pretreatment Program? • Identify: • Categorical Industrial Users (CIU) • Significant Industrial Users (SIU’s) • IU’s of concern • Permit • Monitor/Sample • Compliance • Inspect Pretreatment

  11. Identify and Locate IU’s • Resources to help identify IU’s • Water and Sewer bills • Applications for sewer service • Telephone and business directories • Business license records • Wastewater collection personnel and field observations • Business Associations • Internet • Send an Industrial Waste Surveys ABC Industries

  12. Permit Contents Monitoring Req’s Reporting Req’s Effluent Limits Standard Conditions Cover Page Special Conditions

  13. Monitor/Sample • At a minimum monitor SIU once per year. • Identify proper sampling location • Sample needs to be representative of discharge. • Proper sample (grab/composite) • POTW should have unrestrictive access to sample location. • IU is also required to self- monitor on a semi-annually.

  14. Compliance Issues • Increase Sampling • Informal Notice of Violation (Verbal) • Written Notice of Violation • Administrative Fines • Compliance Orders • Consent Orders • Show Cause Hearings • Cease and Desist Orders • Criminal Prosecution

  15. Inspections • At a minimum you must inspect all SIU’s annually.

  16. POTW Reporting Requirements • Approved Pretreatment Programs Must Submit an Annual Report • Report submitted contains info on: • Enforcement Actions • Penalties collected • Updated list of permitted IU’s • Samples collected/violations • Inspections • SIU’s published for SNC Pretreatment Annual Report

  17. Questions??

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