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Pretreatment for Small Businesses

Topics. Pretreatment Program OverviewElements affecting small businessesSpecialized cases. Background. 1972: Congress passes Clean Water ActNPDES Permit Program is established with National Pretreatment Program as a component.. Water Use/Wastewater Generation. Average Americans use 100-200 gall

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Pretreatment for Small Businesses

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    1. Pretreatment for Small Businesses Gary F. Kelman MD State Pretreatment Coordinator April 14, 2003

    2. Topics Pretreatment Program Overview Elements affecting small businesses Specialized cases

    3. Background 1972: Congress passes Clean Water Act NPDES Permit Program is established with National Pretreatment Program as a component.

    4. Water Use/Wastewater Generation Average Americans use 100-200 gallons of water a day. Less than 1% is consumed, the rest is wastewater. This wastewater is discharged into wastewater treatment plants.

    5. Wastewater Treatment Plants Designed to treat domestic sewage. Non-biodegradable pollutants will either: Pass-through untreated Interfere with plant operations Contaminate sewage sludge

    6. Toxics More than one-third of all toxics enter the Nations waters through wastewater treatment plants. 190-204 million pounds of metals and 30-108 million pounds of organics are removed each year as a result of pretreatment requirements.

    7. How is this accomplished?

    11. What is Pretreatment ? It is the treatment of non-domestic wastewater prior to its introduction into the sanitary sewer to: Reduce pollutant concentrations or loadings Eliminate pollutants Alter pollutant properties or characteristics

    12. How is the Program Implemented? EPAs General Pretreatment Regulations (40 CFR Part 403) establish framework, responsibilities and requirements for implementing and enforcing pretreatment standards.

    13. Governmental Partnership Program is implemented as a partnership between EPA, States and Local Government. EPA delegates pretreatment responsibility to the States.

    14. How is the Program Implemented? Maryland delegates primary responsibility for the implementation of the pretreatment program to Local Jurisdictions. Currently 19 areas of the State have been delegated pretreatment programs.

    15. Local Government Focus Unlike other environmental programs, the pretreatment program places the majority of the responsibility for implementation with local governments.

    16. Who Must Implement Pretreatment ? Not all governments must implement a pretreatment program. POTWs with design flows exceeding 5 million gallons per day (MGD) and receiving industrial wastewater MUST develop a program.

    17. What about the smaller plants ? POTWs with 5 MGD design flows or less and receive industrial wastewater MUST implement a program IF potential exists for upsets of treatment processes, violations of NPDES permit requirements or contamination of sewage sludge.

    18. How are Industries Screened? Industrial Waste Survey Classify Industries Discovered in Survey Concentrate on those with most potential impact: Significant Industrial Users

    19. Significant Industrial Users 25,000 gallons per day process flow; 5% of hydraulic or organic flow of POTW; Reasonable potential to cause pass through or interference; Categorical industry.

    20. To Be a Significant Industrial User You dont have to be BIG. Its all relative and, like politics, its all local. Just like direct dischargers, it depends on the size of the place receiving the wastewater.

    21. Besides SIUs, POTWs may decide to focus on other users or groups of users such as: Hospitals Photo processors Dry cleaners Laundries Auto body shops Dentists Garages Gas Stations Restaurants Landfill leachate Printers Car Washes

    22. And Metal Finishers, a categorical industry

    23. Why? Several small industries can have the impact of one large industry. Over time, small discharges can degrade the conveyance system (low pH, blockages due to FOG, pumping station failures) If an industry is located at the end of a sewer interceptor, the effect can be relatively quick.

    24. How does the program achieve its goals ? Through the implementation of pretreatment standards (usually contained in local sewer use ordinances): Prohibited discharge standards Federal categorical pretreatment standards Local Limits

    25. What are general prohibited discharge standards ? Forbid the discharge of pollutants that will pass-through the treatment plant untreated or will interfere with the operation of the treatment plant. Tied to violation of the treatment plants NPDES permit.

    26. What are specific prohibited discharge standards ? Forbid the discharge of certain pollutants or the release of wastewater with certain characteristics.

    27. What are specific prohibited discharge standards ? Create a fire or explosion hazard in the POTW; Have a closed-cup flashpoint of less than 140 degrees Fahrenheit; Have a pH less than 5.0; Solid or viscous substances that will obstruct flow and create interference;

    28. What are specific prohibited discharge standards ? Flow rates and/or concentrations that will create interference Increase temperature at introduction into treatment plant greater than 104 degrees Fahrenheit; Petroleum oil, non-biodegradable cutting oil or products of mineral oil origin in amounts that create interference or pass-through.

    29. What are specific prohibited discharge standards ? Result in the presence of toxic gases, vapors or fumes; Trucked or hauled pollutants, except at designated points.

    30. What are federal categorical pretreatment standards ? Any regulation containing pollutant discharge limits promulgated by EPA in accordance with the Clean Water Act which apply to a specific category of users and appear in 40 CFR, Chapter I, Subchapter N, Parts 405-471.

    31. What are local limits ? Limits developed by the local sewer authority to protect the POTW, its personnel, the receiving stream and the sludge. Local limits can increase efficiency of the process and help the POTW to cut treatment costs.

    32. What are local limits ? Local limits apply to a specific wastewater treatment plant taking into account local conditions such as the type of treatment, type of conveyance system, local industrial/commercial users, local water quality standards and local sludge standards. See handout.See handout.

    33. What are local limits ? Can be developed for conventional pollutants (BOD, TSS, COD, oil and grease, total petroleum hydrocarbons, pH, phosphorus) Can be developed for toxic pollutants (metals, cyanide, organics) Limitations for conventional pollutants may be imposed where the treatment plant does not have the capacity to treat high strength wastewater to the level required by its NPDES permit. Surcharges may be imposed where the treatment plant has capacity to treat for high strength wastewater so that excess treatment costs can be recouped. Limitations may be imposed to protect treatment plant against pass-though, sludge contamination, inhibition of processes or to protect treatment plant workers. Limitations may be imposed uniformly to all users or to specific users.Limitations for conventional pollutants may be imposed where the treatment plant does not have the capacity to treat high strength wastewater to the level required by its NPDES permit. Surcharges may be imposed where the treatment plant has capacity to treat for high strength wastewater so that excess treatment costs can be recouped. Limitations may be imposed to protect treatment plant against pass-though, sludge contamination, inhibition of processes or to protect treatment plant workers. Limitations may be imposed uniformly to all users or to specific users.

    34. Need for local limits Categorical standards do not address all pollutants. Do not address many toxics. Do not address many conventional pollutants. Do not address all significant industrial users.

    35. Need for local limits As a result, categorical standards will not adequately protect the POTW.

    36. How are these standards applied? Through the issuance of an industrial user permit with specific and general requirements.

    37. How is compliance tested ? Inspections and compliance monitoring performed by the local authority. Self-monitoring and reporting performed by the industrial user. Enforcement.

    38. Remember: "Life is like a sewer. What you get out of it depends on what you put into it." Tom Lehrer.

    39. Any questions ?

    40. Contact Information Gary F. Kelman Maryland State Pretreatment Coordinator Industrial Discharge Permit Division Water Management Administration Maryland Department of the Environment 1800 Washington Blvd. Suite 455 Baltimore, Maryland 21230-1708 410-531-3630 or gkelman@mde.state.md.us

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