svEPA
      United States
      Environmental Protection
      Agency
                            EPA's National Pretreatment  Program, 1973-2003:
                            Thirty Years of Protecting the Environment
EPA's National Pretreatment Program has led the way to dramatically reduce or eliminate discharges of pollutants to
sanitary sewer systems and to the nation's water bodies. The Program controls a complex array of industrial wastestreams
in order to prevent interference or pass—through of municipal treatment system processes. Without these controls, a
number of harmful pollutants could make their way into the nations' waters. Federal, state, and local partnerships are
central to the successful implementation of the Program.  Renewed commitment and support to the Pretreatment Program
will conserve the environmental gains of the last 30 years, strengthen strategic partnerships, and prepare communities to
meet the pollution challenges of the 21st Century.

The Pretreatment Program
Pollutants in industrial wastewater may compromise municipal treatment plants' processes or contaminate the nation's
waters. To protect municipal treatment plants and the environment, the Pretreatment Program requires industrial
dischargers to use treatment techniques and management practices to reduce or eliminate the discharge of harmful
pollutants to sanitary sewers. The Pretreatment
Program is a core part of the Clean Water Act's
National Pollutant Discharge Elimination
System (NPDES), and it has helped communi-
ties:
       .
•    Maintain and restore watershed quality, at a
     much lower cost than upgrading treatment;
•    Encourage pollution prevention;
•    Increase beneficial uses of sewage sludge;
•    Prevent formation of poisonous gases in the
     sanitary sewer system;
•    Meet wastewater discharge standards; and
•    Institute emergency—prevention measures.

The Pretreatment Program's strategic partnerships go beyond ensuring the success of Publicly Owned Treatment
Works (POTWs). The partnerships—involving approximately 1,500 communities and 27,000 industrial facilities
nationwide—promote:
                                                          •   Protection of drinking water supplies, by
                                                              reducing contaminants released into source
                                                              waters by POTWs;
                                                          •   Prevention of overflows that include raw
                                                              sewage from sewers, through controls on oil
                                                              and grease;
                                                          •   Extension of the life of the nation's wastewater
                                                              infrastructure, which has an estimated funding
                                                              gap of over $6 billion per year, through
                                                              controls on corrosion;
                                                          •   Worker safety, by protecting workers from
                                                              harmful fumes through limits on the discharge
                                                              of dangerous gases and gas—forming substances;
Reduction in Copper Concentration in Clams
            through Pretreatment
"COG
            1985     1990     1995     2000
      - POTW Effluenl	Coppw Concervtralian In Ciams
 Through its pretreatment program, Palo Alto, California has reduced
 pollutants discharged to San Francisco Bay. As the quantity of copper in
 the POTWs effluent has improved, copper levels in clams nearthe city's
 outfall have decreased.
and
Homeland security, by ensuring proper
disposal of wastes from decontamination
showers.

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Partnerships that Work
Through the Pretreatment Program, POTWs
have worked intensively in a federal, state, and
local partnership that is a model of
intergovernmental cooperation.

National data affirm the Pretreatment
Program's success:
•   Industries release fewer toxic contaminants to
    POTWs. Data from EPA's Toxics Release
    Inventory show that industries have reduced
    the amount of pollutants they discharge to
    sewage treatment plants during the past 10
    years.
•   POTWs now generate sewage sludge that
    poses fewer threats to public health and the
    environment. An Association of
    Metropolitan Sewerage agencies (AMSA)
                                                         Transfer of Toxic Organic Chemicals
                                                                 to POTWs Nationwide
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                                             The Toxics Release Inventory is a publicly available EPA database that contains
                                             information on toxic chemical releases and other waste management activities
                                             reported annually by covered industry groups and the federal government.
        Percentage of Midwestern POTWs with Biosolids
           that Meet Metals Limits for Land Application
survey of biosolids concluded that the Pretreatment Program was directly responsible for reductions in metals found
in sewage sludge. Surveyed POTWs experienced a modest 13 percent decline in metals not regulated by the
Pretreatment Program.  However, concentrations of metals regulated under the Pretreatment Program decreased
considerably, dropping 59 percent from 1986 to 1997-
                                                                •   Because of the successful implementation
                                                                    of industrial discharge limitations, more
                                                                    POTWs are able to apply sewage sludge
                                                                    to land. For example, six Midwestern
                                                                    states saw a significant increase in the
                                                                    percentage of POTWs whose sludges
                                                                    qualified for the term 'biosolids.'  More
                                                                    than 90 percent met metals limitations
                                                                    that allow POTWs to land apply their
                                                                    biosolids.  As a result of this national
                                                                    progress, many POTWs, like the Unified
                                                                    Sewerage Agency ofWashington County,
                                                                    Hillsboro, Oregon, have been  able to use
                                                                    100 percent of the biosolids they
                                                                    produce. Hillsboro applies 11,000 dry
                                                                    metric tons annually to amend soils and
                                                                    improve crop production.
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            1997
                      1938
                                 1999
2000
                                                     2001
 Data obtained from EPA's Permit Compliance System, representing informa-
 tion reported to EPA by POTWs in Illinois, Michigan, Minnesota, Ohio, and
 Wisconsin.
Supporting Key Environmental and  Public Health Programs
Drinking Water Protection—EPA's Pretreatment Program has been helping communities protect their sources of
drinking water for the last 30 years by:
•   Protecting POTWs' treatment processes from upsets, which could compromise the treatment facility's ability to
    treat harmful substances, such as pathogens.  Elevated pathogen levels could have substantial impacts on public
    health if the pathogens exit POTWs and enter surface waters. Downstream drinking water treatment facilities may
    be challenged by significantly higher—than—normal pathogen levels.
•   Controlling industrial releases of carcinogenic contaminants that might otherwise be discharged to municipal sewage
    treatment plants. Without controls on industrial dischargers, carcinogens might pass through the sewage treatment
    plant and enter reservoirs tapped for drinking water supplies. Therefore, the Pretreatment Program eliminates the
    need to install additional, expensive water treatment equipment to protect the long—term health of consumers.

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CSO, SSO, and storm water management—Combined and
Sanitary Sewer Overflows (CSOs and SSOs) contain raw
sewage, and may also carry industrial waste and debris.  EPA's
wet—weather programs recognize the importance of the
Pretreatment Program in helping communities:
•   Mitigate overflows.  For example, many cities halt
    discharges of waste flows from industrial facilities to the
    combined sewer system during wet weather events. In
    addition, industries may retain storm water from their
    properties and release it to the sewer system after the
    storm has ended and sewer system capacity is adequate.
•   Control grease buildup in sewers—a major cause of
    SSOs. As part of their pretreatment programs, many
    communities require food service establishments to
    recycle all fats, oils, and greases or to use oil and grease
    removal equipment. Annapolis, Maryland's pretreatment
    program practically eliminated SSOs associated with the restaurant community.
•   Inventory and control non—domestic sources of pollutants, the types of pollutants discharged, and the volume of
    industrial flow.  These inventory efforts not only protect  wastewater treatment plants, but also help identify
    industrial contributions to municipal separate storm sewer systems.
Infrastructure Protection—Pretreatment
programs help to protect underground
infrastructure from costly damage and the need
for premature replacement.  The gap between the
average annual funding needed and the funding
available for wastewater treatment and collection
systems is estimated to be $6.1 billion per year
from 2000  to 2019- EPA's Pretreatment
Program helps to extend the life of infrastructure
and postpones costly replacement.  For example,
limits on pH prevent corrosion of collection
systems and treatment plants from acidic
discharges.  Discharge limits on sulfides  and
sulfate—bearing wastewaters also protect
infrastructure from corrosion caused by  bacteria.
          Grease-Related Stoppages Reported
    40
        1993  1994  1995  199B  T99T 1998  1999  2000 2001
San Antonio, Texas achieved significant reductions in grease-related
stoppages through its pretreatment program.
                                                 Worker and Public Safety—Ensuring safety is an important goal
                                                 of EPA's Pretreatment Program. The Program accomplishes this
                                                 goal by:
                                                 •   Protecting the physical integrity of the sewer system. Volatile
                                                    organic compounds discharged to sewers may accumulate in the
                                                    head space of sewer lines, increasing the potential for explosions
                                                    that may cause significant damage. Discharge limitations and
                                                    management practices required by the Pretreatment Program
                                                    reduce the likelihood of such catastrophes.
                                                 •   Preventing the buildup of poisonous gases. Discharges of toxic
                                                    organics can generate poisonous gases, through various kinds of
                                                    mixing and chemical reactions.  Appropriate pretreatment
                                                    discharge limits prevent this gas build up.

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Homeland Security Initiatives—As they increase their
preparedness for possible terrorist attacks, communities
across the country will rely on their local pretreatment
programs. The Pretreatment Program helps communities
build contingency plans for the control and disposal of
decontaminated wastes, such as wastes from
decontamination showers.  Recently, pretreatment
authorities in Boca Raton,  Florida managed the disposal  of
anthrax wastes as part of clean—up activities in that city.

Future Challenges
The Pretreatment Program must evolve to face tough new
challenges in protecting public health and the environment.
Future challenges include:
•   Addressing emerging industries and pollutants. Every year, new industries and new pollutants of concern
    challenge POTWs. For example:
    •  The Pretreatment  Program must keep pace with the constant shifts in industrial processes and the development
       of new industries and chemicals. For example, in the 1980s and 1990s, the rapid growth of the semi—conductor
       industry required new pretreatment program strategies. Mounting evidence now suggests that persistent,
       bioaccumulative, and toxic (PBT) chemicals, surfactants, and hormone—disrupting substances can pass through
       wastewater treatment plants and endanger human health. Through their pretreatment programs, communities
       continue to address changes in industrial operations.
    •  New effluent guidelines for transportation equipment cleaning and centralized waste treatment facilities address
       highly complex industries with a history of disrupting POTW treatment. Communities will rely on the
       Pretreatment Program as the vehicle to implement these guidelines and control these highly variable and highly
       toxic wastestreams.
•   Water conservation andreuse.  Industries and municipalities have a growing understanding of the economic
    benefits of using water more efficiently. Effluent waters from POTWs are increasingly used for irrigation and for
    cooling  in power generation and industrial processes. The high quality waters needed for these uses emphasizes how
    important pretreatment is to the growing area of water reuse and conservation.
•   Improving watershed quality through Total Maximum
    Daily Loads (TMDLs).  TMDLs are established to ensure
    that rivers and streams meet their intended uses, such as
    recreational areas and drinking water supplies. State  and local
    pretreatment personnel are increasingly called upon to provide
    expertise in developing appropriate TMDLs and community-
    based strategies. These individuals are aware of the
    contributions from industrial pollutants within the local
    watershed and sewer—shed, and can share their knowledge of
    how to implement pollutant limits while pursuing complex
    watershed—based solutions.
Communities will rely on the leadership of the Pretreatment
Program to meet these and other unanticipated challenges.  While
the Program has had many successes in the last 30 years, a firm
commitment to the federal, state, and local partnerships
established under the Program is critical to protecting public
health and the environment in the future.
~~
Office of Water
EPA833-F-03-001
September 2003

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