Report to the OOOR89103
Great Lakes Water Quality Board
TD223.3
.R48
1989
A Review of Pretreatment Programs
in the Great Lakes Basin
by the
Municipal Fretreatment Task Force
of the
Point Source Coordinators
International Joint Commission
Great Lakes Regional Office
Windsor, Ontario
August, 1989
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International Joint Commission
A Review of Pretreatment Programs
1990, ISBN I - 895085 - 07 - 1
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Report to the
Great Lakes Water Quality Board
A Review of Pretreatment Programs
in the Great Lakes Basin
by the
Municipal Pretreatment Task Force
of the Point Source Coordinators
International Joint Commission
Great Lakes Regional Office
Windsor, Ontario
U.S. Environmental Protection Agency
A««ru«t 1989 Re^on 5,library (PL-12J) _ ^
August, 1989 7^*Wesl JacRson BoutevanJt 12ttl floor
Chicago. IL 60604-3590
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This report to the Water Quality Board was carried out as the principal
activity of the Municipal Pretreatment Task Force of the Point Source
Coordinators. While the Board supported this work, the specific conclusions
and/or recommendations do not necessarily represent the views of the
International Joint Commission, the Nater Quality Board or its committees.
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GLOSSARY OF ACRONYMS
AO's administrative orders
BATEA Best Available Technology Economically Achievable
BSA Buffalo Sewer Authority
CEPA Canadian Environmental Protection Act
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CWA Clean Water Act
DEC Department of Environmental Conservation
DNR Department of Natural Resources
FOA Final order of Abatement
FTE(s) full-time employee(s)
GLWQ Great Lakes Water Quality
IDEM Indiana Department of Environmental Management
IPP Industrial Pretreatment Program
MISA Municipal Industrial Strategy for Abatement
MOE Ministry of the Environment
MPCA Minnesota Pollution Control Agency
NEORSD Northeast Ohio Regional Service District
NITEP National Incinerator Testing and Evaluation Program
NPDES National Pollution Discharge Elimination System
NPP National Pretreatment Program
OWPCA Ohio Water Pollution Control Association
PACT Power Activated Carbon Treatment
PCI Permit Compliance Inspections
PCME Pretreatment Compliance Monitoring and Enforcement
PCS Permit Compliance System
POTW(s) publicly owned treatment works
PPETS Pretreatment Permits Enforcement Tracking System
QNRC Quarterly Noncompllance Report
RCRA Resource Conservation and Recovery Act
SIU(s) significant industrial user(s)
STP(s) sewage treatment plant(s)
SWDA Solid Waste Disposal Act
TOMP(s) toxic organic management plan(s)
TTO(s) total toxic organic(s)
UGLCCS Upper Great Lakes Connecting Channels Study
WENDB Water Enforcement National Data Base
WLSSD Western Lake Superior Sanitary District
WPCA Water Pollution Control Association
WPCC Water Pollution Control Center
WWTP Wastewater Treatment Plant
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TABLE OF CONTENTS
Page
I EXECUTIVE SUMMARY 1.
II FINDINGS AND RECOMMENDATIONS 9.
Ill INTRODUCTION 13.
IV ESTIMATION OF THE RELEASE OF SELECTED TOXIC SUBSTANCES
TO THE GREAT LAKES BASIN FROM MUNICIPAL SEWAGE
TREATMENT PLANTS 15.
V PRETREATMENT PROGRAM STRUCTURES 31.
Pretreatment Programs In the United States 31.
Federal 31.
Pretreatment Programs of the Great Lakes States 42.
Pretreatment 1n Canada 53.
Federal 53.
Provincial Ontario Pretreatment Provisions 54.
VI PRETREATMENT PROGRAM ADEQUACY 59.
U.S. Analysis 59.
Detailed State Assessments 63.
Summary of Findings 68.
Canadian Analysis 68.
Ontario 68.
APPENDIX 1: PRETREATMENT PERMITS ENFORCEMENT TRACKING SYSTEM
WENDB DATA FIELDS 73.
APPENDIX 2: DETAILED AUDITS OF SELECTED MUNICIPAL WASTEWATER
TREATMENT PLANTS IN THE GREAT LAKES BASIN 79.
TASK FORCE MEMBERSHIP LIST 135.
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I. EXECUTIVE SUMMARY
The Great Lakes support a population in excess of 40 million people, the
majority of whom live In large urban centres. As of 1985, there were 1,199
municipal wastewater treatment plants with a total hydraulic design capacity
of 19.5 x 106 m3/d (5,130 USMGD) in the basin. Three hundred ninety of
these facilities are considered major, having design capacities in excess of
3,800 m3/d (1 USMGD).
The Municipal Pretreatment Task Force of the Water Quality Board reviewed
the significant features and objectives of current municipal pretreatment
programs in the Great Lakes basin, 1n the light of Article VI of the amended
Agreement which calls for the "establishment of pretreatment requirements for
all Industrial plants discharging waste Into publicly owned treatment works
[POTWs] where such Industrial wastes are not amenable to adequate treatment or
removal using conventional municipal treatment processes."
Under its Terms of Reference, The Municipal Pretreatment Task Force was
charged to:
Review and report on the significant features and objectives of current
municipal pretreatment programs in the Great Lakes basin and determine and
compare their contribution to the control of toxic substances discharges.
Compile information on the plans and strategies to improve current
pretreatment control programs.
Analyze and report on compliance among those Industrial sources subject to
pretreatment provisions or requirements.
Estimate the contribution of toxic substances (both metals and organic
chemicals) released to the basin ecosystem from municipal wastewater
facilities via atmospheric emissions, sludge disposal and effluent
discharges.
Assess the adequacy of present and proposed pretreatment programs to
achieve both the jurlsdlctlonal goals and the reduction and virtual
elimination of discharges of persistent toxic substances called for 1n the
amended Agreement.
Estimation of Contribution of Selected Toxic Substances
To estimate the total contribution of toxic substances released to the
Great Lakes basin from municipal wastewater facilities via atmospheric
emissions, sludge disposal, and effluent discharges, detailed Information on
plant design, operating parameters and influent wastewater characteristics was
assembled under contract by Canviro Ltd. for a selected population of
approximately 20% of 1,199 municipal sewage treatment plants (STPs). These
data were used in conjunction with a predictive model and estimates of
contaminant removal efficiences achievable in different treatment plant
designs to estimate concentrations of selected contaminants in raw sewage,
treated effluents and sludges from all municipal facilities. From these
estimates, the total loadings of the selected contaminants to the Great Lakes
basin from municipal STP effluents and releases associated with atmospheric
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emissions and sludge disposal practices were calculated. The contaminants
considered and the estimated total releases are presented 1n Table 1.1. These
represent a first-order estimate of the releases from all sources related to
the operation of municipal STPs 1n the Great Lakes basin.
For three of the organic compounds (2,3,7,8-TCDD, tetrachlorodlbenzofuran
and anthracene), due to the very limited data available, no credible estimate
of the mass released from municipal STPs was possible.
In summary:
Total releases of selected toxic contaminants from publicly owned
treatment works (POTWs) In the Great Lakes basin ranged from approximately
less than 1 tonne (one thousand kilograms) per annum (t/a) of
hexachlorobenzene and total PCBs respectively to more than 500 t/a of
chromium, lead and zinc for the year 1985. The PCB estimate of
approximately 1 tonne/a Is consistent with extrapolations from other
available data.
Because of a lack of an adequate database, no estimate of the quantities
of 2,3,7,8-TCDD, tetrachlorodlbenzofuran and anthracene could be made.
These calculated releases are considered 'order-of-magnitude1 estimates
but are generally in reasonable agreement with quantities calculated based
on literature values for effluent and sludge concentrations. However, the
mass of benzene released appears to be underestimated, based on comparison
to literature values and to releases of other similar compounds.
Suggested future activities Include:
The data files, model and treatment/removal efficiencies developed
for the Task Force's report need to be routinely updated and expanded
to Improve the generated estimates and determine If any trends can be
established.
More comprehensive data on emissions from POTWs due to incineration
and volatilization are needed.
Pretreatment Programs in the United States
In the U.S., pretreatment programs are designed to address four concerns
within the sewage treatment system: interference with the effective operation
of the POTWs; passthrough of toxic contaminants to receiving waters;
contamination of municipal sludge by toxic substances; and exposure of
treatment plant workers to chemical hazards. Generally, POTWs with flows
greater than 5 million US gallons per day (USMGD) (18,925 cubic metres per
day) are required to develop control programs under the National Pretreatment
Program (NPP). Other POTWs may be required to meet NPP requirements because
of treatment plant upsets, contaminated sludge, or violation of effluent
permit limits.
Section 405 of the Clean Water Act (CWA), the Solid Waste Disposal Act
(SWDA), Including the Resource Conservation and Recovery Act (RCRA) and state
sludge management regulations prepared pursuant to Subtitle D of the SWDA, the
Clean Air Act, the Toxic Substances Control Act, and the Marine Protection,
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Table 1.1
ESTIMATE OF TOTAL RELEASE AND ESTIMATED DISTRIBUTION OF CONTAMINANTS
FROM MUNICIPAL STPs WITHIN THE GREAT LAKES BASIN ECOSYSTEM FOR 1985
% of Total Release
via
Contaminant
Arsenic
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Benzene
Toluene
Ethyl benzene
Chloroform
Tetrachloroethylene
Trichloroethylene
1 ,1 ,1-trlchloroethane
Hexachlorobenzene
PCBs (Total)
Phenol (Total)
2,3,7, 8-Tetrachlorodi benzo-p-
dioxln (TCDD)
Tetrachlorodlbenzofuran
Base-Neutral Extractable PAHs
Anthracene
Naphthalene
Effluent
66
76
49
43
73
59
44
79
51
61
45
31
70
36
58
49
NS
50
94
NE
NE
NE
53
Atmosphere
NS
NS
NS
NS
NS
NS
NS
NS
NS
39
55
69
30
64
42
51
25
NS
NS
NE
NE
NE
20
Sludge*
Disposal
34
24
51
57
27
41
56
21
49
NS
NS
NS
NS
NS
NS
NS
75
50
6
NE
NE
NE
28
Total Release
(tonnes/yr)
19.
26.
640.
300.
89.
580.
3.
130.
1300.
2.
42.
55.
34.
76.
26.
76.
<1.0
<1.0
85.
NE
NE
NE
28.
NE = No Estimate
NS = Assumed to be not significant
* via landfill or land application
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Research and Sanctuaries Act, all can have some bearing on the operations of a
POTW.
The U.S. Industrial pretreatment standards consist of two broad
Initiatives: the control of prohibited discharges, which are discharges of
substances that could threaten the operation of the sewage collection and
treatment system, and control of particular Industrial categories that
discharge specific toxic contaminants.
Categorical pretreatment standards developed under the CWA currently
affect 28 specific Industrial sectors. Six of the categories
(electroplating, metal finishing, electrical and electronic components, copper
forming, aluminum forming, and coil coating (can-making subcategory only))
have a pretreatment standard established for total toxic organics (TTO). The
TTO Is defined as the sum of the masses or concentrations of specific toxic
organic compounds found in the Industrial user's process discharge at a
concentration greater than 0.01 mg/L.
The focus of any pretreatment program is direct control by the
municipality; the local pretreatment program is the legal, technical and
administrative framework for achieving effective IU discharge control, with
the state and U.S. EPA playing an oversight role.
The essential tasks of a pretreatment program are 1) to develop and Issue
permits/agreements with Industry; 11) to carry out Inspection/monitoring
activities on significant industrial users (SIUs), including direct sampling
of their wastewater as necessary; ill) to maintain and update data on
municipal effluents; 1v) to enforce and remedy noncompllance; v) to report to
the approval authority at least annually on the status of programs; and vi) to
perform other special condition requirements.
Typical POTW permits contain specific conventional effluent limits and
nonconventional pollutant effluent limits and, Increasingly, water quality
based limitations for toxics and nonconventionals, narrative toxlcity
limitations (e.g. no toxics in toxic amounts), and whole effluent toxlcity
limits. However, many National Pollution Discharge Elimination System (NPDES)
permits do not Incorporate any sludge criteria per se. Sludge requirements
may be contained In state or federal regulations and/or state-Issued sludge
use and disposal limits. Where states have promulgated numerical water
quality standards for specific toxic pollutants, POTWs are required to develop
limits in their permits to meet these standards. Otherwise, NPDES permitting
authorities are expected to use a combination of biological techniques and
available toxic effect data to establish effluent toxicity limits or limits on
specific contaminants. POTW local limits would then be developed to ensure
these targets are met.
Anticipated Program Changes - U.S. Federal Program
No fundamental changes to the U.S. pretreatment program are planned.
However, several initiatives will be undertaken In the coming years, Including:
Improvements in information management and trend data analyses
through the Permit Compliance System (PCS), including establishment
of a common definition of compliance, tracking of minimum data
elements, and automated screenings for POTW non-compllance.
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Improved control of hazardous materials discharged to POTWs
including those discharged with domestic waste under current RCRA
exemption.
Improved control of toxicants discharged from POTWs through toxic
limitations in permits and improved control of sludge disposal
through National Sludge Disposal regulations.
Increased emphasis on enforcement as represented by the National
Pretreatment Enforcement Initiative scheduled to occur in late 1989.
State Pretreatment Programs-Description and Assessment
Over 95% of the pretreatment programs at individual U.S. Great Lakes
municipalities are now approved; only 8 programs In Michigan and 1 In Ohio
remain unapproved. Indiana, New York and Pennsylvania have not been delegated
primary oversight of pretreatment programs.
Three primary mechanisms (compliance inspections, program audits, and the
solicitation and review of periodic POTW pretreatment reports) are or will be
used by the states to ensure program compliance. The pretreatment compliance
inspection should occur annually. A POTW program audit is a comprehensive
review by the state of all elements of the POTW pretreatment program,
especially the adequacy of local limits; the effectiveness of POTW-1ssued
control mechanisms; and the suitability of POTW administrative procedures;
these audits occur typically once every five years or as NPDES permits
require. For both delegated and nondelegated states, specific program goals
and activities are negotiated annually between EPA and the state.
Table 1.2 presents summary data on state pretreatment programs in the U.S.
portion of the Great Lakes basin. Noncompliance of SIUs as presented In this
table is based upon definitions of the terms "noncompllance" and "SIUs"
largely developed by individual municipalities; thus the noncompllance data
between individual treatment plants, as well as jurisdictions, should not be
considered comparable. The States and the EPA are moving to introduce
compatible definitions of these terms to the extent practical in the basin.
The table also notes that some of the compliance information is given for
plants In the basin segment of the state only, while others are given on a
statewide basis. No such distinction is necessary for Michigan, which is
entirely within the basin.
An estimate of compliance of individual users, similar to that determined
in other states, was not available for New York, as the data required to
provide same was not assembled in a coordinated fashion at the Department of
Environmental Conservation (DEC). However, using the results of overall PCI
(Permit Compliance Inspections) ratings, including IU inspections, 23 of the
25 New York programs in the basin were deemed to be satisfactory.
In the case of Michigan, a majority of the noncompliant SIUs were located
in the Detroit treatment system; both the state and the EPA are moving to
address the obvious deficiencies in the Detroit pretreatment program.
Wisconsin operates under the most stringent definition of compliance in
the basin, and thus the noncompllance level should not be considered as
entirely indicative of the comparative merit of that state's program, which is
among the best in the basin.
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Table 1.2 SUMMARY OF PRETREATMENT PROGRAMS
GREAT LAKES STATES
New York
Michigan
Ohio
Indiana
Minnesota
Wisconsin
Pennsylvania
Delegated
Program
No
Yes
Yes
No
Yes
Yes
No
GL POTWS u
Pretreatment
Programs
31
116
41
9
1
11
1
EPA
Approved
Programs1
25
108
40
9
1
11
1
Pretreatment
Compliance
Inspections1
32
167*
112
0
0
8
1
Pretreatment
Audits
24
44
23
7
1
6
1
Estimated
Industrial
User
Noncompliance0
N/A3
161/945 (17%)
117/820 (14%)2
33/283 (11%)2
1/9 (11%)
119/494 (24%) 2
N/A
D Illinois has no POTWs with pretreatment programs discharging into the basin;
Pennsylvania plants were not considered significant
1 Between 1986 - March 1988 in G.L. basin
* some facilities inspected twice
2 statewide; other compliance data are for plants in basin
0 compliance based largely on individual POTW definition
3 In the case of New York, compliance is estimated by a different measure.
Using the results of overall PCI ratings, including industrial user inspections,
23 of 25 programs were deemed to be satisfactory.
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This information, the knowledge and experience of the Task Force members,
and Information gleaned from the detailed audit of selected treatment plants
indicated that, although the framework for an adequate pretreatment program
was in place, the selective deployment of further resources at the municipal
and state level was necessary to affect adequate tracking and enforcement of
pretreatment programs. Development of common definitions of significant
noncompllance and SID, as well as computer based tracking systems at the local
and state level and further training of municipal and Industrial operators,
should be part of this Initiative. Also, the inability or unwillingness of
some municipal governments to prosecute pretreatment program violators should
be rectified and multijurisdictional variances in requirements and enforcement
among municipalities should be resolved.
The Canadian Regulatory Framework
The Canadian federal government's main Instrument for developing water
quality controls Is the Fisheries Act. Under that Act, In the mid 1970s
Environment Canada promulgated regulations and guidelines on discharges from
six industrial sectors, representing approximately 65% of the total industrial
wastewater discharge in Canada. However, inasmuch as the federal government
has delegated enforcement of these regulations to the provinces, compliance
monitoring and enforcement have been within the provincial domain and have
only been periodically reported by the federal government. Thus,
implementation of the exemption clause has been inconsistent and unverified.
The new Canadian Environmental Protection Act (CEPA), passed in 1988, is to
provide for life cycle control of specific substances considered to be a
significant threat to human health and the environment. The Act can be used
to limit direct or Indirect discharges, but will rely on provincial delivery
systems to an extent being currently determined. Thus, the Impact of CEPA on
point source discharge control is not clear at this time.
Ontario Programs - Description and Assessment
The discharge of industrial, commercial and institutional wastes to STPs
is regulated locally by municipalities through the use of an Industrial Waste
Sewer Use Bylaw developed by the local level of government under the Ontario
Municipal Act. Many of the municipal by-laws are based entirely or in part on
a Model Sewer Use Bylaw of 1975. The most recent version was Issued in late
1988 and many municipalities are reviewing their by-laws in light of this
newer proposal. This by-law prescribes limits for conventional pollutants,
most metals, hazardous wastes and a few organic contaminants.
All regional municipalities, district municipalities and most cities,
which in total treat 4,120,000 m3/d (1,088 USMGD) of sewage, have
implemented some form of sewer use control programs. However, by-law
implementation and enforcement activities in most of the towns and villages
vary markedly depending on the degree of industrialization. Many small
municipalities have no effective enforcement program. At the moment,
pretreatment at lUs is focused on neutralization, destruction of cyanide, and
precipitation of metals; this level of treatment is the rule rather than the
exception in the province and is consistent with the majority of treatment
concerns experienced by Ontario municipalities.
A detailed assessment was made of a number of Ontario STPs, which revealed
many of the same difficulties unearthed in the U.S. review, namely that the
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selective deployment of further resources at the municipal level was necessary
to affect adequate tracking and enforcement of local sewer use programs.
Development of a common set of criteria within the framework of a
comprehensive sewer use program at the provincial level, as well as computer
based tracking systems and further training of municipal and Industrial
operators at the local level, 1s vital and should be encouraged. Also, the
Inability or unwillingness of some municipal governments to prosecute sewer
use program violators should be rectified and multijurisdictional variances In
requirements and enforcement among municipalities should be resolved.
In summary, although there is considerable effort, particularly at the
larger municipalities, to deliver programs comparable to those at POTWs in the
Great Lakes states.there is no comprehensive, coordinated pretreatrnent program
at the provincial level at this time. The Ministry of the Environment (MOE) is
committed to the delivery of such a program within the next several years.
Current Developments
Although large municipalities do have sewer use programs in place, a
comprehensive and uniform coordinated pretreatment program at the provincial
level is needed. In recognition of this, under the Ontario
Municipal/Industrial Strategy for Abatement (MISA) emerging Sewer Use Control
Program, a regulatory strategy 1s under development. This strategy will likely
Include the following:
A pretreatment standard for Industrial categories based on Best Available
Technology Economically Achievable BATEA provincial regulations with an
allowance for municipalities to set more stringent "local limits."
Regulation enforcement by local or regional municipalities, with
provincial auditing.
All municipalities, regardless of size of STP, are to be included in the
strategy.
Measures to address the discharge of toxics to sewers from domestic
sources are being evaluated. Various options are under consideration,
Including public education programs, more accessible waste collection depots,
and enforcement measures.
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II. FINDINGS AND RECOMMENDATIONS
FINDINGS
As part of a national Initiative, jurisdictions in the U.S. portion of the
Great Lakes basin have put in place programs that respond to the
pretreatment requirements of Article VI of the 1987 Great Lakes Water
Quality Agreement with Protocol and, if properly applied, are responsive
to the requirements for virtual elimination of persistent toxic substances
called for in the Agreement.
Further effort is required on the part of the EPA and the states to
adequately track and enforce pretreatment program requirements In the U.S.
portion of the basin.
The Canadian government has general provisions for the control of
discharges from selected industries to POTWs, but their Impact has not
been verified. The federal and Ontario governments have continued to
cooperate on the refinement of a model sewer use by-law for voluntary
adoption by Ontario municipalities; however, notwithstanding a renewed
interest in achieving this objective by the current provincial government,
a comprehensive pretreatment program coordinated at the provincial and
federal level does not currently exist. Such a program Is being developed
as part of the MISA initiative of the MOE. Monitoring of municipal
systems receiving Industrial discharges is expected to begin In 1990.
Although there are pretreatment activities of merit at the 35 major
municipalities/regions in Ontario, these programs are not uniform in
substance or vigor and do not have any centrally administered review or
audit to determine their effectiveness.
The proposed Ontario MISA sewer use program appears to meet the intent of
the GLWQ Agreement and should establish a uniform, coherent and effective
provincial program containing provisions for the regular and detailed
determination of compliance with established objectives by Individual
municipalities.
To a great extent, programs at the municipal level in both countries
remain focused on toxic metals and relatively few selected organic
compounds. In the U.S., adequate identification of other toxic organic
compounds, particularly those on the Priority Pollutant list, is now
largely completed, and Implementation of regulations necessary for their
control is continuing. In Ontario, the MISA review of sewer use
requirements will address control of a number of organic contaminants,
using a list based, in part, on the EPA Priority Pollutant list.
Certain U.S. categorical standards have not limited major toxic organic
discharges of pollutants such as methylene chloride, 1,1,1-trichloroethane,
toluene, and ethyl benzene. Major industrial sources of these unregulated
pollutants include the Pharmaceuticals, Equipment Manufacturers, and
Petroleum refining industries. EPA is considering revisions of these
categorical standards or guidance documents and extension of the
contaminant list among all categorical industries to include other toxic
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organics. The Impact of the discharge of hazardous materials to the sewer
system under the RCRA domestic sewage exemption 1s also under continued
review.
U.S. NPDES Great Lakes permits establish water quality limits for toxic
substances; however, current human health considerations are not
Incorporated Into every state's water quality standards.
In the United States portion of the basin, a comparable standard
definition of significant noncompHance among lUs has not been entirely
achieved at either the municipal or state level; thus, a precise
comparison of program performance among the Great Lakes States 1s
Impossible.
Resources are a key factor In the effectiveness of a pretreatment program
at all levels regardless If they are allocated to operator training,
Inspection and monitoring, enforcement, data management or other aspects
of the program. In selected Instances, very specific resource concerns
were Identified 1n established programs at a number of levels.
Most of the U.S. POTWs have sufficient legal authority to operate their
programs effectively. Very few ordinances contained serious deficiencies,
or were lacking authority to take Immediate action to halt an Industrial
discharge In an emergency situation that threatens human health or
welfare. Ontario municipal programs do not have the same depth of legal
authority and this Issue needs to be addressed.
The willingness of local levels of government to pursue prosecutions for
significant violations of current regulations and requirements 1s a matter
of concern. Such actions are frequently hampered by the absence of an
appropriate and established policy and specified procedures. Due to close
working relationships with local Industry, smaller communities often are
reluctant to pursue enforcement actions. Many municipalities had never
taken formal enforcement actions, even In the face of significant
violations.
The Task Force Identified a need for a significant additional amount of
education and assistance at the municipal level, Including legal staffs,
throughout the basin to make current and proposed programs completely
understood and effective.
Some training of government and industrial treatment operators exists, but
it Is limited and needs to be more widely Implemented. Industrial
management may not be fully aware of all the benefits obtainable through
operator training and education.
As further refinements occur in Industrial pretreatment or sewer use, the
volume of toxic materials 1n wastewater from domestic sources will take on
more significance.
Several programs face multljurisdlctlonal enforcement Issues. Lack of
resolution 1n multljurisdlctlonal situations could result 1n a failure to
take enforcement actions against lUs outside the boundaries of the
municipality in which the STP is located.
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Generally, 1n jurisdictions with major programs, data adequate to allow
characterization of program delivery have been collected; however, an
Inordinate level of effort was frequently required to do so. The most
common shortcoming encountered was decentralized files, making a review of
relevant permit Inspection and enforcement difficult. Development of
electronic databases at the local level would simplify greatly tracking by
all levels of government and subsequent review of enforcement activities.
Local limits are a cornerstone of an effective program and are a necessary
supplement to categorical standards and the prohibitions 1n the control of
Impacts of other hazardous wastes on a site-specific basis.
Total estimated releases of selected toxic contaminants from POTWs In the
Great Lakes basin ranged from approximately less than 1 tonne (one
thousand kilograms) per annum (t/a) of hexachlorobenzene and total PCBs
respectively to more than 500 t/a of chromium, lead and zinc for the year
1985. Because of a lack of an adequate database, no estimate of the
quantities of 2,3,7,8-TCDD, tetrachlorodlbenzofuran and anthracene could
be made.
RECOMMENDATIONS
General
Research should be undertaken to determine If domestic sources of toxic
substances should be considered for additional control and to Identify the
methods for effecting suitable controls.
Municipalities should have a centralized Electronic Data Processing
system, with effective and efficient accessibility. Ontario and the states
should ensure the timely, accurate, responsive, and continuous transfer of
compliance data from municipalities to their respective databases or
record systems In a manner to allow an accurate, responsive, comprehensive
and ongoing determination of program status and compliance.
Development of local limits to respond to contaminants in both effluent
and sludge as well as process inhibition and worker health and safety
concerns, should be done as a regulated requirement using a methodology
approved by state or provincial authorities. The substances controlled
and the extent of that control needs to be consistent throughout the basin.
Expanded use of regulatory biomonitoring techniques to demonstrate
nontoxicity should be encouraged as part of the permit development
process, or whole effluent toxicity limitations and other biomonitoring
requirements should be included in municipal point source permits.
Jurisdictions should cooperate in the collection of more broadly-based
data sets Including loadings associated with air emissions and groundwater
exfiltration from STPs and collection systems. The significance of such
releases from plants should be explicitly considered in the development of
local limits, as well as controls where these appear necessary.
Further emphasis and resources should be dedicated to the provision, on a
regular basis, of training of both municipal and industrial wastewater
treatment plant operators as well as discharge permit Inspectors. State
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and provincial governments should develop, with federal support, training
programs for such personnel by the end of calendar year 1992.
Detailed, specific compliance and enforcement policies and practices
should be provided as an element of the regulatory program at all levels
of program administration, but particularly at the local level. These
practices should include a mandatory permit system or equivalent for all
direct municipal dischargers to the basin and associated SIUs.
All jurisdictions should review the resource requirements of their
programs and ensure that resources adequate for the effective functioning
of these programs are provided.
Specific
Ontario should put the current proposed MISA sewer use control program in
place by the end of calendar year 1991.
EPA and the Great Lakes states should actively address the need to
introduce, 1n the short term, further commonality in their pretreatment
programs, particularly In the definitions of SIUs and Significant
Noncompliance, and In enforcement procedures and activities.
To further develop the mass balance approach and evaluate program
progress, the Parties and jurisdictions, in cooperation with the
Commission, should undertake to continue the enhancement of the current
estimates of toxic releases from the municipal sector through the
collection of additional data on Influent, effluent and sludge quality and
relevant information on the operating characteristics of treatment plants
in the Great Lakes basin.
The U.S. EPA and Environment Canada should be encouraged to provide
technical assistance to states and Ontario and take whatever additional
steps are necessary to ensure adequate water quality and sludge standards
are in place. In the process of developing such standards, critical
pollutants, hazardous polluting substances and persistent toxic
substances, as determined under the 1987 Great Lakes Hater Quality
Agreement with Protocol, should be considered for Inclusion in the
standard development exercise.
The Parties (U.S. and Canada), as part of their reporting to the
Commission, should provide a biennial update on the status of their
pretreatment programs in the Basin to coincide with the Water Quality
Board reporting cycle, with particular emphasis on compliance and
enforcement activities.
- 12 -
-------
III. INTRODUCTION
The Great Lakes support a population 1n excess of 40 million people, the
majority of whom live In urban centres serviced largely by communal wastewater
treatment facilities. As of 1985, there were 1,199 municipal wastewater
treatment plants, with a total hydraulic design capacity of 19.5 x 106
cubic meters per day (m3/d) (5,130 million U.S. gallons per day) in the
basin. Three hundred and ninety of these facilities are considered major,
having design capacities In excess of 3,800 m3/d (1 USMGDXReport of the
Water Quality Board - 1985).
In accordance with its terms of reference, the Municipal Pretreatment Task
Force of the Water Quality Board has prepared this report with the intention
of reviewing the significant features and objectives of current municipal
pretreatment programs In the various jurisdictions of the Great Lakes basin.
The Task Force has considered these programs in the light of Article VI of the
current Great Lakes Water Quality Agreement, which calls for the
"establishment of pretreatment requirements for all industrial plants
discharging waste into POTWs where such industrial wastes are not amenable to
adequate treatment or removal using conventional municipal treatment
processes." In performing this review, the Task Force was cognizant of and
drew upon the work of the 1983 Municipal Abatement Task Force of the Water
Quality Board.
In preparing this overview, the Task Force has reviewed information on the
diverse pretreatment strategies in place In the basin and on ongoing
developments to effect additional levels of pretreatment control, with a
particular emphasis on control of toxic substances.
As the list of members (appended) indicates, national, state, provincial,
and municipal agencies were represented on the Task Force in some capacity.
The state of Illinois was not represented because none of its STPs discharges
into the Great Lakes basin; nor was Pennsylvania, which has few POTWs
discharging to the Basin.
Under the direction of the Water Quality Board, and with the participation
of the federal, state, provincial and municipal governments, the Municipal
Pretreatment Task Force was charged to:
i) Review and report on the significant features and objectives of
current municipal pretreatment programs in the various jurisdictions
of the Great Lakes basin and, to the extent possible, determine and
compare their impact on the adequacy of control of toxic substances
discharged in the Basin.
ii) Compile information on the plans and strategies under development in
the jurisdictions to further Improve current pretreatment control
programs.
ill) Analyze and report on the success of jurisdictions in obtaining
compliance among those industrial sources subject to pretreatment
provisions or requirements.
iv) Estimate the contribution of toxic substances (both metals and
organic chemicals) released to the basin ecosystem from municipal
- 13 -
-------
wastewater facilities via atmospheric emissions, sludge disposal and
effluent discharges as well as what portion of this total burden
originates from Industrial, commercial and domestic sources
discharging to these facilities.
v) Through an examination of programs at selected sewage treatment
facilities In the Great Lakes basin, assess the adequacy of present
and proposed pretreatment programs to achieve both the jurisdictional
goals for which they were established and the reduction and virtual
elimination of discharges of persistent toxic substances called for
in the 1978 Agreement, and repeated in the revised 1987 Agreement
with protocol.
vi) Using the findings from the efforts listed above, develop appropriate
recommendations for the consideration of the Water Quality Board.
- 14 -
-------
IV. ESTIMATION OF THE RELEASE OF SELECTED TOXIC SUBSTANCES TO THE
GREAT LAKES BASIN FROM MUNICIPAL SENAGE TREATMENT PLANTS
In response to Its charge under Item iv of its Terms of Reference - to
estimate the total contribution of toxic substances (both metals and organic
chemicals) released to the ecosystem of the Great Lakes basin from municipal
wastewater facilities via atmospheric emissions, sludge disposal, and effluent
discharges - the Task Force initiated a contract with Canviro Inc. Their
report, 'An Estimation of Toxic Substance Release to the Great Lakes basin
from Municipal Sewage Treatment Plants' has been filed at the Regional Office
of the Commission and formed the basis for this chapter.
Under the provisions of the contract, a selected population of all
municipal STPs in the basin was contacted to assemble detailed information on
plant design, operating parameters and influent wastewater characteristics.
These data were used in conjunction with a predictive model and estimates of
contaminant removal efficiences achievable 1n different types of treatment
plants to estimate concentrations of selected contaminants in raw sewages,
treated effluents and sludges from municipal facilities. From these
estimates, the total loadings of the selected contaminants to the Great Lakes
basin from municipal STP effluents and associated atmospheric emissions and
sludge disposal practices were calculated by an extrapolation procedure.
Loading estimates for toxic substances, both metals and organic chemicals,
were of interest to the Task Force. Most investigations have focused on the
U.S. EPA 'priority pollutants' which includes 126 compounds, of which 13 are
trace metals. In order to reduce the information base to a manageable level,
it was agreed that a 'short list1 of toxic contaminants or groups of
contaminants would be included in the estimate, based on their known presence
in POTW effluents and sludges, known environmental or human health
significance, and public concern. The short list Included inorganic
contaminants, including cyanide, arsenic, cadmium, chromium, copper, lead,
mercury, nickel and zinc, PCBs (total), 2,3,7,8-tetrachlorodibenzo-p-diox1n
(2,3,7,8-TCDD), related dibenzofurans, phenols (total), volatile aromatic
hydrocarbons, Including benzene, toluene and ethylbenzene, chlorinated
volatile and semi-volatile compounds including chloroform,
tetrachloroethylene, hexachlorobenzene, 1,1,1-trichloroethane and
trichloroethylene and base-neutral extractable polyaromatic hydrocarbons
(PAHs), including naphthalene and anthracene.
It was recognized that less data would be available on dibenzofurans,
which are not included in the U.S. EPA Priority Pollutant List, and on
2,3,7,8-TCDD, in particular, which was included in only a very few of the POTW
investigations of toxic organic contaminants. It was further agreed that the
estimate developed would reflect the toxic contaminants load for the entire
Great Lakes basin and would not be further subdivided into component parts.
Plant Selection
There are approximately 1200 POTHs discharging to the Great Lakes basin,
of which about 360 had flows in excess of 4,540 m3/d (1.2 USMGD). To meet
the schedule and budget constraints, it was agreed to conduct the analysis on
a select number of plants from this population and then extrapolate to estimate
- 15 -
-------
the total loading of selected toxic contaminants to the basin. Approximately
20% of the plants in the basin were to be Included 1n the detailed analysis,
selected largely at random. The distribution of these POTWs would be skewed
toward the larger plants, rather than equally distributed over all sizes, but
would be representative of the distribution of plant types in the basin. The
base year of estimation was chosen to be 1985.
A further search of various databases, including STORET and NEEDS, yielded
1,199 POTNs for which information was available regarding size and plant
type. These were subdivided into two jurisdictions (United States and
Ontario) and further categorized according to facility type and quantity of
flow. This procedure produced 27 different categories or 'strata' shown 1n
Table 4.1. The 'miscellaneous1 stratum represented less than 1% of total flow
and the lack of definition of these plants was not a source of significant
relative error. Selection of the approximately 20% of the plants was random,
subject to the following constraints:
1. Each stratum was to be represented by at least two POTWs.
2. At least one POTW was to be selected for each of the U.S.
jurisdictions in the basin.
3. At least one of the five largest POTWs in U.S. and Canada would be
selected for contact.
4. Approximately one-half of the number of plants selected to be
contacted were to be selected to serve as replacement plants. The
number of POTWs to be selected for contact was set at 240 (20% of
the total).
With these constraints, the selection of specific plants to be contacted
or to serve as replacements was done at random from the population of POTWs in
the basin according to the following procedure:
1. Two POTWs were selected at random to represent each stratum (27
strata x 2 POTWs = 54 POTWs).
2. The remaining 186 POTWs to be selected (240 minus 54) were
distributed into the 27 strata according to the percent of total
flow represented by POTWs in each stratum.
A brief questionnaire, dealing primarily with the following plant specific
information: plant size (flow), plant type, type of aeration (if
appropriate), type of grit removal process, sludge generation, sludge disposal
method, and estimated Industrial/commercial/domestic contributions to the
plant Influent, was developed. The selected plants were contacted by
telephone. In total, data from 225 plants were used In the final data
analysis.
Estimation of Pollutant Removal Efficiencies
Major sources of data for the estimation of pollutant removal efficiencies
for the various plant designs were taken from available literature as well as
several ongoing research programs, including the MOE MISA Municipal STP Pilot
Monitoring Project and an associated activity being conducted by Environment
- 16 -
-------
Table 4.1
DISTRIBUTION OF POTWs INCLUDED IN THE SURVEY
Jurisdi
Ontario
United
States
ction Plant Type
Lagoon
<0.3785
0.3785-3.785
>3.785
Primary
<3.785
3.785-37.85
>3.785
Secondary
<3.785
3.785-37.85
37.85-113.55
>113.55
Tertiary
<3.785
3.985-18.925
>18.925
Lagoon
<0.3785
0.3785-3.785
>3.785
Primary
<3.785
3.785-37.85
>3.785
Secondary
<3.785
3.785-37.85
37.85-113.55
>113.55
Tertiary
<3.785
3.985-18.925
>18.925
Mlsc^
<0.3785
0.3785-3.785
TOTAL
°/. of
Total
Flow
0.02
0.49
0.33
0.11
0.37
3.09
0.50
3.28
4.51
12.22
0.12
0.43
0.62
0.06
0.70
0.85
0.23
0.38
0
2.18
8.54
8.69
39.76
0.55
2.06
9.86
0.02
0.02
100.00
Total
Number of
Plants
19
70
8
8
5
7
69
49
15
7
19
7
3
51
109
18
29
9
-
303
150
28
20
77
48
21
45
5
1199
Contact
Plants
5
6
6
6
5
7
6
12
14
7
6
6
3
6
6
7
6
6
-
10
21
22
20
6
9
21
6
5
240
Replacement
Plants
3
3
2
2
0
0
3
6
1
0
3
1
0
3
3
4
3
3
-
5
11
6
0
3
5
0
3
0
Total
8
9
8
8
5
7
9
18
15
7
9
7
3
9
9
11
9
9
-
15
32
28
20
9
14
21
9
5
73 313
*A11 Flows in 1000 m3/d
- 17 -
-------
Canada's Wastewater Technology Centre, aimed at determining emissions of
selected toxic organlcs due to volatilization from aeration tanks and grit
tanks, and sludge Incinerators tested under Environment Canada's National
Incinerator Testing and Evaluation Program (NITEP), as well as published
literature sources.
Removal efficiencies for each type of treatment facility for specific
toxic contaminants under consideration were determined from the available
literature. For each type of facility, an average value representative of the
overall removal of that specific contaminant was calculated and these values,
as presented In Table 4.2, were incorporated into the toxics removal data file
for calculation of average effluent concentrations from municipal POTWs.
For several contaminants, Including 2,3,7,8-tetrachlorod1benzo-p-d1oxin,
dibenzofuran and anthracene, removal data are not reported in Table 4.2 for
some plant types. However, these contaminants were not identified at
detectable levels in Influents to these types of facilities in the literature.
In Table 4.2, there are a few anomalies where the degree of removal
achieved for a particular contaminant is higher in a lagoon, for example, than
in a tertiary facility. Where these estimates were based on actual plant
monitoring data, the values were retained in the data file.
The contribution of biodegradation, volatilization and adsorption to the
total removal of each contaminant under consideration in each type of POTW was
estimated and is summarized in Table 4.3. The primary source of these data
was the U.S. EPA Domestic Sewage Study. The contribution of volatilization to
the overall removal of organic contaminants from aeration tanks and grit tanks
was based on data produced by the Wastewater Technology Centre, Environment
Canada.
Land application of sludges, landfill disposal and airborne emissions from
sludge incinerators were considered as sources of toxic loadings in the basin
due to sludge disposal practices. Concentrations of toxic contaminants In
POTW sludges were calculated based on the estimated degree of adsorption of
each contaminant (Table 4.3).
Because analytical detection limits were such that accurate estimates of
emissions of dioxin were difficult, the measured emissions of dibenzofurans at
one of two plants sampled by Environment Canada were used as first order
estimates of sludge incinerator dioxin emissions.
Influent Model
HAZPRED, an interactive microcomputer based model, was used to predict the
concentration of each contaminant under consideration in an industrial,
commercial and residential wastewater discharged to the POTW. Since limited
information of questionable accuracy was available to define the types of
Industries discharging to the selected POTWs, a generic industrial wastewater,
based on an A.D. Little study, was assumed. The waste water concentrations
assumed by HAZPRED are given in Table 4.4.
Part of the "Report to Congress on the Discharge of Hazardous Wastes to
Publicly Owned Treatment Works" (1985) included an estimate of loadings of
hazardous materials from domestic sources to POTWs. For hazardous metals and
- 18 -
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- 20 -
-------
Table 4.4
WASTEWATER CONCENTRATIONS USED BY HAZPRED
Contaminant
Total Cyanide
As
Cd
Cr
Cu
Pb
Hg
Ni
Zn
Total Phenols
Benzene
Toluene
Ethyl benzene
Chloroform
Tetrachloroethylene
1 ,1 ,1-trichloroethane
Trichloroethylene
Naphthalene
Industrial
90.7
3.2
20.7
713.2
124.8
323.7
1.9
108.7
860.0
204.1
1.2
52.3
100.4
12.0
69.9
85.1
25.4
50.7
Concentrations '
Commercial
0.2
2.6
0.6
56.8
54.5
49.8
0.4
12.4
138.1
37.0
2.7
11.0
5.0
6.7
21.4
2.9
12.8
2.6
(yg/L>
Domestic
1.1
4.8
1.8
16.3
72.1
97.3
0.4
4.2
214.0
30.8
0.2
2.6
0.4
3.0
6.3
2.3
0.4
2.1
cyanide, the nationwide estimate for the United States was 5,563 Metric Tons
per annum (MT/A), or approximately 7% of estimated total metal loadings;
hazardous organic discharges were estimated to be 2,633 MT/A, approximately
20Z of total organic loadings. As full implementation of pretreatment
programs occurs, the domestic contribution of hazardous metals 1s projected to
increase to 60% of the total metals loadings.
HAZPRED does not have the capability to predict the concentration of
2,3,7,8-TCDD, dlbenzofurans or anthracene, since these contaminants were not
measured in the industrial wastewater characterization conducted by A.D.
Little. Further, PCBs and hexachlorobenzene were not detected In industrial,
commercial or domestic wastewaters at concentrations above the detection limit
(1 yg/L and 10 pg/L, respectively). Therefore, no predicted
concentrations for those compounds could be generated by HAZPRED.
Calculation Method
The step-by-step procedure (Figure 4.1) used to estimate the total
contaminant loading Into the Great Lakes Involved the following steps:
Information obtained from the procedure outlined above and data from the
POTW data file were used to estimate the quantities of toxic contaminants
released by municipal POTWs in the Great Lakes basin by the following
procedure:
1. The HAZPRED model was used to determine the concentrations of
contaminants in the Influent to surveyed POTWs based on the reported
contributions of industrial, commercial and domestic operations to
the influent.
- 21 -
-------
2. The estimated Influent concentrations were screened by comparison to
available Ontario or Ohio data (Table 4.5 and 4.6). In cases where
the predicted influent concentrations were outside the established
[l/3x(min1mum) to 3x(maximum)] concentration range, or where HAZPRED
did not contain an estimate of the contaminant, the average influent
concentration from the Ontario or the Ohio POTW data was substituted.
Note that the Ohio data include sampling programs spanning early 1985
to mid 1988; thus some of these data may have been obtained prior to
full implementation of a pretreatment program at the sampled plant.
Also, arithmetic averages are used as averages in the Ohio data,
while geometric means are used as averages in the Ontario data. This
difference is not considered significant, given the inaccuracies
associated with the calculated first estimates of total toxic
releases.
3. Effluent concentrations for each surveyed POTW were calculated based
on the removal efficiency established for that contaminant in that
type of plant.
4. The calculated effluent concentrations were checked against Ontario
or Ohio data. Based on the screening criteria given under Step 2,
these concentrations were accepted or replaced with the appropriate
average.
5. Using percent volatilization and percent adsorption estimates for
each plant type, the fraction of each selected compound emitted
directly to atmosphere or accumulated in sludge was calculated.
6. Calculated concentrations of contaminants adsorbed to sludge were
checked against those observed in POTW sludges in Ontario or Ohio.
Outliers were identified and replaced by average concentrations.
7. From the very limited data available on sludge Incineration emissions
sampling, the quantity of each contaminant emitted to the atmosphere
from POTWs practicing sludge incineration was estimated.
8. The mass loading of each contaminant resulting from effluents
discharged by surveyed POTWs was calculated as the product of POTW
flow and effluent concentration.
9. The mass loading of each contaminant emitted to atmosphere from
aeration tanks and grit tanks at surveyed POTWs was estimated based
on the influent load and the degree of volatilization estimated for
that compound.
10. The mass loading of each contaminant resulting from sludge disposal
practices at each surveyed POTW was calculated based on the estimated
sludge concentrations, reported sludge generation rates and
applicable sludge disposal methodology.
11. The quantity of each toxic compound released from surveyed POTWs in
each jurisdiction/type/size stratum (Table 4.1) from all pathways
(effluent, atmosphere, sludge) was summed.
- 22 -
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12. The total quantity of each toxic compound emitted from all POTWs In
each stratum was calculated by extrapolation based on the ratio of
the total flow from POTNs In the stratum to the flow of surveyed
POTWs In the stratum.
13. The total emissions of each toxic contaminant from municipal STPs In
the Great Lakes basin was calculated as the sum of the total
emissions from each stratum.
It should be noted that the reported total emissions do not represent the
total quantity of these contaminants deposited In the Great Lakes since no
assumptions were made with respect to the fate of the atmospheric volatile
emissions from aeration and sludge disposal. These totals represent a
first-order estimate of the emissions from all sources related to the
operation of municipal STPs 1n the Great Lakes basin.
Estimation of Release of Toxics from Municipal STPs
Following the calculation method, the mass of selected contaminants
released from municipal STPs 1n the Great Lakes basin via atmospheric
emissions, sludge disposal practices and effluent discharges was estimated.
The results of these calculations, Including approximate pathway distribution,
are presented 1n Table 4.7. These estimated first order emissions, as noted
previously, are for the year 1985.
For three of the organic compounds, 2,3,7,8-tetrachlorod1benzo-p-d1ox1n,
tetrachlorodlbenzofuran and anthracene, no credible estimate of the mass
released from municipal STPs was possible. Concentration data for these
compounds were not available 1n HAZPRED and no estimate of their concentrations
In POTW Influents was possible. 2,3,7,8-tetrachlorodlbenzo-p-dloxln was not
detected at a concentration above the detection limit In any sample (Influent,
effluent or sludge) from any treatment facility Included In the Ontario or the
Ohio analytical database. Tetrachlorodlbenzofuran was not Included In the
analytical program 1n Ohio. In Ontario, tetrachlorodl- benzofuran was detected
In only one raw sewage sample (of 54 samples tested), two treated effluent
samples (of 38 samples tested) and none of the treated sludges. Therefore,
Insufficient data were available to support an estimate of the mass released.
Similarly, anthracene was not detected In the Influent or effluent from any
facility monitored 1n Ohio or Ontario at a concentration above the detection
limit. One sludge sample from a POTW 1n Ohio and one sludge sample from a
POTW In Ontario had a detectable concentration of anthracene.
For all other contaminants, a first-order estimate of the mass released
from municipal STPs In the Great Lakes basin was generated. The mass emitted
varied from less than 1 tonne/year for hexachlorobenzene and total PCBs
respectively to more than 500 tonnes/year for chromium, lead and zinc. As
mentioned, an estimation of the distribution/pathway of each contaminant Is
also Included, based on limited data.
An annual total PCB release of 1 tonne/a Is consistent with estimates
derived from the extrapolation of STP effluent data generated by the Upper
Great Lakes Connecting Channels Study (UGLCCS). In determining total release^
It was assumed that the amount of PCB discharged In effluent was equivalent to
that released In air. No such confirming estimates were made for
hexachlorobenzene.
- 26 -
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Table 4.7
ESTIMATE OF TOTAL RELEASE AND ESTIMATED DISTRIBUTION OF
CONTAMINANTS FROM MUNICIPAL STPs IN THE GREAT LAKES BASIN
% of Total
Release Emitted
via
Contaminant
Arsenic
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Benzene
Toluene
Ethylbenzene
Chloroform
Tetrachloroethylene
Trichloroethylene
1 ,1 ,1-trichloroethane
Hexachlorobenzene
PCBs (Total)
Phenol (Total)
2,3,7,8-
Tetrachlorodlbenzo-p-dloxin
Tetrachlorodibenzofuran
Anthracene
Naphthalene
Effluent
66
76
49
43
73
59
44
79
51
61
45
31
70
36
58
49
0
50
94
NE
NE
NE
53
Atmosphere
NS
NS
NS
NS
NS
NS
NS
NS
NS
39
55
69
30
64
42
51
25
0
0
NE
NE
NE
20
Sludge*
Disposal
34
24
51
57
27
41
56
21
49
NS
NS
NS
NS
NS
NS
NS
75
50
6
NE
NE
NE
28
Total Release
(tonnes/vr)
19.
26.
640.
300.
89.
580.
3.
130.
1300.
2.
42.
55.
34.
76.
26.
76.
<1.0
<1.0
85.
NE
NE
NE
28.
NE = No Estimate
NS = Assumed to be not significant
* via landfill or land application
- 27 -
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NOTE: These estimates are based on estimated removal of each
contaminant by adsorption, blodegradatlon and
volatilization 1n the sewage treatment process. These
removal mechanisms are poorly defined for many of the
contaminants In question; because of the limits on quality
and quantity of data, these values should be considered as
only roughly Indicative of any actual distribution.
The estimated total release of selected toxics from municipal STPs in the
Great Lakes basin is considered to be of 'order-of-magnitude' accuracy.
Estimated releases of heavy metals are generally in agreement with values
calculated based on average effluent and sludge concentrations from the
literature. With the exception of benzene, similar agreement exists for
organic contaminants, although a poorer quality database is available for
comparison. In the case of benzene, the calculated emissions are How because
of the low influent concentration estimate generated from HAZPRED as compared
to literature values. However, because the HAZPRED estimate was within the
acceptable range compared to the Ohio POTW data (benzene data were unavailable
from the Ontario POTW data), the low HAZPRED estimate was carried through the
calculation procedure; given the ubiquitous presence of benzene in the
environment, this value should be taken as an anomaly.
Conclusions
Using the procedures outlined herein, estimates of the mass release of
selected inorganic and organic toxic contaminants from municipal STPs in the
Great Lakes basin were developed. These estimates were presented in Table
4.7. Specific conclusions related to these estimates follow:
Total releases of selected toxic contaminants from municipal STPs in
the Great Lakes basin ranged from approximately less than 1
tonne/year of hexachlorobenzene and total PCBs to more than 500
tonnes/year of chromium, lead and zinc for the year 1985.
Because of a lack of an adequate database, no estimate of the
quantities of 2,3,7,8-tetrachlorodibenzo-p-dloxln,
tetrachlorodibenzofuran and anthracene could be made.
These calculated releases are considered 'order-of-magnitude1
estimates but are generally in reasonable agreement with quantities
calculated based on literature values for effluent and sludge
concentrations. However, the mass of benzene released, based on
these calculations appears to be an underestimate based on comparison
to literature values and to releases of other similar compounds (i.e.
toluene and ethylbenzene).
4.5 Suggested Future Activity
Although an effective procedure has evolved for the estimation of toxic
releases from POTWs, improved data In specific areas would increase confidence
in the accuracy of these estimates. Specifically,
The HAZPRED model needs to be updated to more accurately reflect
present industrial wastewater discharge characteristics and applied
analytical procedures. Additional data are also needed for specific
- 28 -
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contaminants In industrial wastewater including 2,3,7,8-TCDD,
anthracene, PCBs, dibenzofurans and hexachlorobenzene.
More comprehensive data are needed to characterize the influent to
POTWs with respect to industrial contributions and extraneous flow.
More comprehensive data on emissions
and volatilization are needed.
from POTWs due to incineration
The data files developed for this report need to be routinely updated
and expanded to improve the estimates generated herein.
- 29 -
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V. PRETREATMENT PROGRAM STRUCTURES
Pretreatment Programs in the United States
Federal
Legislative Framework
The five principal U.S. federal laws that govern waste and components of
waste management in the United States include the:
Federal Hater Pollution Control Act, Clean Hater Act (CHA) is the core
legislation for the regulation of discharges to municipal sewer systems.
Solid Haste Disposal Act including Resource Conservation and Recovery
Act (RCRA) defines waste in its many forms and sets out the regulatory
procedures to control the discharge of waste. It contains an exemption
for discharges comingled with domestic waste water, which will be
discussed in greater detail later in this report.
Clean Air Act addresses air quality in the United States; air emissions
from U.S. POTWs are required to comply with the provisions of this Act.
Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) or "Superfund" is designed to identify and remediate releases of
hazardous wastes from abandoned waste sites, and thus would only bear on
the operation of a small majority of POTWs receiving such discharges. The
impact of CERCLA requirements on U.S. POTWs in the Great Lakes basin is
considered insignificant for the purposes of this report.
Toxic Substances Control Act, through the identification and control of
toxic chemicals, supports the above acts and many other U.S. laws.
The U.S. Federal Government's role in the development of National
Pretreatment Standards began with the passage of the CWA In 1972. This act is
concerned with wastewater and sludge, as compared to the more comprehensive
mandate of RCRA, and calls for the U.S. Environmental Protection Agency to
address control of certain pollutants from Industrial sources to POTWs. An
overall regulatory framework was developed in the General Pretreatment
requirements, initially published in 1973, and since modified in 1978 and 1981.
The goal of the current CWA continues to be the restoration and
maintenance of the quality of surface water. Three programs that have a
bearing on the control of sewer uses have been established under the CWA.
The NPP, which requires industrial pretreatment of waste to a
technologically based standard prior to discharge to municipal sewers;
The NPDES Program, which provides technology or water quality based
effluent standards and an associated permitting system that dischargers to
surface waters, including POTWs, must comply with;
Sludge disposal requirements under the CWA specify pollutant specific
limits for exercising various sludge disposal options.
- 31 -
-------
Pretreatment programs are designed to address four concerns within the
sewage treatment system: control of substances which interfere with the
effective operation of the POTWs; prevention of passthrough of significant
quantities of toxic contaminants from the treatment system to receiving
waters; limitations on the contamination of municipal sludge by toxic
substances; and the control of exposure of treatment plant workers to chemical
hazards. Generally, POTWs that have flows larger than 5 USMGD (18,900 m3/day)
are required to develop control programs that meet the requirements of the NPP
as a condition of their NPDES permits; all other POTWs may be required to meet
NPP requirements if non-domestic wastes have caused treatment plant upsets,
contaminated sludge, or violated effluent permit limits.
The four concerns noted above were addressed via two broad initiatives:
the control of prohibited discharges, which are discharges of substances that
could threaten the operation of the sewage collection and treatment system,
and control of particular industrial categories that discharge specific toxic
contaminants of concern both to POTWs and users of the ultimate receiving
water.
Regulatory Requirements
Prohibited Discharge Standards
The Prohibited Discharge Standards contained in 40 CFR 403.5 list both
general and specific prohibitions. Under the General Pretreatment Regulations,
general and specific prohibitions are established and Implemented through
local limits. Under the General Prohibitions, a user may not introduce into a
POTW any pollutants which cause passthrough of contaminants or interfere with
the treatment process. The term 'passthrough' is defined as a discharge which
exits the POTW into waters of the United States in quantities or
concentrations which, alone or in conjunction with a discharge or discharges
from other sources, is a cause of a violation of a_ny_ requirement (emphasis
added) of the POTW's NPDES permit, Including an Increase In the magnitude or
duration of a violation.
Interference is further defined as a discharge which inhibits or disrupts
the POTW operations and causes a violation of any requirement of the POTW's
NPDES permit or the prevention of sewage sludge use or disposal in compliance
with the statutory provisions and regulations.
Section 405 of the CWA, the Solid Waste Disposal Act (SWDA), Including the
RCRA, state sludge management regulations prepared pursuant to Subtitle D of
the SWDA, the Clean Air Act, the Toxic Substances Control Act, and the Marine
Protection, Research and Sanctuaries Act, all can have some bearing on the
operations of a POTW. (Guidance Manual on the Development and Implementation
of Local Discharge Limitations under the Pretreatment Program, Dec. 1987, U.S.
EPA). Specific prohibitions forbid the discharge of five categories of
pollutants:
Those that create a fire or explosion hazard in the collection
system or the treatment plant.
Those that are corrosive, including any discharge with a pH lower
than 5.0, unless the POTW is specifically designed to treat such
discharges.
- 32 -
-------
Solid or viscous pollutants In amounts that will obstruct the flow
In the collection system or treatment plant, resulting In
Interference with operations.
Any pollutant discharged In quantities sufficient to Interfere with
POTN operations.
Discharges with temperatures above 104°F (40°C) on arrival at the
treatment plant, or of a temperature which interferes with the
biological treatment processes at the STP.
Local Limits
As noted in the immediately preceding discussion, Section 403-5 of the
General Pretreatment Regulations requires the implementation of General &
Specific Prohibitions through the local limits process under two specific
circumstances:
1. POTWs with local pretreatment programs shall develop and enforce
specific limits to Implement the prohibitions under 403.5 a) and b)
(General and Specific Prohibitions).
2. All other POTWs shall, in cases of Interference or Pass Through
resulting in a violation, develop and enforce specific effluent
limits for Industrial and all other users to ensure renewed or
continued compliance with the POTWs NPDES permit or sludge use or
disposal practices.
Typical municipal effluent permits may contain both specific conventional
and non-conventional pollutant effluent limitations and, increasingly, water
quality based toxic pollutant limitations, narrative toxicity limitations
(e.g. no toxics in toxic amounts) and whole effluent toxicity standards.
Section 406 of the 1987 Water Quality Amendments also requires the imposition
of "conditions in permits issued to POTWs ... to protect public health and the
environment from any adverse effects which may occur from toxic pollutants in
sewage sludge". The EPA has provided a guidance manual outlining in detail
appropriate methodologies for development of discharge limitations on sewage
collection system users (Guidance Manual - EPA, Dec. 1987).
Currently, some NPDES permits include criteria for sludge use or disposal;
however, many permits do not. At this time, sludge technical criteria are
under development by the Office of Water at EPA; in the interim, sludge
requirements may be contained In State or Federal regulations and/or State
issued sludge use or disposal limits. In order that POTWs meet such limits,
it is frequently necessary to develop a further limit on the contents of
wastewater discharges to the POTW from industrial sources.
As the NPDES permitting system continues to evolve, increasing numbers of
POTW effluent permits will incorporate limits for specific toxic
contaminants. Where states have promulgated numerical water quality standards
for specific toxic pollutants, POTWs whose effluents contain such contaminants
may be required to develop limits in their industrial permits to ensure that
these standards are met. In the absence of such State criteria, NPDES
permitting authorities are expected to use a combination of biological
techniques and available toxic effect data to develop permit conditions that
- 33 -
-------
establish whole effluent toxldty limits or limits on specific contaminants.
POTW local limits would then be developed to ensure these targets are met.
Local limits may also be developed to prevent fume toxldty to sewage
plant workers and for the reduction of toxic emissions to the airshed from the
POTW. Additional state requirements 1n areas such as solid waste management
and hazardous waste acceptance should also be considered In the development of
local limits. It should be emphasized that the existence and application of a
Federal categorical standard does not relieve a municipality of Its obligation
to develop a more stringent local limit where the need for same Is
demonstrated.
Methodology for Limit Development
A number of methods exist for the development of local limits, depending
on the specific concerns being addressed e.g. passthrough, exploslvlty,
control of volatile organic compounds, or control of sludge content.
Selection of a particular technical approach Is largely a local decision,
providing that the resulting limits are enforceable and scientifically
defensible. For further Information, refer to: "Guidance Manual on the
Development and Implementation of Local Discharge Limitations under the
Pretreatment Program", December, 1987, U.S. Environmental Protection Agency,
Office of Water, Office of Water Enforcement and Permits, 401 M Street, S.W.,
Washington, DC 20460.
Categorical Pretreatment Standards
As noted earlier, categorical pretreatment standards are aimed at
controlling the content of discharges of toxic substances to the POTW from
specific Industrial sectors. Development of these standards began 1n 1978 and
has continued to this day under 40 CFR parts 400-499. Each categorical
standard covers one particular Industrial sector.
In determining target Industrial sectors, the categorical standard
Initiative made use of the EPA list of 126 toxic pollutants (often referred to
as the Priority Pollutants) Identified as having the greatest potential to
harm human health or the environment (Table 5.1). Some of the standards also
regulate Industrial discharges of non-conventional pollutants which are not
Included among the 126 chemicals. Those 28 Industrial sectors currently
affected by categorical standards are listed In Table 5.2.
Six of the Industrial categories have a pretreatment standard established
for TTOs. The TTO is defined as the sum of the masses or concentrations of
specific toxic organic compounds found In the industrial user's process
discharge at a concentration greater than 0.01 mg/1. Each Categorical Standard
lists the specific toxic organic compounds that are to be Included In the
summation to define TTO for that particular category. The categories affected
by a TTO limit include electroplating, metal finishing, electrical and
electronic components, copper forming, aluminum forming, and coil coating
(can-making subcategory only). The TTO requirement for these Industries
resulted from industry studies which demonstrated significant potential for
TTO discharges from them.
Industrial users in the electroplating, metal finishing, and electrical
and electronic components categories, rather than perform routine TTO
- 34 -
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monitoring, may prepare a toxic organic management plan (TOMP). Such a plan
specifies the toxic organic compounds used In the process, the method of
disposal used rather than discharge into wastestreams, and procedures for
ensuring that toxic organlcs do not routinely spill or leak Into wastewaters
discharged to POTWs. In the Detailed Audit of Selected POTWs appended to this
report, repeated reference will be made to both TTOs and TOMPs. Both
initiatives, TOMPs in particular, are consistent with the goal of virtual
elimination of persistent toxic substances called for 1n the Agreement,
although contaminants addressed under them are not explicitly limited to that
goal. (Reference: "Guidance Manual for Implementing Total Toxic Organic
Pretreatment Standards", Permits Division, Office of Water Enforcement and
Permits, Office of Water, U.S. Environmental Protection Agency, Sept. 1985.)
There are three circumstances under which categorical standards may be
modified for an Industry to which they do apply. If the service water to an
industry contains a regulated pollutant, a net/gross adjustment may be made,
which would allow the Industry to discharge that particular pollutant in a
quantity which would exceed the limit in the standard by the amount found in
the service water.
The second adjustment is referred to as a removal credit. If the STP
serving the industrial facility demonstrates effective removal of a pollutant
of concern, the limit applicable to served industries discharging that
pollutant may be adjusted. The use of such credits has been temporarily
prohibited, in accordance with an April 1, 1986 court decision.
The third adjustment accounts for the existence of 'fundamentally
different factor(s)'. If a POTW, Industry or Interested party can
demonstrate that a factor or factors exist that were not considered In the
application of the standards, they may apply for a change 1n the standards.
For example, firms which introduce process technology which was not considered
in the development of the standards may be eligible for relief under this
provision.
Hazardous Waste Discharges to Sewer System (RCRA)
The RCRA, which was passed by Congress in 1976, and followed by
implementing regulations In 1980-1982, was designed to provide 'cradle to
grave' management of hazardous waste, Including its generation,
transportation, storage and disposal. Hazardous wastes which are regulated by
RCRA can be divided into two broad classes; 'characteristic1 waste, I.e. those
exhibiting one or more of the properties of ignitabi1ity, corrosivity,
reactivity or toxicity, and 'listed' wastes, including 375 specific hazardous
constituents identified in Appendix VIII of the Act. However, in the original
RCRA legislation, an exemption was granted for mixtures of domestic sewage and
other wastes (which could Include hazardous wastes as defined by RCRA) that
passthrough a sewer system to a POTWs. Thus, for example, discharges of such
common solvents as xylenes and acetone, which are not among the 126 Priority
Pollutants but are listed as part of the RCRA Appendix VIII, from a
categorical industry, would not be regulated if discharged via the sewage
collection system to a POTW, other than through the general provisions or a
specific local limit. Also, priority pollutants from non-categorical
industries discharging into the sewer collection system would not be subject
to control other than by general provisions or a specific local limit.
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In the Hazardous and Solid Waste amendments of 1984, the Congress directed
the EPA to determine the types, size, and number of hazardous waste generators
disposing of waste through domestic sewage treatment systems, the types and
quantities of waste disposed of in this manner, and to determine if further
regulation would be required to protect human health and the environment from
such discharges. The findings of the subsequent Domestic Sewage Study were
considered in this review and those relevant to the Great Lakes basin will be
emphasized herein.
Implementation
The General Pretreatment regulation for Existing and New Sources of
Pollution (40 CFR 403) requires that any POTW or combination of POTWs operated
by the same authority with a design flow greater than 5 million U.S. gallons
per day must establish a pretreatment program as a condition of Its NPDES
permi t.
The focus of any pretreatment program is largely direct control by the
municipality; the local pretreatment program is the legal, technical and
administrative framework for achieving effective discharger control. In a
great majority of cases, the municipality has the legal authority, procedures
and funding to operate the pretreatment program, with the State and the EPA
playing an oversight role.
POTWs with design flows less than 5 USMGD (18,900 m3/day) may be
required to develop a pretreatment program if non-domestic wastes cause
upsets, sludge contamination or violations of NPDES permit conditions, or if
their ILJs are subject to national categorical pretreatment standards.
Under 40 CFR Part 403.10d3, a permittee's NPDES permit shall contain
pretreatment conditions as enforceable items. An approved program is to
contain a minimum requirement for a compliance monitoring/sampling procedure
including a system for receiving, reviewing and maintaining records received
by the POTWs from SIUs of the sewer system. A SID is defined In the EPA
Guidance Document as one meeting any of the following conditions: is subject
to promulgated categorical standards; generates waste having an Impact on the
POTW; constitutes 5% (25,000 GPD) or greater of the flow to the POTW; or Is
otherwise considered significant by the control authority.
The essential elements of a pretreatment program, to be carried out for
the most part by municipalities, were seen as: i) developing and Issuing
permits/agreements with industry; 11) carrying out inspection/monitoring
activities on SIUs, including direct sampling of their wastewater as
necessary; ill) maintenance and updating of data on municipal effluents; iv)
enforcement and necessary remedy of non-compliance; v) reporting to the
approval authority at least annually on the status of programs; and vi)
performing other special condition requirements.
Categorical Industry Reporting Requirements
Categorical industries (those for whom regulations have been promulgated
as listed in Table 5.2) discharging to a POTW, must report to the control
authority (usually the POTW) in the following fashion:
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Baseline Monitoring Report: Within 180 days of the effective date of
adoption of pretreatment standards for their industry, IDs of a POTW
must submit Information on their production, flow rates, nature and
concentration of regulated substances, and either a schedule to
achieve compliance with the pretreatment standards or a certification
that this has been achieved.
Periodic Progress Report: Non-complying Industries are to submit,
within 14 days of each milestone date in the compliance schedule
shown in the Baseline Report, progress reports on achieving
compllance.
90 Day Compliance Status Report: Following submission of the 180 day
Baseline Report requirement, a categorical Industry has a maximum of
three years after the effective date of the standard to achieve
compliance. Within 90 days of this final compliance date, all
facilities, regardless of compliance status, must file a report that
certifies compliance or addresses steps being taken to achieve
compliance.
Self-Monitoring (Semi-annual) Reports: After the final compliance
date, in June or December of each year, or more frequently, or at
other dates if required by the Control Authority, categorical
Industries are to submit self-monitoring reports to the control
authority to verify compliance.
As mentioned, compliance with the categorical standard is required as soon
as possible, but no later than three years after the effective date contained
in the appropriate standard.
Anticipated Program Changes
Oversight
No fundamental changes to the U.S. Pretreatment program are planned.
However, several adjustments will be made over the course of the coming months
and years. These adjustments can be grouped into three broad areas:
improvements in information management.
improved control of hazardous materials discharged to POTWs.
improved control of toxicants discharged from POTWs.
Information Management
Nationwide, the pretreatment program controls more individual sources than
the U.S. program for control of sources which directly discharge wastes to
surface waters. It is also the most decentralized water pollution program, as
primary responsibility for enforcement of national standards resides at the
municipal level. Because of the large number of sources and decentralized
nature of the program, transfer of program Information from the local to
national level to date has been poor.
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Information management should be greatly improved by two simultaneous
initiatives. By use of the Permits Compliance System (PCS), the national
water program database, summary statistics of each approved POTW program,
including its pretreatment elements, will be available on a national basis.
At the same time, the compliance activities of state pretreatment programs
will be monitored through the Quarterly Noncompllance Report (QNCR) system.
As of October 1987, PCS had the capability to track 54 national
pretreatment data elements. In addition, several 'blank1 fields will be
available for EPA Regions and States to use in managing their programs more
effectively. Fourteen data elements will be required to be entered by the
states.
These 14 required elements form the pretreatment component of EPA's Water
Enforcement National Data Base (WENDB). The WENDB elements provide POTWs
specific information on the universe of regulated IDs, the quality of the
POTWs control mechanism, and a summary of the POTWs compliance monitoring
and enforcement program. The remaining 'optional' elements Include data on
the POTWs legal authority, general program deficiencies, program resources
and other information.
States are presently required to report significant or 'reportable'
noncompllance with NPDES permits to EPA on a quarterly basis. This report is
called the Quarterly Noncompliance Report (QNCR). Presently, the regulations
governing the QNCR (40 CFR Part 123) specify that failure to submit program
reports and failure to implement approved pretreatment programs must be
reported on the QNCR and addressed by state enforcement action.
Guidance to date has been very general as to what constitutes "failure to
implement approved pretreatment programs". EPA is presently finalizing
specific guidance on significant noncompllance with pretreatment
implementation requirements. The guidance will center on failures of POTWs to
issue Industrial User control mechanisms, conduct sampling and inspection
activities and enforce pretreatment standards.
Having refined the guidance through demonstration applications during late
calendar year 1987 and early 1988, the agency will propose any necessary
modifications to Part 123 of 40 CFR shortly.
Control of Hazardous Materials
When the RCRA was amended in 1984, EPA was directed to review the nature
and amount of hazardous wastes discharged to POTWs both through the user's
normal sewer connection and transported to the POTW by truck, rail or
dedicated pipeline. In this latter case, POTWs are subject to RCRA permit by
rule. Hazardous wastes discharged into domestic waste streams are not
regulated under RCRA, as it was assumed that they would be sufficiently
controlled by the pretreatment program. Recognizing the considerable effect
of the Domestic Sewage Exclusion on industry notification practices, in the
1984 RCRA amendments, Congress required that generators discharging hazardous
wastes to POTWs comply with RCRA notification requirements.
A large percentage of these wastes were not 'priority' pollutants and, as
such, were not targetted for coverage in the pretreatment program. Since the
pretreatment program is not yet completely implemented, and 1n anticipation of
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Increased usage of this exemption by Industry, the Agency Is undertaking
several activities to Improve the control of hazardous wastes discharged to
POTWs via this and other means. The Impact of the domestic sewage exclusion
should be the subject of continued review to determine If extension of the
exemption Is consistent with sound ecosystem management In the basin.
Both the categorical and prohibited discharge standards will be expanded.
Twelve Industrial categories are being Investigated for new or broadened
standards. These Include: equipment manufacturers; pharmaceutical
manufacturers; solvent and barrel reclaimers; hazardous waste treatment
facilities; paint manufacturers; Industrial laundries; waste oil reclaimers;
motor vehicle services; transportation services; laboratories and hospitals;
and timber and textile products. EPA expects to Issue additional categorical
standards and/or guidance for control of wastes from these Industry sectors In
the next five years.
The prohibited discharge standards will be broadened to Include more
detailed prohibitions on explosive/flammable compounds and wastes which could
Impact worker health and safety.
In addition to adjusting the pretreatment standards, EPA 1s considering
modifying POTW program Implementation requirements and the procedural
requirements placed on IDs. These changes will center on spill prevention and
the quality of POTW Issued control documents and Improvements to municipal
enforcement programs. Appropriate regulations were proposed on November 23,
1988 and should be promulgated sometime 1n 1989.
Pretreatment Programs of the Great Lake States
Table 5.3 notes the number of pretreatment programs required and approved
1n the U.S. portion of the Great Lakes basin. Over 95% of the programs are
now approved; only 8 programs in Michigan and 1 1n Ohio remain unapproved.
Indiana, New York and Pennsylvania, all of whom have POTWs discharging Into
the basin, have net been delegated primary oversight of pretreatment programs
by the EPA. Current efforts In the balance of the states are focused on
providing appropriate scrutiny and review.
As noted 1n the following state segments, the essential strategy used In
Implementing pretreatment programs 1s their Integration Into existing NPDES
permitting and compliance programs. Priority activities for the states will
remain the oversight of POTWs with approved programs and of Industrial users
(IDs) whose discharges to POTWs without approved programs require scrutiny.
POTWs with an approved program are charged with maintaining an Inventory
of IDs; applying pretreatment standards; securing and reviewing IU reports;
inspection and monitoring of lUs; and enforcement as required.
Three primary mechanisms, the pretreatment compliance inspection,
pretreatment program audit, and the solicitation and review of periodic POTW
pretreatment reports, are or will be used by the states to ensure program
compliance. The pretreatment compliance inspection, or PCI, is comprised of
an onsite interview with responsible POTW officials and a review of POTW
pretreatment files. These Inspections are designed to occur annually In
conjunction with other NPDES Inspections. As is the case with other NPDES
inspections, concerns identified in PCIs should be resolved within six months
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by corrective action, an enforcement schedule or formal enforcement action.
Table 5.4 summarizes PCI activity by state.
A POTW program audit is a comprehensive review by the state or EPA of all
elements of a pretreatment program. Based on a review of initial audits,
compliance inspections and annual reports, audit activities will likely focus
on three areas; the adequacy of local limits; the effectiveness of POTW Issued
control mechanisms; and the suitability of POTW administrative procedures.
Such audits should be scheduled a year prior to permit expiration, which
occurs in routine cases approximately every five years. Data on audit
activity in the Great Lakes basin are also presented in Table 5.4.
POTWs with pretreatment programs should also file reports on program
activities at least on an annual basis. Information on Industrial Inventory
updates, permitting, inspection, monitoring and enforcement, including a list
of significant violators, should be provided In these reports.
The United States Environmental Protection Agency is responsible for
review of state program activities. Within the basin, EPA conducts reviews of
state pretreatment programs. For both delegated and non-delegated states,
specific program goals and activities are negotiated annually. As noted in
the discussion of future initiatives, the recently established PCS
computerized database will be expanded to track pretreatment Issues. Audit,
PCI and POTW annual report results are being loaded into PCS so an assessment
of Implementation can be more easily made.
All pretreatment POTWs are encouraged to conduct a monitoring program.
Typically, monthly monitoring for metals and cyanide in the Influent, effluent
and sludge and at least one annual GC/MS broadscan of these three streams for
organic species should occur, with further follow-up as required. Significant
changes in annual reporting requirements can be made based on the findings of
such scans.
The need for an active monitoring program is apparent when the extent of
the spill and illegal discharge problem at POTWs is considered. In 1985, the
Association of Metropolitan Sewerage Agencies surveyed 107 of their member
municipalities, representing 308 POTWs corresponding to 39% of the estimated
total flow nationwide. This survey revealed that nearly all POTWs receive
hazardous wastes, the most common being corrosives, solvents, electroplating
baths and sludges. The most commonly reported sources of such wastes were
spills, illegal discharges from industries, and routine discharges from
Industries.
Half the respondents noted discharges of explosive or flammable materials
(gasoline, jet fuel, benzene, xylene) and nearly half reported corrosion of
sewer lines due to acids and hydrogen sulfide gas. Approximately 30% of the
respondents have experienced one or more biological treatment system upsets
since 1980 as a result of significant quantities of hazardous materials
contained in plant influent (Guidance Manual for Reporting Interference at
POTWs, Sept. 1987, U.S. EPA).
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TABLE 5.3
UNITED STATES PRETREATMENT PROGRAMS IN THE GREAT LAKES BASIN
STATE
INDIANA
MICHIGAN
MINNESOTA
OHIO
WISCONSIN
NEW YORK
PENNSYLVANIA
ILLINOIS
TOTAL
TOTAL PROGRAMS REQUIRED
IN THE GREAT LAKES BASIN
9
116
1
41
11
25
1
0
201
APPROVED
PROGRAMS1
9
108
1
40
11
25
1
0
192
i Programs approved as of May 1, 1988
TABLE 5.4
CUMULATIVE PRETREATMENT FACILITY INSPECTIONS (1986 - March 1988°)
IN GREAT LAKES BASIN
STATE
INDIANA
*M I C H I G A N
MINNESOTA
OHIO
WISCONSIN
NEW YORK
*PENNSYLVANIA
NUMBER OF PRETREATMENT
COMPLIANCE INSPECTIONS
0
167
0
112
8
32
1
NUMBER OF AUDITS
7
44
1
23
6
24
1
*Some facilities inspected twice.
0Retrieval PCS database
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New York State
1) Approach
A June 1988 application from the State of New York for delegation of Its
pretreatment program Is currently under review by EPA. Delegation Is
anticipated in 1989, however, resource and legal authority Issues are
currently under review. Oversight of the implementation and enforcement of
the 56 approved pretreatment programs in the entire state is carried out by
the New York Dept. of Environmental Conservation under an extended Memorandum
of Understanding with EPA Region II.
These 56 municipalities contain 91 POTWs with more than 1,500 SIUs.
Approximately half of these SIUs are subject to some form of toxic
consideration. Twenty-five of these municipalities, containing a total of 31
POTW treatment facilities, discharge Into the Great Lakes basin, and all have
state approved pretreatment programs.
The development phase of these 56 programs was conducted by the Department
of Environmental Conservation's (DEC) Central Office and overseen and formally
approved by EPA Region II. Program guidance and oversight remains a Central
Office function; however, the Inspection, report review, monitoring/sampling,
and non-compliance follow-up activities are provided by DEC'S nine regional
offices.
In New York State, Water Quality regulations are based on receiving water
classifications as defined by best usage of the waters. Quality standards
with numerical limits are Included for protection of human and aquatic
health. These regulations were amended in 1985/86 to Include ambient water
quality standards. Some 96 hazardous or toxic substances are Included In the
ambient water quality standards which also have numerical limits based on
human and aquatic considerations. These regulations and standards in effect
"ban the discharge of toxic substances in toxic amounts". Point source direct
discharge permits are developed on an individual basis and address these water
quality regulations.
A municipality's POTW discharge permit includes, where applicable,
requirements for the implementation of all pretreatment program elements,
including the requirement to issue IU permits Incorporating local discharge
limits. Each approved pretreatment program originally provided the legal
authority, procedures, and staffing to implement the program. During program
development (1980-1985) at least one GC/MS scan was required to determine
recommendations for local limits. Analysis and allocation of Influent loading
to STPs were used to determine local limits, and continue to be a periodic
requirement; various data that document process inhibition also serve as Input
for local limits.
The strict water quality standards, as well as other toxic substances
controls placed on the point source discharge, must now be reflected in local
limit development as part of the ongoing oversight. DEC'S policy guidance
toward local limits is to ensure that all available data and regulations are
included when setting local limits, local limits are set correctly, and limits
are modified appropriately when conditions or requirements change. DEC uses
EPA's "Guidance Manual on the Development and Implementation of Local
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Discharge Limitations Under the Pretreatment Program" 1n establishing
pretreatment programs.
POTW sludge disposal Is regulated by a separate division within DEC based
on the presence of hazardous or toxic substances. Sludge disposal options
practised in the state include landfllllng, composting, land application, and
incineration. A permit system controls each one of these technical disposal
options. All priority pollutants are considered when selecting a disposal
option to be used by a municipality.
Technical assistance to municipalities on the Implementation and
enforcement aspects of the pretreatment program has been and continues to be a
focus for EPA/DEC efforts. In 1988, a statewide local limits workshop was
held and the guidance manual was distributed to all affected POTWs. Also, 3
regional PCME workshops were held. In addition, roundtable discussions
co-sponsored by the Water Pollution Control Association (WPCA) occurred in
1988 and are planned for 1989.
Statewide pretreatment oversight consumes approximately six full-time
employees (FTE), half of whom are provided by the Central Office.
11) Implementation
Once a program has been approved, a municipality's point source discharge
permit is modified to require pretreatment program Implementation and
reporting. Under these requirements, municipalities will: 1) enforce
categorical pretreatment standards; 2) Issue IU discharge permits that Include
local limits; 3) maintain program records; 4) carry out sampling, Inspections
and monitoring activities on lUs; 5) obtain/enforce remedies for
non-compliance; 6) report to DEC on the implementation and non-compliance
activities required, planned and taken; and 7) fulfill special conditions as
required. The DEC emphasizes assuring complete Implementation and Identifying
non-compliant program elements as determined through municipal program reports
and DEC Inspection/audits and the verification of definition and achievement
of corrective actions.
In fulfilling its oversight role, the DEC monitoring and enforcement
activities include, at a minimum, an annual pretreatment inspection/audit of
approved pretreatment programs. In addition, the DEC conducts one annual
compliance evaluation inspection and three reconnaissance inspections of all
permitted municipal dischargers. These compliance evaluation Inspections are
enhanced to include pretreatment program inspection elements as appropriate to
provide thorough point source and pretreatment program oversight without undue
duplication. Sampling of POTWs or lUs depend on the priority and
availability of Department resources given the inability of many of the
Individual municipalities to perform adequate self monitoring programs.
Michigan
1) Approach
The Michigan pretreatment program has had delegated status since June
1983. It is organized under the Michigan Department of Natural Resources
(DNR); field responsibility is charged to nine District offices, with Central
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office staff providing overall coordination. Approximately 7.5 FTEs are
currently involved in the program.
The Michigan program operates under narrative water quality standards,
with specific procedures for calculation of effluent limitations on a site
specific basis. It is not confined to the EPA Priority Pollutant list;
significant toxicity data are factored into effluent permit levels. Human
health considerations (carcinogenic!ty) are also a factor in the determination
of discharge levels.
The DNR took the lead in the development of local limits with the issuing
of "Industrial Pretreatment Guidebook for POTWs" in 1982. This guidebook
outlined a method of headworks analysis and mass balance techniques to
determine local limits based on water quality criteria. Although there is not
a broad requirement for updating limits, as new limits are Introduced on
pollutants such as silver, other established limits are then reviewed.
Sludge disposal is regulated under a PERM ( Program for Effective
Residuals Management) initiative, which is required by the POTWs NPDES
permit. The PERM requires that the operator develop a preliminary and a
contingency method for the disposal of sludge. The majority of Michigan
municipalities has approved sludge management programs and several others are
under review at this time. The residuals management program focuses on
metallic pollutants and selected organic compounds, as well as nutrient
content in the form of nitrogen, phosphorus and potassium.
The DNR provides technical support through monthly meetings of the
Pretreatment Coordinating Committee. They also maintain contacts with the
local arm of the Water Pollution Control Federation, the Michigan WPCA and its
Industrial Pretreatment Committee. As of Oct. 1988, the DNR has resumed
issuing Pretreatment bulletins on a quarterly basis.
In reviewing areas in which the program could have been improved, in
retrospect, earlier training of the program staff would have been useful;
annual staff and community training is the current objective.
The strength of the Michigan program is Rule 57, the Toxic Substances
Rule, which permits only low passthrough values. Limits developed under Rule
57 are not restricted to any toxicant list, and provide protection for aquatic
and terrestrial organisms, as well as human health.
Michigan initially identified 113 POTWs for which industrial pretreatment
programs would be required. Three more communities have subsequently been
identified, bringing the total to 116. Twenty nine (29) of these POTWs have a
flow capacity of 5 million gallons per day (USMGD) (18,900 m3/d) or more.
Seventy nine (79) POTWs are considered to be major facilities, with design
flows of 1 USMGD (3,785 m3/day) or more. One hundred and eight (108) POTWs
have received state approval to implement their pretreatment programs. All
surface water dischargers in Michigan discharge to waters that flow to the
Great Lakes.
ii) Implementation
Industries discharging to POTWs are subject to control and regulation by
both Federal Pretreatment regulations and local sewer ordinances (local
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limits). In Michigan, the focal point for pretreatment program Implementation
lies with the local unit of government. Sewer use ordinances are the local
government's legal basis for exercising Its control.
Michigan regulates and oversees local government Implementation of the
program through use of program audits, facility Inspections, and review of
annual reports. NPDES permits Issued to pretreatment communities contain
program requirements and discharge limits to prevent unacceptable levels of
toxic pollutant discharge through the POTW. In order to assure compliance
with these permit requirements, POTNs must monitor IDs and enforce Industrial
discharge controls as least as restrictive as Federal Pretreatment Discharge
Standards. POTWs must submit annual pretreatment compliance reports that
summarize the status of Industrial compliance with discharge standards.
When toxic pollutants are identified 1n a municipal wastewater discharge,
water quality based effluent limits are developed for these pollutants and
Incorporated Into the municipal NPDES permit. The municipality then uses Its
pretreatment program authority to establish local discharge limits on
non-domestic users to ensure compliance with NPDES permit limits. The state
has chosen to require pretreatment programs of all POTWs (regardless of size)
receiving wastewater from one or more categorical industries.
The Michigan Pretreatment Program is administered by the Surface Water
Quality Division of DNR. Responsibility for program overview lies with the
nine Surface Water Quality Division District Offices; the staff of these
offices conduct all facility inspections and program audits, as well as review
all submittals required under NPDES permit, including annual reports.
Enforcement action, if warranted, will be initiated by the district staff.
The State may take concurrent action against both the municipality and any
particular Industry contributing to a non-compliance situation.
Ohio
1) Approach
The pretreatment program was delegated to Ohio by the EPA In July of
1983. The program is managed from Ohio EPA headquarters, with five field
offices performing sampling and other support functions. FTEs dedicated to
the program total 12, with four 1n the Central offices and eight In the
field. These personnel also respond for the state In enforcement situations.
Ohio water quality standards are numerically based, developed using the
procedures contained within the EPA Gold Book, and are updated annually. With
regard to Priority Pollutants, the state has developed and 1s Implementing an
approach similar to Michigan Rule 57; however, it is based only on the
protection of aquatic life at this time. Human health considerations are
currently being evaluated and will be incorporated into this legislation in
some form within the next year.
The state requires that POTWs develop sludge management plans addressing
all proposed methods of disposal. The general focus is on metallic
contaminants; organic contaminants are considered on a case-by-case basis.
Local limits are developed through the review of three GC/MS scans of
influent/effluent/sludge at each POTW. The limits are set on a case-by-case
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basis through the application of the state water quality standards of 1978,
generic inhibition data, sludge disposal options, and removal data, both site
specific and values derived from the literature.
Renewal of each permit calls for a demonstration of the adequacy of local
limits and, in addition, the state requests an annual review of limits.
One hundred POTWs have been required to develop pretreatment programs; of
these, 98 now have approved programs. These 100 Include all POTNs with design
flows greater than 5 USMGD (18,900 m3/day) having contributing Industries,
and smaller POTWs with apparent problems associated with industrial discharges
or receipt of a large industrial waste contribution. Forty-one (41) of the
targeted POTWs discharge into the basin and 21 of those have a flow of greater
than 5 USMGD (18,900 m3/day).
Industrial users not affiliated with targeted facilities (Including some
falling under federal and state categorical standards) are regulated directly
by the Ohio EPA, Division of Water Pollution Control, under their permitting
program. Approximately 50 SIUs are under state control 1n the basin.
Compliance monitoring is conducted by the Division of Water Quality and
Assessment.
The state provides technical support through workshops held statewide
every 15 months and linkages with professional organizations such as the Ohio
Water Pollution Control Association (OWPCA). Categorical pretreatment groups
are also used for program review.
ii) Implementation
Following Initiation by the State, ongoing development and Implementation
will be largely the responsibility of the local level of government through
NPDES permits Issued to the POTWs. Permits for POTWs with approved
pretreatment programs require submission of program status reports and data on
IU effluents.
Each municipal pretreatment program Is Inspected at least once per year to
ensure that the POTW is complying with its approved program. Twenty percent
of these Inspections will be program audits, designed to assess program
effectiveness and adequacy as well as compliance.
POTWs with approved pretreatment programs conduct at least annual on-site
inspections at each categorical and SID. POTWs monitor IDs regulated by
federal and state categorical standards at least twice per year. Other SIUs
are monitored at least once each year. Ohio EPA will Inspect significant and
categorical lUs not affiliated with targeted facilities annually and will
continue to monitor these industries annually as resources allow.
The Ohio EPA has established a computer database to facilitate the receipt
and analysis of baseline reports, self monitoring reports, compliance
schedules and compliance reports, including information on influent, effluent,
and sludge analysis from POTWs. Compliance inspection and audit procedures
have been tied into those already in existence in the POTW direct discharge
sampling program.
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A definition of noncompllance will be adopted In the state rules during
this year; 1t is anticipated that a one year transition period will be
required for complete Implementation.
Inadequate training in the application of the National Enforcement
Protocol is a concern, as Is the reluctance of a number of municipalities to
proceed with legal action for enforcement. It is clear that the state and
federal governments must provide more technical assistance and continuous
training to all the municipal personnel, including the legal staff. There was
also a need to simplify the language 1n a number of the training manuals,
particularly those used at the municipal level.
Indiana
i) Approach
Indiana has applied for and is currently awaiting delegation of its
pretreatment program from EPA Region V.
The state program is administered from one central office, using
approximately 3 FTEs, rather than the 5 called for in the program design.
These personnel issue and audit permits only; enforcement is under another
branch using an additional 1 to 2 FTEs.
The Indiana Department of Environmental Management (IDEM) presently
requires, through the NPDES permit program, 45 POTWs to operate federal and
state approved pretreatment programs. All 45 programs have been approved. Of
these POTWs, there are nine that discharge Into the Great Lakes basin.
Facilities In the Great Lakes basin Include those at Gary, East Chicago,
Michigan City, South Bend, Mishawaka, Elkhart, Goshen, Kendallvilie, and Fort
Wayne.
The IDEM has direct control of a number of IDs that discharge process
wastewater to POTWs not required to develop and operate a pretreatment
program. There are presently 11 lUs under State control in the basin.
Presently, permits are written based on the EPA Gold Book criteria, which
calls for no discharge of toxic substances 1n toxic amounts. EPA Priority
Pollutant data are used to set water quality based effluent limits. Revised
water quality standards, including narrative standards, are currently under
development.
Sludge disposal Is regulated under a separate Land Applications Section of
the Indiana Department of Environmental Management. The focus of the program
is on metals, phosphorus, nitrogen and PCBs.
Initially there was heavy technical assistance in the development of local
limits, much of it based on the EPA program software. The limits were
technology based and originally used default values derived from the old
National Removal Rates; currently the "Prelim" values are used. (PRELIM USERS
GUIDE, Version 3.0, USEPA, Office of Water Enforcement and Permits, 401 M
Street, S.W., Washington, D.C. 20460).
NPDES permits contain heavy metal limits (Cu, Zn, Cr, N1, Pb, Cd, Hg) as
well as cyanide. Individual industrial surveys were used to determine permit
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needs beyond these metals. In a few Instances, monitoring for toxic organic
substances is required on an annual or semi annual basis. Permits are updated
as they are reissued; typically the updating takes approximately one year. To
provide some technical assistance, the state met with the POTW community last
year and will attempt to do so again this year.
ii) Implementation
a) Major Facilities
As stated above, pretreatment programs are made an enforceable part of the
POTWs NPDES permit through the incorporation of effluent limits for Ills, and
the administration of monitoring and inspection activities to determine
compliance by the IDs. Also, POTWs are required by permit to enforce their
ordinances against the IDs, operate compliance monitoring programs and report
IU compliance status.
Compliance with pretreatment requirements is verified by computer tracking
by the IDEM of analytical results contained in the monthly monitoring reports,
and through audits or PCI on municipal programs.
The state also tracks, through quarterly IU compliance status reports from
each POTW, the compliance status of each IU. These data are also stored on
computer.
State pretreatment staff visit each POTW once per year, at minimum, to
perform onsite and audits or PCIs of program operation.
b) Minor Facilities
The state has identified 11 lUs discharging to POTWs 1n the Great Lakes
basin for continued scrutiny. Industrial Pretreatment Permits have been
issued by the State to all 11 lUs. These permits require the lUs to meet
effluent limits, analyze and report results to the State, etc. The permits
have been issued in accordance with state and EPA guidelines for permit
wri ting.
Minnesota
The EPA delegated the Minnesota pretreatment program to the state in July
of 1979. Management of the program is under the Minnesota Pollution Control
Agency (MPCA); the headquarters office is charged with overall coordination
and 2 to 3 FTEs are dedicated to the program.
The state water quality standards are set on the basis of use
classifications for fisheries, recreation, domestic consumption, and several
other uses. Some numerical standards are used to define water and effluent
quality, as well as a narrative omnibus clause banning discharge of "toxic
substances in toxic amounts." The standards will be reviewed in 1990.
The MPCA provides sludge management through a permit system which controls
metals, nutrients, and PCBs. Since the Western Lake Superior Sanitary
District (WLSSD) plant Incinerates its sludge, air quality limitations are
also used to develop local limits. Human health concerns are reflected
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through the application of water quality limits based on drinking water and
fish consumption considerations.
Local limits are developed for metals, cyanides and other toxic
contaminants on a case-by-case basis through a technical review. Site
specific water and air quality criteria are used, coupled with generic data on
Inhibition of the treatment process.
The MPCA last held a pretreatment seminar more than a year ago; they
respond now to Individual queries.
One POTN with a federally delegated pretreatment program (WLSSD - Duluth
and Cloquet) and one POTW with a limited local pretreatment program (H1bb1ng -
two treatment plants) discharge Into the Great Lakes basin. At the WLSSD
POTW, water quality based effluent limits are determined by mass balance and
other water quality criteria. Of the nine SIUs discharging to the WLSSD
plant, one (11%) Is not In compliance with reporting requirements.
In addition, five other POTWs (Eveleth, Kettle River, Silver Bay, Two
Harbors, and Virginia) discharging to the Great Lakes basin were evaluated and
found not to have IU Inputs significant enough to warrant program development.
In all cases, the MPCA retains the authority and responsibility to
administer the national program both 1n communities with limited local
pretreatment programs and those with no approved program. The MPCA Issues
State Disposal System Permits to categorical industries In accordance with the
National Categorical Standards and monitors compliance through IU self
monitoring reports and state Inspection and monitoring as required. All
pretreatment programs are audited by the MPCA to assure compliance with the
approved plan and conditions contained in the NPDES permits.
Wisconsin
The state was delegated the pretreatment program in 1982. The Department
of Natural Resources (DNR) administers a pretreatment program under a
Memorandum of Understanding with the EPA. The 24 major POTWs over 5 USMGD
(18,900 m3/d) design capacity (11 in the Great Lakes basin) are
administering pretreatment programs regulating their lUs. These POTWs have
established local limits for toxics and issued permits with numerical limits
to their lUs.
There are approximately 450 lUs of POTWs in Wisconsin subject to
categorical pretreatment standards. Two-thirds of these are located 1n
municipalities with programs and the balance are directly regulated by the DNR.
The DNR requires these municipalities to provide annual pretreatment
program reports and has audited or inspected each program on a yearly basis.
Pretreatment activity is centered in the Headquarters office among 4 FTEs,
who centrally administer the program, carry out audits and program reviews,
and assist with enforcement. Three to four FTEs assigned to the districts
carry out field inspections, review reports from lUs and directly oversee
approved pretreatment programs and lUs of POTWs located outside municipalities
that have approved pretreatment programs .
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On March 1, 1989, Wisconsin Administrative Codes NR105 and 106 were
promulgated to establish comprehensive procedures for establishing Water
Quality based limitations for protection of the aquatic environment, wildlife
and human health. The Department uses comprehensive procedures associated with
these codes, including a review of ILJs, biomonitoring and chemical specific
monitoring as necessary, to identify concerns and develop limits in the
Wisconsin Pollutant Discharge Elimination System (WPDES) permits issued to
municipalities.
POTWs operate with a Sludge Management Plan, which is part of the WPDES
permit, regulating disposal methods and establishing sludge monitoring
requirements. The focus is on metals and selected organic contaminants.
Local limits were developed using initial headworks analysis based on
industrial removals, metals and cyanide monitoring, and GC/MS scans. Sludge
data are required in the POTW's WPDES permit.
The state provides technical support through Pretreatment Program over-
sight activities which include annual pretreatment program audits and reviews.
Pretreatment in Canada
Federal
i) National Standards
In Canada, the federal government's main instrument for developing water
quality controls is the Fisheries Act. Although the Act deals primarily with
regulating fishing and managing fish stocks, it also contains provisions for
protecting fish habitat. It is these provisions that support federal water
quality controls in Canada.
Environment Canada promulgated federal regulations and guidelines on
allowable wastewater discharges from six industrial sectors, including pulp
and paper, petroleum refining, chlor-alkali, metal mining, metal finishing and
food processing (I.e. potato processing, meat and poultry products, fish
processing), in the m1d-'70s. Together, these sectors represent approximately
65% of the total industrial wastewater discharge in Canada.
Where these industrial sectors discharge to municipal sewerage systems,
all control documents, except pulp and paper and chlor-alkali regulations,
contain a sewer use exemption clause. The Minister of Environment is to give
approval for exemption from the control documents only where the off-site
facility provides "equivalent" treatment. If the off-site facilities are not
approved by the Minister, the effluents leaving the plant are subject to the
legislative requirements.
11) Implementation
Responsibility for implementation of the regulations under the Fisheries
Act has been delegated to the provinces. Implementation of the exemption
clause of federal control documents has been inconsistent among regulated
industrial sectors and various regions of the country. For example, in the
pulp and paper sector, there are 24 mills nationwide discharging to municipal
sewers; they are not exempted from the controls nor from the monitoring
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requirements. Although the effluents from the 24 non-Integrated mills are
believed to be 1n compliance, monitoring is not being conducted In accordance
with the regulations and guidelines. Thus, Federal legislation has not
provided any effective basis for a national sewer use control program.
A 1983 survey by Environment Canada found that, in Ontario, over 95% of the
approximately 350 metal finishing companies were discharging wastewaters to
municipal sewers. Two-thirds of the wastewater discharges were less than 5,000
m3/yr. (1.32 US MGY); about one-third was over 10,000 m3/yr (2.64 US MGY).
Effluent pretreatment was being practised at less than 50% of these plants.
Record keeping for waste disposal was generally inadequate. Monitoring
activity (self or external) occurred at little better than half the companies
surveyed.
111) Recent Developments
In 1988, Canada passed a new Environmental Protection Act which permits a
life cycle control of substances deemed to be a significant threat to human
health and the environment. The legislation provides for control of specific
substances and, through regulation, may limit direct or Indirect discharges to
the environment.
The Act provides for federal/provincial cooperation and, in fact, to a
large degree will rely on provincial delivery mechanisms to ensure adequate
control of priority substances. The degree to which indirect dischargers may
be controlled or Influenced by these measures 1s not clear at this time.
In summary, although the individual industrial regulations under the
Fisheries Act address discharges to municipal sewers, compliance and
enforcement have been accorded a low priority by Environment Canada, and the
noted components cannot be considered as a national Industrial sewer use
control program.
Provincial Ontario Pretreatment Provisions
1) Provincial Standards
In Ontario, 407 municipal STPs process an average of 5,345,000 cubic
metres per day (1,410 USMGD) of wastewater. These STPs accept waste from
approximately 12,000 industries.
Sewage treatment plants fall under the Ontario Water Resources Act and the
Environmental Protection Act. STP process design, operating criteria and
discharge limits for conventional wastewater parameters and, in some cases,
toxics are prescribed in a Certificate of Approval. Effluent discharge limits
are usually specified on the basis of type of treatment, e.g. secondary
treatment, lagoons, etc. However, more stringent discharge limits based on the
local receiving water quality are required In some instances. These effluent
discharge limits are derived from the policies and objectives listed in "Water
Management - Goals, Policies, Objectives and Implementation Procedures of the
Ontario Ministry of the Environment (1984)" and local field studies conducted
by MOE staff.
The discharge of industrial, commercial and Institutional wastes to STPs
is regulated locally by municipalities through the use of an Industrial Waste
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Sewer Use By-Law developed by the local level of government under the
Municipal Act. A revised Model By-Law developed by the MOE, Environment Canada
and representatives of the Municipal Engineers Association, was issued in late
1988. Many of the municipal by-laws remain based entirely or in part on the
Model Sewer Use By-Law of 1975, but are currently under review.
The Municipal Act provides adequate authority under section 147, paragraph
210 to implement and enforce a local sewer use by-law. However, there are no
provisions in the Act to allow the courts to terminate the use of the sewers
or to issue effluent discharge permits to TUs. In June 1988, the Act was
amended by increasing the maximum allowable fines to $5,000 for the first
offence and $10,000 for subsequent offences for individuals and $25,000 for
the first offence and $50,000 for subsequent offences for corporations.
The 1988 Model By-law prescribes limits for conventional pollutants, most
metals and some organics, as well as addressing surface runoff, industrial
waste surveys, compliance programs, spills control and general procedures for
sampling, analysis, and enforcement. Discharge of hazardous waste is also
banned. Effluent limits are developed to preclude worker health and safety
problems and address concerns related to passthrough to the receiving water,
sludge contamination, and interference with STP processes and equipment.
Industrial discharges to the sewer system are also regulated by the Ontario
Hater Resources Act with respect to passthrough and Interference.
Hazardous wastes are regulated under Regulation 309 of the Environmental
Protection Act. Currently the discharge of landfill leachate to treatment
plants requires approval under Regulation 309 and only receives approval based
on the potential impact on the sludge quality, the operation of STP and
effluent quality.
The majority of the STPs in Ontario use agricultural land application for
sludge disposal. This disposal practice also falls under Regulation 309 of the
Environmental Protection Act and the metals and conventional pollutant limits
In the sludge are specified in "Ontario's Guidelines for Sewage Sludge
Utilization on Agricultural Lands (1986)." The guidelines also have
restrictions on spreading sites to prevent contamination of water courses or
groundwater and to allow agricultural use of the land. Any land spreading site
must be approved by the MOE.
11) Implementation
The Model by-Law acts as a guideline that municipalities can adopt or
adapt, on a voluntary basis. All regional municipalities, district
municipalities and most cities, which in total treat 4,120,000 cubic metres
per day (1,088 USMGD) of sewage, have Implemented sewer use control programs.
These 35 municipalities monitor industrial discharges from 2,500 Industries
using 95 municipal staff. In 1986, they collected and analyzed 11,800 samples
and carried out enforcement actions against 246 industries. Administration of
sewer surcharge programs for extra strength waste was a significant part of
these activities.
In comparison, by-law implementation and enforcement activities in most of
the towns and villages vary markedly. Many small municipalities have no
effective enforcement programs.
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At the moment, pretreatment at lUs is focused on neutralization,
destruction of cyanide, and precipitation of metals; this level of treatment
is the rule rather than the exception in the province.
Effluent sampling, plant inspections and enforcement activities are
carried out by the local municipality and the MOE. In part, they can include
the following:
inspection and compliance sampling of significant industrial
dischargers by the municipality;
periodic audit of STP operational and effluent data by the MOE;
audit of sludge quality for sludges applied on agricultural land;
audit of sludge spreading sites, spreading practices and application
rates;
audit of Regulation 309 Waste Generator Reports and Manifests by the
MOE;
inspection and compliance sampling by the MOE of industries where
complaints are received from the public, concerns are identified by
the municipality, or problems are Identified by STP or sludge
application on land audits.
Although major facilities do have pretreatment programs in place, a
comprehensive and uniform sewer use control program at the provincial level
does not yet exist.
ill) Anticipated Program Changes
In September, 1988, under the MISA Initiative, the MOE released a
discussion paper that outlined a sewer use program to control industrial
discharges.
The proposed program 1s based on five principles: control of indirect
dischargers at source; setting of provincial discharge limits for twenty-two
Industrial sectors at levels that can be obtained using the BATEA; application
of more stringent "local limits" on a site specific basis where necessary;
requiring the implementation of a user-pay scheme to assist In meeting program
costs; and providing for public participation In the development and
implementation of these programs. Industrial dischargers will be required to
self-monitor their effluents.
Municipalities will be required to develop and implement a "Municipal
Enforcement Program". These programs will include: industrial waste surveys;
sampling of the discharger, in the sewer system and at the treatment works;
local limits development; a sewer use by-law; effluent discharge permits for
dischargers; sampling and inspection programs; enforcement programs; an
equitable user pay system; the opportunity to petition the courts to terminate
the rights to discharge to a sewer; and a public participation program.
All municipalities with collection systems and STPs will be included In
the proposed program. However, the implementation will be in a number of
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phases. According to the proposal all regional municipalities, district
municipalities, cities, and towns and townships with a population greater than
10,000 or with a total combined sewage flow greater than 4546 cubic metres per
day (1.2 USMGD) will be required to develop and implement a "Municipal
Enforcement Program" on regulation promulgation. All other municipalities will
be required to develop and implement a "Municipal Enforcement Program" when
specific concerns at the treatment plant or a sector industry or SIUs of the
collection system have been identified by the MOE.
Under the MISA program, Municipalities will be required to report the
results of all municipal enforcement activities on a quarterly basis including
results of municipal monitoring and the status of all abatement and
enforcement actions. The MOE audit program will include review of these
reports, one detailed compliance audit per year and a minimum of one facility
inspection per year.
Nine full time MOE staff are currently involved in the development of the
MISA sewer use control program. By the summer of 1989, another thirteen FTEs
will be added to the program.
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VI. PRETREATMENT PROGRAM ADEQUACY
Approach to Evaluating Adequacy
This section offers an evaluation of the existing programs in the Great
Lakes basin and provides comment on the Ontario program now under
development. In its evaluation, the Task Force will be guided by the
principles for pretreatment and persistent toxic substance control contained
in the 1987 Agreement with Protocol.
Article VI, Section 1 (a) of the current Great Lakes Nater Quality
Agreement describes programs to be undertaken by the Great Lakes jurisdictions
to control pollution from municipal discharges, including the "establishment
of pretreatment requirements for all industrial plants discharging waste into
POTWs where such industrial wastes are not amenable to adequate treatment or
removal using conventional municipal treatment processes". In addition, Annex
12 of the Agreement advocates the establishment of programs and strategies for
the control and,virtual elimination of discharges of persistent toxic
substances, including those listed under the specific objectives in Annex 1,
in the Great Lakes basin. For the purposes of the Agreement, "persistent
toxic substance" is defined as any toxic substance with a half life in water
in excess of eight weeks and would refer to such contaminants as mercury,
Mirex, lead, PCBs etc. From Annex 12 (2a), regulatory strategies for
controlling or preventing the input of persistent toxic substances to the
Great Lakes system are to be adopted in accordance with the following
principles:
i) The intent of programs specified in this Annex is to virtually
eliminate the Input of persistent toxic substances In order to
protect human health and to ensure the continued health and
productivity of living aquatic resources and human use thereof;
11) The philosophy adopted for control of inputs of persistent toxic
substances shall be zero discharge; and
ill) The reduction 1n the generation of contaminants, particularly
persistent toxic substances, either through the reduction of the
total volume or quantity of waste or through the reduction of the
toxiclty of waste, or both, shall, wherever possible, be encouraged.
In its assessment, the Task Force gave particular emphasis to the
compatibility of the jurisdictional pretreatment program goals with those of
the Agreement, and determined if the design and execution of the
jurisdictional program are adequate to meet both the jurisdictional and
Agreement requirements. Part of this assessment consisted of a review of
pretreatment programs at a select number of individual facilities in the
various jurisdictions of the Basin; this information is contained in Appendix
2.
U.S. Analysis
Regulatory Measures
As described earlier, the first U.S. federal pretreatment regulations were
established in 1972 under Section 307 (b) of the CWA (PL 92-500). This
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regulation set forth pretreatment standards largely for the protection of the
publicly-owned treatment facility from nondomestic sources of substances which
either interfere with the operation or performance of the treatment plant or
passthrough such plants in significant quantities. For a more thorough
description of the U.S. program, see Chap. V.
In 1978, the U.S. EPA developed the General Pretreatment Regulations,
which established mechanisms for use by state and local programs to control
largely conventional pollutants such as pH, oil and grease, BOD and suspended
solids. At approximately the same time, the EPA shifted the focus of its
pretreatment program to the control of toxic pollutants through the use of
categorical standards which, based on available technology, limit the
discharge of toxic pollutants to POTWs from particular selected industrial
sectors or categories.
To evaluate the adequacy of the U.S. jurisdictions' pretreatment efforts,
the Task Force gauged the ability of each jurisdiction to compel POTWs to
perform satisfactorily in four areas: development of local limits,
application of pretreatment standards, enforcement of pretreatment standards
and securing overall IU compliance.
The CWA states as its goal that "discharge of toxic materials in toxic
amounts" shall be forbidden. Sections 307(b) and 402<8> of that act
require the development of pretreatment standards and programs consistent with
the goal. The Task Force has concluded that, if properly designed and
applied, the U.S. program establishes a framework for the virtual elimination
of persistent toxic substances from lUs of POTWs as that target is presently
defined in practice in the basin.
Local Limits
The development of local limits for lUs by interpolation from the POTW
effluent limit necessary to meet water quality standards in the receiving
water body and sludge disposal requirements is an important element of any
pretreatment program. These limits also provide compliance or non-compliance
reference points for monitoring and enforcement. To the extent that POTW
programs include local limits which are based on a detailed evaluation of all
relevant environmental criteria (process, stream/water body water quality,
sludge use), the jurisdictional program is adequate. Conversely, where POTW
programs do not include local limits, where limits were established with
incomplete or unscientific procedures, or where environmental criteria are not
available, there is a potential for environmental degradation.
40 CFR Part 403.5(c)(l) requires all POTWs developing pretreatment
programs to adopt specific local limits to prevent the discharge of pollutants
by lUs which would passthrough the POTW causing interference with the
operation of the POTW, causing a discharge permit violation or causing the
POTW to violate sludge disposal requirements. The Task Force reviewed each
jurisdiction's process for requiring and approving these local limits. The
basis for local limits include the State's Water Quality Standards, sludge
disposal requirements, sensitivity of the POTW to process upset, and any
discharge permit limitations.
Local limits are the primary means that POTWs use to comply with
environmentally driven requirements such as Water Quality Board effluent
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limitations and sludge limits. Where local programs were approved without
adequate limits, where states fail to have up-to-date water quality standards,
or sludge disposal programs, where limits were established using incomplete or
unscientific methods, or where limits do not keep pace with changing
requirements, there is significant potential for deleterious impact on the
environment.
Application of Standards
Application of standards is determined by a demonstration of successful
calculation of IU effluent limits by the POTW. The application process
includes: properly categorizing lUs, identifying sampling locations, adjusting
categorical pretreatment standards for combined waste streams, and applying
the more restrictive categorical or local limit.
Standards must be applied so that all categorical users have equal minimum
treatment and any need to comply with more restrictive local limits is identi-
fied. Relevant factors considered in the review of standards application
include the rate of adoption of categorical pretreatment standards, the
adequacy of state and local expertise and the availability of suitable
technical support by the state or EPA. 40 CFR Part 403.8(f)(2) requires that
POTWs notify their Ills of applicable pretreatment standards.
The definition of a SIU currently varies slightly from state to state, as
noted in the state program descriptions. Although the absence of a uniform
definition is an inconvenience in assessment, of and by itself 1t does not
constitute a significant problem.
There is considerable variation, from state to state, in the number of
pretreatment programs under state control. For example, approximately one
third or 150 of the IDs in Wisconsin are directly under that state's control,
whereas in Michigan, all Ills operate under some sort of municipal framework.
Such direct ID control and supervision by states has typically resulted in
improved cooperative program developments with municipalities, as the state's
personnel are better acquainted with the practicalities and challenges faced
in directly administering a pretreatment program.
Enforcement Program Activities
Prior to any enforcement action, a definition of significant non-compliance
is required to identify major violations. At this time a specific, generic
definition of significant non-compliance is lacking. Without such a
definition, all violations, no matter how small or meaningless their impact on
the POTW Influent, must be considered for prosecution. One result Is that
insignificant violations, such as a tardy submission of a report, could
conceivably divert legal resources away from the prosecution of significant
instances of receiving water contamination. The EPA is currently coordinating
the development of a working definition of 'significant non-compliance1 among
the Great Lakes states. Such a common definition of significant non-compliance
should allow a more adequate comparison and assessment of municipal and state
programs.
Factors considered in a current assessment of compliance include the
POTWs, municipality and state interpretation of significant non-compliance
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among IDs, and the maintenance of records adequate to Indicate the state of
compliance at any given POTW.
In order to determine Industry compliance (or non-compliance), a vigorous,
high quality Inspection and monitoring program is necessary. Adequate
sampling, addressing all significant QA/QC questions, must be performed as
part of any monitoring program. States applying for pretreatment program
approval and subsequent delegation are required to demonstrate a monitoring
program, both at the state and the municipal level.
Self monitoring by the industries is a widely applied approach to reduce
municipal resource requirements. There are concerns regarding this option,
because of the possibility of abuse by industries; however, perhaps the
success of a self monitoring program is best secured by a strong, successful,
and visible municipal pretreatment program. For example, Cleveland has made
self monitoring an integral part of their pretreatment program since the
mid-seventies. This self monitoring is used as an initial indicator of
compliance or non-compliance, and is subsequently followed up by intensive
municipal monitoring as necessary.
The following are key factors which should be considered In any assessment
of a monitoring program: the visibility of the monitoring program; the
frequency of regulatory and self monitoring and the protocols governing each;
the adequate management of data; establishment of priorities for action; and
the consistency of the monitoring program with the balance of the pretreatment
program.
40 CFR Part 403.9(b)(2) requires that all POTW programs specifically state
how IU noncompliance will be addressed through local enforcement. Such
enforcement response procedures should address how IU compliance reports and
POTW sampling data will be evaluated, how noncompliance is identified,
determine instances of ID noncompliance that require formal response by the
POTW, establish an escalating set of responses for continued noncompliance,
identify typical responses to typical violations and establish time frames for
the completion of the above activities. Such procedures must be specific
processes, not a simple commitment to enforce requirements.
Where approved programs do not contain specific enforcement procedures,
POTWs are not compelled to take specific actions in response to IU
noncompliance, and inequities will arise among approved programs.
Factors to be considered include the degree to which approved programs
include appropriate, detailed enforcement procedures, the adequacy of the
jurisdictional process to establish, maintain and upgrade related Information,
the amount of formal enforcement by POTWs/municipalities in a given
jurisdiction, and remedial action taken to address and correct defective or
Inadequate programs.
At this time, as the detailed program summaries contained in Appendix 2
indicate, enough significant violations are occurring to indicate that a
greater effort at enforcement is required if pretreatment programs are to be
entirely effective in the U.S. portion of the basin.
The ability of a state to translate environmental targets and minimum
federal requirements to working pretreatment programs is tied directly to the
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resources dedicated to review, approval, and oversight of approved
pretreatment programs. Without adequate resources, state programs will find
themselves continually reacting to problem facilities rather than preventing
pollution through the operation of delegated POTW programs.
Detailed State Assessments
To facilitate review of the jurisdictions' programs, the Task Force
Identified a number of "typical" POTW programs for each jurisdiction in the
basin and reviewed the operation of their pretreatment programs. Significant
features of each POTW program are presented in Appendix 2. The Task Force
also considered available data on IU compliance as one estimate of the success
of various jurisdictions in achieving adequate control of Industrial sources.
From these data, and from other information presented to the Task Force, the
following was revealed.
New York
The State of New York uses technically based standards developed in 1985
for the formulation of its local limits; as is the practice 1n other states,
these local limits are currently being updated to reflect newer water quality
standards.
The mechanism used for application of developed standards appears to be
reasonable, although the detailed assessment database (Appendix 2) is far too
narrow to serve as any comprehensive indicator of the quality of the program.
A determination of compliance of IDs was not done due to the absence of
firm data at the state level on this issue; the four local programs noted as
involved in correcting non-compliance In the state synopsis cannot be taken as
a complete accounting of those that should be doing so. Twenty-three of the
25 pretreatment programs in the Great Lakes basin were judged satisfactory by
detailed EPA audit; however, definition and assembly of ID compliance data
will not be undertaken until further resources are dedicated to pretreatment
at the local and state level.
The quality of the Buffalo Sewer Authority program outlined in Appendix 2
indicates that the ability of the local and state personnel to develop and
implement an effective pretreatment exists.
Michigan
The State of Michigan program operates under guidelines and water quality
standards promulgated in 1982. Water quality standards were revised 1n 1986
and are currently being reviewed. The state has yet to put In place a local
limit review process incorporating these revised standards.
The Michigan program is decentralized, with nine district offices
directing its program with some central office coordination. There is concern
that a lack of resources and central direction is impeding the uniform
application and enforcement of the program.
What data are available indicate a level of noncompllance of approximately
17%, among a total population of 945 SIUs (the greatest number of SIUs in any
state in the Great Lakes portion of the basin); a majority of the noncompliant
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users discharge to the Detroit STP. As recommended in the recently released
Upper Lakes Connecting Channels Study, Detroit's pretreatment program should
be reviewed and the compliance of specific contributors of Industrial
wastewaters should be determined. In mid 1988 the Federal government Issued a
formal notice of violation to the City of Detroit for failure to Implement a
pretreatment program.
A February 1988 review of the Kalamazoo program, described 1n the detailed
audit, indicated that that program was not being implemented as approved. A
lack of developed local limits at all IDs was a major shortcoming of the
program; this was a result of the presence of conventional limits only in the
POTW's NPDES permit. The city is currently dedicating a significant amount of
resources to Implement and enforce the program as a result of the audit
findings; state and federal enforcement actions are also underway to address
this situation.
Assessment of the four other Michigan programs Indicates similar concerns
about the levels of resources dedicated to pretreatment. Pinconning has not
monitored all SIU's annually and thus the effectiveness of the program at
sources other than the major one is difficult to gauge.
In Ludington, another smaller centre ( population 9,000), the pretreatment
program appears to more adequately address the needs and requirements of the
POTW, but there was no record available of the resources actually dedicated to
the program.
The Boyne City program description is characterized as "adequate", with
two identified shortcomings being the lack of an enforcement response guide
and a number of incidents of failure to report self-monitoring results.
The Flint POTW, embracing as it does a number of major industries and a
relatively large urban population, has an approved program in place which
limits discharges of selected metals and cyanide, as well as an established
revenue collection mechanism. A recent review of PCS data indicates that all
SIUs are adequately Inspected and are in compliance with their permit
requirements. The frequency of self monitoring programs could be more
rigourous and reduce the level of municipal resources required.
A number of facilities in the audit were in a multijurisdlctlonal
situation, which had an Impact on the development of an effective enforcement
program. This factor is also apparent at a number of other Michigan POTWs.
In summary, while progress has been made through the efforts of committed
staff, further resources are required to ensure delivery of an effective,
quality assured and well documented state pretreatment program.
Ohio
The Ohio program required development of local limits under technically
based 1978 water quality standards, which also considered POTW removals and
sludge disposal requirements. These water quality standards have been updated
in 1984 and are now under review. Individual POTWs are required to update
local limits based on audit results or at the time of permit reissuance.
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The application of standards under the Ohio program is good, with adequate
staff support and significant transfer of knowledge from the state IU programs
to those state staffers overseeing municipal programs.
Compliance with programs could be characterized as average; of a total of
820 SIUs, 117 (14.2%) are not in compliance, based on various local
definitions of compliance. Ohio will adopt a definition of noncompllance
sometime during this year.
Among the programs audited in Ohio, the Bryan program has established
appropriate limits for the discharge of metals and cyanide, and has adequate
legal authority for implementation and enforcement. However, the determination
and application of appropriate standards has proved difficult on occasion;
sampling locations have not been clearly delineated in the permits and some
lUs have not been advised of RCRA requirements.
Compliance at the Bryan facility could not be accurately determined as the
City did not routinely sample for all the parameters in the user's permit and
ID inspection records were incomplete. Enforcement efforts are not adequately
documented and the state of the records is such that effective enforcement may
be precluded. In summary, the Bryan program does not appear to be deploying
adequate resources to be effective.
A review of the Northeast Ohio Regional Sewer District, which Includes
five facilities in the Cleveland area, also raises similar issues. The
District was very active in the development of pretreatment programs prior to
federal delegation to the state of Ohio; however, it is the state's
observation that legal authority In addition to the sewer use code Is
necessary, particularly a requirement for the Issuance of permits to all SIUs.
Concerns were raised as well regarding the sampling programs associated with
the application of standards.
Notwithstanding these concerns, the District compliance monitoring program
appears thorough, and ten percent of the IU population has been subjected to
some form of enforcement action over a twelve month period. Data management is
adequate and is being enhanced as part of office real location; the program
resource level also appears adequate.
The third Ohio program reviewed in the detailed assessment, Willoughby
Eastlake, appears to respond well to all the principal requirements of the
pretreatment program with the exception of the lack of vlgourous enforcement
by the municipality to established noncompHance among some of the SIUs.
Elyria was the remaining Ohio facility assessed by the Task Force. The
need for updating of the local ordinance to embrace categorical standards was
identified. Notwithstanding this need, the application of standards at this
facility was judged to be fair; both categorical and local standards are used
in assessment. However, some revision to sampling programs is recommended to
allow the city to make an independent assessment of compliance.
Compliance determinations have been focused on a few of the lUs; however,
the overall compliance determination effort does not meet program commitments.
Enforcement efforts are lacking, due to the absence of a strategy; five
industries have been out of compliance for over two years. Record keeping is
not adequate to determine continued compliance in some cases. The assessment
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determined that resources appeared adequate, but more efficient deployment of
same was required, and noted that the city was moving to meet this
requirement.
Notwithstanding some of the deficiencies noted in the detailed assessment
of individual programs, the state enforcement program is considered good and
the state is making a concerted effort to improve enforcement at appropriate
individual facilities.
Indiana
In developing and reviewing its pretreatment program, Indiana uses a
combination of older water quality standards and literature values. While
discussing program delegation with the EPA, the state is currently 1n the
process of developing additional numerical standards.
The application of available standards was judged to be fair to good, with
good staff support by the state.
Compliance determinations are hampered by the lack of a uniform state
level definition of significant noncompllance. Notwithstanding this factor,
recent estimates indicate that 11% of the 293 lUs were out of compliance with
their requirements.
The detailed assessment of the Fort Wayne, Indiana facility indicated a
fundamentally sound program was In place, with improvements suggested in the
extension of TTO requirements, consideration of the need to Increase
monitoring at sources demonstrated to be out of compliance and the development
of an enforcement response procedure.
Review of the pretreatment program at Elkhart again revealed a sound
program, with one similar concern - the need to extend TTO requirements among
the IU community. Legal authority, record-keeping and enforcement were judged
to be adequate.
In considering the statewide enforcement program, It was judged to be
fair, but a need for significant revision to the program was identified citing
lack of enforcement procedures and concerns regarding adequacy of resources.
These were identified in Indiana's most recent application (1988) for
delegation of programs from EPA. A need for additional state resources to
administer the program was also apparent. The state efforts to offer some
technical assistance to the POTW community were noted, but further effort in
this area would enhance the program.
Minnesota
Minnesota used guidelines and water quality standards largely developed
circa 1980 to establish pretreatment local limits. The standards were revised
in mid 80's and are to be reviewed in 1990. Where appropriate, such as at
facilities which incinerate sewage sludge, air quality standards are also
applied. Re-evaluation of local limits is required in audit findings and
permit re-issuance, where needed.
Application of standards through the state program was judged to be good;
at the one principal plant with a pretreatment program discharging to the
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Great Lakes (Western Lake Superior Sanitary District), one of the thirteen
SIUs was out of compliance (7.7%), a relatively good performance. However, the
state has advised the District to Improve inspection and monitoring of Ills and
to resolve the noncompliant situation. Data management by the District could
also be improved.
The state's efforts to enforce the program were considered good; a
revision to the water quality standards and associated re-evaluation of local
limits would fulfill all program structural requirements.
Wisconsin
As of 1989, Wisconsin uses comprehensive procedures to establish water
quality and local limits. These procedures are not driven by numerical values
for water quality per se, but are based on the protection of the aquatic
environment, wildlife and human health. Wisconsin defines consistent
compliance based on U.S. EPA's PCME Guidance Manual (Sept. '86). Failure to
achieve consistent compliance can include minor to significant exceedences of
categorical standards, local limits, or failure to report according to an
established schedule.
Most Ills have installed and are operating pretreatment systems and have
made process changes to reduce the discharge of regulated pollutants.
Compliance rates should improve as Ills enhance the consistency of their
operation of their pretreatment systems and make additional process changes.
Municipalities also revise local limits, which can be more restrictive than
necessary to protect POTW operations and receiving waters. A review of the
state application of standards indicates that, as a result of excellent state
agency support, this is carried out in a good to excellent manner.
Under the state's rigorously applied criteria, 24% of the 494 SIUs
tributary to POTWs with pretreatment programs are not in consistent
compliance, considering both failure to report to an established schedule and
major and minor exceedences of categorical standards or local limits. Levels
of noncompliance are very comparable between the local administered programs
and those administered by the state.
A review of the detailed audit of the pretreatment program operated by the
City of Manitowoc noted that the City should update its local ordinance to
reflect changes in the federal requirements. Revisions to the local limits
may also be necessary to prevent violations of water quality based standards.
Compliance monitoring was determined to be adequate, but the City appeared
hesitant to take formal enforcement action against violators. The level of
resources applied to the program appear to be appropriate for quality
delivery; no comment was made on the conditions and procedures under which
records are maintained.
The program at Green Bay was also reviewed and it was noted that the City
ordinance also requires upgrading. Application of standards was also judged
adequate, reinforced by a a good compliance monitoring and inspection program.
Data management was considered good and enforcement adequate. Resources levels
were also judged adequate, with a total of 2 FTEs dedicated to the program.
The program at Fond Du Lac, one of the smaller capacity facilities which
operates a pretreatment program in the state, was also reviewed. The current
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program addresses conventional pollutants and metals, and will be Devaluating
Its local limits during 1989. Its local ordinance must also be upgraded to be
consistent with the federal requirements. The need for a more detailed
enforcement management system was noted and data management and application of
standards were considered adequate. Resources levels, at 1 FTE, were also
considered adequate.
The Task Force review of the state program indicated that the state level
of effort in enforcement was good, but there was some reluctance In the POTW
community to vigorously pursue violations. The state is aware of this and is
working to improve the approach at the local level. In summary, a program
which meets federal requirements is in place, but further effort on
enforcement at the local level is required. The upgrade of ordinances and
local limits is also necessary; this latter task is being pursued by the state
and the POTWs.
Summary of Findings
In summary, although the framework for an adequate pretreatment program is
in place in the Great Lakes states, the states and the U.S. EPA should move to
address deficiencies in the implementation and enforcement of that program.
The extension of the categorical Industry requirements to embrace other
significant industrial sectors, an initiative currently underway withirr the
EPA, should be encouraged. The consequence of the differences among state
criteria used to establish municipal requirements in the various jurisdictions
must be further considered.
The agency is encouraged to continue its review of the Impact of the
domestic exclusion clause in RCRA (see pages 37-38); as loadings from other
source sectors are reduced, further more accurate determinations of the toxic
content of domestic wastewater should be made to allow for a consideration of
the significance of contributions from this source.
The selective deployment of further resources at the municipal and state
level is necessary to affect adequate tracking and enforcement of pretreatment
programs. Development of common definitions of "significant noncompllance" and
"significant Industrial user" should be brought to fruition, and the
implementation of computer based tracking systems at the local level should be
encouraged.
Also, the inability or unwillingness of some municipal governments to
prosecute pretreatment program violators should be rectified and
multijurisdictional variances 1n requirements and enforcement among
municipalities should be resolved. Further opportunities for training at the
municipal and industrial treatment sites should be provided to ensure that the
capabilities of these systems are fully realized.
Canadian Analysis
Recent reviews done in preparation of the MISA pretreatment strategy
indicated that by-law enforcement varied markedly across the province. Most
enforcement actions were informal and municipalities were generally slow at
initiating them. Seven hundred enforcement actions were carried out against
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246 industries. Verbal warnings accounted for 38%, written warnings accounted
for 52% and prosecutions accounted for 9% of these actions. Forty-three
compliance programs were also issued. There is a reluctance in many
municipalities to initiate legal actions against industrial sources violating
by-law requirements. Most municipalities do not include compliance program
procedures in their by-laws.
Eight municipalities accepted sewage from one or more adjacent
municipalities. In most cases, the agreements between these municipalities,
did not contain clauses identifying responsibility for sampling and enforcing
a sewer use by-law in the adjacent municipality or mechanisms whereby a
municipality accepting the sewage could ensure itself that such by-laws were
enforced. In many multi-tiered municipalities, difficulties with
jurisdictional responsibilities were also identified, even though most of the
Regional Municipality Acts specified that the upper tier municipality was
responsible for sewage treatment and collection.
Survey reports and data from the waste treatment systems of Ontario
municipalities with flow less than 4500 m3/d (1.2 USMGD) indicated
concerns regarding Industrial discharges at 60 of the 200 municipalities 1n
this group. Site visits to these respondents indicated that industrial
discharges to the sewer systems were having a major impact at 17
municipalities and creating minor difficulties at 22. Although many of the
municipalities in this group have a sewer use by-law, none of them routinely
sampled industrial dischargers.
The results of the survey are significantly better in municipalities with
total combined sewage flows greater than 4500 m3/d (1.2 USMGD). In this
group, 35 municipalities monitored industrial discharges from 1,200
industries, including surcharged industries, using 120 municipal staff. In
1986, they carried out 916 enforcement actions against 246 Industries
including 376 verbal and 417 written requests for correction. Civil action
was initiated in 71 of these incidents and 63 programs were approved. However,
by-law Implementation and enforcement activities also vary markedly among this
population.
The functional responsibilities of the municipal staff employed 1n these
programs were distributed as follows: management 9%; program development 6%;
industrial waste surveys 8%; sampling 19%; Inspection 14%; enforcement 3%; lab
analysis 27%; legal 2%; and clerical 9%. Municipal staff collected and
analyzed 15,500 samples of which 4,400 samplings were of surcharged industries.
Generally, samples were analyzed for conventional parameters including BOD,
suspended solids, oil and grease (animal and vegetable), oil and grease
(mineral and synthetic), phosphorus, and metals. The metal group generally
included chromium, lead, copper, nickel, and zinc. No ID'S effluent samples
were analyzed for specific toxic organics. The sampling programs in many
municipalities must be improved by increasing both the sampling frequency and
the list of parameters of interest. Most municipalities did not include a
requirement for an industrial waste survey in their by-laws.
The province has initiated development of a training program for municipal
staff employed in sewer use by-law enforcement. Six courses (environmental
law enforcement; sampling, monitoring and inspection of industrial
dischargers; control of spills; local limits development; unit processes
(industrial and waste treatment); and control instruments) are in various
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stages of development. The environmental law and sampling courses should be
offered In the falT of 1989. Two data management packages will soon be
available also.
Detailed audits were conducted on 6 facilities In the Ontario segment of
the Great Lakes basin. The largest of these, the municipality of Metropolitan
Toronto, operates four wastewater treatment facilities. The local by-law
controls, revised in 1982, limit concentrations of conventional pollutants,
metals and cyanide to the four plants; 1n 1986 the municipality collected
2,759 samples from 306 IDs and initiated 82 enforcement actions, the majority
being prosecutions. Eighteen compliance programs were also implemented. Total
resources dedicated to the local program in 1986 was $732,000 CAN and 29.5
FTEs, including personnel required to administer surcharge agreements.
Within the current structure, Metropolitan Toronto has adequate authority
under the Municipal Act to Implement and enforce Its by-law within its
boundaries. However, it should alter its current agreement with the adjacent
'municipality to extend provisions for controlling industrial dischargers to
the Metro sewer system.
Application of available standards was judged to be good. The
Municipality should upgrade its by-law to provide for an industrial waste
survey and consider a local limits development program.
Compliance monitoring was judged adequate, but requiring further
documentation of procedures. Enforcement was also considered adequate;
however, data management could be improved by the development of a computer
based system to maintain data on sampling, inspection and enforcement programs
The Regional Municipality of Waterloo passed Its current by-law in 1987,
which addresses influent to 11 waste treatment facilities with a combined
capacity of 163,000 m3/d (43 USMGD). Local limits have been developed for
conventional pollutants, metals, phenols and cyanide.
In 1986, the regional municipal collected 2,768 samples (some far
surcharge agreement purposes) from 203 lUs. Sixty lUs were inspected and 131
enforcement actions were initiated against lUs, the majority being written
warnings. There were two prosecutions and 13 compliance programs were
established. Resource levels 1n 1986, including those required to oversee
surcharge agreements, were $412,000 CAN and 11.1 FTEs.
The municipality has adequate legal authority to implement and enforce a
sewer use by-law. The current by-law should be revised to include provisions
for Industrial waste surveys and spills control. The program could also be
improved through a local limits development program. The compliance and
enforcement programs were judged to be adequate; the need for a computer based
data management system was apparent.
The City of Windsor operates two treatment plants with a total combined
flow of 156,000 m3/d (41 USMGD), under a sewer use by-law passed In 1985.
Wastes are received from a number of adjacent towns and townships without the
benefit of an operating agreement. Local limits based on the model by-law
requirements and sludge disposal requirements were established for
conventional pollutants, metals, phenols and cyanide.
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In 1986, 242 samples were collected from 95 lUs. The City Initiated 55
enforcement actions against IDs, the majority being verbal or written
warnings. One compliance program was developed and one prosecution initiated.
In 1986, the program consumed $233,000 CAN and utilized 3.5 FTE's.
The municipality does not currently have adequate agreements with the
adjacent municipalities discharging sewage to its facilities, including
provisions for the control of industrial discharges in the adjacent
municipalities. The by-law should also be upgraded to include Industrial waste
surveys, spills control and compliance programs.
Application of standards was judged to be adequate. A review of local
limits is recommended. Compliance monitoring and enforcement were judged to be
adequate and data management and resource levels were judged to be good.
The pretreatment program in the City of Barrie was established under a
by-law passed in 1970 and is part of the operation of a 28,600 m3/d (7.6 USMGD)
treatment plant operation. Local limits have been developed for conventional
pollutants, metals, phenols and cyanide. In 1986, 239 samples were collected
from 21 IDs and 35 users were inspected. One enforcement action was taken. In
1986 the City spent $105,000 CAN and utilized 2.8 FTE's.
The current by-law should be upgraded to include industrial waste surveys,
spills control and compliance programs. Application of standards and
compliance monitoring were judged adequate. Enforcement and data management
were considered adequate, while the resource level was judged appropriate.
The City of Brantford sewer use by-law dates from 1982; the two treatment
facilities in the community have a combined flow of 52,000 m3/d (13.7 USMGD).
Local limits have been established for conventional pollutants, metals,
phenols and cyanide. In 1986, 250 samples were collected from 30 IDs with
surcharge agreements with the City, and 50 Industrial Inspections were carried
out. Eighteen enforcement actions were initiated, the majority being verbal or
written warnings. Six compliance programs were also Issued. Resource levels
for 1986 were $136,000 CAN and 2.4 FTEs.
A need to update the by-law to Include Industrial waste surveys and spills
control was identified. Application of standards was judged to be inadequate,
with too many uncatalogued industries; an industrial survey and local limits
review would be appropriate. Compliance sampling was also inadequate, as only
the surcharged population was sampled. There is an apparent reluctance to
sample under and enforce the by-law requirements. Both data management and
resources were judged adequate.
Brockville operates a treatment facility with a total flow of 17,000 m3/d
(4.5 USMGD), with a pretreatment program organized under a 1983 by-law.
Conventional pollutants, metals, phenols and cyanide are subject to local
limits. In 1986, 52 samples were collected from five lUs and two users were
inspected. $17,000 CAN and 0.4 FTEs were dedicated to the program in 1986.
The city should reach agreement with the outlying township and upgrade its
current law to include provisions for industrial waste surveys, spills control
and compliance programs. Standards have been properly applied; however,
compliance monitoring and enforcement were judged to be inadequate; an
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enforcement strategy should be developed to commit the municipality to an
established course of action.
Management of the data currently available was judged adequate but
resource levels were not; further staff appear to be required to make the
program fully functional.
Two waste treatment facilities with a combined total of 13,000 m3/d
13.43 USMGD) are operated In Cobourg. The sewer use by-law was passed In 1969,
containing local limits for conventional pollutants, metals, phenols and
cyanide. In 1986, 1,360 samples were collected from 10 lUs. Twenty industries
were inspected, including execution of an Industrial waste survey. Twenty nine
enforcement actions ( a majority being verbal warnings ) were taken and three
program approvals were issued. The city spent $32,000 CAN and 0.85 FTEs on
their sewer use program.
The municipality should upgrade its by-law to Include provisions for
'industrial waste surveys, spills control and compliance programs. Application
of standards was judged to be adequate, but the limits in the by-law should be
reviewed to determine if they remain adequate. Compliance monitoring was
judged to be good, with enforcement and data management considered adequate.
It was determined that further resources must be made available if the program
is to continue to be of acceptable quality.
Summary of Findings - Canada/Ontario
Although there are a number of well administered independent sewer use
programs at the municipal level in the Canadian segment of the Great Lakes
basin, the Province of Ontario has recognized, under MISA, the need for a
comprehensive and centrally administered pretreatment program for that
province. Such a program should Introduce formal monitoring and data
collection requirements which will allow a comprehensive overview of
compliance data for lUs of sewage treatment systems. Further it should
eliminate, or reduce to insignificance, the variances among the current
municipal pretreatment programs.
Some municipalities should also be encouraged to take a more aggressive
approach to the prosecution of violators of their current sewer use by-laws
and to undertake adequate industrial surveys and address deficiencies with
respect to spills control. Resources necessary to operate an effective program
at both the municipal and provincial level should be further enhanced from
current levels.
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APPENDIX I
PPETS DATA ELEMENTS (REVISED 2/10/87)
Pretreatment Permits Enforcement Tracking System
Water Enforcement National Data Base
WENDB
DATA
ELEMENT
Universe
1. Number of Significant Industrial Users (SIUs)
2. Number of Categorical Industrial users
Control Mechanism
3. Number of SIUs where the required control mechanism has not been
Issued
4a. Did the Control Authority technically evaluate the need for local
limits for all of the following pollutants:
cadmium, chromium, copper, lead, nickel, zinc, and any others
required by the Approval Authority?
4b. If the technical evaluation Indicated that local limits for these
pollutants were needed, did the Control Authority adopt such local
limits?
Compliance Information
5. Number of SIUs In significant noncompllance with applicable
pretreatment standards, or reporting requirements
6. Number of SIUs in significant noncompliance with compliance schedules
to meet pretreatment standards
7. Number of SIUs not inspected and/or sampled by the Control Authority
in the past year
8. Number of SIUs in significant noncompliance with self-monitoring
requirements
9. Number of SIUs which are in significant non-compliance with
self-monitoring requirements and have not been inspected or sampled
by the Control Authority In the past year
Enforcement Actions
10. Number of civil or criminal judicial actions filed against SIUs
11. Number of formal enforcement actions (other than judicial actions)
initiated against SIUs
12. Number of lUs assessed penalties
13. Number of SIUs with significant violations listed in the local
newspaper.
Other
14. Has the Control Authority's permit been modified to include language
requiring implementation of an approved pretreatment program?
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LIST OF OPTIONAL PPETS DATA ELEMENTS
CONTROL MECHANISM AND LEGAL AUTHORITY
1 Which of the following components are not sufficient or are not contained
in the POTW's control mechanisms:
effective dates and expiration dates
reference to local ordinance or other legal authorities
applicable discharge limits
sampling location
sample type
IU self-monitoring requirements
IU reporting requirements
standard conditions?
2 Number of jurisdictions covered by the Control Authority's pretreatment
program
3 Which of the following deficiencies exist In the multijurisdictional
agreements:
lack of oversight authority
lack of inspection authority
lack of remedies for noncompllance
lack of clean delineation of responsibilities for program
Implementation?
4 In which of the following areas do problems/deficiencies exist in the
POTW's legal authority:
denying or conditioning new or Increased contributions
applying and enforcing pretreatment standards
controlling each IU through permit, contract, etc.
requiring development of IU compliance schedules
requiring submission of IU reports
allowing IU inspections and sampling
obtaining remedies for noncompllance
halting or preventing discharges
complying with confidentiality requirements?
5 Has the Control Authority technically evaluated the need for, and adopted
as necessary, local limits to address toxicity concerns, sludge criteria,
and pollutants specifically designated by the Approval Authority?
COMPLIANCE INFORMATION
6 Number of SIUs not sampled or Inspected by the Control Authority at a
frequency in accordance with the approved pretreatment program or permit.
7 Percent of all SIUs which have not installed treatment although required
to do so.
8 Number of SIUs in significant noncompliance with pretreatment standards.
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LIST OF OPTIONAL PPETS DATA ELEMENTS (continued)
CONTROL MECHANISM AND LEGAL AUTHORITY (continued)
9 Number of SIUs in significant noncompliance with reporting requirements
10 Are there any indications of passthrough or interference incidents in the
past year?
11 Which of the following deficiencies exist in the POTW's sampling of lUs:
improper sample types
inadequate sampling frequency
improper sampling protocols
improper or inadequate parameters sampled
inadequate chain of custody procedures?
12 Number of SIUs currently on compliance schedules
13 Number of categorical lUs in significant noncompliance in the past year
14 In the audit report, which of the following deficiencies were noted by the
inspector in the Control Authority's interpretation and application of
pretreatment standards to lUs:
failure to identify all categorical industrial users
incorrect categorization of industrial users
failure to apply more stringent standard (local vs. categorical)
improper application of production-based standards
application of inappropriate long-term average
failure to apply appropriate TTO limitations
improper use of the combined wastestream formula
inadequate sample type and/or sample frequency
improper designation of sampling location
failure to use effective control mechanism?
15 In the PCI/audit report, did the inspector report that the POTW performs
(in combination with IU self-monitoring) adequate inspections and sampling
of its lUs to:
identify the character and volume of pollutants from all lUs
receive and review industrial user reports
assess industrial user compliance
investigate instances of noncompliance
produce admissible evidence in an enforcement action?
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LIST OF OPTIONAL PPETS DATA ELEMENTS (continued)
ENFORCEMENT ACTIONS
16 Number of SIUs subject to any kind of enforcement action.
17 Does the Control Authority have an enforcement response guide?
18 What is the maximum dvll penalty provided by law?
19 Number of violation notices Issued to SIUs.
20 Number of administrative orders Issued to SIUs.
21 Number of civil suits filed against SIUs.
22 Number of criminal suits filed against SIUs.
23 Amount of penalties collected.
OTHER
24 Which of the following program elements have been changed since the last
PCI/audit without approval:
legal authority
control mechanism implementation
local limits
inspection and monitoring program
enforcement program
resources?
25 In the PCI/audit report, in which of the following broad areas were
deficiencies noted during the Inspector's review of IU files:
file contents
control mechanisms
POTW compliance monitoring
IU self-monitoring
POTW enforcement initiative
spills / slug loading?
26 If applicable, has the Control Authority violated any schedule for
implementation of needed remedial measures identified as a result of
audits or inspections? If so, has the Approval Authority responded by
Initiating judicial enforcement action?
27 Did the PCI generally support statements made by the Control Authority in
the most recent pretreatment report?
28 Does the POTW have removal credits?
29 Date of removal credits approval.
30 Has the Control Authority's original pretreatment program been modified,
with accompanying permit modifications, to address the domestic sewage
study follow-up requirements: Has the Control Authority's original
pretreatment program been modified, with accompanying permit
modifications, to address the recent "PIRT amendments" to the General
Pretreatment Regulations*?
31 Does the POTW accept hazardous waste (as defined by 40 CFR 261) by truck,
rail, or dedicated pipe?
*After these amendments are Issued In final form and associated guidance is
prepared, this question may be modified to include specific modifications that
should be made to the program and to the permit.
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LIST OF OPTIONAL PPETS DATA ELEMENTS (continued)
32 Which of the following types of wastes other than domestic sewage and
Industrial wastes does the POTW receive by any means:
none
hauled septage
landfill leachate
RCRA/CERCLA site wastes or leachate
other?
33 Which of the following methods of sludge disposal are utilized by the
Control Authority:
land application
landfill
Incineration
public distribution
ocean disposal
other?
34 What is the frequency of the POTW's toxicant sampling of Its influent
(times/year)?
35 What Is the frequency of the POTW's toxicant sampling of Its effluent
(times/year)?
36 What is the frequency of the POTW's toxicant sampling of Its sludge
(times/year)?
37 Which of the following deficiencies exist in the POTW's data management
and public participation efforts:
failure to annually publish a list of significant violators
failure to provide notice to interested parties when local limits are
developed
failure to provide adequate procedures for handling confidential
information
failure to provide to the public, upon request, unrestricted access
to effluent data
failure to maintain records for at least three years
poor documentation of activities In IU files?
38 Which of the following inadequacies are there in the POTW's pretreatment
resources:
inadequate numbers of personnel
insufficient training of personnel
inadequate sampling equipment
inadequate safety equipment
inadequate numbers of vehicles
inadequate access to analytical equipment
inadequate funding?
39 Approximate annual pretreatment budget
40 Name of the pretreatment coordinator
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APPENDIX II
NEH YORK
WASTEWATER TREATMENT PLANTS IN THE GREAT LAKES BASIN
BUFFALO SENER AUTHORITY
PROGRAM DESCRIPTION AND IMPLEMENTATION
The Industrial Pretreatment Program (IPP) for the Buffalo Sewer Authority
(BSA) was approved In September of 1984. The State point source discharge
permit has been modified to require Implementation of the approved.
pretreatment program. For all 56 programs In New York State such a permit
modification typically requires the approved pretreatment program Control
Authority (now BSA) to 1) Issue Industrial user discharge permits; 2) define
local limits with details such as sampling, reporting, and special conditions;
3) develop compliance schedules as needed; 4) enforce local limits and
categorical pretreatment standards; 5) maintain program records; 6) carry out
sampling, Inspections and monitoring activities on Industrial users; 7) report
on Implementation and non-compliance activities; 8) obtain/enforce remedies
for non-compliance; 9) conduct other special conditions.
BFA submits a quarterly report to the State describing Its pretreatment
program Implementation. This report contains an updated SIU survey listing
with local permit status, a current listing of SIU Inspections, noting
deficiencies, a listing of SIU violations with causes and corrective actions,
relevant plant operating and sampling data, and related follow-up
correspondence.
The BFA has developed a computer tracking system to manage its
pretreatment program data. They also have developed various reporting,
guideline, and inspection forms to facilitate program administration. These
forms include an SIU inspection form, a trucker's discharge permit, a spill
control (solvent management) guideline, a spill control permit, and an SIU
permit.
The most recent quarterly report showed all SIUs Inspected (36 out of 164
total) as in compliance. These SIUs are identified as to whether they are
categorical, non-categorical, surchargeable, trucker permit, or spill control
permitted. BSA's pretreatment program is fully implemented.
Trend data documented by BSA between 1983 and 1986 demonstrate the
effectiveness of its pretreatment program. Mass loading data were collected
to insure that no metal was exceeding the treatment plant's daily critical
influent mass loading. Levels are not only below the required pretreatment
program's influent limits but show a dramatic reduction over the years. Some
correlation In this reduction of metals loadings can be made with the
implementation of the National Categorical Pretreatment Standard for
electroplaters and metal finishers in June of 1984.
In another study conducted by DEC, a comprehensive sampling and analysis
was performed on municipal and industrial wastewaters discharging to the
Niagara River during 1981-1982 and again In 1985-1986. The results showed a
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dramatic (typically over 50%) reduction In total priority pollutant loadings,
both metallic and organic, to the river contributed by both industrial and
municipal users. These reductions can be attributed to several factors: 1)
completion and operation of some large wastewater treatment plants, BSA
included, 2) stabilization of operations of some other newer wastewater
treatment plants, 3) chemical corporation plant closings (estimated to account
for 20%), 4) operational changes required by renewed (more strict) point
source discharge permit limits that now include toxic parameters, and 5)
implementation of pretreatment programs and associated best management
practice programs.
PROGRAM EFFECTIVENESS
Legal Authority: Adequate local legal authority exists for the enforcement of
approved pretreatment program. Much as the State would enter into an Order of
Consent with a point source discharger, the municipality (BSA) can pursue a
similar course of action to achieve compliance with an industrial user.
Application of Standards: Pretreatment standards are adequately applied to
both categorical and non-categorical industries. The state's requirement for
industrial user permits insures the development and enforcement of local
discharge limits.
CojnaLijLncje_iiQnltgjn_ng: BSA has an excellent compliance inspection and
sampling program. The status 1s updated quarterly in their report to the
Approval Authority.
Enforcement: BSA has an excellent enforcement program with responses that
range from verbal non-formal requirements to consent decrees with penalties.
The National Enforcement Response Guide provided by EPA has been embraced as a
management tool.
Data_Mana_gement: Excellent: BSA has taken a lead in utilizing databases to
maintain records and report on the Implementation of its approved pretreatment
program.
fies_o_urce_s: BSA has adequate resources to deliver an effective pretreatment
program. An expertise has been developed over the years that provides
efficient use of resources.
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MICHIGAN
CITY OF KALAMAZOO
PROGRAM DESCRIPTION AND IMPLEMENTATION
The IPP for the City of Kalamazoo (City) was approved on October 1, 1985.
The IPP requirements were included in the NPDES permit on July 18, 1988 by
permit modification. The City is not operating under any consent decree,
administrative order or other document containing pretreatment program
requirements. However, on February 17-18, 1988 the U.S. EPA conducted an IPP
audit at the City. The audit exit interview indicated that the IPP was not
being implemented as approved. Based on that information, the Michigan
Department of Natural Resources prepared a Final Order of Abatement (FOA) to
correct the indicated shortcomings in the IPP as well as to address
operational problems at the POTW. This FOA was signed by the City and
approved for public notice by the Michigan Water Resources Commission during
its September 1988 meeting.
The FOA specifically demands that the City:
1. Establish local limits.
2. Develop and implement an enforcement program.
3. Verify that sufficient resources are designated to
implement the IPP.
4. Implement procedures to enforce industrial self-monitoring
and reporting.
5. Submit data to verify removal rates and provide calculated
allowable influent loading for each parameter of concern.
6. Issue individual control documents to all significant
nondomestic users.
7. Verify that all nondomestic users are in compliance with
the IPP requirements.
Items 2, 3, and 5 were submitted to the Michigan DNR by September 30,
1988, the date designated in the FOA.
The collection system to the Kalamazoo POTW reaches out to sixteen (16)
surrounding communities. The IPP is enforced by the sewer use ordinance of
the City and by contracts with the surrounding communities. In addition the
City has direct contracts with three (3) major industries in the area. The
contracts enable the City to establish limits and to administer and implement
the IPP. Administrative orders (AO's), including discharge limits for each
industry, are issued to individual industries. Enforcement of the IPP is by
the local units of government as advised by the City.
The City has identified nearly two-hundred and fifty (250) non-domestic
users. Of these, twenty-two (22) are categorical Industrial Users (lUs), 38
are significant noncategorical lUs, and nineteen (19) are other regulated
noncategorical lUs. The rest are not specifically regulated. Significant
noncategorical lUs have been defined as those lUs that discharge more than
25,000 U.S. gallons of wastewater per day or discharge toxics or have a
significant Impact on the POTW. Other regulated noncategorical lUs are the
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ones that are determined to possibly have a significant impact on the
collection system.
The City continually updates the industrial waste survey as inspections of
IDs are completed.
The City based its IPP on the availability of removal credits and as yet
has not developed local limits that apply to all IDs. The FOA includes a
requirement to develop local limits by December 31, 1988. The original IPP
submittals listed only 1,2-Dichloroethane as passing through the POTW. The
new Powder Activated Carbon Treatment (PACT) system removes this chemical.
For that reason no local limit was established for 1,2-Dichloroethane. At the
time of IPP approval the NPDES permit set numeric limits only for conventional
parameters. Categorical standards have been used as local limits.
The NPDES permit for the City will contain a biomonitoring requirement as
well as limits or monitoring for cadmium, lead, mercury, silver, cyanide,
1.2-dichloroethane and polychlorinated biphenyls. Limits for these parameters
will be Included in AO's, issued by the City, as warranted.
The City has issued AO's that include limits to specific industries.
Three (3) Industries are subject to production-based categorical limits. Two
(2) industries have limits for TTOs. Seventy-nine (79) industries have
solvent management plans. The combined wastestream formula is applied to
sixty (60) industries. Spill Prevention Plans to address toxic discharges are
in place. The City does not accept hazardous waste by truck, rail, or
dedicated pipeline. The City's IPP is deficient in that it does not include
procedures for notifying Ills of RCRA requirements.
The City regularly inspects and monitors the IDs. Enforcement options
include Notice of Violation, Establishment of IU Compliance Schedule,
Revocation of Permit, Injunctive Relief, Fines, and Termination of Service.
The City has dedicated the equivalent of ten (10) FTEs to the
implementation of its IPP and has budgeted $600,000 per year to fund the
implementation of the IPP.
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CITY OF PINCONNING
INDUSTRIAL PRETREATMENT PROGRAM IMPLEMENTATION EFFORT
PROGRAM DESCRIPTION AND IMPLEMENTATION
The City of Pinconning is a small community of approximately 1,000
citizens located near the west shore of Saginaw Bay, 20 miles north of Bay
City. A cheese production facility is located in town. This facility
generates high strength wastewaters that historically biologically overloaded
the City's wastewater treatment plant (WWTP) resulting in the City's failure
to comply with effluent limitations contained in the NPDES permit, MI0020711.
Because of this situation, the DNR required the City to develop and implement
an IPP. The IPP was approved for implementation August 23, 1985.
Requirements for Implementing the IPP are contained in Part I.B.I, of the
permit. No other judicial or administrative document presently exists
containing IPP requirements.
All lUs regulated by the City are located within the City limits. The
City has identified four (4) "Significant" users to the system. No
categorical industries are located in the City.
The City has no formal definition for a "Significant" ID. This judgment
is left to the WWTP superintendent based on the actual or potential
operational interference presented by the IU. The control mechanism used to
regulate significant IDs is the permit. All significant IDs have been issued
a permit. In addition, one non-significant IU has been issued a permit. Only
a cheese producer has been given discharge limits different from the general
discharge limitations specified in the City's sewer use ordinance. No
toxic/priority pollutant monitoring requirements are contained in the City's
NPDES permit. Likewise, no specific discharge limits for these compounds have
been issued to lUs by the City other than the general discharge prohibitions
contained in the ordinance. Also no lUs are presently subject to the combined
wastestreams formula, production based standards, TTO limits or solvent
management plans.
The City inspects all significant users yearly. The cheese production
facility is monitored daily. The City attempts to monitor all other
significant lUs annually. No self-monitoring or reporting is required of any
significant IU. Should noncompliance with discharge limitations occur, the
City has all enforcement options available from verbal warning to termination
of service.
No special resources have been allocated by the City to implement the
IPP. The duties are being handled by existing WWTP staff with existing
resources. It is estimated by the superintendent that approximately one hour
per day is devoted to IPP (less than one-half FTE). Financial resources
devoted annually to the program have been approximated to be in the vicinity
of $8,000.
Program Effectiveness:
Le^aLAuthority: Pinconning's ordinance is unchanged from the date the IPP
was approved by the Department. The City has issued all necessary discharge
permits as stipulated in the ordinance.
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Application of Standards: Plnconnlng 1s properly applying IPP discharge
standards. Wastes generated by the cheese factory In excess of discharge
limitations have been pumped and hauled to another nearby treatment facility
(also with an approved and satisfactorily implemented IPP). A land
application program to assist in properly disposing of wastes beyond the
treatment capabilities of the Pinconning WWTP has also been undertaken.
Pinconning has properly categorized users and uses dty generated data to
evaluate compliance with local limits.
Comp.lJ.ance_.jMQnlt.Qring: The City has invested the majority of its monitoring
efforts towards wastewater discharge from the cheese factory. The City is
working to expand its monitoring efforts to the rest of the significant ILJs.
The City has not always monitored all other significant ILJs annually as
identified in the approved programs.
Enforcement: The City's enforcement efforts have been sufficient to ensure
that discharges from the principal source comply with local limits. All other
significant lUs have complied with local limits and have not required
enforcement efforts by the City.
Data Management: The City's files are adequate to meet the needs of the
program.
Resources: Sufficient at the present time.
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PERMIT NO. MI0020711
PART I
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
1. Final Effluent Limitations
a. During the period beginning on the date of issuance and lasting until the
expiration date, the permittee is authorized to discharge treated municipal
wastewaters from the Pinconning wastewater treatment plant through outfalls
001 and 002 to Pinconning River, in Section 23, T17, R4E. Such discharges
shall be limited and monitored by the permittee as follows:
Effluent
Characteristic
Flow (in MGD)
Carbonaceous
Biochemical
Oxygen Demand
(CBOD5)
_Discharge Limitations
Total Suspended
Solids
Ammon i a
Nitrogen (as N)
Total
Phosphorus (as P)
Dates In
Effect
All Year
May 1-Oct 31
Nov 1-Mar 31
Apr 1-Apr 30
All Year
May 1-Oct 31
Nov 1-Mar 31
Apr 1-Apr 30
All Year
Daily Daily 30-Day 7-Day
Minimum Maximum Average Average
10.0 mg/1 4.0 mg/1
42.0 Ib/d 17.0 Ib/d
9.0 mg/1 6.0 mg/1
38.0 Ib/d 25.0 Ib/d
25.0 mg/1 40.0 mg/1
104 Ib/d 167. Ib/d
20.0 mg/1 30.0 mg/1
83 Ib/d 125. Ib/d
2.0 mg/1 0.5 mg/1
10.0 mg/1
Monitoring Only
1.0 mg/1
Dissolved Oxygen
Fecal Coliform
Bacteria
Total
Residual
Chlorine
pH (S.U.)
May 1-Mar 31
Apr 1-Apr 30
All Year
All Year
All Year
7.0 mg/1
3.0 mg/1
200/100ml 400/100ml
0.036
6.5
9.0
The following design flows were used in determining the above limitations, but
are not to be considered limitations or actual capacities themselves: 0.5 MGD.
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ATTACHMENT C
3.02.5 Supplementary Limitations
No discharger shall discharge wastewater containing concentrations (or mass
limitations) greater than the following enumerated materials, except under
permit from the Authority. For industrial users with discharges that do not
meet the following standards or permit provisions, pretreatment of the
wastewater shall be required to meet the appropriate concentrations or mass
limitations.
Material Concentration Mass Limitation
(mg/'l) (Ibs/day)
Cadmium 0.5 2.1
Copper 0.5 2.1
Cyanide 0.2 0.8
Lead 0.3 1.25
Nickel 1.0 4.2
Total Chromium 1.0 4.2
Zinc 1.0 4.2
BOD 300 75
Suspended Solids 300 75
Phosphorus 8 2
The Authority may impose mass limitations on dischargers using dilution to
meet the pretreatment standards or requirements of this Ordinance, or in other
cases where the imposition of mass limitations is deemed appropriate by the
Authority.
3.03 SPECIAL AGREEMENTS
No statement contained in this article shall be construed as preventing any
special agreement or arrangement between the Authority and any industrial
concern whereby an industrial waste with unusual strength or character may be
accepted by the Authority for treatment, subject to payment therefore, by the
industrial concern, unless prohibited by State or Federal Regulations.
1/30/85
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CITY OF LUDINGTON
PROGRAM DESCRIPTION AND IMPLEMENTATION
The City of Ludington, with a population of 9000, is located on the shore
of Lake Michigan in Mason County, Michigan. The City discharges approximately
two million gallons per day of treated sewage to the Pere Marquette River
under authority of NPDES Permit # MI0021334. In addition to effluent
limitations, the permit requires the development and implementation of an
IPP, IPP requirements were met by the City and the program was approved on
March 29, 1985.
Ludington's NPDES Permit does not contain effluent limitations for
non-conventional pollutants, but the Permit has been modified to include
specific IPP language. The modification requires the City to:
1. Maintain records related to IPP for a minimum of three years.
2. Submit annual reports to the state.
3. Issue discharge permits in accordance with the approved program plan.
4. Protect the quality of sludge.
5. Protect the quality of treated effluent.
6. Prevent operational upsets due to industrial discharges.
7. Ensure local limits are met.
8. Ensure federal limits are met.
The current permit expires October 1, 1991. The City is not operating
under any consent decrees, administrative orders, or other documents that
contain pretreatment program requirements.
The City identified 308 non-domestic users connected to the wastewater
treatment facility. Of that number, 16 were located outside the City
boundaries in Pere Marquette Township. Non-domestic users in the Township are
required to meet IPP requirements by Township ordinance and by an
interjurisdictional agreement between the City and Township.
Of all the non-domestic users, one has been identified as a categorical
industrial user, two have been identified as significant, and four have been
identified as regulated non-categorical industrial users. The City defines
significant to mean more than 10,000 gallons per day of flow, the discharge of
toxic pollutants, or a non-domestic discharge which creates a significant
impact at the treatment facility or receiving stream. The two significant
dischargers at Ludington are listed due to flow greater than 10,000 gallons
per day. The four regulated non-categorical industries include Harrington
Tool Company, House of Flavors, NSI Cleaners, and Great Lakes Castings.
- 87 -
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No detectable discharge
The categorical discharger has been issued a discharge Permit. Ordinance
authority and permits form the basis of City regulation of non-domestic users.
Since the construction of the treatment facility, there have been no
historical problems due to industrial dischargers. Local limits were
developed based on influent data, effluent data, sludge analysis, ONR
guidance, plant records, literature review, and categorical pretreatment
standards.
Based on this information, the following limits were adopted in the city's
sewer use ordinance.
Arsenic 0.92 mg/1
Cadmium 0.07 mg/1
Chromium (Total) 1.71 mg/1
Copper 2.07 mg/1
Cyanide 0.65 mg/1
Lead 0.43 mg/1
Mercury
Nickel 2.38 mg/1
Silver 0.24 mg/1
Zinc 1.48 mg/1
Total Toxic Organics 2.13 mg/1
Phenols 0.30 mg/1
In addition, the city's ordinance limits conventional pollutants. Within
ranges established by the ordinance, the City may collect surcharges for these
pollutants. However, the ordinance sets an upper limit for the discharge of
these pollutants.
The approved program provided that categorical users would be monitored
monthly and provided that a semi-annual report must be submitted by the user.
Significant Users will be monitored four times per year.
The City ordinance provides the following enforcement options. The City
can impose fines of up to $500 per day, can terminate service, can revoke
permits, can seek injunctive relief, can issue letters of violation, and
require plans, specifications, and construction schedules. Current level of
effort expended by the City is approximately $5000 per year and 250 person
hours.
PROGRAM EFFECTIVENESS
Lejal_AuJ;_hQ_rlty: The extension of sewer services into other areas is underway
at the present time. A county ordinance is being adopted. Along with this
ordinance, interjurisdictional agreements between the County and City must be
negotiated.
Application of Standards: Local standards and categorical standards are being
applied in both the City and Pere Marquette Township. However, one industry
is subject to the combined wastestream requirement and federal limits have not
been adjusted yet to reflect this.
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Compliance Monitoring: The City has met the monitoring requirement of the
approved program, and in some cases exceed their program commitment.
Enforc_eme_nt: Ludington presented an enforcement procedure as part of its
approved program. One permit has been issued to the categorical discharger.
Compliance tracking is by hard copy files. Individual files are maintained
for all significant, categorical, and other regulated dischargers.
Resource Commitment: The approved program indicated that 250 hours per year
would be devoted to pretreatment. However, a line item account has not been
established to accurately gauge such expenditures.
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BOYNE CITY
PROGRAM DESCRIPTION AND IMPLEMENTATION
The Boyne City pretreatment program was approved by the Michigan DNR on
May 1, 1985. Pretreatment program requirements were incorporated into the
City's NPDES permit issued September 19, 1985. The City is not operating
under any consent decree, administrative order, or other document containing
pretreatment program requirements.
All IDs are located within the jurisdictional boundaries of the POTW.
Boyne City has a total of 60 lUs on their system. There is only one
categorical IU and one significant non-categorical IU. The remaining 58 are
other nondomestic users. The POTW has defined significant IU as any industry
which discharges greater than ten percent of the design flow or design loading
of the wastewater treatment plant.
There are no Ills subject to the combined wastestream formula or
production-based categorical standards. One IU is subject to TTO requirements.
Boyne City has issued permits to its two significant lUs. These permits
are effective for one year.
The City's NPDES permit contains the following toxic pollutant monitoring
requirements. All samples are to be 24-hour composites.
Effluent
Par_amete_r Monitoring Frequency
Chromium, total Quarterly
Nickel Quarterly
Silver Quarterly
Tetrachloroethylene Quarterly
Boyne City initially evaluated local limits without using site-specific
information (i.e. background pollutant concentrations, removal rates, etc.).
Maximum headworks loadings were calculated using EPA guidance. The POTW is
currently in the process of re-evaluating its local limits using site-specific
data.
Boyne City's monitoring program established compliance sampling and
inspection frequencies as follows:
Significant
Categorical Non-categorical
IU Inspections by POTW I/year I/year
POTW monitoring of IU 4/year 4/year
Self-monitoring by IU I/month 4/year
Reporting by IU 2/year 4/year
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Program Effectiveness
Boyne City's pretreatment ordinance provides adequate legal
authority for regulating its IDs.
Application of Standards: Boyne City has done an adequate job of applying
pretreatment standards. The two significant IDs have been properly
categorized. The City's compliance sampling of the categorical IU is done at
the end of the process.
Compliance Monitoring: The City has conducted compliance sampling in
accordance with the approved program frequency.
Enforcement: Very little enforcement action has been needed to date due to
the City's close working relationship with its two significant IDs. Both SIUs
have documented consistent compliance with pretreatment standards. The City
has recently had to issue notice letters concerning failure to report
self-monitoring results. The City does need to develop an enforcement
response guide.
Data Management: The small number of SIUs simplifies data management by
program personnel. Files are well documented with monitoring data,
inspections, and compliance activities. The status of each SIUs compliance is
easi ly determined.
Res ou_ r c e_s : The City has committed approximately 0.1 FTEs to the pretreatment
program and appears to have adequate resources for implementation.
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CITY OF FLINT
The City of Flint operates an advanced water treatment facility which
treats the municipal and industrial discharges of the City of Flint and the
Beecher Metropolitan District. The wastewater treatment plant currently
processes an average flow of 35 USMGD (132,475 m3/d)(dry weather) with an
activated sludge system followed by micro screens. Approximately 38% of this
flow is industrial or non-domestic in nature. Sludge is treated with the
zimpro process, belt filter pressed and incinerated.
The City of Flint IPP program was approved on May 29, 1985. The ordinance
adopted by the City on February 25, 1985, contains provisions for issuance of
permits to significant IDs. The City's NPDES permit was modified on August
22, 1985, to incorporate the approved program. The NPDES permit requires that
the City submit annual reports on the status of the program, including
effluent limits for cadmium, copper, lead, silver, and amenable cyanide (see
Table 1).
At this time, the City of Flint has issued twenty-seven (27) discharge
permits broken down as follows: categorical users - seven; significant
non-categorical users - seven; and regulated non-categorical users -
thirteen. Of the twenty-seven permitted dischargers, there are two using the
combined wastestream formula, nine subject to total toxic organic limits, and
nine subject to solvent management plans. There is also one significant
discharger located in the Beecher Metropolitan District. The Beecher
Metropolitan District is handled via a multl-jurisdictional agreement.
A SIU is defined as having any of the following; a flow of 25,000 gallons
per day or greater; a flow of greater than 5% of the Influent flow; a
discharge which contains a toxic pollutant or has a IPP
significant impact on the POTW either singly or in combination with other
industries.
The following parameters appear in the Flint POTN's NPDES permit. All
samples are required to be 24 hour composites.
TABLE 1
Parameter
Amenable Cyanide
Total Lead
Total Silver
Total Cadmium
Total Copper
Frequency
Effluent
Monitoring
Weekly
Weekly
Weekly
Weekly
Weekly
Effluent
Limits
Daily 30-Day
Maximum Average
30 vig/1* 5 ng/1*
449 pg/1* 19 v>9/l*
2 vig/1* 0.1 pg/1*
46 pg/1* 1.0 pg/1*
121 fig/1* 65 jag/1*
*Effluent Limits take effect 10-1-90
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Permit limits and ordinance limits are based upon a review of available
information and calculations based on treatability and passthrough criteria.
There is no history of difficulties caused by industrial dischargers and the
plant is in consistent compliance with their effluent limits.
TABLE 2
1. Discharge Limitations - User Total Discharge Volume to POTW
Less than 10,000 gpd
Discharge Limitation (mg/1)
P_ajcamet_er (Daily Average)
Arsenic 0.5
Cadmium 2.0
Chromium (Total) 5.0
Copper 3.0
Lead 0.5
Mercury 0.02
Nickel 3.5
Silver 0.5
Zinc 5.0
Cyanide 2.0
2. Discharge Limitations - User total discharge volume to POTW
Greater than 10,000 gpd
Discharge Limitation (mg/1)
Parameter (Daily Average)
Arsenic 0.10
Cadmium 0.70
Chromium (Total) 2.6
Copper 1.2
Lead 0.4
Mercury 0.005
Nickel 1.3
Silver 0.2
Zinc 1.1
Cyanide 0.60
The approved program contains recommended monitoring (both self and POTW)
frequencies as a guideline for operating staff which allows them the
flexibility of increasing or decreasing monitoring based on user compliance
with their permit.
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User
Characteristics
TABLE 3
MONITORING SCHEDULE
Self-Monitoring
Requirements
POTW
Scheduled
Monitoring
Unscheduled
User Regulated by
Federal Categorical
Discharge Regula-
tions
Review Applicable
Federal Categorical
Discharge Regulation
of Self-Monitoring
Requirements.
Monthly
Quarterly
User with High Quarterly
Potential to
Impact on POTW
Process
User with Low Annually
Potential to
Impact to
POTW Process
Semi- Semi-
Annually Annually
Annually None
NOTE: The above Monitoring Schedule is meant to serve as a guideline only.
The actual monitoring requirements for a particular User should be based upon
User performance. If a User has consistently met or violated the requirement
of a User Permit, the monitoring requirements should be modified appropriately.
The adopted ordinance allows the City several enforcement tools dependent
upon the severity of the violation. Options range from verbal or written
notices up to the termination of service; to date, there have been no major
enforcement actions by the City, due to significant compliance by lUs with
program requirements.
The current program is operated with a staff of 2.3 FTE's and an annual budget
of approximately $110,000.
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OHIO
CITY OF BRYAN
PROGRAM DESCRIPTION AND IMPLEMENTATION
The City of Bryan's pretreatment program was approved on January 18, 1985
and pretreatment requirements were subsequently Incorporated In Its NPDES
permit. Bryan is not operating under an enforcement order, consent decree, or
other document containing pretreatment program requirements.
All lUs tributary to the Bryan POTW are located within its jurisdictional
boundaries.
Bryan has six IDs in their system. Of these six, three are subject to
categorical standards and three are considered significant non-categorical
users. Bryan Issues wastewater discharge permits for a duration of two years
to SIUs. SIUs are either subject to categorical standards or are discharging
industrial waste that has the potential to upset plant operations. Bryan has
issued the six ID permits required by their approved program.
The combined wastestream formula is applied to two of the lUs. Two are
also subject to TTO requirements. None of the IDs In Bryan are subject to
production based standards.
The following parameters appear in the Bryan POTW's NPDES permit.
samples are required to be composites unless otherwise noted.
All
PARAMETER
MONITORING FREQUENCY
Cadmium
Chromium, hex
Chromium, total
Copper
Lead
Nickel
Zinc
Mercury
Phenols
Cyanide, total
influent
monitoring
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month*
effluent
monitoring
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month*
l/month*+
sludge
monitoring
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
"grab samples
monitoring only
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Local limits calculations for the program submission were based on three
sampling periods of the influent, effluent and sludge in 1983. Removal rates
were calculated based on these data. Maximum plant headworks loadings were
then back-calculated using the most limiting factors among activated sludge
biological processes, anaerobic sludge digestion, and land application of
sludge. Sampled background headworks loadings were subtracted from the
calculated allowable influent loadings and then allocated uniformly to
industrial contributors.
In 1985 Bryan revised their local limits to reflect new water quality
standards using the same procedures but new data collected over three months
of daily 24 hour composite sampling. Bryan's local limits are as follows:
Parameter Limit (mg/1)
Cadmium 0.69
Chromium 3.32
Copper 0.09
Lead 3.91
Nickel 0.69
Zinc 3.59
Phenols 2.74
Cyanide, total 0.16
Bryan's approved program establishes inspection and monitoring frequencies
as follows:
Categorical SIU
IU inspections by POTW I/year I/year
POTW monitoring of IU I/year I/year
Self-monitoring by IU 4/year 4/year
Reporting by IU 2/year 2/year
Bryan has not developed a definite enforcement strategy to be applied
uniformly to situations of noncompliance. Any enforcement that has been
initiated in the past has consisted mainly of verbal warnings and informal
letters that have been poorly documented.
The funding for Bryan's pretreatment program 1s borne completely by the
POTW's general operating fund. One tenth of a FTE has been committed to the
program.
PROGRAM EFFECTIVENESS
Legil_Au±hfir.1_ty.: Bryan is considered to have adequate legal authority to
implement and enforce its pretreatment program. The only shortcoming in
Bryan's sewer use ordinance is the absence of the recently revised federal
definitions of passthrough and interference.
Application of Standards: Program staff have had periodic problems
determining the correct limits to put in permits as well as the proper
application of the combined wastestream formula. Sampling locations have not
been Identified in the permits. Bryan has also failed to notify its lUs of
RCRA requirements.
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Comp11 ance_ Mon1 tor ing: The City has failed to document IU inspections, making
it difficult to establish if these inspections have been conducted. The
City's compliance monitoring events did not routinely sample for all
parameters limited in the user's permit. In addition, chain of custody forms
for samples are not used.
£nfp_rcjeme_nt-' Out of six SIUs, one has been consistently out of compliance
with local limits. The city has not placed this user on a compliance
schedule, but the industry is installing pretreatment facilities to meet
permit limitations.
There is no clear record that all ID violations have been acted upon. The
City has not consistently issued notices of violation. Presently any type of
enforcement against an industrial contributor would be difficult, if not
impossible, due to the lack of inspection, monitoring and documentation done
by the POTW.
Data_Ma.nag_ejTient: Bryan's program files do not contain adequate
documentation. In addition, baseline monitoring reports are missing for
several categorical industries.
Resource!: Bryan is not providing sufficient resources to adequately
implement the pretreatment program. Additional manpower is required to
correct the deficiencies noted herein.
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NORTHEAST OHIO REGIONAL SEWER DISTRICT
PROGRAM DESCRIPTION AND IMPLEMENTATION
Northeast Ohio Regional Sewer District's (NEORSD) pretreatment program was
approved on September 6, 1985; however, much progress was made in pretreatment
prior to that time. Pretreatment requirements have been incorporated into
three of the four affected NPDES permits. Presently, the District oversees
program requirements for four separate wastewater treatment facilities and
their service areas and has procedurally incorporated a fifth facility. The
Southerly, Easterly, Westerly and Strongsvllle "A" treatment plants are
covered under the pretreatment program and the Berea STP is being
incorporated. All IDs are within the jurisdictional boundaries of the
District. NEORSD is not presently under any consent decree or enforcement
order for pretreatment regulations.
There are approximately 29,000 lUs in the District's system. 160 users
are subject to categorical standards, five are considered significant
non-categorical users and 774 are other regulated non-categorical users.
NEORSD defines a SIU as a user (categorical or non-categorical) in violation
of the local sewer use code.
The combined wastestream formula Is applied to five lUs. 150 users are
subject to TTO requirements. 15 users are subject to production-based
categorical standards.
NEORSD's program does not include a control mechanism other than their
sewer use code.
At the time local limits were being developed for pretreatment program
approval, several of the District's treatment facilities were still under
construction. This made determining representative removal rates from
sampling results marginal at best. Also, background concentrations from
sampling showed relatively high levels of cadmium, copper and zinc.
Therefore, NEORSD decided to retain their existing heavy metals pretreatment
limits. These limits were initially selected after an extensive review of
similar programs. NEORSD's local limits are as follows:
Parameter Limit (mg/1)
Cadmium 2
Chromium, hex 10
Chromium, total 25
Copper 2
Nickel 10
Iron 50
Zinc 15
Lead 2
Cyanide, free 2
Cyanide, total 10
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NEORSD's approved program establishes Inspection and monitoring frequencies as
follows:
Categorical SIU
ID inspections by POTW I/year - min I/year - min
POTW monitoring of IU I/year - min I/year - min
Self-monitoring of ID 2/year varies
Reporting by IU as necessary varies
NEORSD's enforcement plan responds to first-time violators by sending a
notice of violation describing the violation and requesting a response within
a specified period of time. If an industry repeatedly discharges pollutants
in excess of the limits contained in the Sewer Use Code, NEORSD typically
follows up with either administrative orders or show cause hearings. Overall,
the enforcement strategies of the District have been effective in limiting
violations.
Operating expenses for NEORSD's Pretreatment Program are set at
approximately $131,500 for program implementation and another $119,000
estimated for lab expenses. The total funding is borne by the general
operating fund. Only lab expenses for TTO testing is billed directly to the
industry. Approximately 5.5 to 6.5 man years are committed to the pretreatment
program.
PROGRAM EFFECTIVENESS
Legal Authority: NEORSD has adequate legal authority to implement and enforce
pretreatment standards and requirements. However, the District currently does
not have a control mechanism other than the sewer use code. Although the code
is of and by itself enforceable, 40 CFR 403 is interpreted by the approval
authority to require additional control. Given that USEPA intends to modify
40 CFR 403 to clearly require issuance of permits (or equivalent) to all SIUs,
NEORSD should modify their program to implement such a system.
Application of Standards: It appears that NEORSD may not be applying standards
appropriately. The District compliance sampling, whenever possible, is
conducted end-of-process; this method does not allow assessment of compliance
with local limits. The District must Identify and quantify wastestreams
introduced downstream of their sampling location. Where necessary, the
combined wastestream formula should be used. NEORSD also needs to identify
representative sampling locations for IU self-monitoring.
Co.mp_lia_n.c_eJlonltp.r.ing: NEORSD's compliance monitoring program appears to be
one of the program's strengths. The District implements a four-day sampling
event for their scheduled compliance monitoring. These sampling events include
a detailed inspection on the first day. Subsequent days are used to follow-up
with questions generated by the first day's inspection, pick up samples and
reset the sampler.
The District has also developed adhesive labels citing the lUs requirement to
notify the District in the event of a slug discharge or treatment equipment
failure. These stickers are being distributed to lUs throughout the District
and are to be placed on treatment control equipment.
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Enforcement: Of the 165 SIUs that discharge to NEORSD's facilities,
approximately ten percent have been subject to some form of enforcement action
during the last twelve months. Five SIUs are considered to be in
noncompliance with categorical standards and three are in noncompllance with
local limits. Eleven users are currently on compliance schedules, with eight
having been returned to compliance.
Data_Manajgejnent: NEORSD's current filing system is by no means ideal, but its
difficulties should be resolved after a move to new offices and establishment
of centralized filing area.
Reiourc_e.s: Program resources appear to be at a reasonable level.
TABLE 1: NPDES Permit Parameters and Monitoring Requirements
(All samples are composites unless otherwise noted)
FACILITY: Easterly WWTP
PARAMETER
FREQUENCY
influent
monitoring
effluent
monitoring
sludge
monitoring
Cadmium
Chromium,
Chromium,
Chromium,
Copper
Lead
Nickel
Zinc
Mercury
Phenols
Cyanide,
tri
hex
total
free
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week*
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week*
kgrab samples
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TABLE 1: Con't.
FACILITY: Southerly WWTP
PARAMETER
FREQUENCY
Cadmium
Chromium, hex
Chromium, total
Copper
Lead
Nickel
Zinc
Mercury
Phenol s
Cyanide, total
PCBs
*grab
FACILITY: Westerly
PARAMETER
Cadmium
Chromium, hex
Chromium, total
Copper
Lead
Nickel
Zinc
Mercury
Phenols
Cyanide, total
PCBs
influent
monitoring
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month
1 /month*
1 /month*
samples
WNTP
influent
monitoring
I/week
I/week
I/week
1 /week
I/week
1 /week
I/week
I/week*
effluent
monitoring
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week*
I/week
FREQUENCY
effluent
monitoring
I/week
I/week
1 /week
I/week
I/week
I/week
1 /week
1 /week
I/week*
I/week*
sludge
monitoring
I/week
I/week
I/week
1 /week
I/week
I/week
I/week
I/week
4/year*
sludge
monitoring
I/week*
I/week*
I/week*
I/week*
I/week*
4/year*
"grab samples
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TABLE 1: Con't.
FACILITY: Strongsville "A" WWTP
PARAMETER
Influent
monitoring
FREQUENCY
effluent
monitoring
sludge
monitoring
Cadmium
Chromium,
Copper
Lead
Nickel
Zinc
Mercury
PCBs
1/month*
total 1/month*
1/month*
1/month*
1/month*
1/month*
1/month*
*grab samples
+facility is under orders
interceptor and abandon
4/year
4/year
4/year
4/year
4/year*
I/year*
to tie
plant
into Southwest
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CITIES OF WILLOUGHBY - EASTLAKE
PROGRAM DESCRIPTION AND IMPLEMENTATION
The City of Willoughby and neighboring Eastlake together form the
Willoughby-Eastlake Water Pollution Control Center (WPCC). Pretreatment
program approval was granted on September 26, 1985 and pretreatment
requirements were subsequently incorporated into their NPDES permit. The WPCC
is not operating under an enforcement order, consent decree, or other document
containing pretreatment program requirements.
The WPCC has jurisdictional authority over all wastewater contributors
tributary to the treatment plant in the cities of Willoughby and Eastlake to
monitor and inspect contributors and to require compliance with the sewer use
ordinance adopted by the WPCC. However, the burden of enforcement falls on
the legal department of the respective cities.
Willoughby-Eastlake has 348 lUs in their system. Of these, 10 are subject
to categorical standards, 75 are significant non-categorical users, and 263
are considered other non-categorical users. Willoughby-Eastlake defines a SIU
as any user discharging process waste or possessing the potential to discharge
other than "normal sewage", a phrase contained in their by-law.
Ten of the users are subject to TTO requirements.
by a production-based categorical standard.
One user is regulated
IU permits expire one year after their issuance date and require the
submission of an updated industrial waste survey when the IU applies for a
permit renewal.
The following parameters appear in the Willoughby-Eastlake WPCC NPDES
permit. All samples are required to be composites unless otherwise noted.
PARAMETER
Cadmium
Chromium,
Chromium,
Copper
Lead
Nickel
Zinc
Mercury
Phenols
Cyanide,
PCBs
hex
total
total
influent
monitoring
I/week
1/week
I/week
I/week
I/week
I/week
I/week
I/week*
I/week*
FREQUENCY
effluent
monitoring
sludge
monitoring
I/week
1 /week*
l/week+
I/week
I/week
I/week
I/week
I/week
l/week*+
l/week*+
1 /month*
1 /month*
1 /month*
1 /month*
1 /month*
1 /month*
I/year*
grab samples
+ monitoring only
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Willoughby-Eastlake's sewer use ordinance contained limitations on some
heavy metals and toxics prior to their pretreatment program submission.
Removal rates were calculated from the preceding 12 months of monthly
composite effluent sampling. An allowable Industrial loading in pounds of
pollutant at the treatment plant headworks was then back calculated from
removal rates and NPDES permit limits. This was used as a comparison with
actual headworks loadings from Industry with the present local limits to
qualify any necessary changes. Milloughby-Eastlake1s local limits are as
follows:
Parameter
Arsenic
Cadmium
Chromium,
Chromium,
Copper
Cyanide:
Iron
Lead
Mercury
Nickel
Phenols
Silver
Zinc
Limit (mg/1)
hex
tri
total
0.
0.
1.
04
4
0
3.0
0.9
0.1
15.0
2.0
0.3
3.0
0.5
1.0
4.0
Nil loughby-Eastlake has defined three different categories of IDs that
have different monitoring and reporting requirements. Users classified as
major significant users are those industries with substantial process waste or
who have a reasonable potential, in the opinion of the POTW, to adversely
affect the treatment system. Those industries that are verified as
categorical industries will be Included as major significant users. Minor
significant users are those industries that have a potential to discharge
process wastes or have a potential for a spill, but at the same time discharge
only sanitary waste, or whose Individual discharges do not significantly
impact the system. If any minor significant user becomes a problem for the
system, the classification will change to major significant.
Nilloughby-Eastlake1s approved program establishes Inspection and monitoring
frequencies as follows:
major minor
significant significant insignificant
IU inspections by POTH
POTW monitoring of Ills
Self-monitoring by lUs
Reporting by IDs
Ml 1loughby-Eastlake's enforcement plan responds to first time violators by
sending a notice of violation, stating the nature of the violation, and
requesting a response on corrective actions and the date by which compliance
will be achieved. If no positive corrective action is taken and if a second
violation occurs within a one year period, the violator is sent a notice to
abate and is ordered to return to compliance within a specified period of
time, usually 30 days. The user 1s given the opportunity to appeal the order.
4/year
1 /month
2/year
2/year
2/year
4/year
2/year
2/year
I/year
I/year
none
none
104 -
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If the violations continue, the user is discussed at a monthly administrative
meeting. A prosecutor's meeting may ensue. If the violations continue, the
user is referred to the Law Department of the appropriate city for enforcement
action. According to the sewer use ordinance, a violating III will be referred
to either Willoughby or Eastlake depending on the Ills location and which city
has jurisdiction in that area.
Annual pretreatment program funding for 1988 is $196,845 with 4.0 full
time equivalents allocated to the program.
PROGRAM EFFECTIVENESS
Legal Authority: Willoughby Eastlake's legal authority is sufficient.
Application of Standards: Program staff appear to be applying standards
correctly and appropriately.
Compliance Monitoring: The compliance monitoring program is sufficient.
Enforcement: Sixty-six Percent of all categorical and SIUs have been subject
to some level of enforcement action during the past twelve months. Of
fourteen ILJs that were in significant noncompl iance with permit limits, nine
have been returned to compliance by use of orders or compliance schedules.
Judicial action against one user in Eastlake has been initiated.
Willoughby-Eastlake's lack of enforcement is the major concern with an
otherwise good pretreatment program. Program staff issue notices of
violation, but the Willoughby legal department has failed to initiate further
action.
Data Management: All files appear to be adequately documented and are in good
order.
Resources: Program resources appear to be at a reasonable level.
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CITY OF ELYRIA
PROGRAM DESCRIPTION AND IMPLEMENTATION
The City of Elyria's pretreatment program was approved by the Ohio EPA on
March 29, 1985. Pretreatment program requirements were incorporated into the
City's NPDES permit issued December 18, 1985. The City Is not operating under
any consent decree, administrative order, or other document containing
pretreatment program requirements.
the
All lUs
POTW.
are geographically located within the jurisdictional boundaries of
Elyria has 134 IDs in their system. Four are subject to categorical
standards, 11 are significant non-categorical users, 27 are other
non-categorical users and 92 are other non-domestic users. The city defines
SIU as a facility which discharges pollutants that may be incompatible with
the Elyria Wastewater Pollution Control Plant.
The combined wastestream formula is applied to two of the Ills. Seven users
are subject to TTO requirements. One user is subject to a production-based
categorical standard.
To date Elyria has issued 9 of the required 15 industrial discharge
permits with an effective term of 3 years. However, permits are issued to lUs
only after they have demonstrated compliance with the City's pretreatment
program regulations. Until compliance is demonstrated, IDs are put on a
compliance schedule for any Improvements that are necessary to achieve that
compliance.
The following parameters appear in the Elyria POTW's NPDES permit. All
samples are required to be composites unless otherwise noted.
PARAMETER
Cadmium
Chromium.
Chromium.
Chromium,
Copper
Lead
Nickel
Zinc
Mercury
Cyanide,
PCBs
hex
tri
total
influent
monitoring
I/week
I/week
I/week
1/week
I/week
I/week
I/week
I/week
free
FREQUENCY
effluent
monitoring
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week
I/week
sludge
monitoring
1/month
1/month
1/month
1/month
1/month
1/month
1/month
I/year*
* grab sample
- 106 -
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Elyria's local limits were developed to protect against 1) inhibiting
biological processes, 2) violating sludge disposal requirements, and 3)
violating NPDES permit limits. Removal rates for 8 heavy metals and cyanide
were determined from previous POTW sampling data and information published by
the U.S. EPA. These numbers were used to calculate allowable influent
loadings for all parameters. The background pollutant value was then
subtracted from the allowable headworks loading to determine the allowable
industrial contribution. This value was divided by the total flow of
industries known to contribute that pollutant to determine a local
limitation. Elyria's local limits are as follows:
Parameter Limit (mg/1)
Cadmium 0.54
Chromium 4.0
Copper 2.1
Lead 0.70
Mercury 0.002
Nickel 5.0
Zinc 3.4
Cyanide, total 1.3
Silver 1.2
Elyria has also established limits for industrial discharges of
conventional pollutants but selectively grants variances on these limits up to
a specified celling. Any concentration above a ceiling level is considered a
violation of the sewer use ordinance, but within this range the POTW levies a
surcharge on that parameter.
Elyria's monitoring program establishes compliance sampling frequencies
for IDs according to the volume of wastewater that is discharged to the POTW.
The frequencies are as follows:
>10.0QO GPP <10.000 GPP
IU inspections by POTW I/year I/year
POTW monitoring of IU 2/month 1/month
Self monitoring by IU 2/month 2/month
Reporting by IU 4/year 4/year
Elyria's approved program calls for a written notice of violation to be
served on a violator requiring compliance within 10 days. An uncorrected
violation would be subject to a citation followed by a hearing with the
Superintendent, who retains the authority to order appropriate relief,
including dismissal of the citation or termination of service. However, in
actual practice, notices of violation have been followed by meetings and
correspondence which have not always been effective in resolving noncompliance.
Elyria has an estimated annual pretreatment program budget of $155,000 and
has allocated 3.2 FTEs to the program.
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PROGRAM EFFECTIVENESS
LegalAuthorjty: Elyrla's existing ordinance requires the city to codify
categorical standards, which has not yet been done. This is a significant
problem since enforcement of standards depends on the city requiring
compliance with their effective code.
Application of Standards: Elyria has done a fair job of applying pretreatment
standards. Program staff have appropriately categorized most of the IDs and
indicate that compliance is assessed against both categorical and local
standards. The city uses their own data to evaluate compliance with local
limits and self-monitoring data to evaluate compliance with categorical
standards. The city must be able to assess compliance status independent of
ID data; therefore, the city must either sample at two locations or sample
only end-of-pipe using the combined wastestream formula to adjust limits.
Also, Elyria has not notified all IDs of requirements under RCRA.
Compliance Monitoring: Although Elyria has conducted extensive compliance
monitoring at a few of their Ills, the overall compliance monitoring effort
does not meet commitments in their approved program.
Enforcement: Elyria has identified eight lUs as being in significant
noncompliance with discharge limitations. None is presently on a compliance
schedule, although three have been in the past. Five of these Industries have
been out of compliance more than two years.
Elyria has not yet fully developed an enforcement strategy. Program personnel
are knowledgeable regarding ID compliance status, but individual IU files do
not document POTW or IU self-monitoring in some cases. Files do not document
where violations have occurred or what enforcement actions have been taken.
The city tends to give more attention to the larger industries and the files
reflect this.
Elyria1s program is in the process of being modified to require discharge
permits for all SIUs regardless of their compliance status. If they are
determined to be in violation of their permit they could then be put on a
compliance schedule to bring them into compliance. This should make legal
enforcement of pretreatment standards on noncomplying lUs much easier for the
City.
&aja__Mjin_ag_ement: The files show monitoring data to be missing in some cases,
and determining compliance status via the files is difficult.
Resources: Program resources appear to be at a reasonable level.
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INDIANA
FORT WAYNE
PROGRAM DESCRIPTION AND IMPLEMENTATION
The Fort Wayne Municipal Code was amended to provide local authority for
the pretreatment program In August of 1985. The Fort Wayne POTW serves 34
categorical Industries, and 38 "significant, non-categorical Industries",
defined as those facilities having in their effluents pollutants other than
oil and grease and pH. In addition, there are 46 other regulated
noncategorical Industries; these are industries that the POTW surcharges,
inspects, controls through a permit, or otherwise regulates, but which are not
considered significant for purposes of the pretreatment program. They include
restaurants, hotels, and motels. Not all these sources are within the
boundaries of the city; however, pretreatment standards are enforced through
interjurisdictlonal agreement.
Of 20 categorical industries required to meet TTO regulations, 10 have met
all TTO requirements; the balance are developing TOMPs required to meet TTO
requirements. In response to survey questionnaires, five other Industries
have met TTO requirements.
The city performs Industrial compliance monitoring once per quarter on all
of the industries that are permitted and inspections of these facilities once
or twice per year. Ills are required to perform self monitoring between two
and six times per month.
The recent survey of 185 industries indicated that 24 were out of
compliance (2 issued notices of violation, 22 non-significant violations
mostly of pH); five of these have developed compliance schedules. Pollutants
for which limits were exceeded included copper, lead, fats, oil and greases,
pH, cyanide, zinc and manganese.
Program Effectiveness
LegaJ _Autho_rl.ty;: Adequate local legal authority exists for the
enforcement of pretreatment standards under the Municipal Code.
Application of Standards: Pretreatment standards are adequately applied
to both categorical and noncategorical industries. The city is making
significant progress in determination of TTO for both types of industries;
however, the state has been encouraging them to expand this effort to embrace
other sources among the industrial population.
C_omp_liance_Monitoring: The city has conducted compliance sampling in
accordance with approved program frequency. It was not clear at this time if
the city has increased the frequency of monitoring at sources demonstrated to
be out of compliance in response to a suggestion from the state.
Enforcement: Generally, enforcement action appears to be adequate, but
the state noted a need for an Enforcement Response Procedure to ensure uniform
and timely response to violations.
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Fort Havne. Indiana - cont'd.
Data Management: Record keeping was judged adequate.
Resource Evaluation: The program staff consists of two field personnel,
one secretary, one lab staff and a program supervisor. Total funding Is 1n
the vicinity of $130,000 per year. This level Is considered adequate for a
sound pretreatment program.
Summ_ary: The city has been determined to be operating a sound
pretreatment program.
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CITY OF ELKHART
PROGRAM DESCRIPTION AND IMPLEMENTATION
The Elkhart pretreatment program was approved on August 30, 1984. The
POTW serves and permits (every five years) 26 categorical Industries, and
eleven "significant, noncategorical industries", defined as those facilities
having a discharge of over 10,000 U.S. GPD (37.85 m3/d) and/or toxic
contaminants.
In the second quarter of 1988, five of the categorical industries were not
in compliance. Two of these lUs were only marginally out of compliance and of
the balance, two were on compliance schedules and the third was referred to
the City Attorney for possible legal action. At the end of 1988 all Ills were
in compliance.
The state expressed concerns regarding the demonstration of the
achievement of TTO requirements at 10 categorical industries. Some of the
industries have performed a TTO analysis and submitted the analytical data to
the city.
The city performs industrial compliance monitoring twice per year on all
of the industries that are permitted and inspects these facilities at least
twice per year. lUs are required to perform self-monitoring between two times
per year and once a month, depending on the type and size of the operation.
Monitoring frequencies do increase when an IU is determined to be out of
compllance.
Program Effectiveness
Legal Authority: Adequate local legal authority exists for the
enforcement of pretreatment standards.
Appl1 cation of Standards: Pretreatment standards are adequately applied
to both categorical and noncategorical industries. The city is making
significant progress in determination of TTO for both types of Industries;
however, the state has been encouraging them to expand this effort to embrace
other sources among the industrial population.
Compliance Monitoring: The city has conducted compliance sampling in
accordance with approved program frequency.
Enforcement: Generally, enforcement action appears to be adequate; an
Enforcement Response Procedure to ensure uniform and timely response to
violations has now been developed and approved by state.
Data Management: Record keeping was judged excellent.
Resource Evaluation: The program staff consists of one full time person
and one half time supervisor and one half time program assistant. Total
funding is in the vicinity of $50,000 per year. This level is considered
adequate.
Summary: The city has been determined to be operating a sound
pretreatment program.
-------
MINNESOTA
Western Lake Superior Sanitary District (WLSSD)
serving Duluth and Cloquet and surrounding areas In Minnesota
DESCRIPTION
The WLSSD pretreatment program was approved on June 24, 1985, pretreatment
program requirements were placed In the WLSSD permit on September 18, 1985,
and the program was Implemented In August of 1986, after Issuance of a Notice
of Violation for non-Implementation of their program.
WLSSD has adopted an Industrial Pretreatment Ordinance which regulates lUs
of their system, 1n addition to a Model Sewer Use Ordinance which has been
adopted by each of the political jurisdictions within their service area.
Together these ordinances comprise the legal authority for the WLSSD
pretreatment program.
The NPDES permit for WLSSD contains monitoring requirements for effluent
chloroform, hexachlorobenzene, methylene chloride and pentachlorophenol twice
a month, plus twice annual monitoring of influent, effluent and sludge for
nickel, copper, cadmium, zinc, chromium, cyanide, phenols and
pentachlorophenol. Priority pollutant scans were also required during the
first year of the permit. WLSSD evaluated the need for local limitations to
prevent interference and passthrough and adopted local limits for six metals.
Industrial flow is about 17 million gallons per day out of a total of
about 35 million gallons per day. All IDs are located in the service area of
WLSSD and are regulated directly by WLSSD. WLSSD has 13 SIUs, two of which
are categorical IDs with relevant limitations.
WLSSD has issued permits to all SIUs as their control mechanism. WLSSD is
now issuing permits, under the pretreatment program, to laboratories,
universities, and hospitals. The local limits from the Industrial
Pretreatment Ordinance or, If they are more restrictive, the limits 1n
National Categorical Pretreatment Standards are placed 1n all permits issued
by WLSSD. Permits issued by WLSSD also include limitations on conventional
parameters when the IU contributes a significant portion of the treatment
plant loading.
WLSSD receives and reviews reports for their permitted lUs and conducts
inspections and monitoring of their lUs regularly. Enforcement actions have
been taken for violations of the ordinances and permits. Implementation of
the pretreatment program is guided by an IPP Procedures Manual.
EVALUATION
Lejia_L_Aujthprt_ty_: The only problem which has been identified in the WLSSD
Industrial Pretreatment Ordinance Is in the temperature limitation in the
general prohibitions. High temperature has caused operational problems at the
treatment plant. This has been identified by WLSSD and they have indicated
that they may be requesting an ordinance change.
- 112 -
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Application of Standards: WLSSD has correctly applied pretreatment standards
and have properly categorized Ills.
Compliance Monitoring: WLSSD has met program commitments for monitoring and
inspecting lUs. However, the effort has not been well organized in some
respects. This has been noted in inspections and WLSSD has committed to
improved planning of inspections and monitoring of lUs.
£n.forcemejit: As of the last pretreatment inspection, one categorical IU was
noted to be in non-compliance with reporting requirements. WLSSD has been
slow to take action against this IU. Monitoring by WLSSD shows that they are
in compliance with limitations. WLSSD was directed to take enforcement action
and resolve this situation. All other lUs were in compliance.
Da_ta_Ma.nasLemejjt: With some effort any needed data could be found in the WLSSD
pretreatment files. Some recommendations have been made to improve file
organization. Because of significant potential for public interest in the
pretreatment files, WLSSD is considering developing specific procedures for
public access to the files.
Resources: Program resources appear to be adequate.
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HISCONSIN
CITY OF MANITONOC
PROGRAM DESCRIPTION
The City of Manitowoc received approval of its local pretreatment program
in June of 1984. The City's WPDES permit was subsequently modified to include
requirements to operate the approved program.
The City's treatment plant receives approximately 10.0 million gallons
(US) (37,850 m3/d) of wastewater each day. Some 4.5 million gallons
(17,437 m3/d) of that waste are from industrial sources.
Manitowoc receives wastewater from an estimated 50 IDs. Twenty-two
(eleven categorical, eleven noncategorical) have been issued IU permits. Two
additional users presently require permits.
All IDs are located within the jurisdictlonal boundaries of the City.
Landfill leachate also is hauled to the plant for treatment.
The City used historical treatment plant monitoring to estimate pollutant
removal rates to establish local limits. Maximum allowable headworks loads
were determined based on the susceptibility of the biological treatment
process to upset or inhibition, and to maintain current sludge disposal
options. Since no water quality based limits for toxic materials were
included in the WPDES permit, this factor was not used to establish the
headworks targets. The City was able to demonstrate that the daily maximum
limits for the electroplating category would protect against process upset and
sludge contamination. The City will be required to reevaluate its local
limits to contain limits for toxics when its WPDES permit is reissued in the
coming months.
The City conducts compliance monitoring at its IDs at least twice a year
using a contract lab. Inspections are to be performed on an annual basis.
The approved program contains an enforcement management system that
describes how violations will receive an escalating response if not corrected
in a timely fashion.
Manitowoc devotes 1.25 full time equivalents to its pretreatment program
efforts.
PROGRAM EFFECTIVENESS
Legal Authority: The City has not experienced any practical problems in
enforcing pretreatment requirements. However, the local ordinance must be
upgraded to reflect changes in federal requirements.
Application of Standards: Revisions to local limits may be necessary to
prevent violations of water quality based limits.
Compliance Monitoring: Adequate.
- 114 -
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Enforcement: The City must follow the procedures In Its approved
program. To date, it has been hesitant to take formal enforcement actions
against violators.
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GREEN BAY METROPOLITAN SANITARY DISTRICT
PROGRAM DESCRIPTION
The Green Bay Metropolitan Sanitary District's (GBMSD) pretreatment
program was approved in September, 1985. Requirements to operate the approved
program were subsequently incorporated into GBMSD1s WPDES permit. GBMSD is
not presently subject to any State or Federal enforcement orders that affect
the pretreatment program.
GBMSD's treatment plant receives approximately 28 million gallons (US)
(105,000 m3/d) of wastewaters each day. Sixteen million gallons (60,600
m3/d) are from industrial sources.
All lUs of GBMSD's treatment works are located within it's jurisdictional
boundaries.
GBMSD serves 75 IDs. Ten of these lUs are subject to National Categorical
Pretreatment Standards. Thirty-four noncategorical IDs discharge wastes which
have the potential to upset or interfere with the treatment processes or
otherwise require monitoring. Also, eight waste haulers have been issued
on-site discharge permits. Generally, these are domestic septage and holding
tank wastes. All of the above Ills have been issued a pretreatment order
(which identifies pretreatment requirements) or a waste hauler permit. These
documents serve as the program's control documents.
GBMSD developed local limits as part of its pretreatment program. The
District used historical plant monitoring data to determine the fate of
pollutants within the treatment system. Acceptable industrial loadings were
then back calculated in consultation with Wisconsin DNR based on literature
values established to prevent inhibition of biological processes (activated
sludge with nitrification, anaerobic sludge digestion) and on instream water
quality criteria. Since GBMSD Incinerates its sludges, no sludge disposal
criteria were factored into these calculations. GBMSD's WPDES permit has been
reissued with a requirement for re-evaluation of local limits.
Generally, each IU which has been Issued an order is to be Inspected and
sampled by GBMSD twice a year. A specific monitoring plan is established each
year by GBMSD based on a case-by-case evaluation of the discharge status of
each user. The compliance monitoring frequency is subject to Department
review and approval.
GBMSD's program contains a detailed enforcement management system which
ensures that similar violations are addressed in a similar fashion and that
significant violations receive highest priority attention.
Green Bay devotes 2 FTEs to pretreatment program activities.
PROGRAM EFFECTIVENESS
Legal Authority: GBMSD has not encountered any practical difficulties in
enforcing pretreatment requirements. However, the existing ordinance will
have to be upgraded to capture changes in the federal requirements.
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Application of Standards: Pretreatment standards have been properly
applied.
Compliance Monitoring: GBMSD operates a high quality compliance
monitoring and Inspection program.
Enforcement: Adequate.
Data Management: GBMSD provides ample documentation of program activities
and understands the status of all lUs.
Resources: Adequate.
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CITY OF FOND DU LAC
PROGRAM DESCRIPTION
The City of Fond du Lac received approval of its pretreatment program in
June 1984. Requirements to operate the approved program were subsequently
incorporated into the City's NPDES permit. The City is not presently affected
by any state or federal enforcement order concerning pretreatment.
The City's treatment plant treats approximately 7.2 million gallons (US)
of wastewater each day (27,252 m3/d). Some 1.8 million gallons (6,810
m3/d) are discharged by IDs.
Fond du Lac receives wastes from industry outside of its jurisdictional
boundaries but has assumed the responsibility for applying and enforcing
pretreatment standards on such industries.
The City receives wastes from six Ills regulated by National Categorical
Pretreatment Standards, three significant noncategorical users, two other
users which are potentially subject to categorical standards, and five waste
haulers. The City is finalizing ID permits for two of the categorical
industries and the two Ills potentially subject to categorical standards. All
remaining categorical and SIUs have been issued permits. The waste haulers
are controlled by a manifest system and do not require permits.
The City used historical monitoring data to establish local limits at the
time of program approvals. Maximum headworks loadings were developed to
protect biological processes (activated sludge, anaerobic digestion) and
sludge disposal (land application and landfill). Because no effluent limits
for toxics were included in the WPDES permit, no headworks loadings were
established to prevent the passthrough of toxics. The City demonstrated that
the daily maximum limits for the electroplating category would be sufficient
to protect the plant operations and sludges. These local limits will be
reevaluated as a condition of a new NPDES permit to be reissued in 1989.
At a minimum, the City conducts one formal IU inspection and two
compliance monitoring events at each permitted user.
In addition to the local sewer use ordinance authorities, the City uses a
stepped enforcement procedure. They have been successful In working with IDs
to achieve compliance prior to the need for formal enforcement action.
Fond du Lac presently devotes 1 FTE to pretreatment program activities.
PROGRAM ASSESSMENT
Legal Authority: The City has not experienced any practical problems in
enforcing pretreatment requirements. However, the local ordinance must be
upgraded to reflect changes in federal requirements.
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Application of Standards: two metal molding and casting permits are In
draft stages. Local limits will be upgraded to address water quality concerns
when Sheboygan's permit is reissued to include revised effluent limits.
Enforcement: The city should consider a more detailed enforcement
management system.
Data Management: Adequate.
Resources: Adequate.
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ONTARIO
CITY: CITY OF METROPOLITAN TORONTO
Program Description and Implementation
The City of Metropolitan Toronto passed their local municipal sewer use
by-law in 1982 and operates four waste treatment facilities with a total
combined flow of 1,375,900 cubic metres per day (iWd) (364 USMGD). The
treatment facilities have Certificates of Approval without limits. The
effluents from the facilities complied with MOE Policy 08-01, except for one
plant which did not meet the total phosphorus requirements. Sludge disposal
is by incineration. The municipality is not operating under any control order
pertaining to its treatment plant operations.
Most lUs discharging to the collection system are located within the
jurisdictional boundaries of the municipality. The municipality receives a
small amount of waste from an adjacent municipality. The agreement with this
municipality does not contain any provisions for controlling the Industrial
discharges to these sewers. The city has 5,870 potential dischargers to the
system according to water use records. Based on EPA data, and using the
population of the municipality for estimation, 347 SIUs would be expected.
The total water use in the municipality was 1,245,000 cubic metres per day
(329 USMGO) in 1986. The water use was 33% residential, 27% industrial and
21% commercial.
The local limits in the appropriate municipal by-law for discharge to the
treatment plants are as follows:
Parameter Limit (mq/L)
BOD 500
TSS 600
Oil & Grease (A&V) 150
Cadmium (T) 2
Chromium (T) 5
Copper (T) 5
Nickel (T) 5
Zinc (T) 5
Mercury (T) 0.1
Phenols (T) 1
Cyanide (T) 2
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; compliance programs for noncomplying
users; sampling and analysis specifications; the reporting of spills; sampling
manhole specifications; and offences. The municipality was also developed and
implemented a sampling and enforcement strategy.
In 1986, the municipality collected 2,759 samples from 306 lUs. The users
have been grouped by the municipality into a number of classes according to
the potential impact of the waste to the treatment system. These classes
include: 126 high potential industries; 188 medium potential industries; 252
low potential industries and 88 surcharged industries. The city initiated 82
enforcement actions against IDs, the majority being prosecutions. There were
18 specific compliance programs implemented.
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City of Toronto - cont'd.
Page 2
The municipality spent $732,200 In 1986 on their sewer use control program
and utilized 29.5 person years. The industrial effluent samples were analyzed
for conventionals and metals in the municipality's labs.
Program Effectiveness
Legal Authority: The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer use
by-law. The city should alter its agreement with the adjacent municipality to
Include provisions for controlling the industrial dischargers to the sewers.
Ap.p.l 1 cat ion of Standards: Good. The municipality should upgrade its sewer
use by-law to include provisions for an industrial waste survey. The program
possibly could be Improved by carrying out a local limits development program.
Compliance Monitoring: The municipality has a well established compliance
sampling program.
Enforcemen.tl The municipality has an excellent enforcement program, with
written procedures, and effectively utilizes compliance programs and
prosecutions to bring about compliance.
P_ata_Managemenii Adequate. The municipality should develop a computer based
system to maintain the data generated by the industrial waste survey and
sampling, inspection and enforcement programs.
Rejourcesj. Resources adequate to meet the objectives of the program have been
provided.
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CITY: REGIONAL MUNICIPALITY OF WATERLOO
Program Description and Implementation
The Regional Municipality of Waterloo passed their local municipal sewer
use by-law 1n 1987. The OMOE operates the 11 waste treatment facilities under
an operating agreement for the municipality. The total combined flow of 11
treatment facilities is 163,000 cubic metres per day (43 USMGD). All
treatment facilities have Certificates of Approval with limits for BOD, total
suspended solids and total phosphorus. Two treatment facilities also have
requirements for ammonia and one also has a requirement for phenolics. The
effluents from the facilities complied with all ministry requirements. All
facilities utilized application on agricultural land for sludge disposal. The
municipality is not operating under any control order pertaining to its
treatment plant operations.
All IDs discharging to the collection system are located within the
jurisdictional boundaries of the regional municipality. The municipality has
677 potential dischargers to the system according to water use records. Based
on EPA data, and using the population of the municipality for estimation, 109
SIUs would be expected. The total water use in the municipality was 129,700
cubic metres per day in 1986. The water use was 36% residential, 31%
industrial and 18% commercial.
The local limits in the by-law are as follows:
Parameter
BOD
TSS
Oil & Grease
Oil & Grease
Cadmium (T)
Chromium (T)
Copper (T)
Nickel (T)
Zinc (T)
Mercury (T)
Phenols (T)
Cyanide (T)
(A&V)
(S&M)
Limit (mg/L)
300
350
100
15
0.5
5
5
5
5
0.1
1
2
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; sampling and analysis specifications;
sampling manhole specifications and offences. The municipality has also
developed and implemented an excellent sampling and inspection program.
In 1986, the regional municipality collected 2,768 samples from 203 Ills.
The lUs have been grouped by the municipality into a number of classes. These
classes include: 35 users who discharge toxics; 40 users with surcharge
agreements; 69 general users; 42 users with a discharge to a storrn sewer; and
20 miscellaneous dischargers. Sixty of the lUs were inspected. The regional
municipality has developed and issued a standard enforcement strategy which
ensures that similar violations are addressed in a similar fashion. The
municipality initiated 131 enforcement actions against IDs, the majority being
written warnings. There were two prosecutions and 13 compliance programs were
established.
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Regional Municipality of Waterloo - cont'd.
Page 2
The municipality spent $411,800 in 1986 on their sewer use control program
and utilized 11.1 person years. The samples were analyzed for conventionals
and metals in the municipal lab.
Program Effectiveness
LejjaLAuthoritXL The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer use
by-law. The municipality should upgrade their sewer use by-law by including
provisions for industrial waste surveys, compliance programs and spills
control.
Application of Standards: The municipality should review their local limits
by carrying out a local limits development program.
Compliance Monitoring: The regional municipality has an adequate compliance
monitoring program.
Enforcement: The regional municipality has an adequate enforcement program.
Datal1anage_mejlt.;L The regional municipality should develop a computer based
system for the data developed by its industrial waste survey and sampling,
inspection and enforcement programs.
Resources: An adequate level of resources has been provided to meet the
objectives of the program.
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CITY: CITY OF WINDSOR
Program Description and Implementation
The City of Windsor passed their local municipal sewer use by-law In 1985
and operates two waste treatment facilities with a total combined flow of
156,000 cubic metres per day (41 USMGD). The facilities receive waste from a
number of adjacent towns and townships. There are no operating agreements
with these municipalities and the industrial wastes discharged in these
adjacent municipalities are not regulated. The treatment facilities have
Certificates of Approval with limits. The sludge from the facilities is
utilized on agricultural land or composted and applied on agricultural lands.
The municipality is not operating under any control order pertaining to its
treatment plant operations.
Most of the Ills discharging to the collection system are located within
the jurisdictional boundaries of the municipality. The municipality has 233
potential dischargers to the system according to water use records. Based on
EPA data, and using the population of the municipality for estimation, 70 SIUs
would be expected. The total water use in the municipality was 143,000 cubic
metres per day (38 USMGD) in 1986. The water use was 39% residential, 44%
industrial and 13% commercial.
The local limits in the by-law are as follows:
Parameter
BOD
TSS
Oil & Grease
Oil & Grease
Cadmium (T)
Chromium (T)
Copper (T)
Nickel (T)
Zinc (T)
Mercury (T)
Phenols (T)
Cyanide (T)
(A&V)
(S&M)
Limit (ma/I)
500
600
150
15
2
5
5
5
5
0.1
1
2
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; sampling and analysis specifications;
sampling manhole specifications and offences. The municipality has also
developed and implemented a sampling strategy.
In 1986, the municipality collected 242 samples from 95 lUs. Industrial
waste surveys were carried out at many of the industries; however, water use
information was not collected. The users have been grouped by the
municipality into a number of manufacturing classes. These classes include:
food and beverage producers; chemical products; electroplaters; metal
finishers and general manufacturers. Seventeen industries have surcharge
agreements. The city initiated 55 enforcement actions against IDs, the
majority being verbal or written warnings. There was one compliance program
issued and one prosecution.
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City of Windsor - cont'd.
Page 2
The municipality spent $233,000 in 1986 on their sewer use control program
and utilized 3.5 person years. The samples were analyzed for conventionals
and metals in the municipality's labs.
Program Effectiveness
Legal Authority: The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer by-law.
The municipality should develop agreements with the adjacent municipalities
discharging sewage to their systems. These agreements should contain
provisions for control of the industrial discharges in the adjacent
municipalities. The municipality should upgrade its sewer use by-law by
including provisions for industrial waste surveys, spills control and
compliance programs.
Application of Standards: Adequate. The municipality should review their
local limits by carrying out a local limit development program.
Compliance Monitoring: The municipality has a good compliance monitoring
program.
Enforcement: Adequate.
PatjLManageme_nt_L The data management system provides good documentation of
the program activities.
Resources: Adequate
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CITY: CITY OF BARRIE
Program Description and Implementation
The City of Barrie passed their local municipal sewer use by-law in 1970
and operates a waste treatment facility with a total flow of 26,800 cubic
metres per day (7.08 USMGD). The treatment facility has a Certificate of
Approval with limits of 0.3 mg/L for total phosphorus and 10 mg/L for BOD.
The effluent from the facility complied with ministry requirements. The
sludge from the facility is utilized on agricultural lands. The municipality
is not operating under any control order pertaining to its treatment plant
operations.
All lUs discharging to the collection system are located within the
jurisdictional boundaries of the municipality. The municipality has 91
potential dischargers to the system according to water use records. Based on
EPA data, and using the population of the municipality for estimation, 22 SIUs
would be expected. The total water use in the municipality was 26,300 cubic
metres per day (7.0 USMGD) 1n 1986. The water use was 40% residential and 60%
industrial and commercial.
The local limits in the by-law are as follows:
Parameter
BOD
TSS
Oil & Grease (A&V)
Oil & Grease (S&M)
Cadmium (T)
Chromium (T)
Copper (T)
Nickel (T)
Zinc (T)
Phenols (T)
Cyanide (T)
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; sampling and analysis specifications;
sampling manhole specifications and offences. The municipality has also
developed and implemented a sampling strategy.
In 1986, the municipality collected 239 samples from 21 lUs. Thirty-five
lUs were inspected and industrial waste surveys have been carried out at most
of the IDs. The users have been grouped by the municipality into a number of
classes. These classes include: metal finishing; food processing; surcharged
industries and dischargers of cooling water. One IU has a surcharge
agreement. No enforcement actions were Initiated against IDs.
The municipality spent $105,000 in 1986 on their sewer use control program
and utilized 2.8 person years. The industrial effluent samples were analyzed
for conventionals and metals in the municipality's lab.
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City of Barrie - cont'd.
Page 2
Program Effectiveness
Leaa_LAuthority.:. The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer use
by-law. The sewer use by-law should be upgraded to include requirements for
industrial waste surveys, spills control and compliance programs.
Application of Standards: Adequate.
Compliance Monitoring: The municipality has an adequate compliance sampling
program.
Enforcement: Adequate.
Data Management: Adequate.
Resources: Good.
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CITY: CITY OF BRANTFORD
Program Description and Implementation
The City of Brantford passed their local municipal sewer use by-law in
1982. The OMOE operates two waste treatment facilities for the city with a
total combined flow of 52,100 cubic metres per day (13.8 USMGD). The city
operates one facility which discharges to a tile field. The operating
agreement between the city and the ministry requires the city to pass and
enforce by-laws controlling industrial discharges to the sewers. The
treatment facilities have Certificates of Approval without parameters or
limits. The effluents from the facilities comply with OMOE Policy 08-01,
except for total phosphorus at the small lagoon. Approximately one-third of
the sludge produced is utilized on agricultural lands. The municipality is
not operating under any control order pertaining to its treatment plant
operations.
All IDs discharging to the collection system are located within the
jurisd1ct1onal boundaries of the municipality. The municipality has 195
potential dischargers to the system according to water use records. Based on
EPA data, and using the population of the municipality for estimation, 31 SIUs
would be expected. The total water use in the municipality was 45,800 cubic
metres per day (12.1 USMGD) In 1986. The water use was 38% residential and
54% industrial and commercial.
The local limits in the by-law are as follows:
Parameter Limit (mg/L)
BOD 300
TSS 300
Oil & Grease (A&V) 100
Oil & Grease (S&M) 15
Cadmium (T) 2
Chromium (T) 5
Copper (T) 5
Nickel (T) 5
Zinc (T) 5
Mercury (T) 0.1
Phenols (T) 1
Cyanide (T) 2
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; compliance programs for noncomplying
users; sampling and analysis specifications; sampling manhole specifications
and offences. The municipality has also developed and implemented a sampling
and inspection program.
In 1986, the municipality collected 250 samples from 30 lUs. Fifty
inspections of IDs were carried out. The users have been grouped by the
municipality into two classes; surcharged industries and non-surcharged
industries. There are 13 industries In the surcharge group. The city
initiated 18 enforcement actions against Ills, the majority being verbal or
written warnings. Six compliance programs were also issued.
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City of Brantford - cont'd.
Page 2
The municipality spent $136,500 in 1986 on their sewer use control program
and utilized 2.4 person years. The industrial effluent samples were analyzed
for conventional and heavy metals in the municipality's labs.
Program Effectiveness
LejLa.LAuthojjtyj. The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer use
by-law. The municipality should update its by-law by including the
requirement for Industrial waste surveys and spills control.
Application of Standards; Inadequate. There 1s an unacceptable number of
uncatalogued industries. The municipality should conduct an industrial waste
survey; sample those industries discharging metals and conventional at levels
which are potentially harmful; then conduct a local limits study to determine
whether the limits in the by-law should be lowered to the levels in the 1988
Model By-Law.
Compliance Monitoring: Inadequate. The municipality only samples surcharged
industries.
Enforcement! To date, the municipality appears to be reluctant to sample and
enforce the sewer use by-law requirements.
Data Management: The municipality provides adequate documentation of program
activities.
Resources: Adequate.
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CITY: CITY OF BROCKVILLE
Program Description and Implementation
The City of Brockville passed their local municipal sewer use by-law In
1983 and operate a primary waste treatment facility with a total flow of
17,000 cubic metres per day (4.5 USMGD). The treatment facility has a
Certificate of Approval, however there are no parameters with limits 1n the
certificate. The facility did not meet the requirements for suspended solids
and total phosphorus 1n Policy 08-01. The sludge from the facility 1s
disposed of In a landfill site. The municipality 1s not operating under any
control order pertaining to Its treatment plant operations.
The municipality also accepts waste from the Township of ElIzabethtown and
has an agreement with the township for controlling the Industrial discharges
in the township. The municipality has 48 potential dischargers to the system
according to water use records. Based on EPA data, and using the population
of the municipality for estimation, 12 SIUs would be expected. The total
water use in the municipality was 15,200 cubic metres per day (4.0 USMGD) in
1986. The water use was 45% residential; 37% industrial and 11% commercial.
The local limits in the by-law are as follows:
Parameter Limit (mg/L)
BOD 350
TSS 350
Oil & Grease (A&V) 100
Oil & Grease (S&M) 15
Cadmium (T) 2
Chromium (T) 3
Copper (T) 3
Nickel (T) 3
Zinc (T) 3
Mercury (T) 0.1
Phenols (T) 1
Cyanide (T) 2
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; sampling and analysis specifications;
sampling manhole specifications; and offences. All Ills with an MOE waste
generator number were surveyed. The municipality has also developed and
implemented a sampling and Inspection strategy. The maximum fine for
noncompllance is $2,000.00.
In 1986, the municipality collected 52 samples from five lUs and inspected
two of the lUs. There were no Ills with surcharge agreements. The city
initiated one verbal compliance program against an IU.
The municipality spent $17,000 in 1986 on their sewer use control program
and utilized 0.4 person years. The industrial effluent samples were analyzed
for conventionals and metals 1n the municipality's lab. No samples were
analyzed for organlcs.
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City of
Page 2
Brockvll1e - cont'd.
Program Effectiveness
keaaJ.J\uthorltyi The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer use
by-law. The municipality has an agreement with Elizabethtown which requires
the township to pass a sewer use by-law and allow the city to sample the
industrial dischargers. The township has not passed a sewer use by-law and
the city has not done any sampling in the township. The municipality should
upgrade its sewer use by-law by including provisions for industrial waste
surveys, spills control and compliance programs.
Application of Standards: The by-law standards have been properly applied.
Compliance Monitoring: Inadequate. The municipality should conduct an
industrial waste survey and sample those industries discharging metals and
conventionals at levels which are potentially harmful.
Enforcement^ Inadequate.
take enforcement actions.
enforcement strategy.
To date, the municipality has been reluctant to
The program would be improved by the adoption of an
Data Management: Adequate.
Resources: Inadequate. The staff complement should be increased.
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CITY: JOHN OF CQBOURG
Program Description and Implementation
The Town of Cobourg passed their local municipal sewer use by-law in 1969
and operate two waste treatment facilities with a total combined flow of
13,000 cubic metres per day (3.4 USMGD). The treatment facilities have
Certificates of Approval without limits. The effluent from the facilities did
not comply with the total phosphorus requirements of OMOE Policy 08-01. The
sludge from the facilities is utilized on agricultural lands. The
municipality is not operating under any control order pertaining to its
treatment plant operations.
All IDs discharging to the collection system are located within the
jurisdictional boundaries of the municipality. The municipality has 47
potential dischargers to the system according to water use records. Based on
EPA data, and using the population of the municipality for estimation, nine
SIUs would be expected. The total water use 1n the municipality was 11,200
cubic metres per day (2.95 USMGD) in 1986. The water use was 48% residential
and commercial and 52% industrial.
The local limits in the by-law are as follows:
Parameter Limit (mg/L)
BOD 350
TSS 350
Oil & Grease (A&V) 150
Oil & Grease (S&M) 15
Cadmium (T) 6
Chromium (T) 6
Copper (T) 5
Nickel (T) 6
Zinc (T) 6
Phenols (T) 0.5
Cyanide (T) 3
The sewer use by-law also contains the following provisions: surcharge
agreements for conventional parameters; sampling and analysis specifications;
sampling manhole specifications; and offences. The municipality has also
developed and implemented a sampling and inspection program.
In 1986, the municipality collected 1,360 samples from 10 Ills. Twenty
industries were inspected and Industrial waste surveys were also carried out
at these industries. The users have been grouped by the municipality into a
number of classes, based on the nature of the waste discharged. One IU had a
surcharge agreement. The town initiated 29 enforcement actions against IDs,
the majority being verbal warnings. Three program approvals were Issued.
The municipality spent $32,000 in 1986 on their sewer use control program
and utilized 0.85 person years. The Industrial effluent samples were analyzed
for conventionals in the municipality's lab and the metals analysis was
contracted out.
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Town of Cobourg - cont'd.
Page 2
Program Effectiveness
Legal Authority: The municipality has adequate authority under Section 147
Paragraph 210 of the Municipal Act to implement and enforce a sewer use
by-law. The municipality should upgrade their by-law by including provisions
for industrial waste surveys, spills control and compliance programs.
Application of Standards: Adequate. The municipality should conduct a local
limits study to determine whether the metals limits in the by-law should be
lowered to levels in the 1988 Model Sewer Use By-Law.
Compliance Monitoring: Adequate.
Enforcement: Adequate.
Data Management: Adequate.
Re_sojjrce_s_l Inadequate. Additional resources should be made available.
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APPROVED BY I,
1987.04.10
MUNICIPAL PRETREATMENT TASK FORCE
oLthe
POINT SOURCE COORDINATORS
Mr. David Hay (Canadian Chairman)
c/o Urban Activities Division
Industrial Programs Branch
Conservation and Protection Service
Environment Canada
Place Vincent Massey
Ottawa, Ontario K1A 1C8
(613) 953-1109
Mr. Jim Smith
Program Coordination
Ontario Region
Conservation and Protection
Environment Canada
25 St. Clair Avenue East, 7th Floor
Toronto, Ontario M4T 1M2
(416) 973-5872
Mr. Jim F. Janse, Manager
Technical Support
Southwestern Region
Ontario Ministry of the Environment
985 Adelaide Street South
London, Ontario N6E 1V3
(519) 661-2200
Mr. Michael G. Thome, P. Eng.
Director
Water Pollution Control
Metropolitan Works Department
The Municipality of Metropolitan
Toronto
439 University Avenue
Toronto, Ontario M5G 1Y8
Dr. Brian Led air
Co-ordinator Sewer Use Control
MISA-Municipal
Water Resources Branch
Ontario Ministry of the Environment
1 St. Clair Avenue West
Toronto, Ontario M4V 1P5
(416) 323-4985
Mail ing Address
135 St. Clair Avenue West
Toronto, Ontario M4V 1P5
01/89
Mr. Dave Rankin (U.S. Chairman)
Pretreatment Program Coordinator
Water Division
5WQP-8
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
(312) 886-6111
Mr. Robert Townsend
Bureau of Wastewater Facility
Operations
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-3790
Alternate
Mr. Robert R. Cronin, P.E.
Chief
Compliance Section, BWFO
Division of Water
New York State Department of
Environmental Conservation
Albany, New York 12233
(518) 457-
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MUNICIPAL PRETREATMENT TASK FORCE - cont'd.
CORRESPONDENTS
Mr. Robert Babcock
Surface Water Quality Division
Michigan Department of Natural
Resources
301 East Louis Click Hwy., 4th Floor
Jackson, Michigan 49201
(517) 788-9598
Mr. Philip G. Preston
Technical Support Branch
Office of Water Management
Indiana Department of Environmental
Management
105 South Meridian Street
Indianapolis, Indiana 46255
(317) 232-8728
Mr. John H. Albrecht
Division of Water Pollution Control
Public Wastewater Section
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Dr.
Columbus, Ohio 43266-0149
(614) 644-2028
Mr. R. Dunnette
Pretreatment Co-ordinator
Regulatory Compliance Section
Water Quality Division
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, Minnesota 55155
(612) 296-8006
Mr. Jim Weber
Manager, Industrial Waste Section
N.E. Ohio Region Sewer District
3090 Broadway
Cleveland, Ohio 44115
(216) 641-6000
Mr. Stan Klelnart, Chief
Pretreatment and Permit Section
Bureau of Wastewater Management
Wisconsin Department of Natural
Resources
P.O. Box 7921
Madison, Wisconsin 53707
(608) 266-3910
Secretariat Responsibilities
John F. McDonald
Great Lakes Regional Office
International Joint Commission
100 Ouellette Avenue, 8th Floor
Windsor, Ontario N9A 6T3
(519) 256-7821 Windsor
(313) 226-2170 Detroit
FTS: 226-2170
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