United States
Environmental Protection
Agency
TECHNOLOGY TRANSFER
Environmental
Regulations and
Technology
The National
Pretreatment Program
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EPA/625/10-86/005
Environmental
Regulations and
Technology
The National
Pretreatment Program
July 1986
Office of Water Enforcement and Permits
Office of Water
U.S. Environmental Protection Agency
Washington, DC 20460
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This document was prepared by David Meyers, Deborah French,
Frank Lowenstem. Jan Connery, and Brana Lobel of Eastern
Research Group, Inc , Arlington, Massachusetts, and was illus
trated by Rob Saunders and Dianne McCaffery
Technical review of the document was provided by Robert
Eagen lEPA Office of Water Enforcement and Permits), Orville
Macomber (EPA Center for Environmental Research Informa
tionl, Keith Silva (EPA Region IX), Gerald Potamis (EPA
Region I), Robert Robichaud (EPA Region X) and Alice Hastings,
Ann Maloy, Janice Wenning, and Jeffrey Lape of SAIC, McLean,
Virginia The document has been reviewed by the U.S. Environ
mental Protection Agency and approved for publication
This (jui(t.)'U c w,is published by
U S Environment.)1 Protection Agency
Cente' for Environmental Resedri h Information
Offu e of ReseHri h PrjxjM"' Mjnjgeme.nt
Offn e of Resejn h .jruj Development
CIFH inn,Hi OH 45268
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Contents
1. Introduction: What Is Pretreatment? 1
2. The Need for Pretreatment 3
Problems of Industrial Discharges into Sewage
Systems 3
"Pass Through" of Toxic Pollutants 4
Interference with POTW Operations 5
Sludge Contamination 6
Corrosion 7
Explosions 8
Worker Hazards 9
3. Overview of the National Pretreatment Program 10
National Standards 10
Local Programs 10
Delegation to the Local Level 10
Approval of Pretreatment Programs 11
Industry s Role and Responsibilities 14
4. National Pretreatment Standards 15
Rationale for National Standards 15
Prohibited Discharge Standards 15
Categorical Pretreatment Standards 15
5. Local Pretreatment Programs 20
Program Components 20
POTW Pretreatment Program Building Blocks 20
Effluent Limits 21
Implementation Activities 21
Information Handling and Public Access 22
6. The Future of the Pretreatment Program 24
The Pretreatment Program Today 24
Future Issues 24
Looking Ahead 26
7. References 27
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1. Introduction: What Is Pretreatment?
Beneath the streets of every city and many smaller communi-
ties, a system of sewers and pumps conveys wastewater away
from homes, factories, offices, and stores. This disposed water,
which may contain a variety of domestic, commercial, and
industrial wastes, flows through the sewers to a wastewater
treatment plant. There, pollutants are removed and the cleansed
water is discharged into an adjacent water body, such as a
river, bay. lake, or ocean. The residues of the treatment process
(sludges) are either used productively as a soil conditioner or
disposed of as a solid waste.
Industrial plants are only one of many sources of wastewater
discharged into municipal sewers. But the wastewater dis-
charged by industry is often contaminated by a variety of toxic
or otherwise harmful substances not common to other
sources- the by-products of industrial processes such as
cyanide from electroplating shops and lead from the manufac-
ture of batteries. These wastes can pose serious hazards.
Because sewage collection and treatment systems have not
been designed to treat them, industrial wastes can damage the
sewers and interfere with the operation of treatment plants;
Figure 1. Wastewater Collection and Treatment. Industry, households and commercial establishments discharge wastewater into a
system of drains, pipes, and pumping stations (a sewage collection system) that channel the flow to the sewage treat-
ment plant. At the plant, the wastewaters are treated and discharged into surface waters. Solids removed from the
wastewater during treatment are either disposed of or used productively.
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INTRODUCTION WHAT IS PRETREATMENT?
Sewage Treatment plant serving the city of Phoenix, Arizona.
pass through the systems untreated, resulting in contamination
of nearby water bodies and Increase the cost and environ-
mental risks of sludge treatment and disposal.
The undesirable effects resulting from the discharge of indus-
trial wastewater into municipal sewers can be prevented. Indus-
trial plants using proven pollution control technologies, can
remove pollutants from their wastewaters before discharging
them Into the municipal sewage treatment system. This prac-
tice is known as "pretreatment."
Industry is already pretreating its wastewater in many commu-
nities. The National Pretreatment Program, a cooperative effort
of federal, state, and local officials, is implementing this prac-
tice on a nationwide basis. By reducing the level of pollutants
discharged by Industry into municipal sewage systems, the pro
gram ensures that industrial development vital to the economic
well being of a community will be compatible with a healthy
environment. This document explains the need for the National
Pretreatment Program; describes federal, state, and local roles
in the program's implementation; and explores the program's
future.
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2. The Need for Pretreatment
Problems of Industrial Discharges into
Sewage Systems
Pretreatment programs are implemented by the municipal
authorities operating the sewage collection systems and
sewage treatment plants, commonly referred to as publicly-
owned treatment works or POTWs. These programs are needed
to eliminate several serious problems that can occur when
industrial wastewaters are discharged into sewage systems
(Figure 2):
* Toxic industrial pollutants may pass through the treatment
plant, polluting a receiving water body and posing a threat
to aquatic life, and, through the food chain, to human
health.
Toxic industrial wastes may interfere with the operation of
the treatment plant, rendering treatment of other wastes
less effective.
Industrial wastes containing high levels of toxic metal or
organic compounds can contaminate sludge, making dis-
posal options more expensive and more limited.
Industrial wastewater can corrode the pipes and equipment
in the sewage collection system and the treatment plant.
Highly volatile wastes can explode, causing considerable
damage.
Some wastes may interact to produce toxic gases which
pose health hazards to workers in the sewers and the treat-
ment plant.
Figure 2. Problems that May Occur When Industrial Wastewaters are Discharged into Sewage Treatment Systems. All these prob-
lems can be controlled through pretreatment.
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THE NEED FOR PRETREATMENT
As the following discussions illustrate, a number of communi-
ties have already experienced dramatic improvements in
environmental quality by aggressively implementing pretreat-
ment programs.
"Pass-Through" of Toxic Pollutants
Sewage treatment facilities generally are not designed to
remove toxic industrial pollutants (Figure 3) and these
contaminants may therefore pass partially treated into the
receiving waters. This phenomenon, commonly referred to as
"pass through," is a major source of pollution and a national
environmental problem. Toxic industrial compounds can cause
fish kills, increase the risk of cancer in humans, and bring about
a variety of other health and environmental effects. In addition,
they may render receiving waters unsuitable for recreation and
for use as water supplies.
An estimated 37 percent of the toxic industrial compounds
entering the surface waters of the United States do so by pass-
ing through sewage treatment facilities unaltered (Figure 4).
These compounds may contain either heavy metals or toxic
organic substances. The U.S. Environmental Protection Agency
(EPA) estimates that 56 million pounds (25 million kg) of toxic
metal compounds are discharged annually by industry into
municipal sewage systems, and an estimated 22 million pounds
(10 million kg) of these metal compounds pass through
unaffected by treatment. When toxic organic compounds are
included, the total amount of toxic industrial compounds pass-
ing through sewage treatment systems unaffected approaches
100 million pounds 145 million kg) per year (1).
Pretreatment programs will dramatically reduce the quantity of
toxic pollutants reaching surface waters. A recent EPA study
estimated that full enforcement of the standards contained in
the National Pretreatment Program would cut industrial dis-
Figure 3. Conventional and Toxic Pollutants
Conventional pollutants and toxic pollutants describe two broad categories of contaminants in wastewaters. Conventional pollu-
tants are contained in the sanitary wastes of households, commercial establishments, and industry, and include sand, leaves,
bits of trash, ground up food from sink disposals, laundry and bath waters, and human wastes. If these pollutants were dis-
charged directly to surface waters, the waters would rapidly become open odiferous cesspools, spreading disease and destroy-
ing aquatic life. Most POTWs have, therefore, been designed to remove conventional pollutants. The Clean Water Act defines
five broad categories of conventional pollutants:
1. Biochemical Oxygen Demand (BOD) - This pollutant category measures the tendency of wastewaters to use oxygen in
the receiving waters (i.e., the surface water bodies into which the wastewaters are discharged). Oxygen is consumed
when organisms in the receiving waters metabolize the organic material in the wastewater. If loo much oxygen is con-
sumed, fish or other aquatic life in the receiving waters might be endangered. Thus, POTW treatment systems are
designed to reduce the BOD of the wastewater.
2. Suspended Solids- This parameter is a measure of the concentration of solid particles that are suspended in the
wastewater.
3. Fecal Coliform - Fecal coliform bacteria are found in the digestive tract of humans and animals. Their presence in water
indicates the potential presence of harmful organisms that can thrive in the human digestive system, such as dysentery
protozoa, typhus bacteria, and other pathogenic (i.e., disease-causing) microorganisms. Fecal coliform bacteria are used
as a measure of health risk since they are more easily detected than the pathogens.
4. pH - pH is a measure of the acidicity or alkalinity of wastewater. pH is measured on a scale of 1 to 14, 1 being extremely
acidic, 7 neutral, and 14 extremely alkaline. Most healthy surface waters have a nearly neutral pH; i.e., they are neither
strongly acidic nor alkaline. Many aquatic species will not thrive or may die if the pH of their habitat changes even
slightly. Thus it iS important to neutralize wastewater prior to discharge.
5. Oil and Grease - These pollutants interfere with POTW treatment processes, impair the use of sludge as a soil conditioner,
and degrade receiving water quality when present in excessive amounts.
Toxic pollutants are those pollutants that are harmful to one or more forms of animal or plant life. They are primarily grouped
into organics and metals.
1. Organic Pollutants - These pollutants include pesticides, solvents, PCBs, and dloxins. Some of these compounds are lethal
to animal life in the range of 1 part contaminant to 1 million parts water.
2. Metals - The metals of concern are known as the "heavy" metals and include lead, silver, mercury, copper, chromium,
zinc, and cadmium. Most heavy metals are not immediately lethal; however, they can accumulate in vital organs of
animals, including humans, causing health problems. Asbestos and cyanide are two other non-organic toxic pollutants
frequently found in industrial wastewater.
Removal of toxic pollutants by industrial pretreatment is critical, since most POTW treatment processes were not designed to
control these pollutants, and since toxic pollutants may destroy the bacteria that are necessary for wastewater treatment.
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THE NEED FOR PRETREATMENT
4?y
;>'
Figure 4. How Toxic Industrial Effluents Reach Surface Waters.
charges of toxic metal compounds into sewage systems by
84 percent from 56 million to 9 million pounds (4 million kilo
gramsl per year (2). This would reduce the annual quantity of
metals passing through the nation's sewage treatment plants
from 22 million to 4 million pounds 110 to 2 million kilograms)
a year
Pretreatment has already produced significant improvements in
environmental quality in a number of communities
Grand Rapids, Michigan The Grand Rapids POTW dis-
charges treated wastewater into the Grand River. The area
had experienced fish kills due to cyanide and heavy metals
in the wastewater in the early 1960s. Controls on industrial
discharges of cyanide and metals into the municipal sewer
system were instituted in 1969, and ten years later concen
trations of heavy metals had dropped approximately 87
percent in both incoming and treated wastewater Trout
and salmon had returned to the Grand River by 1974 (3).
Rockford, Illinois In 1974, Rockford instituted a pretreat
ment program limiting the discharge of cyanide and metals
into its sewer system. In 1976, the city also implemented a
program limiting discharges of other pollutants into the
sewer system and instituted a system of water usage fees
designed to encourage industrial water conservation. It
also imposed further pretreatment requirements in 1982 in
conjunction with its implementation of the National
Pretreatment Program. As a result of these programs, cad
mium, chromium, and zinc levels in treated wastewater
from the POTW decreased by more than 85 percent from
1973 to 1983 Toxic metal concentrations in the nearby
Rock River declined by almost 50 percent (4)
Interference with POTW Operations
A second problem is that toxic industrial compounds can inter
fere with POTW operations. Municipal wastewater treatment
systems (Figure 5) are designed to treat typical household
wastes and biodegradable commercial and industrial wastes.
Some industrial discharges, however, contain a variety of toxic
pollutants not envisioned when the system was designed.
While some of these pollutants pass through the treatment sys
tem without affecting operations, others may directly interfere
with POTW operations, particularly those processes that
employ bacteria to stabilize organic matter in the wastewater
The toxic effects of metals on bacteria can interfere with both
primary and secondary treatment systems In primary treatment
of wastewater, solids usually are removed by sedimentation
These solids are referred to as primary sludge Primary sludge is
often treated in digesters that utilize bacteria under anaerobic
conditions to render the sludge acceptable for disposal Toxic
metal compounds, particularly those containing chromium, can
destroy these bacteria or inhibit their reproduction, thereby dis
ruptmg the sludge treatment process and producing sludges
that cannot be disposed of without special treatment
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THE NEED FOR PRETREATMENT
4 ^/.s/i ladder on the Grand River in Mn hicjan f ish returned to
this river following implementation of an effective pretreatment
program
Bacteria are also used in secondary treatment of wastewater to
remove non toxic organic wastes. If toxic pollutants adversely
affect the bacteria at this stage, the secondary treatment SYS
tern will not remove pathogenic organisms or much of the
remaining organic material Failure of the secondary treatment
system can result in the discharge of partially treated waste
water into surface waters, resulting in sludge deposits and a
reduced oxygen level in these water bodies
Pretreatment programs have helped a number of communities
increase the effectiveness of their sewage treatment systems.
Toxic industfin/ (Jischnrqus can interfere with wa^tewater trea
merit t)y h< ' .
sions causing .is many as ten violations of the i 'ty s wa
fHi'i^ty peinut ir J sinc]le ve.ir SifH:e iniplenientiruj its
pretreatment program Broomflelc) has had '>P'\ o"e \mla
lion each year City of' < uils atl'ihute this (Ir.itnatu
improvemetit 1o the 'eclvji t on IP the (iiiant'U of t">'i "le
i ornpo'.jncls ir t'ie ,\ ast"-.\ .iter disc ha'i)'"i tiy 'n, ., '-il ,s
tries ' 5i
Sludge Contamination
While some toxic materials pass through the treatment plant
unaffected others are removed and remain in the numicipa'
wastewater s'udge The < oi'tanvnation of sludge |iy 'vgh 'eyfls
of toxic metal c ompoutids or toxic organic c ompounds from
mclustrial users niay preclude some use or disposa' methods I*
the sludge is destined for a landfill these pollutants may ieac h
out and contanvr'.ate ad|acent surface and ground waters
When incineration s used IOXK; pollutants may tie released to
the atmosphere Uncontaminated sludges or products derived
from them (such as compost i may be applied to agricultural
land as a fertilizer or a soil conditioner Such beneficial use
eliminates the need for disposal of the sludge as .1 'waste
However, contaminated sludges are generally not suitable for
such beneficial use. as the crops or pasture grasses produced
may not be safe for human or animal consumption Through
pretreatment many of these problems can be avoided
Milwaukee, Wisconsin The Milwaukee Metropolitan
Sewerage District (MMSDi sells its sludge as a product
called Milorgamte. which is used as a soil conditioner and
fertilizer. In 1979, MMSD noted an excessive level of cad
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THE NEED FOR PRETREATMENT
HI t,u",-?> N't
Figure 5. The Wastewater Treatment System at a POTW. On entering the sewage treatment plant, the wastewater is first
passed through a series of coarse screens IAI to remove leaves, rocks, sticks, and other large pieces of trash The sewage then
flows into a grit chamber (B) and a sedimentation tank (Cl where sand and suspended particles settle out. The remaining
wastewater still contains a high percentage of organic material, most of which is in soluble form. To remove this material, the
wastewater is treated in a large tank into which air is continually added and mixed (D). Here, aerobic bacteria remove much of
the remaining organic matter in the wastewater. After sedimentation (El, the wastewater is disinfected to destroy any remain
ing pathogenic bacteria, and then discharged to surface waters.
mium in its sludge, which threatened the continued market
ing and use of Milorganite The district adopted an
ordinance for the control of cadmium in 1980 From 1980
to 1984, cadmium levels in incoming wastewater declined
by 69 percent. The MMSD has recently instituted addi
tional controls on other toxic metal compounds. All these
measures will ensure the continued marketing and use of
Milorganite (6).
Hampton Roads Sanitation District, Virginia In the early
1970s, sewage sludge from the Hampton Roads Sanitation
District showed a high level of certain metals as a result of
industrial discharges. The district began its pretreatment
program in 1972 By 1985. sludge quality from eight of
nine treatment plants had improved sufficiently to allow
land application (7l.
Corrosion
Highly acidic industrial wastes can corrode piping and equip
ment in both the sewage collection system and the sewage
treatment plant, causing disruptions in service and leakage of
raw sewage, and the necessity for replacing sewer lines and
pumping stations in the system. Municipal pretreatment pro
grams place restrictions on the pH of industrial discharges,
greatly reducing the potential for corrosion.
Washington Suburban Sanitary Commission I WSSC/ The
WSSC, which has six treatment plants serving Prince
Georges and Montgomery Counties, Maryland, has
experienced numerous corrosion problems due to highly
acidic industrial discharges Several thousand feet of sewer
line have had to be replaced or repaired The WSSC devel
oped extensive pretreatment requirements in 1972 and
received federal approval of its program in 1983 The
pretreatment program has enabled the WSSC to identify
and control the sources of its corrosion problems (8)
Me/bourne, Florida The Municipal Sewer District of the
city of Melbourne, Florida, operates three sewage treat
ment plants that process a total of approximately 6 million
gallons (23 million liters) of wastewater per day The city
has experienced corrosion problems in its sewers At one
location a pumping station was destroyed by the discharge
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THE NEED FOR PRETREATMENT
Concrete sewer corroded by acidic industrial wastewaters
of extremely acidic industrial wastes. Since implementing a
pretreatment program, the district has effectively con
trolled the pH of industrial discharges and reduced the
potential for corrosion (91
Explosions
Some industrial wastes contain volatile compounds, which may
explode in the sewage treatment system, causing widespread
damage. In February 1981, a large accidental discharge of hex
ane into the Louisville, Kentucky, sewer system caused a major
explosion that destroyed more than 3 miles (4.8 kilometers) of
sewers and resulted in more than $20 million in damages
The Louisville and Jefferson Sewer District is now using its
pretreatment permit system to reduce the likelihood of future
explosions. Major industrial facilities with more than one drum
(55 gallonsl of hazardous material stored above ground must
-*'-
-V-.'- ' ?-' -^^^^V1Ž***.^'' '->''
;-
explosion in the Louisville sewers resulted in over $20 million in damages.
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THE NEED FOR PRETREATMENT
develop a plan to deal with accidental spills as a condition of
sewer use. The plan must include security procedures, training
of employees, a contingency plan for emergencies, admimstra
live procedures, and a spill history for the facility. Of the 130
ma|or industrial facilities that use the system, TOO have been
required to submit spill plans All plans must be approved by a
professional engineer
As a further precaution, the sewer district has expanded its
sampling and monitoring procedures Each day 30 locations
throughout the collection system are monitored for explosive
hazards and pH Sewage samples are also collected regularly.
Worker Hazards
The discharge of industrial wastes into sewers can also result in
the release of poisonous gases. This typically occurs when
highly acidic wastes combine with other wastes in the collec
lion system For example, wastes from electroplating often con
tain traces of cyanide If the sewage is acidic, a reaction
resulting in the formation of highly toxic hydrogen cyanide gas
may occur. Similarly, sulfides from leather tanning, in combina
tion with acidic sewage, can generate poisonous hydrogen
sulfide gas
Poisonous gas in the sewers is a serious health and safety haz
ard, particularly for municipal workers By controlling both the
pH of industrial discharges and the discharge of toxic sub
stances such as cyanide, pretreatment programs greatly reduce
such hazards
Chicago. Illinois In the early 1970s, highly acidic wastes
in the Chicago sewer system combined with sulfides dis
charged by leather tanneries to form hydrogen sulfide gas
The gas caused nausea and dizziness among POTW
workers and there was a risk of fatal exposures The
Metropolitan Sanitary District of Greater Chicago imple
merited both sulfide and pH controls to stop the formation
of hydrogen sulfide and other poisonous gases (10)
Nnw York. Ni'W York The New York City Department of
Environmental Protection operates 12 treatment plants
serving all the boroughs of New York City At one plant a
worker was overcome by fumes emanating from solvents
discharged by a nearby industrial laundry City officials
determined that these hazardous pollutants came from
rags saturated with industrial solvents The officials pro
hibited the facility from laundering rags contaminated b\
solvents, and thereby eliminated the hazard illi
A wall around nn industrial storage container provides an effec-
tive control measure that prevents any accidentally spilled
materials from entering the sewer
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3. Overview of the
National Treatment Program
Restrictions on the pollutant content of wastewaters dis-
charged by industry into municipal sewage systems have
existed in some localities for many years. The Milwaukee
Metropolitan Sewerage District, for example, has regulated pH,
oil and grease, and temperature levels in industrial wastewaters
since the 1920s (Figure 6). Such regulations are the predeces-
sors of modern pretreatment programs, which include both
national standards and local programs to control industrial
pollutants.
National Standards
The federal government's role in pretreatment began with the
passage of the Clean Water Act in 1972. The Act called for the
EPA to develop national pretreatment standards to control
industrial discharges into sewage systems. The standards are
uniform national requirements which restrict the level of certain
pollutants in the sewage from industries. All POTWs must
enforce the federal standards, The standards in effect today
consist of two sets of rules: "categorical pretreatment stan-
dards" and "prohibited discharge standards."
Categorical pretreatment standards are organized by type of
industry, and different requirements are mandated for each
specific industry. For example, there is a categorical standard
for the iron and steel industry which limits the concentration of
ammonia, cyanide, and other specific toxic pollutants that may
be present in the wastewater discharged into sewage systems
by any firm in that industry.
Prohibited discharge standards prohibit any discharge to sewer
systems of certain types of wastes from all sources. For exam-
ple, the release of any wastewaters with a pH lower than 5.0 is
forbidden, since such wastes may corrode the sewer system.
chapter 4 of this document describes the prohibited discharge
standards and the categorical pretreatment standards in detail.
Local Programs
The overall framework for the National Pretreatment Program is
contained in the General Pretreatment Regulations that EPA
published in 1978 and modified in 1981 (Figure 7). These regu-
lations require all large POTWs - those designed to accommo-
date flows of more than 5 million gallons (19 million liters) per
day - and smaller POTWs with significant industrial discharges
to establish local pretreatment programs. Approximately 1,500
POTWs are participating in the National Pretreatment Program
by developing local programs. The local programs, which are
described in detail in Chapter 5, must enforce all national
pretreatment standards. The local POTWs also may enforce
more stringent discharge requirements (i.e., local limits) to pre-
vent disruption of the sewage treatment system, adverse
environmental impacts, or disruption of sludge use or disposal.
Thus, the National Pretreatment Program consists of approxi-
mately 1,500 local programs designed to meet federal require-
ments and to accommodate unique local concerns.
RULES AND REGULATIONS
Applicable to the
MILWAUKEE METROPOLITAN
SEWERAGE DISTRICT
ADOPTED NOVEMBER 30, 1923
REVISED and AMENDED JULY 11, 1935
ADOPTED BY THE
SEWERAGE COMMISSION
OF THE
CITY OF MILWAUKEE
ON JULY 11, 1935
and the
METROPOLITAN SEWERAGE
COMMISSION
OF THE
COUNTY OF MILWAUKEE
ON JULY 18, 1935
EFFECTIVE AUGUST 1, 1935
MILWAUKEE, WISCONSIN
Figure 6. Early Milwaukee Pretreatment Regulations.
Delegation to Local Level
The decision to delegate enforcement authority for the pretreat-
ment program to the local level was based on several factors.
First, POTW officials are familiar with their industrial users.
They usually know the location, wastewater flow, and pollutant
loadings of the industries they serve. They may already have
mechanisms to regulate their industrial clients, such as permits
or contracts, These documents may contain agreements con-
cerning both the nature and volume of industrial discharges and
fees for the service. Thus, POTWs already have administrative
mechanisms and client relationships in place on which to base
enforcement of the pretreatment program.
10
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OVERVIEW OF THE NATIONAL PRETREATMENT PROGRAM
Figure 7. The General Pretreatment Regulations
The General Pretreatment Regulations define the National Pretreatment Program. These regulations are published in
Volume 40, Part 403 of the Code of Federal Regulations (40 CFR 403). This document is available in many libraries and
government offices. The General Pretreatment Regulations contained in 40 CFR 403 are divided into 16 subparts 403.1
through 403.16.
403.1 Purpose and Applicability
403.2 Objectives of General Pretreatment Regulations
403.3 Definitions
403.4 State or Local Law
403.5 National Pretreatment Standards: Prohibited Discharge
403.6 National Pretreatment Standards: Categorical Standards
403.7 Revision of Categorical Pretreatment Standards to Reflect POTW Removal of Pollutants
403.8 POTW Pretreatment Programs Development by POTW
403.9 POTW Pretreatment Programs and/or Authorization to Revise Pretreatment Standards: Submission for Approval
403.10 Development and Submission of NPDES State Pretreatment Programs
403.11 Approval Procedures for POTW Pretreatment Programs and POTW Revision of Categorical Pretreatment Standards
403.12 Reporting Requirements for POTWs and Industrial Users
403.13 Variances from Categorical Pretreatment Standards for Fundamentally Different Factors
403.14 Confidentiality
403.15 Net/Gross Calculation
403.16 Upset Provision
As of July 1986, the EPA was in the process of revising certain definitions and other technical components of the
regulations.
A second reason for delegating pretreatment authority to the
local level is that the POTWs are in the best position to under-
stand and to correct problems within their own treatment sys-
tems. Therefore, they can tailor discharge requirements in
pretreatment permits to preclude inference with their partic-
ular treatment system. The POTW is also in the best position to
understand other problems that must be considered in for-
mulating pretreatment permits, such as the hazard of explo-
sions or corrosion in the sewage system and the treatment
plant.
Finally, the POTW is the logical level of government to respond
to emergencies in the treatment system. The unexpected dis-
charge of pollutants by an industrial user could result in the dis-
charge of untreated wastes by the POTW itself, violating federal
standards and presenting an environmental hazard. In many
cases, the POTW can quickly pinpoint the cause of the problem
and take corrective action.
Although a strong case can be made for POTW control of
pretreatment programs, the states of Vermont, Connecticut,
and Mississippi have elected to direct the program at the state
level. Several other states, such as Nebraska and New Jersey,
delegate authority to some POTWs but retain authority in other
sewer districts. The reasons for this approach include the lack
of funding, technical resources, or administrative structure at
the POTW level or the preference by some states for centralized
control of environmental programs. In most states, however,
approved pretreatment programs are or will soon be
implemented by POTWs.
Approval of Pretreatment Programs
Federal, state, and local government agencies are all involved in
establishing pretreatment programs. In general, the federal
government requires that states develop pretreatment pro-
grams; the states, in turn, review, approve, and oversee the
programs of local POTWs. The specifics of pretreatment pro-
gram development and approval, however, vary from state to
state, depending on the status of the state's program to control
direct discharges - the National Pollutant Discharge Elimination
System (NPDES).
NPDES Programs
The National Pollutant Discharge Elimination System (NPDES)
regulates the direct discharge of wastewaters to surface waters
(Figure 8). Under this program, industrial facilities and POTWs
must receive an NPDES permit before discharging wastewater
directly to surface waters. The permits require compliance with
all federal standards and may also require additional controls
based on local conditions.
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OVERVIEW OF THE NATIONAL PRETREATMENT PROGRAM
t V ',,,, 4 v
f ' ' IS '
Figure 8. Direct and Indirect Industrial Dischargers. Industrial or municipal sewage treatment facilities that discharge their
wastewaters directly into rivers, streams, lakes, bays, estuaries, and oceans are referred to as direct dischargers. Indus
trial facilities that discharge their wastewaters into a municipal sewer system are referred to as indirect dischargers; it is
these indirect dischargers that the National Pretreatment Program aims to regulate
12
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OVERVIEW OF THE NATIONAL PRETREATMENT PROGRAM
Figure 9. Status of State NPDES and Pratreatment Program Dalagation (July 1986). Thirty-six states and one territory have
approved NPDES programs. Twenty-two states have approved pretreatment programs.
Because POTWs are direct dischargers, they must obtain and
comply with an NPDES permit. This permit limits the amount of
pollutants the sewage treatment plant may discharge. If the
concentration of pollutants is too high, or if its discharges
endanger public health or the environment, it violates its permit
and can be fined and/or forced to upgrade its operation.
A POTW may have trouble meeting its NPDES permit conditions
if the concentration of toxics in the wastewater flowing into the
treatment plant (the influent wastewater) is too high. One way
to control the concentration of toxics in the influent waste-
water is to require pretreatment. Thus, the conditions of a
POTW's discharge permit might dictate the need for pretreat
ment. Since the implementation of the National Pretreatment
13
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OVERVIEW OF THE NATIONAL PRETREATMENT PROGRAM
Program in 1981, a pretreatment program is, in fact, required of
many POTWs for permit renewal.
The authority to issue NPDES permits in a given state rests
either with the state's environmental agency or with the
U.S. EPA. States can gain approval to administer the NPDES
program by demonstrating that their state program meets all
federal requirements. To date, 36 states and 1 territory have
been given NPDES authority (Figure 9). These states are com-
monly referred to as NPDES states. In NPDES states, permits
for direct discharge are issued by the state; in non-NPDES
states, permits for direct discharge are issued by the EPA
regional office.
Pretreatment Programs
States that have NPDES authority are required to develop
pretreatment programs for EPA approval (40 CFR 403.10).
States are granted pretreatment authority by the EPA if they
show that their program meets all federal requirements. States
with pretreatment authority are referred to as pretreatment-
delegated states. To date, 22 states have been given approval to
operate pretreatment programs (Figure 9). In these states,
implementation of the National Pretreatment Program is the
responsibility of the state; in the remaining states, the EPA
implements the National Pretreatment Program.
The POTWs develop local pretreatment programs which are
approved either by the state (in pretreatment-delegated states)
or by the EPA. Once a program is approved, the state or the
EPA conducts periodic checks to ensure that the program is
operating properly. As noted above, a small number of states
retain authority for all aspects of pretreatment programs and,
therefore, do not delegate any authority to the POTW.
If a POTW does not have an approved pretreatment program,
national pretreatment standards and requirements are enforced
by the EPA (in nonpretreatment-delegated states) or the state
(in pretreatment delegated states). Thus, pretreatment regula-
tions may be enforced by either the EPA, the state, or the
POTW, depending upon the status of program approvals for a
given community
Industry's Role and Responsibilities
As the generator of toxic pollutants, industry is responsible for
the removal of contaminants present in quantities that might
cause problems in the collection system, the treatment plant,
or the outside environment. Industry must finance, construct,
and operate any pollution control equipment or facilities neces-
sary to comply with pollutant discharge limits required under
federal pretreatment regulations or local pollution control rules.
Compliance by industry ensures that industrial toxic pollutants
will not damage human health or the environment.
14
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4. National Pretreatment Standards
The federal government has developed national regulations or
"standards" that restrict the quantity of toxic Industrial pollu-
tants discharged into sewage systems. Individual POTWs can
impose limitations stricter than the national standards, but can-
not allow less stringent levels of control except under certain
special circumstances.
Rationale for National Standards
Although POTWs have the legal authority to develop discharge
limitations for their industrial users, there are several reasons
for having national standards. First, there are many long-term
health and environmental impacts of industrial pollutants that
are not Immediately apparent to local communities. Because of
these potential long term Impacts, Congress required in the
Clean Water Act that national effluent standards for Industrial
facilities be established based on the best pollution control
technology that can be economically achieved. It IS logical that
the federal government (EPA) develops these technology based
standards since it has access to the technical resources needed
to assess the Industrial processes utilized by each Industry and
to identify the best economically achievable pollution control
technology.
A second reason for federal standards IS to ensure that all sew-
age districts control the toxic discharges of Industrial facilities
to certain minimum levels. Without these standards, some
POTWs would not Implement a pretreatment program which
effectively controls toxic pollutants. In some communities, for
example, there IS political pressure to relax pollution control
requirements for facilities that provide a large number of local
lobs. Federal standards ensure that all POTWs will provide a
minimum level of control, thus making a contribution to the
goal of reducing toxic pollution of the nation's waters.
Finally, national pretreatment standards assure a degree of
equity within each Industry regarding expenses for pollution
control. If pollution control requirements were established
solely by POTWs. then two firms producing the same product in
different sewage districts might be subject to widely different
pollution limitations and costs. This could lead to an unfair
competitive advantage for one of the firms. The national stan-
dards ensure that firms in the same Industry are subject to the
same minimum requirements throughout the country.
The national pretreatment standards consist of two sets of
rules, prohibited discharge standards and categorical pretreat
ment standards.
Prohibited Discharge Standards
The national prohibited discharge standards forbid certain types
of discharges by any sewage system user (40 CFR 403.5). The
prohibited discharge standards apply to all sewage system
users, regardless of whether or not they are covered by cate-
gorical pretreatment standards.
These standards have both general and specific prohibitions.
The general prohibitions forbid pollutants to be discharged into
the sewage system if they pass through the POTW untreated or
if they interfere with POTW operations. The specific prohibi-
tions outlaw the discharge of five categories of pollutants:
* Pollutants that create a fire hazard or explosion hazard in
the collection system or treatment plant.
* Pollutants that are corrosive, including any discharge with a
pH lower than 5.0, unless the POTW is specifically
designed to handle such discharges.
* Solid or viscous pollutants in amounts that will obstruct
the flow in the collection system and treatment plant,
resulting in Interference with operations.
* Any pollutant discharged in quantities sufficient to Interfere
with POTW operations.
Discharges with temperatures above 104°F (40°C) when
they reach the treatment plant, or hot enough to Interfere
with biological treatment processes at the sewage treat-
ment plant.
The POTWs must enforce these general and specific prohibi-
tions as a condition for approval of their pretreatment pro-
grams. POTWs must establish limits on specific pollutants from
certain facilities to ensure that the prohibited discharge stan-
dards are not violated. For example, if an industrial plant dis-
charges a pollutant that could cause interference, the POTW
would have to set limits on that pollutant in the plant's pretreat-
ment permit.
Categorical Pretreatment Standards
Categorical pretreatment standards are pollution control regula-
tions for specific Industries. The standards regulate the level of
pollutants in the wastes discharged into the sewage system
from an Industrial process (Figure 10). Each categorical stan-
dard covers one Industrial category. Within the Industrial cate-
gory, separate pollution control requirements might be
established for distinct Industrial processes or "subcategories"
(Figure 11).
Categorical standards place restrictions on 126 toxic pollutants
identified by EPA as having the greatest potential to harm
human health or the environment (Table 1). The categorical
standards may require that industrial facilities reduce their dis-
charges of these toxic substances by 80 percent or more. Some
of the categorical standards also regulate industrial discharges
of certain non-conventional pollutants which are not included in
the list of 126 toxic pollutants but which nevertheless present a
threat to the aquatic environment or to human health. Cate-
gorical standards have been or are being developed for indus-
trial categories that generate the bulk of toxic Industrial
pollutants (Table 2).
Development of Categorical Standards
The Industrial Technology Division within the EPA Office of
Water Regulations and Standards develops the federal
categorical pretreatment standards. This is done in conjunc-
tion with the development of pollution control regulations for
direct dischargers. The process begins with the collection of a
15
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NATIONAL PRETREATMENT STANDARDS
Figure 10. End-of-Process Versus End-of-Pipe Wastewaters. A manufacturing facility covered by a categorical standard gener-
ates wastewater within the Industrial process, and may also generate other wastewaters (e.g., sanitary wastes from bathrooms
and shower facilities). The categorical standard regulates the wastewater coming out of the industrial process (i.e., the end-of-
process wastewater). In some cases, end-of-process wastewater combines with other wastewaters kg., sanitary wastes) prior
to discharge into the sewer. Wastewater discharged into the sewer, which may consist of several types of wastewater from
within the manufacturing facility, is referred to as end-of-pipe wastewater. Individual POTWs may monitor the wastewater at an
end-of-process or an end-of-pipe location. If the POTW monitors at an end-of-pipe location, it must perform certain calculations
to translate the end-of-process pollutant limitations in the standard into end-of-pipe requirements for the entire facility. A
mathematical formula, termed the combined waste stream formula, has been developed for this purpose (40 CFR 403.6[e]).
16
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NATIONAL PRETREATMENT STANDARDS
Figure 11. Industrial C
ton industrial category, sometimes referred to a* an indus-
try, to broad classification of establishments involved in
an industrial activity. For example, the battery manufac-
turing industrial category refers to establishments engaged
in the manufacture of a> types of storage batteries. Within
an industrial category, EM might define a number of tub-
categories to distinguish firms using different processes. In
the battery manufacturing industry, for example, EM has
set pollutant discharge limitations for six separate sub-
categories.
variety of process engineering and environmental data concern-
ing the regulated industry. EPA reviews these data to determine
the types and quantities of effluents generated by the industry.
The EPA next identifies the best available technology economi-
cally achieveable (BAT) to control the industry's effluents
(Figure 12). BAT technology performance is then analyzed to
determine how much of each pollutant the technology can
remove from the effluent (the numerical pollution control
limits). The EPA standard for direct dischargers is based on
these limits. Although industrial discharges must meet EPA
numerical pollution control limits, EPA does not require indus-
tries to use any specific treatment processes to comply with
the standard.
Table 1. Toxic Pollutants Regulated Under Categorical Standards
1. acenaphthene
2. acrolem
3. acrylonitrile
4. benzene
5. benzidine
6. carbon tetrachloride
7. chlorobenzene
8. 1,2,4-trichlorobenzene
9. hexachlorobenzene
10. 1,2-dichloroethane
11. 1.1,1 -trichloroethane
12. hexachloroethane
13. 1,1 dichloroethane
14. 1,1,2-trichloroethane
15. 1,1,2,2-tetrachloroethane
16. chloroethane
17. bis(2-chloroethyl) ether
18. 2-chloroethyl vinyl ether (mixed)
19. 2-chloronaphthalene
20. 2,4,6-trichlorophenol
21. parachlorometa cresol
22. chloroform (trichloromethane)
23. 2-chlorophenol
24. 1,2 dichlorobenzene
25. 1,3-dichlorobenzene
26. 1,4-dichlorobenzene
27. 3,3-dichlorobenzidine
28. I.Vdicrtlotoethvlene
29. 1,2 trans-dichloroethylene
30. 2.4-dichlorophenol
31. 1,2-dichloropropane
32. 1,2-dichloropropylene
(1,3-dichloropropene)
33. 2.4-dimethylphenol
34. 2.4 dimtrotoluene
35. 2,6-dinitrotoluene
36. 1,2-diphenylhydrazine
37. ethylbenzene
38. fluoranthene
39. 4-chlorophenyl phenyl ether
40. 4 bromophenyl phenyl ether
41. bis(2-Chloroisopropyl) ether
42. bis(2 chloroethoxyl methane
43. methylene chloride (dichloromethane)
44. methyl chloride (chloromethane)
45. methyl bromide Ibromomethane)
46. bromoform (tribromomethane)
47. dichlorobromomethane
48. chlorodibromomethane
49. hexachlorobutadiene
50. hexachlorocyclopentadiene
51. isophorone
52. naphthalene
53. nitrobenzene
54. 2-nitrophenol
55. 4-nitrophenol
56. 2,4-dmitrophenol
57. 4.6-dinitro-o-cresol
58. N-nitrosodimethylamine
59. N-nitrosodiphenylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62. phenol
63. bis(2-ethylhexyl) phthalate
64. butyl benzyl phthalate
65. di-n-butyl phthalate
66. di-n-octyl phthalate
67. diethyl phthalate
68. dimethyl phthalate
69. benzolalanthracene
(1,2-benzanthracene)
70. benzo(a)pyrene (3,4-benzo-pyrene)
71. 3,4-benzofluoranthene
IbenzotbWuoi amhenet
72. benzo(k)fluoranthene
(11,12-benzofluoranthene)
73. chrysene
74. acenaphthylene
75. anthracene
76. benzolghilperylene (1,12-benzoperylene)
77. fluorene
78. phenanthrene
79. dibenzo(ah)anthracene
(1.2,5,6-dibenzanthracene)
80. indeno (1,2,3-cdlpyrene
(2,3-o-phenylenepyrene)
81. pyrene
82. tetrachloroethylene
83. toluene
84. tnchloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane
(technical mixture & metabolites)
89. 4.4 DDT
90. 4.4 DDE (p,p-DDX)
91. 4,4 ODD (P.P-TDEI
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrih
96. endrin aldehyde
97. heptachlor
98. heptachlor epoxide
(BHC-hexachlorocyclohexane)
99. Alpha BHC
100 Beta BHC
101. Gamma-BHC (lindane)
102. Delta BHC
(PCB polychlonnated biphenyl)
103. PCB 1242 (Arochlor 1242)
104. PCB 1254 (Arochlor 1254)
105. PCB 1221 (Arochlor 1221)
106. PCB 1232 (Arochlor 1232)
107. PCB 1248 (Arochlor 1248)
108. PCB 1260 (Arochlor 12601
109. PCB-1016 (Arochlor 1016)
110. toxaphene
11 V antimony UotaH
112. arsenic (total)
113. asbestos (total)
114. beryllium (total)
11 5. cadmium (total)
1 16. chromium (total)
11 7. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)
121. nickel (total)
122. selenium (total)
123. silver (total)
124. thallium (total)
125. zinc (total)
1 26. 2,3,7,8-tetrachlorodibenzo-o-dioxin
(TCDD)
17
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NATIONAL PRETREATMENT STANDARDS
Table 2. Status of Categorical Pretraatment Standards
Industry Category
Data Standard was Issued
in F+dtrml Kfg/sttr
Effective Date
Compliance Date for Existing Sources'
Timber Products
Electroplating
Iron and Steel
Inorganic Chemicals 1
Textile Mills
Petroleum Refining
Pulp. Paper. Paperboard
Steam Electric
Leather Tanning
Porcelain Enameling
Coil Coating 1
Electrical and Electronic Components 1
Metal Finishing
Copper Forming
Aluminum Forming
Pharmaceuticals
Coil Coating (Canmaking)
Electrical and Electronic Components II
Non Ferrous Metals 1
Battery Manufacturing
Inorganic Chemicals II
Plastics Molding and Forming
Non Ferrous Metals Forming
Non Ferrous Metals II
Pesticides
Metal Molding and Casting (Foundries)
Organic Chemicals and Plastics and
Synthetic Fibers
1-26-81
1-28-81
71583
5-27-82
6-29-82
9-2-82
10-18-82
11-18-82
11-19-82
11-23-82
11-24-82
12-1-82
4-8-83
7 15 83
8-15-83
10-24-83
10-27-83
11 17 83
121483
3-8-84
3-9-84
8-22-84
12-17-84
8 23-85
9-20-85
10-4-85
103085
12/86
33081
33081
8 2983
71082
8-12-82
10-18-82
12-1-82
1-3-83
1 2-83
1-6-83
1-7-83
1-17-83
51983
8 29 83
9-26-83
12-7-83
12-12-83
1-2-84
1-27-84
4-23-84
4-23-84
10-5-84
1-30-85
10-7-85
11 4-85
11-18-85
12-13-85
2/87
1-26-84
4-27-84 (Non-integrated)"
6 30 84 (Integrated lb
7-15-86 (TTOP
71085
8-12-85
C
12-1-85
7-1-84
7-1-84
11 25 85
11-25-85
12-1-85
7-1-84 ITTO)"
11-8-85 (As)d
6-30-84 (Part 433, TTO)e
7-10-85 (Part 420. TTO)'
2-15-86 (Final)'
8-15-86
10-24-86
10-27-86
11-17-86
7-14-86
3-9-87
3-9-87
6-29-85 (CuSO., NiSO.I
8-22-87
C
8-23-88
9-20-88
11-18-88
10-31-88
2/90
* The compliance date for any new source is the same date as the commencement of the discharge.
b Integrated electroplators are establishments involved both in electroplating and in other activities that are regulated by other EPA categorical
pretreatment standards. Non integrated electroplators are establishments involved in electroplating only. The compliance date for removal of total
toxic orgamcs (TTOl is July 15. 1986.
c No numerical pretreatment limits have been established for these industrial categories, and there is no final compliance date for categorical
pretreatmant standards Firms in these categories are required to comply only with the General Pretreatment Regulations in 40 CFR 403.
d The compliance date for existing Phase I Electrical and Electronic Components manufacturers for TTO is July 1, 1984 The compliance date for
arsenic is November 8, 1985
' Existing sources that are subject to the metal finishing standards in 40 CFR Part 433 must comply only with the interim limit for Total Toxic
Orgamcs ITTOl by June 30. 1984. Plants also covered by 40 CFR Part 420 must comply with the interim TTO limit by July 10. 1985 The com
pliance date for metals, cyanide, and final TTO is February 15. 1986. for all sources
SOURCE US Environmental Protection Agency, July 1986
The pollution control capabilities of BAT technology are
also used to establish pretreatment standards for indirect
dischargers. Before establishing pretreatment standards based
on BAT. however, EPA considers the pollution removal capabili-
ties of sewage treatment plants (Figure 13). If treatment plants
using secondary treatment processes typically remove any of
an industry's pollutants to the same extent as BAT technology,
then pretreatment standards for those pollutants are generally
18
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NATIONAL PRETREATMENT STANDARDS
Figure 12. Categorical Standards Development
In identifying BAT technology for a given industry, ERA
considers a number of alternative pollution control sys-
tems. Technical and economic analyses are performed to
determine whether the systems will work and whether
they are economically achievable for the industry. These
analyses are described in the Federal Register notice of the
proposed rule ERA also publishes a "development docu-
ment" concerning each industry's pretreatment standard.
These documents expand on the discussions in the Federal
Register and provide more detail concerning the technolo-
gies that were considered in establishing BAT. In some
cases, EPA also publishes a summary manual concerning
an industry's pretreatment standard. To obtain copies of
the development documents or summary manuals, contact
the U.S. Environmental Protection Agency, Office of Water
Regulations and Standards, Industrial Technology Division,
Washington, DC.
not promulgated for that industry. If any of an industry's pollu-
tants typically pass through the treatment plant, discharging a
higher level of pollutants than would occur if the industry's
facilities were direct dischargers using BAT technology, then
pretreatment standards equivalent to BAT technology are
promulgated for those pollutants for that industry. Thus,
pretreatment standards are set using BAT technology as a refer-
ence point, with some pollutants excluded based on the perfor-
mance capabilities of sewage treatment plants.
Implementation of Federal Categorical Standards
Once a categorical standard is promulgated, POTWs or indus-
trial officials might be unsure whether or not a given facility is
subject to the new regulation. The POTW or the industrial user
can request a ruling by the EPA concerning the industrial cate-
gory of the facility in question (i.e., a category determination).
The Water Division Director in the EPA regional office where
the facility is located makes the final decision.
If an industrial facility is subject to a categorical standard, it
must submit a report to the POTW documenting the plant oper-
ations and discharges. In these reports, referred to as baseline
monitoring reports, the industrial facility must also indicate
whether applicable pretreatment standards currently are being
met. If the standards are not being met, the facility must sub-
mit a description of the facilities and operating procedures
required for compliance and a schedule showing when these
compliance measures will be implemented. If an industrial plant
has already submitted the required information as part of its
existing pretreatment permit application, it need not resubmit
the information in a baseline monitoring report.
All industrial facilities included in a category are responsible for
installing any pollution control equipment and instituting any
operations and maintenance procedures that might be required
Figure 13. Removal CapaMtties of POTWs
Categorical standards regulate only pollutants that are not
controlled by POTW treatment systems. To assess the
removal capabilities of POTWs, ERA has developed exten-
sive data on the performance of 50 representative facili-
ties. This data is available in the EPA publication titled Fate
of Priority Pollutants in Publicly Owned Treatment Works.
The information on POTW pollutant removal contained in
this document is used to determine whether a given pollu-
tant in an industry must be covered under categorical stan-
dards. Copies of the document can be obtained by
contacting the U.S. Environmental Protection Agency,
Office of Water Regulations and Standards, Industrial Tech-
nology Division, Washington, DC.
for compliance with the standard. The effective date of a cate
gorical standard is usually several weeks after the standard is
promulgated in the Federal Register as a final regulation. In
most cases, new facilities must comply with the regulation for
any discharges occurring after the effective date of the regula-
tion; existing plants must comply within 3 years of the effective
date of the regulation.
Modifications of Categorical Pretreatment Standards
Although categorical standards apply throughout the country,
they may be modified in three specific circumstances. If the
water coming into a particular industrial facility already con
tains a pollutant regulated by the categorical standard for that
facility, a net/gross adjustment may be authorized (40 CFR
403.15). Net/gross adjustments allow the facility to discharge a
particular pollutant at a level in excess of the federal standard,
but such an adjustment is allowed only to the degree that the
pollutant is present in the incoming water
A second type of adjustment, termed a removal credit, allows a
categorical standard to be modified for a particular pollutant at
a particular facility if the sewage treatment plant serving the
facility removes the pollutant effectively (40 CFR 403.7). If a
POTW demonstrates to the EPA Regional Administrator that a
pollutant is removed by its sewage treatment process, then the
categorical pretreatment standards for that pollutant can be
adjusted accordingly for industries served by that POTW.
Categorical standards can also be adjusted if a POTW, an indus-
trial firm, or an interested party can show that a factor or fac-
tors exist that were not considered in the development of the
standards. For example, a firm or industry might apply for a
change in the standard because it is using a process that was
not considered by EPA when the Agency developed the cate-
gorical standard. Such adjustments are termed fundamentally
different factorfsl variances (40 CFR 403.13).
19
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5. Local Pretreatment Programs
Program Components
The POTWs develop local pretreatment programs which imple-
ment federal standards and protect local interests. They prepare
detailed pretreatment program documents which are reviewed
by the state, in pretreatment-delegated states, or by the EPA. To
gain approval, these submissions-must meet the requirements
for local pretreatment programs contained in 40 CFR 403 (Fig-
ure 14).
Figure 14. EPA Manuals Describing POTW Pretreatment
Programs
In addition to obtaining copies of 40 CFR 403, a person
interested in understanding the components of local POTW
programs should obtain the EPA publication entitled Gui-
dance Manual for POTW Pretreatment Program Develop-
ment. This document explains in lay terms the elements
that must be included in a local pretreatment program to
gain EPA or state approval. Separate chapters of the docu-
ment explain the requirements for legal authority, technical
information, industrial waste surveys, monitoring,
implementation procedures, and program staffing. The
document's appendices contain sample forms such as a
sample pretreatment permit for an industrial discharger, a
checklist for POTW pretreatment program submissions,
and a sample compliance schedule.
To be successful, the local pretreatment programs must have
the following elements:
i Building Blocks - local pretreatment programs require legal
authority, a professional staff, funding, and an information
base on the industrial dischargers.
Effluent Limits-For industrial users of the sewage system,
effluent limitations that enforce federal standards and pro-
tect local interests must be established.
I Implementation Activities - POTWs must undertake a
number of activities to implement their effluent limits
including notification, permit administration, inspection,
monitoring, and enforcement.
I Information Handling and Public Access-Pretreatment pro-
grams must include a data management system and must
provide mechanisms to allow the public to have access to
information about the program and to comment on pro-
gram elements.
Figure 15 provides an overview of the critical components of a
local pretreatment program.
POTW Pretreatment Program Building Blocks
A local pretreatment program must have four major building
blocks in order to succeed. First, the POTW must have the legal
authority to implement the program. This legal authority usually
is based on state law and local ordinances. State law authorizes
the municipality to regulate industrial users of municipal sew-
|sĽS>S<Ľs
Kj^^^S
Figure 15. POTW Retreatment Programs.
20
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LOCAL PRETREATMENT PROGRAMS
age systems. The municipality, in turn, establishes a local
ordinance that sets forth the components of its pretreatment
program and identifies the director of the POTW as the person
empowered to implement the program.
The legal authority granted by state and/or local law must
authorize the POTW to limit the pollution levels in discharges
from industrial users of the sewage system. It must be autho-
rized to enforce national pretreatment standards and to imple-
ment local limits in addition to or in excess of the standards. It
also must be empowered to issue permits or enter into con-
tracts with industrial users which set forth all applicable pollu-
tion control requirements. Finally, the POTW's legal authority
also must include the right to inspect and monitor industrial
facilities without prior notice, and to take enforcement action
against violators.
In addition to obtaining legal authority, the POTW must develop
a comprehensive data base describing its industrial dischargers.
An industrial waste survey is commonly used to obtain data
identifying the volume and pollutant concentration of industrial
effluents. This survey provides a data base that allows the
POTW to identify the major sources of toxic effluents within
the sewage system.
A successful pretreatment program also requires adequate
staffing. Personnel are required for sampling and inspection,
laboratory analysis, technical assistance, legal assistance, and
program administration The resources required for each
activity depend upon the size of the sewage district, the num-
ber of industrial users, and POTW policies.
The final key building block of a successful pretreatment pro-
gram is funding. Funding for the program may be included in
the municipal budget for the POTW or recovered through
charges to the industrial facilities. These charges can be incor-
porated into a facility's basic fees for sewage services, or levied
as a separate pretreatment charge. The size of the charges can
be based on the amount of POTW services (e.g.. monitoring)
required by a facility, the facility's wastewater flow, or the tox-
icity of its pollutants.
Effluent Limits
A POTW with adequate legal authority, a sound data base, and
adequate staffing and funding can proceed to develop effluent
limitations for each industrial plant. At a minimum, all facilities
are required to comply with federal prohibited discharge stan-
dards. The industries covered by federal categorical standards
also must comply with the appropriate discharge limitations.
The POTW may also establish local limits in excess of or in
addition to the federal standards for some or all of its industrial
users. To identify the need for and the nature of such limits, the
POTW determines whether any public health or environmental
problems related to POTW operations will exist, even with full
enforcement of the federal standards. This assessment
addresses the following issues:
Interference - Even with full implementation of federal
standards, will the remaining pollutant loadings interfere
with the sewage treatment system? To answer this ques-
tion, the POTW must analyze its treatment system's
susceptibility to various problems and its history of
breakdowns.
Sludge Contamination - Will any of the pollutants con-
taminate the municipal sludge? To answer this question,
the POTW must determine the concentration of con-
taminants in its sludge after full enforcement of federal
standards and analyze the environmental residuals
associated with each possible sludge disposal method.
NPDES Permit Violations -Will the pass-through of any pol-
lutants cause an NPDES permit violation? To answer this
question, the POTW must determine whether any of the
pollutants that remain in the system after full enforcement
of federal standards will pass through the treatment plant
in quantities significant enough to cause a permit violation.
Surface Water Impacts - Will any of the pollutants that
pass through the treatment plant adversely affect the
receiving water body? To answer this question, the POTW
must examine the environmental condition of the receiving
water body and determine whether the pass-through of
any pollutants might have a substantial impact.
Worker Safety - Will any of the pollutants create a safety
hazard for municipal employees? To answer this question.
the POTW must review the design and operation of its
treatment system and the chemical composition of Its pol-
lutant inflow to determine whether any of the pollutants
individually, or in combination, will create a worker hazard.
If the answer to any of the above questions is "yes," the POTW
will have to establish local limits to be incorporated into the dis-
charge limitations of some or all of the industrial plants that it
serves. To determine these limits, the POTW must estimate the
maximum concentration of each pollutant in the incoming
wastewater that will not cause any of these problems. It can
then calculate the maximum pollutant loading of each user that
can be allowed without exceeding the maximum concentration
of pollutants arriving at the treatment plant. These calculations
must consider such factors as the level of pollutants already
present in the water supply, the chemical decomposition of pol-
lutants within the sewage system, and the need to accommo-
date future industrial growth. Based on these calculations, local
limits for each pollutant are established for each industrial
facility.
Implementation Activities
The POTWs must take a number of steps to implement the
effluent limits established in their programs. First, the industrial
plants must be notified of the effluent limitations that apply to
them. These limitations might be based on categorical pretreat-
ment standards, prohibited discharge standards, or local limits.
The effluent limits are then incorporated in a permit, contract,
or other agreement between the POTW and the industrial
facility.
21
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LOCAL PRETREATMENT PROGRAMS
POTWs must then ensure that the industrial facilities comply
with the effluent limits in their pretreatment permits. They
require industrial plants to submit self-monitoring reports in
which they report the total volume and pollutant concentrations
of their wastewater discharges. Federal regulations require that
these reports be submitted semi-annually, at a minimum. The
industrial facility's pretreatment permit might also require the
submittal of additional information such as a description of any
accidental discharges into the sewage system.
The POTW cannot rely solely on the information supplied by
industry in self-monitoring reports. It must, therefore, conduct
its own inspection and monitoring activities. POTWs identify
locations within the industrial facility for collecting samples of
wastewater for chemical analysis. Sampling locations might be
at the end of the industrial process or at the point of connec
tion to the public sewer. The effluent concentrations consid-
ered acceptable at each sampling location are based on the
facility's pretreatment permit.
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POTW personnel monitor an industrial facility.
Municipal personnel periodically visit each industrial site to col-
lect wastewater samples at the designated sampling locations
within the facility. Some of these inspections are held on a
regularly scheduled basis. There are also unannounced monitor-
ing visits to ensure that the information collected during sched-
uled visits or submitted in self-monitoring reports truly
represents the character of the plant's wastewater discharge.
Monitoring also may occur in response to a suspected violation
of a pretreatment permit, a public complaint, the suspected
presence of explosive or corrosive materials, operating difficul
ties in the sewage treatment plant, or violation of the POTWs
NPOES permit. Monitoring is generally undertaken immediately
following the onset of a serious problem.
The frequency and extensiveness of monitoring and inspection
by the POTW depends on the facility's potential impact on the
sewage system and the environment. In general, major indus
trial facilities such as those covered by categorical standards
are subject to at least one scheduled and one unscheduled
monitoring visit per year; more if resources allow. The volume
of wastewater discharges, the toxicity of the discharge, or the
variability of monitoring results are used by sewer districts to
determine the frequency of monitoring visits.
When an industrial plant violates its permit conditions, the
POTW takes enforcement action. Before taking this step, how
ever, the POTW verifies the violation. In most cases, verification
involves sampling and laboratory analysis of the plant's effluent
to confirm that a violation has occurred.
In emergency situations, the sewer district may take immediate
action to halt all discharges from a facility that is discharging
hazardous pollutants. In less serious cases, however, the POTW
will immediately inform the violator verbally of the violation,
then later will do so in writing. The facility is required to meet
its permit conditions within a specified period of time. Monitor
ing of the facility's discharges is then instituted to ensure that
these compliance deadlines are met.
When compliance deadlines are not met, civil and/or criminal
proceedings may be initiated against the violator. In some
cases, violations can be handled without litigation. However,
when a facility persists in violations that endanger public health
and the environment, the POTW may take strong enforcement
action. It may levy fines and/or seek injunctions to force the
violating facility to come into compliance.
Information Handling and Public Access
POTW pretreatment programs require comprehensive data
management systems. Large POTWs that serve many industrial
facilities and operate several sewage treatment plants generally
will have a computerized data management system. The com
puter stores records of the pollutant discharges allowed in a
facility's permit, and it records the actual pollutant levels
detected in wastewater samples. This allows for a rapid com-
parison of observed and allowed discharges and the automatic
22
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LOCAL PRETREATMENT PROGRAMS
detection of violations. The computerized data base can also be
used to assist the POTW to determine the source of problems,
to calculate local limits, and to plan for system expansion.
In general, information and data that the POTW collects on
industrial dischargers is available to the public and to govern-
ment agencies without restriction. The public owns the POTW
and, therefore, has the right to review the information it main-
tains, including any data showing evidence of detrimental
effects on the collection system or the treatment plant. Restric-
tions are made, however, when the industrial facility is able to
demonstrate that the release of such material would divulge
information, processes, or methods of production entitled to
protection as trade secrets. In these cases, information in a
facility's file that might disclose trade secrets or secret
processes is not made available for public inspection. However,
industrial effluent data always remains available to the public
without restriction.
Upon written request to government agencies, non-disclosed
portions of a facility's file are made available for uses related to
the pretreatment program. For example, a state agency may
request confidential information for use in judicial review or
enforcement proceedings. The company affected should be
notified whenever confidential information is released to a
government agency or to the general public.
The pretreatment program is a public service designed to pro-
tect the public health and environmental quality of a commu-
nity. In large part, public support for the program will depend on
public participation in the program and public access to the
information used in developing and administering the program.
The POTW staff is responsible for working with industries and
the community to define the objectives and benefits of the
pretreatment program. The POTW can hold public meetings
during the development of its pretreatment program and during
the program's implementation. These meetings open a formal
channel for public comment on the program and for dialogue
with local industries and environmental groups. When local
limits are developed or revised, all interested parties must be
notified and invited to comment on these actions.
Public access to non-confidential information regarding the
pretreatment program must be maintained at a convenient loca-
tion. At this place, interested people can read or copy docu-
ments, permits, monitoring reports, and records of violations.
Local libraries, the city or town hall, and public works offices
are usually good locations for public access.
Another aspect of providing information to the public is man-
dated by federal regulations: the POTW must inform the public
whenever a significant violation occurs (40 CFR 403.8 |f||2|).
The POTW is required to publish in the area's largest daily
newspaper, on at least an annual basis, the names of industries
that have significantly violated pretreatment standards during
the previous 12 months.
23
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6. The Future of the
Pretreatment Program
The Pretreatment Program Today
The federal, state, and local officials involved in the National
Pretreatment Program continually strive to improve its effective-
ness. To ensure that the program provides maximum protection
to human health and the environment, a number of activities
have been undertaken.
The immediate goal of the program is to have all states and
POTWs develop pretreatment programs. Significant progress has
already been made. Of the 1,468 POTWs now required to
develop programs, 1,369 already have approved programs, while
another 21 have filed complete submissions that now await
government review (Table 3). Most of the remaining sewage
authorities have at least started to develop pretreatment pro-
grams. The development of state programs also has progressed,
with 22 of the 37 NPDES states already having gained EPA
approval for their pretreatment programs.
To assist the EPA, state, and POTW personnel in effectively
implementing pretreatment programs, the EPA recently convened
the Pretreatment Implementation Review Task Force (PIRT). The
task force consisted of EPA headquarters personnel, EPA regional
personnel, state officials, POTW officials, environmental advo-
cates, and industry representatives. Their report, titled Pretreat-
ment implementation Review Task Force: Final Report to the
Administrator, was released in January 1985 and is available
from the EPA Office of Water Enforcement and Permits,
Washington, DC. It recommends improvements in several areas:
Clarification of the program requirements.
Improvements in enforcement procedures.
Allocation of additional resources to the program.
Better definition of the roles and relationships of program
participants.
Consideration of regulatory changes.
EPA is currently developing guidance documents and policy
measures in accordance with these recommendations.
Future Issues
Whole-Effluent Toxicity
Several emerging issues provide a new set of challenges to the
Pretreatment Program. One issue is the consideration of effluent
toxicity in establishing local discharge limitations to be incorpo-
rated into pretreatment permits. Currently, pretreatment permits
for industrial users of the sewage system restrict the concentra-
tion of particular toxic contaminants (e.g., specific toxic metal
compounds) rather than the toxicity resulting from the combined
effect of all of the pollutants in a facility's wastewater. However,
the toxicity of a industrial facility's effluent is not simply the sum
of the toxicity of the individual pollutants. Some types of pollut-
ants within a facility's wastewater react with each other to form
a more toxic effluent, while some combinations of pollutants
neutralize each pollutant's toxicity.
Table 3. Pretreatment Program Approval Status3
EPA EPA Stata state Total Total
Region Required Approved Required Approved Required Approved
I
II
III
IV
V
VI
VII
VIII
IX
X
68
57
116
28
99
123
13
52
120
24
52
54
90
23
69
112
13
27
120
21
13
24
24
377
240
63
21
11
21
12
365
204
-
62
21
80
81
139
417
333
123
76
53
121
45
67
76
125
402
300
117
76
43
121
42
Totals
700
581
763
697
1468
1369
a As of July 1986, approximately 21 complete program submis-
sions were either under or awaiting review, reviewed and found
approvable for public notice, or on public notice. Most of the remain-
ing POTWs have submitted one or more portions of their programs for
review.
SOURCE U S. EPA. July 1986
To date, pretreatment permits have not considered the toxicity of
the whole effluent. EPA researchers, however, have developed
tests to measure whole-effluent toxicity. Regulatory officials are
now developing recommended methods for using these toxicity
tests to Incorporate whole-effluent toxicity restrictions into
industrial pretreatment permits. In other words, future permits
will not only limit the discharge of particular toxic substances,
but they will also limit the toxicity of the effluent as a whole.
This will provide an additional degree of protection to public
health and the environment.
Toxics Control Requirements in the Discharge Permits of
Sewage Treatment Plants
Currently, the discharge permits of municipal sewage treatment
plants usually do not contain specific limits for toxic pollutants.
The POTWs are restricted by language in their permits pro-
hibiting the discharge of "toxic substances in toxic amounts."
Federal and state governments, however, will soon be
implementing stricter controls on the ambient concentration of
toxic pollutants permitted in surface water bodies (i.e., ambient
water quality standards). To comply with these new ambient
water quality standards, states and localities may be required to
enforce stricter controls on toxic pollutants from all dischargers,
including municipal sewage treatment plants.
Because of these changes, it is anticipated that future NPDES
permits of sewage treatment plants will include specific limits on
toxic pollutants and possible limits on whole-effluent toxicity.
These changes will create additional incentives for POTWs to
control the toxic discharges of their industrial users so that the
level of toxic pollutants in the treatment plant's influent is
reduced. Thus, limits on toxic pollutants in future NPDES permits
of municipal sewage treatment plants will create the need for
more effective pretreatment programs.
24
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THE FUTURE OF THE PRETREATMENT PROGRAM
Federal Sludge Regulations
A major function of a pretreatment program is to limit the level
of toxic contaminants that end up in the sludge of the treat-
ment plant (see Chapter 2). If contaminant levels in sludge are
too high, certain disposal methods, such as land application of
sludge as a soil conditioner, may become more expensive or be
prohibited. Currently, restrictions on sludge disposal are based
principally on state regulations.
The EPA is now developing national regulations that will place
additional controls on sludge disposal and use. These regula-
tions will cover the major methods of sludge disposal, including
landfilling. land application, distribution and marketing, ocean
disposal, and incineration. Depending on the exact limitations
included in these new rules, POTWs might be required to imple-
ment additional pretreatment measures to ensure that their
sludges will comply with the new federal regulations.
Effect of New Hazardous Waste Laws on the
Pretreatment Program
Another major challenge to the Pretreatment Program is
responding to the effects of the Resource Conservation and
Recovery Act (RCRA) amendments, passed by Congress in late
1984. These amendments establish new, more stringent
requirements for the treatment, storage, and disposal of hazard-
ous wastes. The concurrent implementation of these amend-
ments and the pretreatment program could result in conflicts.
Some industrial establishments might discharge additional
quantities of hazardous wastes and toxic pollutants into sew-
age systems to avoid the costs imposed by more stringent
hazardous waste disposal controls. Conversely, the full
implementation of pretreatment programs may increase the
amount of hazardous wastes (sludges) generated by industrial
plants operating pollution control systems to remove toxic
pollutants as required under their pretreatment permits.
EPA is currently completing a study to determine whether haz-
ardous discharges to municipal sewage systems will increase
as a result of the new RCRA amendments. This subject will
also be addressed by the newly formed Clean Water Act/RCRA
Task Force. Although the extent of this problem has not yet
been quantified, there are several reasons for concern:
The RCRA program is operated under the assumption that
the Pretreatment Program will control hazardous waste dis-
charges to municipal sewage systems. However, the
Pretreatment Program principally controls typical industrial
wastewater constituents. Hazardous wastes that were not
previously associated with industrial wastewater dis-
charges, or pollutant sources outside the purview of the
current Clean Water Act classes and categories of indus-
tries (see Chapter 4), may receive little regulatory scrutiny
under the Pretreatment Program.
The RCRA Program and the Pretreatment Program use
different methods to select materials for regulation. The
Pretreatment Program focuses principally on 126 toxic pol-
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> " , '''*%,Ť, *. . ,'*^;-^ %,,i Ť
New federal regulation may place additional restrictions on
sludge use and disposal methods, including land application
shown here.
lutants. RCRA identification of regulated materials is more
dynamic. Wastes may be deemed hazardous if they pos-
sess certain characteristics or if they have been specifically
listed as hazardous by EPA. Listed wastes may encompass
substances containing one or more of 375 hazardous
constituents.
The Pretreatment Program is implemented by individual
POTWs. These municipal agencies have the authority to
expand the list of pollutants covered under their permits to
include more than the 126 toxic pollutants. Municipalities
must engage in an analytical process to identify pollutants
that might interfere with the operation of their POTW or
cause environmental problems. To date, however, POTWs
have not focused on hazardous constituents.
As a result of all the above factors, industrial establishments
generating hazardous wastes may discharge some of these
wastes into municipal sewage systems, where they may be
unregulated, rather than disposing of them through the regu-
lated RCRA process. Generators of small quantities of hazard-
ous wastes, some of which are now regulated for the first time
under the RCRA amendments, might be particularly likely to
avoid new disposal costs by discharging hazardous wastes into
sewage systems. The increased hazardous discharges into sew-
age systems could interfere with POTW operation, contaminate
POTW sludges, or result in the pass-through of hazardous
wastes to receiving waters. Therefore, POTWs will have to
broaden the scope of their pretreatment programs to respond to
this new source of pollution in the sewage system.
25
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THE FUTURE OF THE PRETREATMENT PROGRAM
Looking Ahead
In summary, the National Pretreatment Program faces a two-
fold challenge. First, it must ensure that all states and affected
POTWs complete the )ob of developing pretreatment programs
that enforce all existing federal categorical standards, pro-
hibited discharge standards, and local limits (where necessary).
Second, the program must develop new strategies to respond
to a number of emerging environment issues such as the poten-
tial increase in hazardous waste discharges into the sewage
systems. By responding to these challenges, the federal, state,
and local officials involved in the National Pretreatment Pro-
gram will ensure that the benefits of industrial pretreatment,
already seen in many areas, will be experienced in hundreds of
other communities throughout the country.
26
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7. References
(1) JRB/SAIC, Assessment of the Impacts of Industrial Dis-
charges on Publicly Owned Treatment Works, November
1981. SAIC, McLean, Virginia.
(2) Ibid (1).
(3) JRB/SAIC, Environmental Benefits of Pretreatment. SAIC,
McLean, Virginia.
(4) JRB/SAIC, Pretreatment Water Quality Improvements.
October 1984, SAIC, McLean, Virginia.
(5) Conversation between Mr. David Meyers of Eastern
Research Group, Inc. (ERG) and Mr. Tom Huston of the
City of Broomfield, Colorado.
(6) Ibid (4).
(7) Ibid (3).
(8) Conversation between Mr. David Meyers of Eastern
Research Group, Inc. and Mr. Michael Armorer of WSSC.
(9) Conversation between Mr. David Meyers of Eastern
Research Group, Inc. and Mr. John Roberts of the City of
Melbourne, Florida.
(10) Conversation between Mr. David Meyers of Eastern
Research Group, Inc. and Mr. Richard Lanyon of the
Metropolitan Sanitary District of Greater Chicago.
(11) Conversation between Mr. David Meyers of Eastern
Research Group, Inc. and Mr. Thomas Vetter of the New
York City Department of Environmental Protection.
27
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