LOCAL PRETREATMENT PROGRAM
REQUIREMENTS AND GUIDANCE
SEPTEMBER 1979
ENVIRONMENTAL TECHNOLOGY CONSULTANTS, INC.
The Executive Plaza - Suite 502 Cincinnati Eranch Office:
6501 Loisdale Court P.O. Box 41252
Springfield, Virginia 22150 Cincinnati, Ohio 45241
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DISCLAIMER
The contents of this document are intended to be
informative in nature and represent Environmental
Technology Consultants, Inc. (ETC) viewpoints and
interpretation of the requirements to be met by
POTWs in developing an approvable local Pretreat-
ment Program required by the U.S. EPA through the
General Pretreatment Regulations (40 CFR, Part
403} promulgated June 26, 1978. The General Pre-
treatment Regulations are currently undergoing
revision and this document has been prepared to
reflect the proposed changes.
This document has not been reviewed for approval
by EPA at this time.
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TABLE OF CONTENTS
Page
I. Introduction 1
Purpose 1
Background . . 2
Pretreatment Authority 5
Federal Pretreatment Regulations .... 6
NPDES State Options 7
Planning Agencies & Pretreatment
Responsibility 9
Effluent Limitations for POTWs 9
Funding Mechanisms for Local Pre-
treatment Programs 12
Resource Conservation and Recovery
Act Considerations 13
II. Development of a Pretreatment Program 15
Introduction 15
Legal Authority 21
Ordinances 23
Industrial Waste Ordinance
History 23
Types of Ordinances 24
Industrial Waste Ordinance .... 25
Enforcement 26
Compliance Procedures 27
Contents of the Compliance Schedule . . 28
Developing Compliance Schedule Dates . . 30
Resources 35
Organizational Structure 39
Large System 39
Administration 39
Industrial Waste Division 41
Field Monitoring 41
Laboratory 42
Legal 42
Medium-Size System 43
Small System 43
Conducting an Industrial Waste Survey .... 46
Identifying and Notifying Industrial
Users 46
Industrial Waste Questionnaire 49
Compile Data 51
POTW Removal Allowance 53
Requirements for Removal Allowance ... 55
Variances from Categorical Pretreatment
Standards: Fundamentally Different
Factors (FDF) Determinations 57
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TABLE OF CONTENTS (Cont)
Page
Sludge Criteria 60
POTW Pretreatment Program Submission .... 61
III. Managing a POTW Pretreatment Program 65
Staffing 65
Public/Industrial Participation 66
Sludge Considerations 68
Monitoring, Field Sampling, and Laboratory
Work 71
Conclusion 73
IV. References . .' 74
V. Appendices
I - Draft Outline of Changes Proposed to
the General Pretreatment Regulations
(40 CFR, Part 403) 1-1
II - Summary of Existing Pretreatment
Standards II-l
III - Draft Model Ordinances III-l
IV - Model Industrial Waste Questionnaire . IV-1
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LIST OF TABLES
Page
Table 1 NRDC Consent Decree - 34 Industries 4
Table 2 NPDES State Options 8
Table 3 65 Toxic Pollutants Listed in NRDC Consent
Decree 18
Table 4 Estimated Number of Indirect Dischargers for
the 34 NRDC Consent Decree Industries ... 19
Table 5 Pretreatment Compliance Dates 32
Table 6 POTW Pretreatment Program Personnel
Requirements 36
Table 7 Estimated POTW Personnel Requirements for
a POTW Pretreatment Program by Personnel
Categories 37
Table 8 Estimated POTW Personnel Requirements for a
POTW Pretreatment by Program Activity ... 38
Table 9 Capabilities of Public Participation
Techniques 67
Table 10 Public Concerns 68
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LIST OF FIGURES
Page
Figure 1 Overview of Pretreatment Environmental
Problem 20
Figure 2 Typical Organization of a Large POTW
System 40
Figure 3 Typical Organization of a Medium-Size
POTW System 44
Figure 4 Typical Organization of a Small POTW
System 45
Figure 5 Procedural Flow Diagram for Industrial
Waste Survey and Ordinance 54
Figure 6 Sludge Management 69
Figure 7 Direct/Indirect Industrial Discharger ... 70
Figure 8 Hazardous Waste Management 71
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I. INTRODUCTION
Purpose
This document has been prepared to assist local govern-
ments and municipalities in the development of Pretreat-
ment Programs as required by the Clean Water Act (CWA) of
1977 (Public Law 95-217) and the General Pretreatment
Regulations for Existing and New Sources of Pollution (40
C-FR, Part 403) promulgated by the U.S. Environmental
Protection Agency (EPA), June 26, 1978. This document
presents information of a technical and administrative
nature pertinent to pretrsatment of industrial wastes and
the control of such wastes within publicly owned treatment
works (POTWs). A large number of POTWs within the U.S.
will be required to develop Pretreatment Programs. This
document is strictly advisory and can serve as guidance in
developing a cooperative effort between POTWs and their
respective industries and the development of sound and
equitable local Pretreatment Programs. It is not intended
as a replacement for the promulgated pretreatment stan-
dards which represent rules and regulations enforceable by
the Federal government.
The objectives of a Pretreatment Program will be to:
0 Prevent the introduction of pollutants into the
POTW which will interfere with treatment oper-
ations and/or the use or disposal of the munici-
pal sludge;
° Prevent the introduction of pollutants into the
POTW which will pass through the treatment works
or be incompatible;
0 Improve the feasibility of recycling and
reclaiming the municipal and industrial waste-
waters and sludges;
0 Enforce applicable EPA Categorical Standards;
and
° Generally, to reduce the health and environ-
mental risk of pollution caused by discharges to
POTWs.
This document can serve as guidance until EPA updates the
guidance publication entitled, Federal Guidelines: State
and Local Pretreatment Programs (MCD-43), January 1977.
EPA is currently reviewing the General Pretreatment
Regulations and anticipates promulgating revisions to
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these regulations in the near future. In order to advise
readers of anticipated changes, parts of this document
make reference to Appendix I which outlines the draft
changes.
Background
Congress first approved national water quality legislation
in 1948 and has periodically updated it since that time.
The Federal Water Pollution Control Act established a
central national strategy for controlling water pollution
based on clean-up requirements for the desired uses of
effluent-receiving waters (drinking water, body-contact
recreation, fishing, navigation, etc.) as determined by
State governments, and the water quality conditions neces-
sary to support those uses.
This strategy was generally ineffective due to a number of
political, technical, and legal weaknesses: stream use
designations tailored to protect against - or attract
industrial development; inadequate information on the
cause and effect links between discharges and water
quality; inadequate consideration of the health of aquatic
ecosystems; problems of equity between old and new pollu-
tion sources; and, general lack of attention to pollution
emanating from sources other than a pipe.
Several major pieces of legislation have been enacted dur-
ing the 1970*s to assist EPA in "closing the circle" of
environmental control within the U.S. and are discussed in
this section. The Federal Water Pollution Control Act,
was amended in 1972 by passage of Public Law 92-500. The
1972 Amendments established a national goal of eliminating
pollutant discharges by 1985, and directed "that wherever
attainable, an interim goal of water quality which
provides for the protection and propagation of fish,
shellfish, and wildlife and provides for recreation in and
on the water be achieved by July 1, 1983."
One of the most significant changes was from an emphasis
on the ambient quality of streams to direct control of
effluents through the establishment of regulations and
standards which form a basis for the issuance of discharge
permits. In addition, the 1972 Amendments required the
development of pretreatment guidelines and standards to
provide a uniform approach to the control of industrial
pollutants introduced into POTWs.
The 1972 Amendments were complex laws covering a wide
range of water pollution control regulations. Both the
municipal and industrial communities were impacted signif-
icantly. Mandatory secondary treatment for POTWs and a
base level of pollution control, Best Practicable Control
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Technology Currently Available (BPCTCA) installed by
direct industrial dischargers to waterways by July 1, 1977
highlighted the requirements. PL 92-500 also required EPA
to establish levels of pollution reduction achievable by
industry using Best Available Technology Economically
Achievable (BATEA) by 1983. In addition, a new source
standard calling fcr the use of advanced technology was
required.
Even with the passage of PL 92-500, Congress clearly
anticipated that review, course-corrections, and fine
tuning of the Act would soon be required. In 1976 and
1979, in settlement of a suit with the Natural Resources
Defense Council (NRDC), EPA agreed to concentrate
attention on potentially toxic substances using tech-
nology-based standards. Toxic substances were to be
included in the Best Available Technology (BAT) Standards
to be issued for the 34 industrial categories listed ip
Table 1. The realization that the water quality field is
changing rapidly — new problems emerge, new technologies
develop and overall knowledge improves apace — led to
further amendments to the Federal Water Pollution Control
Act (PL 92-500) subsequently known as the Clean Water Act
of 1977 (PL 95-217). The Act incorporated substantial
portions of the NRDC agreement and brought about other
changes in the direction of improved water quality.
Probably the most important of the 1977 amendments are
those which expressed concerns about chemical pollution,
materials recycling, and environmentally compatible
technical systems.
The 1977 amendments reflect Congressional recognition that
dangerous toxic pollutants were not being adequately
addressed. Most previous attention has focused on the
control of more conventional pollutants such_as Bio-
chemical Oxygen Demand (BOD) and Suspended Solids (SS).
It was realized that there are different kinds of pollu-
tion, and that some kinds pose a greater threat to public
health than others. This recognition, combined with
emerging questions about the cost effectiveness of apply-
ing more stringent technology-based limitations on "ordi-
nary" wastes, led in 1977 to a new classification of
pollutant types with different requirements specified for
each category. These changes result in a much greater
emphasis on the control of toxic pollutants. The 1977
legislation also promotes recycling and reuse of pollution
control by-products such as effluent, sludge, and
nutrients; energy conservation; and multiple use of lands
and waters which are components of wastewater treatment
systems.
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EPA promulgated on June 26, 1978 the General Pretreatment
Regulations (40 CFR, Part 403). This regulation, mandated
by the CWA, governs the control of industrial wastes
introduced into POTWs. This pretreatment regulation
establishes the framework for application and enforcement
of technology-based Categorical Pretreatment Standards
(published as separate regulations) and Prohibited Dis-
charge Standards for indirect industrial or non-domestic
dischargers. Those portions of the Act that pertain to
pretreatment, including the section providing authority,
are discussed later.
TABLE 1
NRDC CONSENT DECREE - 34 INDUSTRIES
NATURAL RESOURCES DEFENSE COUNCIL (NRDC)
Industry Industry
1.
Adhesives
18.
Pulp & Paper
2.
Leather Tanning
and Finishing
19.
Textile Mills
20.
Timber
3.
Soaps & Detergents
21.
Coal Mining
4.
Aluminum Forming
22.
Ore Mining
5.
Battery Manufacturing
23.
Petroleum Refining
6.
Coil Coating
24.
Steam Electric
7.
Copper Forminga ^
25.
Organic Chemicals
8.
Electroplating '
26.
Pesticides
9.
Foundries
27.
Pharmaceuticals
10.
Iron & Steel
28.
Plastic & Synthetic
11.
Nonferrous Metals3
Materials
12.
Photographic Supplies
29.
Rubber
13.
Plastics Processing
30.
Auto & Other Laundries
14.
Porcelain Enamel
31.
Mechanical Products
15.
Gum & Wood Chemicals
32.
Electric & Electronic
16.
Paint & Ink
Components
17.
Printing &
33.
Explosives Manufacturing
Publishing
34.
Inorganic Chemicals
a Industries for which interim pretreatment standards
have been developed and promulgated by EPA.
/
k While interim guidelines had been developed for the
electroplating industry, these were suspended on May 14,
1979. EPA expects to promulgate the proposed February 14,
1978 electroplating pretreatment regulation (BPT level)
in September 1979.
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Pretreatment Authority
Under Title III of the Clean Water Act, "Standards and
Enforcement," several sections are included that specifi-
cally refer to the pretreatment of pollutants introduced
into POTWs.
"For the purpose of assisting States in carrying out
programs under Section 402 of this Act, the Adminis-
trator shall publish.... and review at least annually
thereafter and if appropriate, revise guidelines for
pretreatment of pollutants which he determines are
not susceptible to treatment by publicly-owned treat-
ment works. Guidelines under this subsection shall
be established to control and prevent the discharge
into the navigable waters, the contiguous zone, or
the ocean (either directly or through publicly-owned
treatment works) of any pollutant which interferes
with, passes through, or otherwise is incompatible
with such works."
The guidance for developing local Pretreatment Programs
should not be confused with pretreatment standards for
both existing and new sources, promulgated under the
authority of Sections 307(b) and 307(c), respectively.
Section 307(b) is directed toward existing sources, and
states:
"The Administrator shall....publish proposed regula-
tions establishing pretreatment standards for intro-
duction of pollutants into treatment works....which
are publicly-owned for those pollutants which are
determined not to be susceptible to treatment by such
treatment works or which would interfere with the
operation of such treatment works."
Under the authority of Section 307(b), EPA promulgated the
General Pretreatment Regulations (40 CFR, Part 403), on
June 26, 1978. Included as Appendix II of this document
are the National Pretreatment Standards for seven
industrial categories as promulgated by EPA. These pre-
treatment standards set forth rules and regulations
designed to protect POTWs from the possible harmful
effects of industrial wastewaters introduced into such
systems. In addition to the general pretreatment stan-
dards, this section also provides authority for the
development of pretreatment standards for specific major
industrial categories of non-residential contributors.
Similarly, Section 307(c) authorizes the promulgation of
pretreatment standards for new sources.
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The distinction between pretreatment standards and the
guidance for developing local Pretreatment Programs given
in .this publication must be reemphasized. This document,
as indicated, is strictly advisory, for the purpose of
providing pretreatment assistance to interested parties
and only recommends approaches to developing pretreatment
policy. In contrast, the pretreatment standards as promul-
gated under Section 307 of the Act, represent rules and
regulations which are enforceable by the Federal govern-
ment.
Federal Pretreatment Regulations
On February 2, 1977, EPA proposed a rule which would
establish mechanisms and procedures for enforcing national
pretreatment standards to control the introduction of
non-domestic wastes into POTWs. These proposed regula-
tions set forth four options as the overall national
policy for the establishment and enforcement of pretreat-
ment standards for existing and new sources under Sections
307(b) and (c) of the Federal Water Pollution Control Act
as amended by the Clean Water Act. On June 26, 1978, EPA
promulgated this regulation (40 CFR, Part 403) and became
effective on August 25, 1978. These General Pretreatment
Regulations replaced the previous Pretreatment Standards
(40 CFR, Part 128).
The EPA Pretreatment Strategy followed in promulgating the
Pretreatment Regulation involves the following goals:
° EPA published revised General Pretreatment
Regulations to replace the previous regulations
(40 CFR, Part 128) published in 1973. The new
regulations established the roles and responsi-
bilities of Federal, State, and local government
and industry to implement national pretreatment
standards controlling non-domestic discharges
which are "incompatible" (pass through or inter-
fere) with the treatment processes of POTWs, or
which may contaminate sewage sludge.
° The preamble and Appendix I of the new regula-
tion has served as a statement of the Agency's
overall pretreatment policy. They were
developed after extensive public input and
Congressional consideration of pretreatment in
the new Clean Water Act.
° EPA is establishing technology-based pretreat-
ment standards under Section 307(b) and (c).
The level of control in the standards is being
determined by applying "Best Available Tech-
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nology" (BAT) decision criteria to indirect
dischargers. The primary focus of all standard
setting will be on incompatible toxic pollutants
with an initial emphasis on the 34 industries
and 65 toxic pollutants listed in the NRDC
Consent Decree, although additional industries
and pollutants may be added later. Local POTWs
or States are expected to specifically address
other pollutants which their investigations
indicate may be affecting performance of the
POTW or causing significant regional or local
human health or environmental problems. With
very few exceptions, EPA will issue guidance for
the control of non-toxic incompatible pollu-
tants, rather than explicit discharge limita-
tions.
0 EPA will strongly encourage local enforcement of
national pretreatnent standards through develop-
ment of POTW Pretreatment Programs. Development
of a local enforcement program will be a
condition for new construction grants. By 1983,
local programs will be required in accordance
with the Clean Water Act of 1977 and made a
condition of NPDES permits for POTWs required to
develop Pretreatment Programs. EPA or NPDES
States will provide for direct State or Federal
enforcement where local governments do not
assume or exercise enforcement responsibility.
0 Federal encouragement of State and local pre-
treatment programs will include financial incen-
tives for program development under Section 106,
201, and 208 and regulatory incentives under
Sections 402, 405, 301, and 309 of the Clean
Water Act.
° The regulation allows for modification by POTWs
of the discharge limits in categorical standards
for documented pollutant-removal efficiencies
attained by the POTW. A local pretreatment
program must be developed and approved and EPA
sludge management requirements (as well as cer-
tain other conditions) met. Proposed changes to
the General Pretreatment Regulations affecting
the requirements for modification of discharge
units is discussed in Appendix I.
NPDES State Options
Three options are available to an NPDES State in meeting
the requirement of implementing a State Pretreatment Pro-
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gram. Table 2 shows the available options. The option
that appears to be reasonable and effective in most cases
is option 1 where the State utilizes applicable POTWs to
conduct local Pretreatment Programs and concurrently con-
ducts programs for the balance of the Industrial Users
(IU's) not covered by POTW Pretreatment Programs. This
option requires a coordination of effort and maximizes the
use of existing personnel within municipalities with
in-house knowledge of local conditions.
The following deadlines apply to NPDES State programs:
0 March 27, 1979 - State submission to EPA for
Pretreatment programs. Applicable to States
with existing statutory authority.
0 March 27, 1980 - State submission to EPA for
Pretreatment programs. Applicable to States
requiring legislative changes.
The State will be required to develop, in a format sug-
gested by EPA, a description of the State Pretreatment
Program for implementing and maintaining the requirements
of 40 CFR, Part 403. The Program format will include a
description of program procedures, funding requirements
and Attorney General's statement setting forth legal
authority.
TABLE 2
State Program 1
Major POTWs
have Programs.
State assumes
responsibility
for a moderate
number of IU's.
NPDES STATE OPTIONS
State Program 2
Majority of POTWs
have Programs.
State assumes re-
sponsibility for
a minimum number
of IU's.
State Program 3
Few, if any POTWs
have Programs.
State assumes re-
sponsibility for
a maximum number
of IU's.
State coordina-
tion effort re-
quired - moderate
resources.
State overview
effort required -
few resources.
Detailed State
involvement re-
quired - maximum
resource invest-
ment.
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Planning Agencies & Pretreatment Responsibility
The Act provides for the establishment of a regulatory
program to assure that any non-domestic wastes discharged
into any POTW meet applicable pretreatment requirements.
Accordingly, a Water Quality Management Planning (208)
Agency may play a role in ensuring that all industrial
wastes discharged into POTWs comply with Federal pretreat-
ment standards promulgated under Section 307 of the Act.
Additionally, such a planning agency may assist municipal-
ities in establishing Pretreatment Programs.
In many cases, as a result of water quality requirements
or other factors specific to a plant or its NPDES permit,
it will be necessary for the municipality to establish
pretreatment requirements more stringent than the Federal
standards. The planning agency may assist the municipal-
ity in developing these pretreatment requirements and en-
suring their compliance.
Industrial Users (IU's) will be required to meet both
Federal and applicable State and local pretreatment
requirements. These requirements will be evaluated within
the Water Quality Management process in order to ensure
that effluent limitations for the POTW designated in its
NPDES permit can be met. Similarly, facilities' plans
will be reviewed and pretreatment will be an issue in
these reviews. In practice, (208) planning agencies may
work closely with municipalities, giving advice on how to
write pretreatment requirements for inclusion into the
municipal ordinance. However, to date, planning agencies
have not played an important role as hoped because of
budgetary constraints.
EPA standards are to be met nationally, regardless of
location. Where State requirements or water quality or
sludge requirements dictate, more stringent standards can
apply. To enforce these requirements, PL 92-500 set the
framework for the National Pollutant Discharge Elimination
System (NPDES). NPDES permits are required for each point
source discharge into waterways; this includes industrial
and municipal sources. The Act (PL 95-217) and the
General Pretreatment Regulations require that the NPDES
permit be the main enforcement vehicle for pretreatment
programs.
Effluent Limitations for POTWs
As a result of the fundamental changes instituted in 1972
by PL 92-500, POTWs are now required to obtain permits for
their discharges and to meet certain minimum effluent
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standards. Both POTW permits and effluent standards have
a direct bearing on the control of industrial pollutants
that must be undertaken within a particular system.
Since most POTWs discharge their effluents to navigable
waters, the Act requires that effluent limiting regula-
tions be promulgated. EPA has established rules and
regulations governing POTW discharges entitled "Secondary
Treatment Information." These regulations set forth
specific concentration limits to be achieved by secondary
wastewater treatment facilities. Limits are placed on
permissible discharge concentrations (or removal efficien-
cies) for BOD, suspended solids, and fecal coliform
bacteria. Additionally, an acceptable pH range for
secondary POTW effluents is set. The pollutants limited
in the regulation are generally susceptible to treatment
in POTWs. As a consequence, industrial pollutants Qnly
become important with regard to secondary treatment
standards when the contribution causes these pollutant
discharge limitations to be exceeded.
In many instances, State or local water quality standards
require a degree of treatment greater than that required
to meet the secondary treatment regulations, such as more
stringent BOD or suspended solids requirements.
Additionally, water quality standards often exist for pol-
lutants other than those regulated in the secondary treat-
ment standards, such as: phosphorous, nitrogen compounds,
metals, general toxicants, etc. Treatment requirements
necessary to meet water quality standards are normally
incorporated into the NPDES permit. Consequently, control
of applicable industrial pollutants can be extremely
important in helping the municipality meet its NPDES
permit requirements.
Procedures developed under Section 402 of the Act provide
details for implementation of the NPDES permit program.
Under the program, all point sources, including POTWs,
must obtain a permit to discharge to navigable waters of
the United States. NPDES permits are not required for in-
dustrial sources contributing to POTWs, but some limita-
tions placed on a POTW, beyond standard secondary treat-
ment, are aimed at controlling the effects of non-domestic
wastewaters.
The NPDES permit has several impacts on State or local
pretreatment policy. First, as a part of the permit
re-application, certain permittees must submit a plan to
the State Water Pollution Control Agency for the develop-
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ment and implementation of a pretreatment program. Such a
submission would include the following:
0 Legal Authority - The POTW must operate under
legal authority which will enable it to apply
and enforce the applicable sections of the Act
and any regulations implementing those sections.
0 Compliance Procedures - The POTW must develop
procedures to insure compliance with the POTW
Pretreatment Program.
0 Adequate Resources - The POTW must show suffi-
cient resources (funds and personnel) to operate
an effective Program.
Secondly, NPDES permit regulations require the permittee
to provide notice to the Regional Administrator of the
following:
0 Any new introduction of pollutants into such
treatment works from a source which would be a
new source as defined in Section 306 of the Act
if such source were discharging pollutants;
0 Any new introduction of pollutants which exceeds
10,000 gallons on any one day into such treat-
ment works from a source which would be subject
to Section 301 of the Act if such source were
discharging pollutants; and
0 Any substantial change in volume or character of
pollutants being introduced into such treatment
works by a source introducing pollutants into
such works at the time of issuance of the
permit.
This notice must include information on the quantity and
quality of wastewater introduced by the new source into
the POTWs, and any anticipated impact on the effluent
discharged from such works.
In addition to effluent limitations, the permit sets forth
special conditions that pertain to pretreatment activi-
ties. Municipalities are considered the first line of
defense for Federal Pretreatment Programs. For this
reason, they are encouraged to enact an ordinance giving
them the power to enforce Federal pretreatment standards
as well as State and local standards "not in conflict"
with Federal pretreatment standards. Areawide planning
agencies may also play an important role in both ordinance
development by municipalities as well as ensuring the
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pretreatuient requirements accomplish the goals of the Act.
In an efficient POTW system, a properly designed ordinance
acts as the impetus for a responsible approach to control
and pretreatment of industrial pollutants. A draft model
ordinance is included in this document.
Funding Mechanisms for Local Pretreatment Programs
To assist POTWs and States developing Pretreatment Pro-
grams, Federal grants under Sections 106, 201, 205, and
208 of the Clean Water Act have been made available.
Under the authority of Sections 201 and 20 8, Federal funds
can provide 75 percent of the eligible costs of developing
POTW Pretreatment Programs. Construction grants would be
used to fund development of a POTW Pretreatment Program
wherever the EPA Regional Administrator or a State deter-
mines that a Section 20 8 plan or areawide wastewater
management plan has not provided for the development of a
Pretreatment Program. It must be emphasized that only
program development costs are grant-eligible. The costs
for operating the program will be recovered through
applicable industrial dischargers by use of user-charges,
etc.
The 201 grants are provided through Section 201 of the Act
for assisting POTWs in the development of local Pretreat-
ment Programs to administer and enforce the Pretreatment
Standards.
Existing or pending Step 1, 2, or 3 grants may be modified
to provide for development of a municipal Pretreatment
Program where such a program has not been provided for in
a water quality management plan under Section 208 of the
Act.
The purpose of amending an existing or pending grant is to
recognize that a large proportion of the total number of
Step 1 grants expected to be made in this program have
already been awarded and to insure development of an
approvable Pretreatment Program at the earliest possible
date. Municipalities that have not yet entered the grant
process will be required to develop a Pretreatment Program
as part of the scope of their Step 1 grants. (If a
municipality is not in the grant process, then Federal
funding is not available.)
Step 3 grant payments will be withheld at the 90 percent
point, unless the particular POTW Pretreatment Program has
been approved. The last ten percent may be awarded if a
"good faith" effort is being made toward program comple-
tion.
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The 208 funds are available through Section 208 of the Act
for Areawide Waste Treatment Management. The Section 208
funds may be available to NPDES States to assist in devel-
oping any additional legal authorities, procedures, or
resources determined to be required from the October 10,
1978 State Submission. After a NPDES State Pretreatment
Program is approved, the State is no longer eligible for
208 funding for pretreatment. The Section 208 funds may
be passed through a NPDES State Pretreatment Program to
assist in developing Pretreatment Programs for POTWs not
eligible for 201 funding.
Resource Conservation and Recovery Act Considerations
Because the General Pretreatment Regulations will affect
the introduction of non-domestic wasts into POTWs, new
concern has developed for the sludges resulting from the
pretreatment of industrial wastes. Therefore, it is
important for industries and POTWs to be aware of applic-
able regulations.
The Resource Conservation and Recovery Act (RCRA) of 1976
(PL 94-580) provides EPA with the ability to control and
regulate all solid wastes, sludges, and hazardous residues
from the "cradle to the grave." The two basic objectives
of RCRA are:
° Protection of public health and environment; and
0 Conservation of natural resources.
Hazardous waste guidelines and regulations on identifica-
tion and listing (Sections 3001, 3002, and 3004) were pro-
posed December 18, 1978 and are currently being reviewed.
Under these proposed criteria, solid waste is considered
hazardous if it is flammable, corrosive, reactive, or
toxic. These regulations are of importance to industry.
EPA estimates there is an 80 to 90 percent chance that
current methods utilized by an industry to treat, store,
and dispose of its hazardous residues will be illegal by
early 1980. EPA will be looking hard at onsite disposal
operations by waste generators. EPA plans to issue 5-year
interim permits for existing facilities.
Regulations covering hazardous-waste management (Subtitle
C) and land disposal of non-hazardous wastes (Subtitle D)
are of major interest. The following breakdown lists
major areas of impact within Subtitles C and D of the
RCRA:
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Subtitle C - Hazardous-Waste Management
0 Section 3001 - Identification and listing of
hazardous wastes (December 1978) (ignitable,
corrosive, reactive, or toxic).
0 Section 3002 - Standards applicable to hazard-
ous-waste generators (December 1978) (records,
labeling, containers, chemical composition,
manifest system, periodic reporting of quanti-
ties and disposition of wastes generated).
0 Section 3003 - Standards applicable to hazard-
ous-waste transporters. Proposed regulations
(April 28, 1978) (records, transport labeled
wastes only, manifest system, transport to
permitted disposal site only).
0 Section 3004 - Standards applicable to manage-
ment of hazardous-waste treatment, storage and
disposal facilities (December 1978) (records;
reporting, monitoring, inspection, compliance;
history; location, design and construction of
facilities; contingency plans; operation, main-
tenance, ownership, personnel, and financial
responsibility; permit compliance.)
° Section 3005 - Permits for treatment, storage or
disposal facilities. Effective 6 months after
regulations are promulgated. (Permit applica-
tion, issuance, interim permits for facilities
in existence as of October 21, 1976 - complied
with preliminary notification requirements and
application filed prior to effective date of
regulations.)
0 Section 3006 - Authorization of State programs.
Federal guidelines to be published. In general,
States will regulate.
Subtitle D - Non-hazardous Waste Management - State
or Regional Solid Waste Plans
0 Section 4004 - Guidelines for plans. (Environ-
mentally sensitive areas such as: wetlands,
etc.; surface water; groundwater; air; land
application consideration such as pathogens, Cd,
etc.; disease vectors; safety.)
14
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II. DEVELOPMENT OF A PRETREATMENT PROGRAM
Introduction
The General Pretreatment Regulations implement various
sections of the Clean Water Act. The regulations apply
to:
0 Industrial pollutants discharged into or trans-
ported and introduced into POTWs;
° POTWs which receive wastewater from sources
subject to national pretreatment standards;
0 States which have National Pollutant Discharge
Elimination System (NPDES) programs approved in
accordance with Section 402 of the Act; and
0 Any new or existing source or discharger subject
to toxic and pretreatment standards.
The General Pretreatment Regulations have been developed
with the intent to assist local governments in developing
Pretreatment Programs which are fair, equitable, cost-
effective, and successful in preventing interference by
industrial dischargers and in reducing industrial
pollutant discharges through POTWs and into the environ-
ment. Development of approved local Pretreatment Programs
will result in better coordination among municipal and
industrial water pollution control programs and provide a
consistent and equitable nationwide approach toward
industrial users of POTWs.
The Pretreatment Regulations apply to municipalities,
whether or not the POTW is federally funded. All local
authorities operating POTWs with total flows in excess of
5 MGD and which receive industrial wastes from sources
subject to the national pretreatment standards will be
required to establish Pretreatment Programs. The estab-
lishment and enforcement of the local Pretreatment Program
is a condition of the NPDES permit. Also, where needed,
establishment of a Pretreatment Program is a condition of
any new construction grant.
POTWs with total flows less than 5 MGD are required to
develop Pretreatment Programs where special problems war-
rant such regulation and/or in order to modify national
standards to account for POTW removal of specific pollu-
tants. EPA and/or States will require POTWs in that range
to establish Pretreatment Programs where necessary due to
the economy of local control.
15
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The Clean Water Act provides for modification of national
pretreatment standards to compensate for removal attained
by POTWs. Where a local Pretreatment Program is approved,
the municipality can request authority to modify national
pretreatment standards to account for POTW removal. Modi-
fications are subject to a POTW's sludge management
program meeting applicable EPA criteria for sludge
disposal.
Two types of national pretreatment standards are being
developed, "prohibited discharge" standards and "categor-
ical" standards. A brief discussion of each follows.
Refer to Appendix I for a synopsis of the proposed changes
to 40 CFR, Part 403 affecting these standards.
0 Prohibited discharges apply to all non-domestic
discharges of pollutants to POTWs whether or not
the user is subject to other standards. Pol-
lutants include:
° Materials that may create a fire or explo-
sive hazard;
° Corrosive-type materials and no discharges
with pH < 5 (unless POTW is specifically
designed for such);
° Solid or viscous pollutants in amounts to
obstruct flow or interfere with operations;
° Discharges of any pollutant (including BOD
and SS) in volume or strength to cause unit
process upset and violation of POTWs per-
mit; and
° Heat discharges which will inhibit biolog-
ical activity or increase POTW influent
40°C (104°F).
0 Categorical Discharge Standards apply to exist-
ing and new sources in specific industrial
subcategories. Consideration will be given to
POTW inhibition/ interference in selecting the
pollutants to be regulated, but when the
decision to regulate has been made, numeric
discharge limitations will be based on best
available treatment technologies economically
achievable for industries to remove the pollu-
tant. All 34 industries listed in the 1979 NRDC
Consent Decree (modification of 1976 NRDC
Consent Decree) are candidates for categorical
standards.
16
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Federal categorical standards will normally deal
only with toxic incompatible pollutants. Table
3 lists the 65 pollutants where attention will
be focused initially. These toxic pollutants
are of the greatest environmental concern
because they:
° Occur in effluents, aquatic environments
and/or drinking water;
0 Lead to immediate or long-term health
hazards under certain conditions; and
° Have toxic effects (at high concentrations)
in human or aquatic organisms. Epidemiol-
ogy studies show some evidence of carcino-
genicity, mutagenicity, and/or teratogenic-
ity.
Where these 65 toxic pollutants are found to be incompat-
ible, they will be regulated in categorical pretreatment
standards of any of the 34 industrial categories that
discharge them. Current estimates indicate there are
approximately 30,500 industrial" dischargers to POTWs in
the 34 industrial categories to be considered initially in
the focus for pretreatment standards. Table 4 illustrates
the EPA estimate for the number of indirect dischargers.
It is important to note that, while all the industries in
the industrial categories will be subject to prohibited
discharge standards, it is anticipated that not all of the
industries will be subject to Categorical Pretreatment
Standards. Figure 1 graphically depicts the environmental
conditions impacted by pretreatment.
POTWs are responsible for addressing other toxicants
outside of the 65 national toxicants which may create a
specific problem within the POTW or from the discharge of
the POTW. The industrial inventory should specifically
address any other significant toxicants.
A large portion of the industries, potentially subject to
the national pretreatment standards, discharge to approxi-
mately 3,000 of the POTWs in the United States. About
1,000 of POTWs affected are providing levels of treatment
greater than secondary.
It is essential to the success of this national effort
that there be substantial cooperation and dedication at
all levels of government involved: municipal, State, and
Federal.
17
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TABLE 3
65 TOXIC POLLUTANTS LISTED IN NRDC CONSENT DECREE AND
REFERENCED IN 307(a) OF THE CWA OF 1977
Acenapthene
Acrolein
Acrylonitrile
Aldrin/Dieldrin
Antimony and compounds
Arsenic and compounds
Asbestos
Benzene
Benzidine
Beryllium and compounds
Cadmium and compounds
Carbon tetrachloride
Chlordane
Chlorinated benzenes
Chlorinated ethanes
Chloralkyl ethers
Chlorinated naphthalene
Chlorinated phenols
Chloroform
2-chlorophenol
Chromium and compounds
Copper and compounds
Cyanides
DDT and metabolities
Dichlorobenzenes
Dichlorobenzidine
Dichloroethylenes
2, 4-dichlorophenol
Dichloropropane &
Dichloropropene
2, 4-dimethylphenol
Dinitrotoluene
Diphenylhydrazine
Endosulfan and metabolites
Endrin and metabolites
Ethylbenzene
Fluoranthene
Haloethers
Halomethanes
Heptachlor and metabolites
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachlorocyclohexane
Isophorone
Lead and compounds
Mercury and compounds
Napthalene
Nickel and compounds
Nitrobenzene
Nitrophenols
Nitrosamines
Pentachlorophenol
Phenol
Phthalate esters
Polychlorinated biphenyls (PCBs)
Polynuclear aromatic
hydrocarbons
Selenium and compounds
Silver and compounds
2,3,7,8,-Tetrachlorodibenzo-
p-dioxin (TCDD)
Tetrachloroethylene
Thallium and compounds
Toluene
Toxaphene
Trichloroethylene
Vinyl chloride
Zinc and compounds
18
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TABLE 4
ESTIMATED NUMBER OF INDIRECT DISCHARGERS FOR 34 NRDC
CONSENT DECREE INDUSTRIES
Industry
Total Indirect Dischargers
1. Adhesives
2. Leather Tanning and Finishing
3. Soaps and Detergents
4. Aluminum Forming
5. Battery Manufacturing
6. Coil Coating
7. Copper Forming
8. Electroplating
9. Foundries
10. Iron and Steel
11. Nonferrous Metals
12. Photographic Supplies
13. Plastics Processing
14. Porcelain Enamel
15. Gum and Wood Chemicals
16. Paint and Ink
17. Printing and Publishing
18. Pulp and Paper
19. Textile Mills
20. Timber
21. Coal Mining
22. Ore Mining
23. Petroleum Refining
24. Steam Electric
25. Organic Chemicals
26. Pesticides
27. Pharmaceuticals
28. Plastic and Synthetic Materials
29. Rubber
30. Auto and Other Laundries
31. Mechanical Products
32. Electric and Electronic Components
33. Explosives Manufacturing
34. Inorganic Chemicals
500
170
535
40
120
54
56
6,586
498
238
79
106
2,700
100
6
1,211
63,000
24^
926
49
0
0
48
100
not available
36
158
221
504
75,000
71,000
8,000
0
120
TOTAL
232,403
NOTE: Numbers represent best available estimates,
March 1979.
19
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INOIUCT DISCHARGERS
FIGURE 1
OVERVIEW OF PRETREATMENT ENVIRONMENTAL PROBLEM
POTWs required to develop a Pretreatment Program must have
the Program developed and approved within three years
after the reissuance or modification of the POTW's exist-
ing NPDES permit but in no case later than July 1, 1983.
The Program requirements will be administered by the POTW
to assure compliance by Industrial Users with applicable
Pretreatment Standards. The following requirements will
be essential to obtaining an approved Program (40 CFR,
Part 403.8):
0 Evaluate and establish the proper legal author-
ity;
0 Establish procedures to ensure compliance with
the Pretreatment Program requirements;
20
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0 Determine and obtain sufficient resources to
carry out the program;
0 Develop an organizational structure;
0 Conduct an Industrial Waste Survey (IWS);
° Apply for authority to revise categorical
discharge limits if desired by the POTW;
0 Awareness of Fundamentally Different Factors
(FDF) determinations;
0 Submit a detailed description of the Pretreat-
ment Program for NPDES State or EPA review and
approval;
Each one of these requirements will be developed in detail
in subsequent sections of this document.
Legal Authority
One of the most significant factors in the establishment
of a viable industrial pollutant control program is the
provision of adequate legal authority to develop, admin-
ister, and enforce the program. Whatever agency is desig-
nated to operate the program must have sufficient power to
enforce its rules and regulations on Industrial Users and
to obtain the data necessary to monitor the degree to
which its rules are being complied.
If the service area of a public sewerage agency coincides
with the boundaries of a political subdivision (city,
county, etc.), the legal problems are usually relatively
simple. However, if the sewerage agency serves more than
one political jurisdiction, and particularly if it serves
them essentially as a wholesaler, the problems can become
more complicated. The solution depends to some extent on
the legal structure of the sewerage agency. If it is only
a voluntary association of independent municipalities, the
agency will generally only have such authority as has been
delegated to it by the agreement or compact creating the
sewerage authority or district. If the sewerage agency
has been established by a superior governmental juris-
diction, it then may be able to superimpose its authority
on that of the local municipalities.
In any case, some existing regional sewerage authorities
or districts are not able to legally interface with all
industries in the system because the industries discharge
to other municipal sewers which, in turn, connect to the
regional agency's system. In such instances, unless the
21
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agreements or contracts are changed, the development and
enforcement of ordinances controlling the discharge of
industrial wastewaters is legally the responsibility of
the individual municipalities in the system. They may
look to the regional agency for guidance in such matters,
but, nevertheless, the municipalities in these cases would
retain the legal authority to deal with industries in
their systems in these situations.
The POTW must operate under legal authority which will
enable it to apply and enforce the applicable sections of
the Clean Water Act and any regulations implementing the
Act. Legal authority such as statutes, ordinances, con-
tracts, agreements, or other written legal authorities
would be applicable. The legal authority established must
be binding upon industrial users, enforceable under
contract law or police powers and at a minimum should
allow the POTW to:
° Deny or condition any increased or new dis-
charges;
° Require compliance with applicable pretreatment
standards;
° Control industrial discharges to the POTW to in-
sure compliance;
° Require the'development of an industrial compli-
ance schedule for installation of required tech-
nologies;
0 Require submission of appropriate notices and
industrial sel'f-monitoring reports necessary to
assess and assure compliance;
0 Conduct, as necessary, inspections, surveil-
lance, and monitoring procedures to independent-
ly determine compliance or non-compliance.
Access to industrial records and entry to any
Industrial User's premises, where an effluent
source or treatment system is located, must be
authorized;
0 Independently assess or recover through judicial
action, fines, penalties, and injunctive relief
for non-compliance by Industrial Users with:
0 Pretreatment standards;
0 Inspections, entry, or monitoring activi-
ties;
22
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0 Any rules, regulations, or orders issued by
the POTW; and
° Any reporting or monitoring requirements
imposed by the POTW.
° Immediately and effectively halt or eliminate
any actual or threatened discharge of pollutants
to the POTW which would endanger health or
welfare and/or proper operation of the POTW.
All of these requirements must be met before a Pretreat-
ment Program will be approved by the approval agency.
Proposed changes to these requirements are discussed in
Appendix I.
Ordinances
Industrial Waste Ordinance History
The content of sewer use ordinances has evolved over the
years roughly paralleling the increased sophistication in
wastewater treatment facilities. Early ordinances were
outgrowths of local plumbing and health codes, the
contents of which were primarily devoted to standardiza-
tion of materials used in the construction of sewers and
connections thereto. Since sewage treatment was limited
to settling of solids material, the content of ordinances
at this stage focused on protection of sewers from
clogging, corrosion, and explosive hazards. Most ordi-
nances are built around these basic provisions and have
increased in scope as new needs have arisen.
With the advent of secondary treatment processes and the
development of anaerobic digestion, closer control over
certain dissolved organic and inorganic pollutants became
necessary to prevent inhibitory effects in these units.
In many instances, this type of control was provided by
setting concentration limits for the acceptable discharge
of critical pollutants.
The recent application of State and Federal water quality
standards, which in many cases require the removal of even
trace quantities of certain toxic pollutants, has caused
many POTWs to establish direct control over significant
industrial users. To gain information and control over
these sources, many ordinances are now including permit
provisions and self-monitoring provisions, or both.
Finally, as the costs of providing increased levels of
treatment have risen, many POTWs have been forced to ex-
pand their revenue base. This has taken the form of a
23
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user charge provision for contributors whose wastes have
greater strength than normal domestic sewage.
There is no single ordinance now in force that could be
considered typical of all or most ordinances currently
being utilized. Effective control of sewer use has been
obtained by both simple and complex ordinance structures.
Types of Ordinances
Two factors influence the size and content of a sewer use
ordinance. The first of these is whether the ordinance is
designed to be self-contained, or whether it simply states
general provisions and relies on separately published
rules and regulations for interpretation and implementa-
tion. The second factor is whether or not the ordinance
incorporates a permit system for either Industrial Users
or all users of the system. Obviously, an ordinance which
is self-contained will be a longer document than one which
is not. Permit systems, if used, will also add length.
Generally, smaller communities with relatively few
industries will use a self-contained ordinance and will
not employ a permit system. As the size of the POTW
increases or, more importantly, as the number of Indus-
trial Users increases, it becomes more difficult to
provide flexibility for the numerous individual differ-
ences between users within the ordinance document itself.
In these systems, a shorter document stating general
provisions may be more effective. This type of ordinance
is usually supplemented by a separate set of rules and
regulations that explain the responsibilities of users
with respect to the general provisions. The supplemental
regulations may take the form of a permit system with or
without industrial self-monitoring provisions. Permit and
self-monitoring requirements are particularly useful for
POTWs which are starting a comprehensive industrial
discharge control program to meet NPDES requirements and
have to comply with a schedule for the development of
information on Industrial Users. By using these pro-
visions, the enforcement authority can expand the coverage
of a smaller initial staff. In subsequent years, as both
field and laboratory capability is increased, more direct
methods of compliance monitoring can be used. Compliance
monitoring is usually the most effective tool for enforce-
ment of the ordinance.
If enforcement of the ordinance relies heavily on a permit
system and self-monitoring, then there should be an
adequate office and field staff to issue and review
permits and to check the periodic self-monitoring informa-
tion. If enforcement is based on analysis of samples
taken by the authority, then an adequate field and labora-
24
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tory capability is necessary. In all cases, sufficient
manpower should be available to follow-up violations
through the administrative procedures provided in the
ordinance. Only by following up on each violation to gain
compliance, will credibility for both the ordinance and
the enforcement authority be established.
Industrial Waste Ordinance
The ordinance is an essential element in the control of
industrial or non-domestic contributors into a POTW
system. In the development of a Pretreatment Program,
special care must be taken to develop an ordinance that
takes into consideration all essential elements particular
to that specific system. Once the ordinance has been
promulgated, it should be used as the vehicle for control-
ling all non-domestic contributors into the POTW system
and, when required, enforcement of its terms should be
applied against all situations of non-compliance.
An important element of the ordinance is the legal author-
ity under which it was developed. Sufficient legal power
is required to provide the needed weight to make the ordi-
nance effective.
With the advent of the General Pretreatment Regulations,
an acceptable sewer use ordinance should include all
functions relating to the industrial or non-domestic use
of municipal wastewater systems, including: industrial
use of the system, prohibitions, limitation, monitoring,
sampling and analysis, enforcement procedures, options,
procedural clauses, standards of construction, provisions
for control of infiltration and inflow, user charges, etc.
For the purpose of this guidance document, only the ele-
ments of an ordinance directly related to meeting pre-
treatment requirements will be expanded. On a case-by-
case basis, existing ordinances should be reviewed and
modified as appropriate to ensure the effective and
successful administration and subsequent enforcement of
pretreatment standards.
The model ordinance contained in Appendix III is self-con-
taining and in its full form could be used independently
as a separate document to administer and control non-
domestic users of a municipal wastewater system. The
model ordinance is divided into the following sections:
° General Provisions - includes purpose, policy,
legislation and definitions;
25
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0 Regulations - includes prohibitive discharge
standards, categorical standards, State require-
ments, excessive and/or accidental discharges,
and any applicable local requirements and op-
tions ;
0 / Fees and Charges - includes information applic-
able to administering a pretreatment program;
° Administration - includes reporting require-
ments, permits, monitoring, sampling, required
pretreatment facilities, etc.;
0 Enforcement - includes provisions and responsi-
bilities for accidental discharges, non-compli-
ance situations, permit revoking, show-cause
hearing, and legal actions;
0 Penalties - includes civil penalties, fines,
etc.;
0 Saving Clause; and
° Conflict.
Enforcement
POTWs will play the major role in insuring and enforcing
compliance by Industrial Dsers of pretreatment standards.
Where approved POTW Pretreatment Programs exist, State and
Federal , enforcement activities will serve in a backup
capacity. As discussed earlier, the POTW derives its
enforcement powers through the legal authorities estab-
lished in developing the Program.
The Approval Authority may request reviews of the Indus-
trial User self-monitoring reports in order to spot-check
the credibility of the POTW in detecting violations. The
Approval Authority will exercise its enforcement authori-
ties, when necessary, to correct inefficiencies or
insufficient enforcement at the POTW level. Actions will
be taken against a POTW for failure to act against an
industrial discharger in violation.
The Clean Water Act, besides granting enforcement
mechanisms and authority to EPA and NPDES States, also
provides, through Section 505, the authority for citizens
to bring civil action against violation of pretreatment
standards. It is essential to eliminating future problems
that this consideration be taken in account when develop-
ing a POTW Pretreatment Program and subsequent public
notification.
26
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The main vehicle for enforcing POTW Pretreatment Programs
will be through the POTWs NPDES permit. Compliance
schedules for developing a Pretreatment Program will be
incorporated into the permit. This schedule will not ex-
ceed 3 years. Other conditions enforceable through the
permit include:
° Executing adequate monitoring, reporting, and
inspection activities;
° Enforcing the standards when violation occurs;
° Maintaining a demonstrated percent removal of
pollutants where removal credits have been
granted;
° Insuring that sludge management practices do not
violate applicable criteria; and
0 Maintaining proper reporting for permit compli-
ance.
In addition, EPA has the authority to enforce against a
POTW for pretreatment violations by its Industrial Dsers
even if there is no POTW Pretreatment Program enforceable
through the POTW's permit.
It will prove to be a good business technique iJor munici-
palities to:
0 Develop sound pretreatment programs;
° Enforce the requirements; and
0 Continue POTW operation to maintain removal
credits and applicable sludge management.
Compliance Procedures
The POTW must develop procedures to insure compliance with
the POTW Pretreatment Program. These procedures should at
a minimum provide for (see Appendix I for proposed
changes):
° Systematic, comprehensive surveys of collection
systems to identify and locate all appropriate
ID's. This inventory shall be made available to
the Regional Administrator (EPA) and Director
(State) upon request;
° Identification of pollutant discharges by char-
acter and volume by the ID's identified by the
27
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survey. This information shall also be made
available to the Regional Administrator and
Director upon request?
0 Notification of IU's identified by the survey of
applicable pretreatment standards and sludge
management requirements;
0 Receiving and analyzing the self-monitoring re-
ports and other notices submitted by IU's?
0 Sampling and analyzing at random the effluents
from IU's;
° Conducting surveillance and inspection activi-
ties to insure compliance. These results shall
be made available to the Regional Administrator
or Director upon request?
° Following up conditions of non-compliance and
collecting additional data, samples, etc. suffi-
cient to provide admissible evidence for
enforcement proceedings?
0 Initiating court actions for.injunctive relief
or other injunctive relief for non-compliance;
° Implementing and enforcing other applicable
rules, regulations, etc.; and
0 Complying with requirements for public partici-
pation, notification, etc. This includes public
notice at least once every 12 months in the
largest local daily newspaper, of all IU's who
were not in compliance with pretreatment stand-
ards or other applicable pretreatment require-
ments during the preceding year. A summary of
enforcement actions during the same 12-month
period shall be included in the notification.
To insure that local Pretreatment Programs are estab-
lished, the State or appropriate permit-issuance authority
will develop compliance schedules as part of the NPDES
permit. A sample compliance schedule for development of
local Pretreatment Programs is given below.
Contents of the Compliance Schedule
The compliance schedule should require that the permittee
develop the authorities, procedures, and resources which
comprise an approvable POTW Pretreatment Program. The
activities listed in the model compliance schedule below
28
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summarize the more detailed requirements of the General
Pretreatment Regulation. It is recommended that the State
review the more detailed requirements set forth in the
regulations before developing the pretreatment compliance
schedule and insert additional schedule activities where
appropriate.
ACTIVITY COMPLETION
NUMBER ACTIVITY DATE
1. The permittee shall apply for
an amendment to its existing
Step 1, 2, or 3 Construction
Grant to acquire funding for
the development of a Pretreat-
ment Program.
2. Submit the results of an indus-
trial user survey including
identification of IU's and the
character and volume of pollu-
tants contributed to the POTW
by the IU's.
3. Submit and evaluate the legal
authorities to be used by the
permittee to apply and enforce
the requirements of the Clean
Water Act, including those
requirements of the Pretreatment
Regulation.
4. Submit a determination of tech-
nical information necessary
to develop an industrial waste
ordinance or other means of
enforcing pretreatment stand-
ards.
5. Submit an evaluation of the
financial programs and revenue
sources which will be employed
to implement the Pretreatment
Program.
6. Submit design of a monitoring
program which will implement
the requirements of the Pre-
treatment Regulation.
29
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ACTIVITY
NUMBER
ACTIVITY
COMPLETION
DATE
7. Submit a list of monitoring
equipment required by the POTW
to implement the Pretreatment
Program and a description of
municipal facilities to be con-
structed for monitoring or analy-
sis of industrial wastes.
8. Submit specific limitations
for prohibited pollutants
contributed to the POTW by
ID's.
9. Submit a request for Pretreat-
ment Program approval and
removal credit approval, if
desired.
The terms and conditions of the POTW Pretreatment Program,
when approved, shall be enforceable automatically through
the permittee's NPDES permit. Activity 1 of the model
compliance schedule (requiring the POTW to apply for a 201
grant amendment to acquire pretreatment funding) must be
included whenever the POTWs permit is modified to include
the pretreatment compliance schedule before the permittee
has acquired funding to carry out the program. Construc-
tion grant funding cannot be used to pay for work done by
the POTW before receipt of the 201 grant amendment. The
State (Approval Authority) may consider the option of
inserting, in the municipal permit along with the
compliance schedule for the development of a pretreatment
program, a clause stating that if the industrial waste
inventory required by the compliance schedule (activity 2)
demonstrates that the POTW does not have industrial waste
contributions which would be subject to pretreatment
requirements, the POTW would not be required to continue
development of the program.
Developing Compliance Schedule Dates
There are several time limitations imposed by the Pre-
treatment Regulation and the Construction Grants Regula-
tions (40 CFR, Part 35) which should be considered in
establishing compliance schedule dates. The Pretreatment
Regulation provides that the compliance schedule will
require the development and approval of a POTW pretreat-
ment program as soon as reasonable and within three years
30
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after the schedule is incorporated into a POTW's permit,
but in no case later than July 1, 1983. Since up to six
months must be allowed for the program approval process,
the compliance schedule date for submission of the
Pretreatment Program for approval (activity 9 of the
compliance schedule) should be two and one-half years
from the incorporation of a compliance schedule or Janu-
ary 1, 1983, whichever is sooner.
Provisions of the Construction Grants Regulations impose
what may be in some cases stricter time constraints on the
development of an approvable program. The Construction
Grants Regulation provides that no grantee may receive a
Step 3 grant after December 31, 1980, until it has devel-
oped an approvable Pretreatment Program. Thus, a permit-
tee which is scheduled to receive a Step 3 construction
grant in January 1981 will be required to develop an
approvable program by January 1981. However, if that same
permittee received a compliance schedule for the develop-
ment of a pretreatment program in December 1978, it would
be allowed, by the Pretreatment Regulation, an outside
date of June 1981 (i.e., two and one-half years from the
incorporation of the compliance schedule) to develop an
approvable program. In this case, the more stringent time
limitation (i.e., that posed by the Construction Grants
Regulation) would apply.
As the example above indicates, in developing the schedule
date for the submission of an approvable Pretreatment Pro-
gram, the State must use that date prescribed by either
the Pretreatment Regulation or the Construction Grants
Regulations which provides the shortest time for the
development of the Program. In addition, the State may
impose reasonable time limitations which are more
restrictive.
Regulatory limitations on the time frame for developing a
Program can be summarized as follows:
° Approval within three years from the incorpora-
tion of a pretreatment compliance schedule in
the municipal permit (application for approval
within two and one-half years);
° Approval by July 1, 1983 (application for ap-
proval by January 1, 1983);
0 Approval prior to payment of grants beyond 90
percent of the Step 3 funding (application for
approval six months before this date);
31
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Development of an approvable Pretreatment
Program by the end of the Step 2 grant for
certain permittees; and
0 Approval by whatever more stringent time limit
is imposed by the permit-issuance authority.
In addition, the Construction Grants Regulation imposes an
interim time limitation on the development of compliance
schedule activities 2 through 4. According to this
regulation, grantees with amended Step 1 grants must have
completed activities 2 through 4 by the time of applica-
tion for the Step 2 grant if Step 2 is to be awarded after
June 30, 1980.
Facilities required to develop a POTW Pretreatment Program
can generally be divided into four groups depending upon
the applicability of the time limitations discussed above
(see Table 5).
TABLE 5
OUTSIDE PRETREATMENT COMPLIANCE DATES BASED ON
CONSTRDCTION GRANT AWARDS AND PRETREATMENT REQUIREMENTS*
2-1/2 YEARS Ron INITIATION
OF COMPLIANCE schedule, jam.
31. 1983. OR 6 MONTHS BEFORE
THE FINAL lot OF STEP 3 GRANT
WHICHEVER IS SOONER
Activities 2-9 Du*
2 Step 1 Step 2
Awarded Awarded
S.'.'P )
Awarded
Activities
2-8 due by
applIcatIon
for step 3
i
•
i
•
•
Activity 9 Dim
•
«
•
i
3 Step 1
Step 2
Act Ivltles
2-i due by
applIcatlor
Tor step 2
.
Step 3
•
i
i
i
i
Activities S"9 t>ue
i
•
i
•
Awarded
Awardec
Awarded
k Step 1
Awarded
1
Step 2
Awardec
Activities
!-V due by
ipplIcatlon
For Step 2
Step }
Awarded
Activities
5-8 due by
appt icat ior
for step 3
i
i
•
•
i
Activity 9 Due
•
•
•
•
%
* Interim dates are negotiable and are established by the perml t-1 nuance authority
t
32
JUNE 30. 1980
Croup
1
OECEHBER 31. 1980
Step 2
Awarded
Step 3
Awarded
-------
Group 1 Facilities which will have received Step 1 and
Step 2 Construction Grants or amendments before
June 30/ 1980, and a Step 3 Construction Grant
before December 31, 1980.
If a grantee is scheduled to receive its Step 2 and Step 3
Construction Grants before June 30, 1980 and December 31,
1980, respectively, the Construction Grants Regulation
requires that, in most cases, the grantee have an approved
POTW Pretreatmenfc Program before it receives the last ten
percent of its Step 3 grant funding. This means that the
grantee would be required to apply for POTW Pretreatment
Program approval at least six months before it is
scheduled to receive payment beyond 90 percent of its Step
3 funding.
The Pretreatment Regulation provides that such a grantee
should request approval of the POTW Pretreatment Program
within two and one-half years from the incorporation of a
pretreatment compliance schedule into its NPDES permit, or
by January 1, 1983, whichever is sooner.
In developing the compliance schedule for permittees in
this group, States should determine which of the above
dates provides for the earliest development of a POTW Pre-
treatment Program. This date should then be used as the
pretreatment compliance schedule deadline for activity 9.
Dates for the remaining compliance schedule activities are
negotiable with the permittee. Generally, however, the
deadlines for completing activities 2 through 4 should not
exceed 15 months from the initiation of the compliance
schedule. \
Facilities receiving their Step 3 grant before June 30,
1980, shall be subject to the same time limitations de-
scribed above. 1
Group 2 Facilities which will have received Step 1 and
Step 2 Construction Grants before June 30, 1980,
and a Step 3 Construction Grant after December
31, 1980.
The Construction Grants Regulation provides that a grantee
which is scheduled to receive a Step 3 grant after
December 31, 1980, must have completed compliance schedule
activities 2 through 8 before it can receive its Step 3
funding. Therefore, in developing the compliance
schedule, the State should use as an outside compliance
date for activities 2 through 8 the date for completion of
the Step 2 grant as determined by the Construction ,Grants
compliance schedule as long as this date would not be
33
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later than two and one-half years from the initiation of
the pretreatment compliance schedule or January 1, 1983,
whichever is sooner.
The compliance date for pretreatment compliance schedule
activity 9 (request for Program approval) should not
exceed two and one-half years from the initiation of the
compliance schedule, January 1, 1983, or six months before
the permittee is scheduled to receive payment beyond 90
percent of its Step 3 funding, whichever is sooner.
Again, the interim pretreatment compliance schedule dates
are negotiable. It is recommended that the completion
date for activities 2 through 4 not exceed 15 months from
the initiation of the compliance schedule.
Group 3 Facilities which will receive a step 2 Construc-
tion Grant after June 30, 1980, and a Step 3
Construction Grant before December 31, 1980.
Under the Construction Grants Regulation, in order to re-
ceive a Step 2 grant after June 30, 1980, a grantee must
first have completed activities 2 through 4 of the pre-
treatment compliance schedule. The State should therefore
ensure that the compliance schedule dates for the
completion of activities 2 through 4 do not exceed the
scheduled date for the completion of the Step 1 grant
activities. The State may at its discretion impose a more
stringent time limitation for the completion of these
activities. It is recommended that the completion date
for activities 2 through 4.not exceed 15 months from the
initiation of the compliance schedule.
The Construction Grants Regulation provides that grantees
which will receive a Step 3 grant before December 31,
1980, must have an approved Pretreatment Program in order
to receive the final ten percent of the Step 3 grant
funds. The final compliance date for activity 9 of the
pretreatment compliance schedule therefore should be no
later than six months before the date upon which the
grantee is scheduled to receive payment beyond 90 percent
of the Step 3 grant funding, unless this date exceeds two
and one-half years from the initiation of the compliance
schedule, or January 1, 1983, in which case the final date
for activity 9 should be no later than January 1, 1983, or
two and one-half years from the initiation of the com-
pliance schedule, whichever is sooner.
The interim dates for activities 5 through 8 are
negotiable with the permittee.
34
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Group 4 Facilities which will receive a Step 2 Construc-
tion Grant after June 30, 1980, and a Step 3
Construction Grant after December 31, 1980.
The Construction Grants Regulation provides that in order
to receive a Step 2 grant after June 30, 1980, a grantee
must first have completed activities 2 through 4 of the
pretreatment compliance schedule. The State should,
therefore, ensure that the compliance schedule dates for
the completion of activities 2 through 4 do not exceed the
schedule date for the Step 2 grant application. The State
may impose a more stringent time limitation for the
completion of these activities. It is recommended that
the completion date for activities 2 through 4 not exceed
15 months from the initiation of the compliance schedule.
In order to receive a Step 3 grant after December 31,
1980, a facility in this category must also have completed
compliance schedule activities 5 through 8. The final
compliance dates for activities 5 through 8 should there-
fore be no later than the completion date for the
facility's Step 2 grant as determined by the Construction
Grants schedule. If the scheduled completion date for the
Step 2 Construction Grants activities is later than two
and one-half years from the initiation of the compliance
schedule or January 1, 1983, then the final compliance
date for activities 5 through 8 should not exceed January
1, 1983, or two and one-half years from the initiation of
the compliance schedule, whichever is sooner.
In establishing the pretreatment compliance schedule dates
for activities 5 through 8, sufficient time must be
allowed for the grantee to accomplish activity 9 (applica-
tion for Program approval) by January 1, 1983, two and
one-half years from the initiation of the pretreatment
compliance schedule, or six months before the permittee is
scheduled to receive payment beyond 90 percent of its Step
3 funding, whichever is sooner.
Resources
The POTW must show sufficient resources (funds and
personnel) to operate an effective Program. In respect to
funding sources, user charges will be required when
Construction Grant funds are involved. Increased costs
attributed to the POTW Pretreatment Program should be
passed on to Industrial Dsers by increasing user charges
and cannot be funded out of general operation and main-
tenance or other funding.
The Program must insure effective implementation. In some
limited cases, funding and personnel may be delayed if:
35
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0 The POTW has adequate legal authority and
procedures to carry out the Program require-
ments; and
0 A limited aspect of the POTW Pretreatment
Program does not need to be implemented immedi-
ately.
In such a case, the POTW must show that the required
funding and personnel will be available when needed.
Table 6 represents estimated POTW personnel requirements
to effectively operate a Pretreatment Program. It should
be noted that POTW staff requirements can be satisfied by
contracting with consulting engineering firms.
TABLE 6
POTW PRETREATMENT PROGRAM
PERSONNEL REQUIREMENT RANGES
POTW
Relative
Range
Flow
Number of
of Personnel
Range
Indirect
Requirements for
MGD
Dischargers
Pretreatment Program3
5
small
2-4
large
3-6
5-25
small
2-4
large
4-8
25-50
small
4-6
large
8-10
50
small
6-8
large
10-15
/
100
large
50-100b
Assume legal aspects require similar efforts regardless
b of size.
Special cases, such as large metro systems require more
indepth review.
36
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Tables 7 and 8 indicate an estimate of personnel
requirements for the development and operation of a POTW
Pretreatment Program for a sample POTW with a flow of
5 MGD and 10 Industrial Users.
TABLE 7
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES
POTW AVERAGE DESIGN FLOW: 5 MGD
NUMBER OF INDUSTRIAL USERS IN PROGRAM: 10
NUMBER
PERSONNEL REQUIRED
1. Supervisor - For delegating the responsi- 1
bilities and running the
program
Joint
2. Engineer - To review reports and assist 1
the Supervisor
3. Field - To take samples and do all 2
Crew field investigations
4. Lab - For analyzing samples part-time
Technician
5. Lawyer - For all legal action and part-time
proceedings
TOTAL PERSONNEL REQUIRED 3.5
37
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TABLE 8
ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PROGRAM ACTIVITY
POTW AVERAGE DESIGN FLOW: 5 MGD
NUMBER OF INDUSTRIAL USERS IN PROGRAM: 10
Program Activity
Frequency
of Act i vi ty
Per POTW
or 1.U.
Number of
Act ivi ties
Workdays
Per
Activity
Total
Workdays
1.
Develop Pretreatment
Program
once
1
15-25
25
2.
Conduct Industrial
Waste Survey
once
1
15-25
25
3.
Determine POTW
Removal Allowance
once
1
5-10
10
4.
Review IU Pretreatment
Faci1ity Proposal
once
10
0.5-2
20
5.
Review IU Compliance
Schedule Reports
(3)
30
0.5-1
30
6.
Review IU Final Compli-
ance Schedule Report
once
10
1-3
30
7.
Review IU Self-
Monitoring Report
2/year
20
0.5-1
20
8.
Samp1e 1U
(spot-check)
1/year
10
2-4
40
9.
Investigate IU
Non-Compli ance •
— — — —
5
1-5
25
10.
Enforcement
Actions
5
5-10
50
11.
Comply with Public
Notice Requirements
1/year
1
3-4
4
12.
Sample POTW Influent,
Effluent, and Sludge
1/year
1
5-10
10
13.
Prepare Self-Monitoring
Report for State
2/year
2
5-10
20
14.
Laboratory Analysis
of Required Sampling
1/year
25
2-3
75
TOTAL WORKDAYS = 384
384*220 WORKDAYS/PERSON/YEAR =1.75 Personnel
38
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Organizational Structure
The success of a POTW Pretreatment Program is dependent
upon the manner in which it was developed and the way it
is managed. The structure of the POTW Program varies with
the size and complexity of the system. For most larger
systems, a well-defined organizational structure having
personnel with specialized training and qualifications
should be developed. .For small systems, a loosely defined
structure with some part-time involvement and contract
services may be sufficient. The following discusses
large, medium, and small systems and suggests organiza-
tional structures.
Large Systems - Figure 2 presents an example of a
Pretreatment Program organization for a large POTW system.
The chart illustrates the need for a structured organiza-
tion to most effectively administer a control Program in a
large system. The larger and more complex the POTW, the
more higly developed and structured the organization
should be. Nevertheless, the components of an effective
organization demonstrated by the chart are essential for a
functional Program in any large system. Specific sections
of a Pretreatment Program organization for a large system
should include the following:
Administration
Administrative responsibility for the Program should rest
with a single person who has intimate knowledge of all
aspects of pollution control and wastewater treatment
within the jurisdictional boundaries. In municipal sys-
tems, usually the Director of Public Works or Superin-
tendent of Sanitation would be the appropriate individual.
In regional authorities, day-to-day operations are usually
administered by an Executive Director, General Manager,
Chief Engineer, or Superintendent.
Decisions pertinent to pretreatment policy should be made
by this individual drawing upon information supplied by
key subordinates. These subordinates should include
personnel such as the Chief Industrial Waste Engineer,
Chief Plant Operator, Chief Chemist, and other specialists
concerned with the Pretreatment Program, including field
investigators, engineers and attorneys. Specific functions
of the administration should include: basic policy
decisions; management of budgetary needs; personnel
administration; and coordination with the public and
appropriate municipal, State, and Federal authorities.
39
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MUNICIPAL
GOVERNMENT OR
BOARD OF
COMMISSIONERS
GENERAL
COUNSEL
DIRECTOR OF
POLLUTION
CONTROL
LEGAL
STAFF
TREATMENT PLANT
OPERATION AND HAINTAtNANtt
INDUSTRIAL WASTE
DIVISION
TECHNICAL
SERVICES
OPERATIONS
1. Administers permit program
a. Reviews applications
b. Issues permits
c. Maintains files
2* Evaluates pretreatoent practices
a. Reviews plans ans specifications
b. Checks operation of facilities
3. Coordinates enforcement activities
a. Analyses self-monitoring and compliance
monitoring data
b. Conducts conciliation meetings
c. Provides technical expertise in court actions
4. foruulates Industrial wastewater policy
a. Evaluates Federal and State standards
b. Recommends specific policy action
5. Administers user charge and Industrial cost
recovery programs
ENGINEERING
RESEARCH &
DEVELOPMENT
LABORATORY
MONITORING
1. Develops Industrial wastewater
a. Reviews applicable records and files
b. Checks industrial plant in field
2. Conducts in-site monitoring and inspection
a. Scheduled monitoring for compliance,
user charge, indusrtial cost recovery
for self-oonitoring reports
(1) Composite sample with flow measure-
ment over several days
(2) Once per year for all major
industries if possible
b. Un-seheduled surveillance for compliance
(1) Composite or grab sample with or
without flow measurement as often as
possible
c. Demand monitoring as required
FIGURE 2
TYPICAL ORGANIZATION OF A LARGE POTW SYSTEM
-------
Industrial Waste Division
The individuals comprising the industrial waste division
represent the heart of any Pretreatment Program. General-
ly, the division is comprised of engineers who conduct the
Program and field inspectors and laboratory technicians
that provide the necessary support for effective opera-
tion. The engineering staff engaged in this activity
should be the most knowledgeable group of individuals on
all aspects of industrial wastewater within a given
system. They should be thoroughly familiar with: the
operation of and wastewater produced by industries in the
system; pretreatment facilities utilized by the indus-
tries; applicable provisions of Federal and State
standards and local ordinances; and characteristics of the
treatment processes utilized in the system. Generally,
this group will formulate industrial wastewater policy and
recommend specific policies to the administrator for
implementation. The industrial waste division also
generally coordinates enforcement activities and provides
necessary technical expertise to the legal staff in court
actions.
Staff levels vary considerably depending upon size, fiscal
resources, organizational structure, number and type of
industries present, and the specific NPDES permit require-
ments of the system. The largest POTW systems in the
country have as many as 50 to 80 individuals reporting to
the Chief Industrial Waste Engineer. Smaller cities and
regional authorities obviously require smaller staffs,
with the level generally varying from approximately 1/2 to
2 individuals per 10 MGD, depending upon the factors
indicated above.
Field Monitoring
The organization should include a group of inspectors
whose only responsibility is the monitoring of non-
domestic contributors. These field investigations should
include initial plant surveys, data acquisition at the
plant site, and all follow-up monitoring and inspection
activities.
The field monitoring section should have total responsi-
bility for surveillance of non-domestic sources. Specific
functions to be carried out by field inspectors include:
sampling and flow measurement at wastewater sources;
inspection of plant and pretreatment operations at the
time of sampling; maintenance of specialized field
equipment; and performance of specialized monitoring
activities in connection with locating the source of
problems within the system, enforcement activities, etc.
41
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The Metropolitan Sanitary District of Greater Chicago
provides uniforms and badges for its inspectors to formal-
ize their status in the community. This can be helpful in
gaining quick access to industrial facilities when
necessary. In any event, all field inspectors should be
provided with proper credentials which should be carried
for identification at all times.
Laboratory
A Pretreatment Program will generally require some
expansion of the typical laboratory required for control
of biological treatment processes. As a result, addi-
tional analytical equipment and personnel may be necessary
to carry out analyses in conjunction with a monitoring
program. Frequently, these personnel are incorporated into
the existing laboratory organization, so that coordination
with the industrial waste division is essential.
Some POTWs are structured so that laboratory personnel
engaged in industrial wastewater analysis report directly
to the Chief Industrial Waste Engineer. Such an arrange-
ment may be preferable for improved communications and
delineation of responsibility.
Where this function is part of the overall laboratory
responsibility, data must be reported to all the indus-
trial waste division so that pretreatment performance can
be evaluated. If any pretreatment standard violations are
suspected, then analytical data would also be passed on to
the legal staff for evaluation and possible enforcement
action. The specific functions of the laboratory in
connection with non-domestic wastewaters include: analy-
sis of field samples; maintenance of laboratory equipment;
and proper record keeping and reporting in support of
industrial waste division activities.
Legal
One or more attorneys may be required to provide legal
services with regard to enforcement of pretreatment
standards and regulations. Attorneys may not have full-
time responsibility in connection with enforcing pretreat-
ment standards and requirements. Instead, the legal staff
may serve the dual function of supporting legal action
against violators, and general legal support of other
activities in the water pollution control area.
For enforcement activity, the legal group should receive
information directly from the industrial waste division
staff, as well as from field monitoring and laboratory
42
-------
personnel. The special functions of enforcement include:
assistance in evaluation of suspected violations; noti-
fication of suspected violators; participation in follow-
up meetings with violators; preparation of briefs for
litigation; and court action.
Medium Size Systems
As the size of a POTW decreases, the operation of the
Pretreatment Program becomes less of a separate entity and
more entwined in the overall operation of the wastewater
collection and treatment facility. Because of limited
resources, administrative and laboratory personnel
generally become responsible for both plant and operations
and control of pollutants contributed by non-domestic
sources. Figure 3 provides a typical organization chart
for a medium-size POTW system.
Since fewer individuals are involved and the organization
is not as structured as in large systems, the essential
functions of the Pretreatment Program must necessarily be
performed in conjunction with other duties. Among these
functions is the use of a field monitoring group to carry
out plant inspections and effluent sampling. The field
crew is essential for all of the specific monitoring re-
quirements necessary to control industrial contributors to
the system.
Other specific functions of a control Program maintained
in a medium-size system include enforcement, summary and
analysis of industrial data, and user charge administra-
tion. However, unlike the large system organization where
individuals or groups of individuals have well-defined
task assignments, the Pretreatment Program for a medium-
size system will most likely contain individuals with
multiple functions and responsibilities. Some medium-size
systems with many industrial contributors may find it
necessary to have an Industrial Waste Engineer or other
individual specifically assigned to the control of
discharges from.these facilities.
Small Systems
i
A large proportion of municipal POTWs that treat non-
domestic wastes fall into the small system category. In a
small system, adequate resources would generally not be
available to have a group of people with sole responsi-
bility for the Pretreatment Program. Instead, all
elements of a Pretreatment Program that are delineated for
large systems would have to be handled by personnel
currently employed by the municipality. This is not
unrealistic, since quite often a small system would be
concerned with only a few or even a single industrial
contributor.
43
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FIGURE 3
TYPICAL ORGANIZATION OF A MEDIOM-SIZE POTW SYSTEM
Figure 4 illustrates an organizational arrangement for a
typical small system. The structure shown is only one of
several that could be effectively utilized in a small
municipality. The variety encountered in the organization
of small local governments suggests that a number of
different arrangements may be equally effective in the
administration of a Pretreatment Program.
In small systems, generally one person has responsibility
for monitoring and all specialized analysis is contracted
to commercial laboratories. Similarly, the Director of
Public Works would most likely have overall administrative
44
-------
FIGURE 4
TYPICAL ORGANIZATION OF A SMALL POTW SYSTEM
responsibility in addition to performing the functions of
the Industrial Waste Engineer. A town engineer may be
utilized for industrial waste control, reporting either to
the Director of Public Works or directly to the governing
body. The town engineer may be a full-time employee if
the needs of the system dictate, but he is most frequently
a consulting engineer under a retainer-type contract to
the municipality. Specialized engineering requirements
would usually be provided by either the town engineer or
another consultant, with legal questions being handled by
the municipal attorney.
45
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Conducting an Industrial Waste Survey
Identifying and Notifying Industrial Psers
The POTW is required to assume responsibility for identi-
fying Industrial Users of the POTW which might be subject
to Federal, State or local pretreatment standards and
requirements. One of the first steps is identifying and
locating IU's by using existing files and records such as:
0 Existing Sewer Authority Files;
0 City and State Industrial Directories;
0 Labor Department Records;
° Property Tax Records;
° Chamber of Commerce Rosters;
° Census Bureau Records;
° Local Telephone Directories;
0 Water Consumption Records;
° Dun's Market Identifiers - Dun & Bradstreet;
° Part 4 of the Municipal Permit Application Form;
° Informative Data Company (IDC), St. Louis, MO;
and
° Utility Company Records.
Through whatever means it chooses, the POTW should insure
that all IU's are identified which fall within one or more
of the 34 industrial categories listed in the NRDC Consent
Decree as well as other high potential toxicant discharge
facilities for which standards may be promulgated. In
addition, at a minimum, the POTW should identify all IU's
which contribute pollutants which might be subject to
Federal Prohibitive Discharge Standards, as indicated in
the General Pretreatment Regulations, or which might
otherwise interfere with the operations of a POTW or pass
through the POTW in quantities which violate applicable
water quality standards or sludge uses.
The information obtained about the industry during the
course of this identification process will help develop a
data base for the Industrial Waste Survey (IWS). If the
existing records and files are complete, the following
information should be obtained:
° Location of the industrial facility;
° Standard Industrial Classification (SIC) Code;
° Product line;
° Product volume;
° Indication of wet or dry industry; and
° Water usage of wet industry.
46
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This data can be utilized to serve as the basis for the
questionnaire survey which is the first element of the
Industrial Waste Survey. The master inventory list of
industries derived through this identification process
should be reviewed to eliminate dry industries from
further consideration. However, dry industries that use
toxic pollutants must be inspected to insure proper spill-
control and that preventative measures have been taken to
protect against accidental discharges or any contamination
of cooling water streams.
At this stage, the POTW may also wish to distinguish be-
tween major and minor IU's. Major IU's must, at a
minimum, include all IU's subject to Federal Categorical
Pretreatment Standards. Minor IU's might include IU's
exclusively subject to State or local pretreatment
standards, and IU's not regulated by Federal Categorical
Pretreatment Standards which might present a potential
interference to the POTW.
*
A preliminary breakdown between major and minor contribu-
tors for those IU's not subject to Federal Categorical
Pretreatment Standards generally can be made on the basis
of flow, which in turn can be estimated from water usage.
A minimum flow value, such as 25,000 or 50,000 GPD could
be used as a first step in a major-minor delineation.
However, other factors including water quality standards,
potential for the discharge of toxicants, and the POTW's
sensitivity to a particular type of wastewater, must also
be taken into account.
An industrial discharger may also be considered major if
it constitutes more than 5 percent of the influent to the
POTW. Establishing a reliable list of major IU's on this
basis ultimately requires direct contact with industry,
and detailed analysis or evaluation of each plant's waste-
water. Nevertheless, at this stage of the survey, any
initial classification should favor viewing IU's as major
sources.
Once the appropriate IU's have been identified, the POTW
must ensure that they are notified of all applicable
existing pretreatment standards. Also, the POTW must have
procedures for notifying IU's when new standards are
established. Acceptable procedures would include a
mailing list for IU's or an arrangement with the POTW
requiring it to provide the requisite notice. Where there
is a need for testing of a toxicant because of potential
health or environmental problems, EPA or the State will
provide the most acceptable method for analysis.
47
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The level of effort required to complete the IWS is a
function of the number of industries discharging into the
POTW and the extent of cooperation and understanding be-
tween the municipality, State, and industry. A good
public relations program with industry, Chamber of
Commerce, and the public is a critical part of an IWS. It
should be initiated as soon as possible and maintained at
all times since it stimulates industrial cooperation and
provides additional input for the entire industrial waste
program.
The primary objectives of an IWS include:
0 Confirm preliminary industrial identification
information;
0 Identify the character and volume of pollutants
contributed to the POTW by the IU's; and
° Develop a data base and provide necessary input
for development of the industrial waste ordi-
nance.
The task of completing a thorough IWS is complicated by
the fact that approved analytical and monitoring tech-
niques are not yet available for use in providing a
quantitative analysis of the presence of many of the
pollutants of concern. Where there is a need for more
testing of a toxicant because of potential human health or
environmental problems, then EPA or the State will provide
the most acceptable method for analysis.
In recognition of this problem, it is recommended that
POTWs follow a two-phased approach in carrying out the
IWS. Initially, prior to the development of sampling and
analytical techniques for many of the complex pollutants
regulated within the 34 industrial categories (and approx-
imately 400 industrial subcategories) set forth in the
1979 NRDC Consent Decree, the POTW should focus on
developing qualitative data on the presence of these
pollutants and quantitative data on those other pollutants
which interfere with the operation of the treatment works.
Then, in phase two, as Federal pretreatment standards for
the 129 pollutants in the 34 industrial categories emerge,
along with recommended sampling and analytical techniques
for such pollutants, the POTW, where necessary, should
elicit specific quantitative information on the character
and volume of pollutants discharged by IU's regulated by
Federal standards where there is an indication that such
information is needed. A POTW is discouraged from
analyzing or requiring dischargers to analyze for all
toxicants.
48
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It is suggested that the POTW follow the steps below in
implementing this two-phase IWS.
Industrial Waste Questionnnaire
Phase 1:
° The industrial waste questionnaire is the
primary mechanism for obtaining the initial
qualitative data on the industrial pollutants in
question. In developing a questionnaire form,
the degree of detail desired, which usually
relates to the size and complexity of the POTW
system, should tie considered. At a minimum,
information should be requested on: production,
employment, raw materials, catalysts, water
usage, number and location of sewer connections,
and wastewater discharge characteristics (type
and approximate quantity of pollutants dis-
charged by the facility). This information
should be obtained entirely from knowledge of
the facility's process and should not require
any sampling at the source. If Section IV of
NPDES Standard Form A has not yet been completed
for each major discharger in the system, it can
be conveniently attached to the questionnaire.
The questionnaire is a very important part of
the IWS. The information included in the ques-
tionnaire may, in many instances, constitute the
first data available on the characteristics of
the discharge from a specific facility. In
municipalities where there has not been a pre-
vious enforcement program, industries in general
know very little about their wastewater charac-
teristics. The questionnaire program provides
the incentive for them to discover, at least
through a qualitative analysis, the materials
contained in the wastewater that they are
discharging to the sewer system. This data also
provides the basis for the POTW to decide which
pollutant parameters require monitoring in the
subsequent sampling program.
A model industrial waste questionnaire,
developed by Black and Veatch, has been modified
and is included in Appendix IV to serve as a
guide.
The State may require additional information
concerning the industrial discharges. A ques-
tionnaire developed for one POTW system may not
49
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be completely applicable for another. The
questionnaire should be mailed to each industry
identified during the initial survey phase.
Some industries may be reluctant to divulge the
information requested on the IWS questionnaire.
An effective method for improving efficiency in
obtaining reliable data from the questionnaires
is to include a cover letter explaining how the
questionnaire relates to the specific type of
establishment in question. The letter would
direct their attention to anticipated areas of
concern with respect to that establishment, thus
aiding in the completion of the questionnaire.
Also, the industry should be informed that it
may request that some information remain con-
fidential. The POTW will have the authority to
decide whether this information should be
classified as confidential. Where the confiden-
tiality of information is in question, it may be
practical to have the industry submit the
confidential information on a separate sheet of
paper and indicate this on the questionnaire.
It is not expected that all industries will com-
plete and return the questionnaires. In order
to promote a high rate of return, the surveying
agency may have to follow up with phone calls or
scheduled plant visits. Although in one
instance a 90 percent followup was required,
experiences around the country have indicated
that between 40 and 60 percent of the industries
will require followup. This followup effort can
take about work-day per questionnaire if done
by phone, and about two work-days if done by
scheduled plant visit.
Identification of Pollutants Causing Interfer-
ence - The POTW should review the qualitative
information supplied through the questionnaire
and identify those pollutants subject to
possible regulation by Federal Categorical
Pretreatment Standards and those pollutants
which, to the best of the POTW's knowledge,
might cause interference with the operation of
the POTW or pass through the POTW untreated in
unacceptable amounts (e.g., in amounts which
would violate applicable water quality standards
or interfere with sludge use). Pollutants
identified in Group 1 as being subject to pos-
sible regulation by Federal standards will be
addressed in phase two of this IWS which calls
50
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for collecting quantitative discharge informa-
tion from the regulated ID's.
The POTW should follow up on those pollutants
identified in Group 2 by sampling the influent
to the POTW to determine which of the pollutants
in this group appear in significant concentra-
tions in the influent to the POTW. In carrying
out this sampling, the POTW should use those
sampling and analytical techniques set forth in
the Guidelines Establishing Test Proce-dures for
the Analysis of Pollutants (40 CFR, Part 136),
and other techniques approved by EPA. If a
pollutant appears at such a low concentration
that it is highly unlikely that it would have an
adverse effect on the operation of the POTW or
pass through untreated, or if the pollutant does
not appear at all in the influent to the POTW,
it may be excluded from further consideration.
Additional analysis will be needed to determine
if the remaining pollutants actually interfere
with the POTW operation or emerge from the POTW
in amounts which are unacceptable. Where the
POTW identifies pollutants posing an interfer-
ence or pass-through problem, it should impose
effluent limitations upon IU's contributing such
pollutants.
Compile Data
Phase 2;
The second phase of the IWS begins with the promulgation
of Federal Categorical Pretreatment Standards applicable
to an IU within the POTW system. As these Federal
standards are promulgated, the POTW should require that
ID's belonging to the applicable sub-categories submit a
report required by the Pretreatment Regulations. These
reports will indicate the results of the ID's quantitative
analysis of its effluent. The IWS will continue to be up-
dated as additional Federal standards are promulgated and
additional reports and data are submitted.
Where resources permit and it is believed to be necessary,
the POTW should carry out a sampling and analysis program
to verify the reports submitted by the ID's. Sampling and
analysis by the POTW is desirable for several reasons:
0 Sampling done by industry may not provide reli-
able data to serve as a base line for the con-
51
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tinuing compliance monitoring program. It is
essential that the initial sampling program
obtain accurate representative data, in that
this information will form the basis for
specific stipulations in the ordinance, develop-
ment of the user charge system, and the estab-
lishment of a viable enforcement program.
0 Data gathered by a single source would be more
consistent in that the same sampling and
analytical procedures would be used.
° Economy of scale may be realized by having one
central source conduct all the sampling and
analysis required.
In summary, the agency involved in conducting an IWS will
follow these procedures:
0 Identify IU's with existing information;
° Develop an Industrial Waste Questionnaire and
cover letter;
0 Mail the questionnaire to all ID's identified as
potentially requiring pretreatment;
0 Receive the completed questionnaires and review
for completeness and make determinations on con-
fidential information;
0 Phone industries that have failed to return
questionnaires;
0 Phone or visit each industry which has filed an
incomplete report;
° After the questionnaire is complete, use it as a
basis for identifying pollutants possibly
subject to Federal pretreatment standards and
pollutants which interfere with the operation of
the POTW or pass through inadequately treated;
° Sample POTW influent (or effluent, where approp-
riate) to identify pollutants which may cause
interference or pass-through problem;
0 Develop effluent limitations where appropriate
to prevent interference or the pass-through of
pollutants;
52
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0 Receive and review self-monitoring and com-
pliance reports submitted by ID's; and
0 Verify the results of reports submitted by IU's
and update the IWS.
A procedural flow diagram is presented in Figure 5 which
illustrates the function of the industrial waste question-
naire in developing a Pretreatment Program.
The information obtained in the IWS is essential for the
development of an industrial waste ordinance.
POTW Removal Allowance >
Modifications of Categorical Pretreatment Standards to
allow for removal of a specific pollutant by a POTW is
provided for in the General Pretreatment Regulation
Section, 403.7. Revision of a particular standard will be
on a case-by-case basis. Removal allowances should be
requested when the POTW submits its program for approval
or when an approved POTW's permit is reissued. Proposed
revisions to the General Pretreatment Regulation would
substantially alter Section 403.7; review Appendix I for
these anticipated changes.
The Approval Authority will receive, review, and evaluate
the requests for removal allowance to determine if the re-
moval allowance requested is justified and documentation
provided is sufficient to warrant the revised limit. It
should be noted that the value of modifying a standard may
be questionable if, in fact, the subsequent cost to indus-
try for funding required sampling, analysis, documenta-
tion, etc. exceeds the reduction in the cost of technology
installed at the industry to meet the modified standard.
The Approval Authority will advise the POTW that a prelim-
inary engineering review of the potential savings to
industry versus the costs of documenting the removal
allowance be made prior to embarking on the modification
submission. The POTW should also consider the financial
implications of the impact of the removal allowance on
municipal sludge disposal or utilization practices and
that all industries discharging a given pollutant must be
considered in any determination.
The review of removal allowance submissions will focus on
the existing performance record of the particular POTW and
potential causes for any previous upsets of permit viola-
tions. An analysis of the potential capabilities of pol-
lutant removal through the unit processes and flow train
of the POTW will be made. An in-depth review of the per-
53
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FIGURE 5
PROCEDURAL FLOW DIAGRAM FOR INDUSTRIAL WASTE SURVEY AND
ORDINANCE AS PART OF THE OVERALL DEVELOPMENT OF AN
INDUSTRIAL WASTE CONTROL PROGRAM
-------
formance data (solid/liquid) presented should be made.
Some backup analytical support is helpful in determining
the validity of the data presented. The potential impact
of the removal allowance on the sludge management tech-
niques used at the POTW should be considered.
Requirements for Removal Allowance
POTW removal of a specific pollutant means reduction or
alteration of the nature of the pollutant by the POTW to a
less toxic or harmless state prior to discharge. This
reduction or alteration can be accomplished by physical,
chemical, or biological processes either specifically
designed into the POTW or incidental to the operation.
Removal allowance may be given for in-line treatment of
biodegradable pollutants where removal can be calculated
even if no detectable amount is found in the POTW influ-
ent. It should be made clear that dilution will not be
considered in approving removal allowance.
Also, the inability of monitoring or detection equipment
to analyze diluted nondegradable pollutants in influents
or effluents will not be considered as meeting removal
criteria.
The following requirements must be met in order for a POTW
to revise pollutant discharge limits in Categorical Pre-
treatment Standards (proposed revisions to these require-
ments are discussed in Appendix I):
0 The POTW has an approved Pretreatment Program;
0 The POTW provides consistent removal (removal
achieved for 95 percent of the samples taken) of
each pollutant for which a credit is requested;
0 POTWs with combined sewers or regular bypasses
must be in the process of correcting these
conditions. At a minimum, an approved facility
plan which includes treatment and control of
bypasses or an application submitted for a Step
• 2 Construction Grant to implement the plan will
be required. POTW removal allowances will not
be considered where efforts are not being made
to minimize pollution from bypasses. EPA's
policy on this is covered in the Office of Water
Programs Operations document, "PRM 7534," also
known as "Program Guidance Memorandum 61,"
December 16, 1975;
° Sludge management will remain in compliance with
applicable regulations, criteria, etc.;
55
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° Approval of removal allowances requested will
not result in the POTW violating water quality
standards applicable to the pollutant; and
° Grants from funds authorized from September 30,
1978 must have completed the analysis required
by the Act and demonstrate that the removal
allowance claimed will not preclude the use of
alternative or innovative technology.
Supportive data and information supplied to the Approval
Authority in consideration of the POTW's application to
revise discharge limits must include the following:
0 The pollutant(s) for which modification is
requested;
0 Operation data on influent and effluent and any
other information which demonstrates consistent
removal for specific pollutant(s) in question.
The data presented must (proposed revisions,
Appendix I):
0 Represent yearly and seasonal conditions;
° Represent quality and quantity of normal
effluent and influent flows. Wet weather
projections, if applicable, should be
included; and
° Be obtained through composite samples taken
on each of three consecutive, days during
each applicable season. A minimum of 12
discrete samples should be taken at equal
time intervals over a 24-hour period and
proportional to flow. Grab samples may be
used where composite sampling is not
appropriate (ex., cyanide, phenol, etc.).
° Analysis performed in obtaining data presented
for modifying standards should be conducted ac-
cording to procedures prescribed in the particu-
lar standard, 40 CFR, Part 136 and amendments,
and/or the EPA publication, Sampling and Analy-
sis Procedures for Screening of Industrial
Effluents for Priority Pollutants, April 1977.
In some cases, it is anticipated that standards
may not require direct analysis of certain
priority pollutants but will utilize indicators
such as Chemical Oxygen Demand (COD), Total
Organic Carbon (TOC), etc.;
56
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0 List of industrial categories and number of
users in each subcategory and pollutant identif-
ication;
° Proposed alternative pretreatment limits;
0 Data showing concentrations in POTW sludge and
air emissions where applicable (similar sampling
techniques as used for liquid stream);
° Specific description of POTW's current sludge
disposal methods, including data indicating con-
tinuing compliance; and
° Certification that the pollutant removal effi-
ciencies and alternative pretreatment limits be
calculated in accordance with EPA regulations
and guidelines.
The following formula is recommended by EPA in calculating
the proposed pretreatment limit for a specific pollutant:
where:
Y = Revised discharge limit for specified
pollutant (mg/1).
X = Pollutant discharge limit specified in the
applicable Categorical Pretreatment Standard
(mg/1).
r = Consistent POTW removal rate percentage ex-
pressed in decimal form.
Variances from Categorical Pretreatment Standards: Funda-
mentally Different Factors (FDF) Determinations
This section does not apply directly to POTWs but is in-
cluded here for general information.
In establishing Categorical Pretreatment Standards for
existing sources, EPA will take into account all the
information it can collect, develop, and solicit regarding
the factors relevant to pretreatment standards under Sec-
tion 307(b). In soqje cases, information which may affect
the pretreatment standards will not be available or, for
other reasons, will not be considered during their
development. As a result, it may be necessary on a case-
by-case basis to adjust the limits in Categorical Pre-
treatment Standards, making them either more or less
stringent, as they apply to a certain IU within an
industrial category or sub-category. The modified stand-
57
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ard will, in effect, acknowledge that the IU in question
is fundamentally different from other facilities con-
sidered by EPA in developing the Categorical Standards.
Any interested party (including the 10) believing that the
factors relating to an IU are fundamentally different from
the factors considered during development of a Categorical
Pretreatment Standard applicable to that user and,
further, that the existence of those factors justifies a
different discharge limit from that specified in the
applicable Categorical Pretreatment Standard, may request
a FDF variance or such a variance request may be initiated
by EPA.
Where a NPDES State has an approved Pretreatment Program,
it will be responsible for receiving requests for FDF
variances and denying such variances where appropriate.
Authority to approve such requests is reserved for EPA,
but the State will have authority to recommend approval of
the variance to EPA.
Dpon receipt of a FDF variance request, the State should
review the request for completeness. Where the State
determines that the request is not complete or that its
substance is in some way deficient, it should give the
requester thirty days to make the appropriate corrections.
The State may extend the time for making corrections at
its discretion. If the requester does not make correc-
tions within the time period specified by the State, the
State should deny the requests and so notify the
requester.
Requests for variances with- supporting evidence must be
submitted in writing to the State. Requests must be
submitted within ninety days after EPA promulgates the
particular Categorical Pretreatment Standard. Requests
submitted after the ninety-day period will not be con-
sidered. The written variance submission is required to
contain the following information:
° Requester's name and address; -
° Requester's interest in variance;
° POTW receiving industrial waste;
° Applicable Categorical Pretreatment Standard;
° List of pollutant or parameter in question;
° Alternative limits proposed for each appropriate
pollutant or parameter;
58
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° Description of the existing industrial water
pollution control facility;
° Schematic of industrial water system - water
supply, process systems, and discharge point?
° Clear statement of need for variance including
supportive data; documentation; and appropriate
evidence such as EPA Development Documents, eco-
nomic data, legal proceedings, etc.; and
I
0 Where control technology recommended will not
meet the standard, or exceed the standard, it is
essential that adequate documentation be pre-
sented.
Request for variance must be reviewed in detail and it
must be determined whether or not the factors identified
are fundamentally different. The following points are
essential for approval of a variance from a Categorical
Pretreatment Standard:
0 Factors relative to the affected ID are funda-
mentally different from the factors EPA con-
sidered. Factors which may be considered as
fundamentally different include:
0 Fundamental aspects of the industrial
process which significantly affect the
nature or quantity of the process waste-
water and discharge;
0 Age, size, land, and space consideration as.
related to equipment and facilities,
processes utilized, and application of
control technology;
0 Adverse impact on non-water quality by
control technology required to meet a
Categorical Standard;
° Increased energy requirements, provided
less energy consumptive control technology
is not available or applicable; and
0 Disproportionate compliance costs due to
one or more of the above.
0 The factors upon which the variance is based
existed prior to EPA promulgation of the
particular standard.
59
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0 Due to the factors in question, the cost of
compliance would be grossly disproportionate to
the cost EPA considered.
° The alternative pretreatment limits are justi-
fied by the extent of the fundamental differ-
ence.
° The request for variance is in accordance with
the procedures in the regulations.
The determination on the FDF variance should be made by a
technical professional, such as a sanitary or environ-
mental engineer. If, after reviewing the FDF variance
request, the State determines that it should be denied,
the State should issue a written statement to this effect
to the requester and to the ID in question if it is not
the requester. This statement should outline the reasons
for not granting the request.
If the State decides that the request should be approved,
it should forward the request, along with a recommendation
of approval and reasons supporting this recommendation to
the EPA Regional Enforcement Division Director.
The Pretreatment Regulations allow for an appeal procedure
for FDF determinations made by EPA. The regulations do
not require that States develop such procedures for State
determinations to deny a request. The denial of a request
by a State cannot be appealed to EPA.
The following are estimates of the level of State effort
required to apply the procedures previously outlined:
° Initial cursory review of FDF request for com-
pleteness;
° Insufficient request notification if required;
and
0 Determination as to whether or not a FDF exists.
Sludge Criteria
Improving the opportunities to recycle and reclaim sludges
and effluents from wastewater treatment facilities is one
of the intents of the national pretreatment policy.
Removal credits should be approved where sludge management
techniques are consistent in meeting this objective.
Consideration of future sludge management requirements via
Section 405 of the Act should play a major role in deter-
60
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mining the acceptability of providing removal credit. The
POTW should assure the Approval Authority that any addi-
tional amount of incompatible pollutants allowed into the
POTW, due to approved removal credits being granted, will
not contaminate the sludge or otherwise interfere with its
use or disposal.
Under Section 405 of the Act, the determination of the
manner of sludge use or disposal is a local decision.
However, once a sludge management option is selected, it
is unlawful for the POTW to violate Federal guidelines
established under Section 405 for that use or disposal
option. The POTW's NPDES permit will include applicable
guidelines from Section 405 as they are available. It
will be good business on the part of a POTW to not accept
pollutants that will create a sludge management problem.
At this point in time, it appears the approach EPA will
take in reference to CWA and RCRA in resolving the
municipal sludge situation is:
0 Municipal sludges will be covered under RCRA
regulations except for Subtitle C (Hazardous
Wastes); and
0 Section 405 regulations when published will be
as (or more) restrictive as the requirements
developed under Section 4004, 3004 for RCRA.
Disapproval of a removal credit submission, where the POTW
sludge will be in violation of pending 405 regulations,
will result unless compliance can be established in a
reasonable amount of time (12 months).
POTW Pretreatment Program Submission
The contents of a POTW Pretreatment Program Submission
must contain suitable information, in sufficient detail,
to adequately demonstrate the POTW's ability and plan of
implementation to carry out the Pretreatment Program.
Prior to submission of three copies of the program
description to the NPDES State Approval Authority or
Regional Administrator of EPA (for POTWs in non-NPDES
States), the POTW must provide information to and consul-
tation with interested and affected members of the public.
A copy of the draft Submission should be available to the
public thirty days before it is submitted to the Approval
Authority. This draft Submission must be accompanied by a
fact sheet, written in layman's terms, adequately describ-
ing the POTW Pretreatment Program and its significance
61
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and/or any request for authority to modify Categorical
Pretreatment Standards for pollutants removed by the POTW.
In order to provide for uniformity, consistency in
reviews, and expediency^ in approvals, the following
outline has been designed to aid in the preparation of a
POTW Pretreatment Program Submission. (Refer to Appen-
dix I for proposed changes to submission procedures.)
I. Program Description
A. Cover Letter
1. Statement from the City Solicitor, a city
official acting in a comparable capacity,
or attorney for the POTW (for those which
have independent legal counsel) that the
POTW has authority adequate to carry out
the Pretreatment Program described in 40
CFR, Part 403, Section 403.8. This state-
ment must:
a. Identify the provision of legal
authority under Section 403.8(f);
b. Identify the manner in which the POTW
will implement the Program require-
ments set forth in Section 403.8. This
will include the POTW's procedures to
ensure compliance with the require-
ments of the Pretreatment Program;
c. Identify the means by which the pre-
treatment standards will be applied to
Industrial Dsers (e.g., by order,
permit, ordinance, contract, etc.);
and
d. Identify how the POTW intends to
insure compliance with pretreatment
standards and requirements and in the
event of non-compliance, how the POTW
intends to enforce the standards and
requirements.
B. Supporting Statutes and Regulations
1. A copy of any statutes, ordinances, regula-
tions, contracts, agreements, or other
authorities relied upon by the POTW for its
administration of the Program. A statement
reflecting the endorsement or approval of
the local boards or bodies responsible for
62
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supervising and/or funding the POTW Pre-
treatment Program shall also be included.
C. POTW Organization
1. A brief description of the POTW with
organization charts. If more than one
agency is responsible for administering the
Program, identification, respective respon-
sibilities, and procedures should be ex-
plained.
D. Resources
1. A description of the funding levels and
full- and part-time personnel available to
implement the Program.
II. Fact Sheet
A. A description of the POTW Pretreatment Program
and its significance and/or any request for
authority to modify Categorical Pretreatment
Standards for pollutants removed by the POTW.
This fact sheet should be written in layman's
terms and will accompany a copy of the draft
Submission for public review.
III. Summary of Public Participation
A. The Submission shall include:
1. A summary of public participation efforts;
2. Major public comments received in# conjunc-
tion with adopting any statute, ordinance,
contract, agreement, or other authority for
enforcing pretreatment standards; and
3. The manner in which major issues identified
by the public have been resolved.
IV. Request for Authority to Revise Categorical Pretreat-
ment Standard's
A. Applications for authorization to revise cate-
gorical discharge limits will be included with
the Pretreatment Program Submission pursuant to
Sections 403.8, 40 3.9 and 403.11 of the General
Pretreatment Regulation. Subsequent applica-
tions will be processed only at the time of any
NPDES Permit reissuance.
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V. Request for Conditional Approval
A. The POTW may request conditional approval of the
Pretreatment Program pending the acquisition of
funding and personnel for certain elements of
the Program. This request for conditional
approval must meet - the requirements set forth
above except that the Submission must demon-
strate that:
1. A limited aspect of the the Program does
not need to be implemented immediately;
2. The POTW had adequate legal authority and
procedures to carry out those aspects of
the Program which will not be implemented
immediately; and
3. Funding and personnel for the Program
aspects to be implemented at a later date
will be available when needed. The POTW
will describe in the Submission the
mechanism by which this funding will be
acquired.
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III. MANAGING A POTW PRETREATMENT PROGRAM
Staffing
Personnel resource estimates are discussed in this
section. These estimates are based on the best, currently
available information and are not meant to be absolute.
There are many factors which influence the number of
personnel required to implement the various phases of the
POTW Pretreatment Program. Some of these factors include:
the size of the POTW Pretreatment Program; the number of
IU's the POTW will directly monitor; and the frequency of
sampling and inspections.
Table 6 on page 36 summarizes the personnel resource esti-
mates which can be used as a rough guide for estimating
the level of personnel effort required. The actual amount
of time for completing the various activities should be
estimated by the POTW based on previous experience. The
major personnel resource requirements include:
° Program Development - Developing the forms, pro-
cedures and program for this type of operation
will require a full-time engineer with assist-
ance at times from higher level management.
This effort will be reduced as the Program is
implemented.
0 Identify and Notify IU's - Gathering existing
information about IU's of POTWs can be accom-
plished using existing records. The POTW will
be involved with IU notification for all IU's
discharging into the POTW.
0 Industrial Waste Survey - The Industrial ~"Waste
Survey requires development of a questionnaire,
mailing, receiving,~and following up to insure
completion of the questionnaire. Review and
analysis of the questionnaire, development of a
sampling schedule and sampling of IU's is
required. Consultants could be utilized for
this effort.
° POTW Preatment Program Submission - Each Program
Submission must be developed to satisfy require-
ments for technical merit and must comply with a
format suggested by the Approval Authority.
° POTW Removal Allowance - Review of the actual
POTW removal for specific pollutants can be part
of the POTW self-monitoring program. Working
with industries which will be affected is very
important at this stage to minimize costs.
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0 Compliance (Monitoring) - This may require
inspection of an IU based on review of self-
monitoring reports submitted by the respective
IU. Where samples are taken, they must be
adequately analyzed and the results reviewed.
0 Enforcement - In order to have a viable enforce-
ment program, legal counsel is required. The
number of attorneys would depend on the size and
complexity of the POTW. An effective public
participation program can play an important role
in reducing the amount of litigation if there is
a feeling of mutual trust and understanding.
Many of the functions necessary to operate a Pretreatment
Program can be handled by existing personnel for small
Pretreatment Programs. As the size and scope of the
Program increases, it is necessary to obtain additional
staff to adequately administer the Program.
Public/Industrial Participation
An important element in implementing and managing a suc-
cessful and effective POTW Pretreatment Program is devel-
oping and maintaining credibility of the Program, its
objectives, and benefit to the entire community. Involve-
ment of the public and industrial communities is required
if a local Program is to meet the objectives discussed
earlier. One main thrust of the local approach to
administering and enforcing pretreatment is to take
advantage . of the knowledge and impact of local consider-
ations. The development of an active and informative
public participation program can minimize potential
enforcement actions. Industrial awareness of the nature,
intent, and sincerity of the POTW Pretreatment Program can
encourage a cooperative arrangement with mutual trust.
The following mechanisms should be considered not only
during the development of the Program, but also should be
continued in order to maintain Program integrity:
0 Public Workshops;
0 Industrial Meetings;
° Development of an Advisory Committee;
° Mailing List;
° Media Programs (i.e., newspapers, television,
advertisements, posters, brochures, etc.); and
° School Information Program.
Table 9 indicates the relative capability of public par-
ticipation techniques. Table 10 lists potential public
concerns in the operation of Pretreatment Programs as
required by the POTW and respective industries.
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TABLE 9
CAPABILITIES OF PPBLIC PARTICIPATION TECHNIQUES
Communication Characteristics
Level of
Ability to
Public
Handle
Degree of
Public Participation
Contact
Specific
Two-way
Technique
Achieved
Interest
Communication
Public hearings
M
L
L
Public meetings
M
L
M
Advisory Committee
meetings
L
H
H
Mailings
M
M
L
Contact persons
L
H
H
Newspaper articles
H
L
L
News releases
H
L
L
Audio-visual
presentations
M
L
L
Newspaper advertisements
l H
L
L
Poster, brochures,
displays
H
L
M
Workshops
L
H
H
Radio talk shows
H
M
H
Tours/field trips
L
H
H
Ombudsman
L
H
H
Task force
L
H
H
Telephone line
H
M
M
L = low
M = medium
H = high
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TABLE 10
PUBLIC CONCERNS
Public Concern
Pre-development land uses and subsequent
environmental impacts
Zoning problems/conflicting land uses
Groundwater pollution and leachate
Gas migration
Vectors
Noise
Odor
Aesthetics - including site visibility
Safety and health
Traffic
Spillage
Sedimentation and erosion
Final land use
Sludge Considerations
The implementation of a POTW Pretreatment Program will re-
duce and/or eliminate problem pollutants from entering the
wastewater treatment plant and will improve the quality of
municipal sludge and effluent generated. The POTW re-
quirements for applicable sludge criteria should be easier
to meet. The question of municipal sludge utilization
will be greatly enhanced by an adequate pretreatment
effort. Figure 6 graphically depicts the sludge situation
for a POTW and an industry with pretreatment.
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O o o o o o o o o o
MUNICIPAL BOUNDARY
Q
FIGURE 6
SLUDGE MANAGEMENT
The POTW should be instrumental in providing advice, guid-
ance, and technical input in assisting industry to solve
their residual problems and meet applicable regulation
requirements in the most economical fashion. The
financial burden of handling industrial residuals will be
borne by the respective industries. The POTW should be
involved in assuring the public that treatment and
disposal techniques utilized for these wastes will not be
harmful to the environment or public health. The concept
of centralized industrial treatment facilities, segregated
landfills, combined sites, etc. should be considered for
POTWs with reasonable amounts of indirect dischargers.
Figure 7 makes the distinction between direct and indirect
dischargers. Pretreatment Programs only impact indirect
dischargers. However, all industry within a community
should be considered if true economy is to be achieved in
handling industrial residuals.
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/\ /M/I/Vl
INDUSTRY
STREAM
DIRECT INDIRECT
FIGURE 7
DIRECT/INDIRECT INDUSTRIAL DISCHARGER
As discussed earlier, RCRA requirements may not pertain to
POTW sludges directly, but will impact industrial
residuals. Figure 8 depicts EPA's "cradle to grave"
approach in handling hazardous and toxic wastes.
To assist POTWs in helping industries with their respec-
tive residuals, EPA is developing an Industrial Pretreat-
ment Residuals Manual. The manual should be available by
Spring of 1980 and will cover categorical industries by:
characteristics; process descriptions; flows; pretreatment
technologies; sludge productions; and treatment, disposal,
and management techniques.
The manual will be extremely beneficial in helping indus-
trial facilities select cost-effective approaches to
handling the industrial residuals question.
70
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To3
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Depending on the specific situation, information obtained
by monitoring may also be used in the development of the
ordinance and in its enforcement. Monitoring information
can be especially useful in developing those sections of
the ordinance that set levels for incompatible pollutants,
as well as determining orders of magnitude for an
equitable system of user charge fees. As a result,
ordinance development and enforcement work hand in hand
with monitoring activities.
Although monitoring, in a broad sense, performs the single
function of obtaining quantitative and qualitative inform-
ation on residential contributors, specific subfunctions
should also be completed to provide a total program. For
monitoring, there are well-defined intermediate steps that
should be accomplished during the course of the overall
Program. In a well-managed Pretreatment Program, informa-
tion should be transferred in a closed loop where
monitoring, compliance, enforcement, and user charge fee
determinations all input to one another.
Organizational and managerial aspects, of a monitoring pro-
gram may vary considerably from system to system, but the
approach to the technical problems encountered in any
field monitoring activities remain fairly constant. The
need to maintain rigor and objectivity dictates that
sound, uniform, and well-defined procedures be maintained
during plant investigations and sampling programs. Some
guidance on how to develop and carry out a monitoring
program is available in an EPA Technology Transfer
document entitled, Handbook for Monitoring Industrial
Wastewater. This document describes technical aspects of
monitoring, but its major emphasis is directed at indus-
tries discharging directly into navigable waters that are
engaged in self-monitoring activities. Although many of
the details remain the same, field considerations for
monitoring industrial contributors in a pretreatment
situation have a slightly different orientation. Special
field considerations for monitoring pollutants introduced
into POTWs are as follows:
0 Preparation for a monitoring visit - industries
should not be notified well in advance, but
rather just prior to the visit to obtain a more
representative sample of daily operation;
° Scheduling - an attempt should be made to sys-
tematically cover all significant contributing
industries annually if resources permit;
0 Sampling and flow measurement - proper selection
of the appropriate sampling procedure should be
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made to insure accurate representation of the
wastewater; and
0 Sample handling - the sample should be properly
stabilized and a chain of possession accurately
documented. Often a parallel sample for inde-
pendent analysis by the industry or consultant
is required.
Once an administrative approach and technical methodology
are developed for obtaining industrial wastewater samples,
a mechanism for accurate and rapid analysis of the samples
must be provided. It is essential that analytical results
be accurate and reproducible to assure that monitoring
activities will provide the quality of information neces-
sary for a Pretreatment Program. A document entitled,
Sampling and Analysis Procedures for Screening of Indus-
trial Effluents for Priority Pollutants published by EPA
In April 1977, outlines procedures required for proper
_aboratory analysis of industrial wastewaters. Additional
information on monitoring, sampling, etc. can be obtained
in the EPA Technology Transfer Seminar handout entitled,
"Pretreatment of Industrial Wastes."
Conclusion
As discussed in this guidance document, a POTW should view
the development and operation of a local Pretreatment
Program as a chance to ensure reliability in operation of
the wastewater treatment facility and provide a consistent
and equitable approach to local industry impacted by
General Pretreatment Regulations. The POTW should set as
its goal the development of a sound Pretreatment Program
with a firm enforcement commitment.
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IV. REFERENCES
1. Federal Guidelines/ State and Local Pretreatment Pro-
grams, Office of Water Programs Operations, USEPA,
Washington, D.C. (MCD-43) 1977.
2. Guidance for NPDES States on Implementation of the
General Pretreatment Regulation (40 CFR, Part 403),
Office of Water Enforcement, USEPA, Washington, D..C.,
1979.
3. Municipal Sludge Landfills - Process Design Manual,
Technology Transfer, USEPA, 1978.
4. Natural Resources Defense Council, Inc., et. al.,
Plaintiffs, v. Douglas M. Costle, Administrator of
the Environmental Protection Agency, et.al.. Defend-
ants, Nos 2153—73, 75-0172, 75-1698, and 75-1267,
March 9, 1979.
5. Pretreatment of Industrial Wastes, Seminar Handout,
Technology Transfer, USEPA, 1978.
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APPENDIX I
DRAFT OUTLINE
OF
CHANGES PROPOSED
TO THE
GENERAL PRETREATMENT REGULATIONS
(40 CFR, PART 403)
Source: U.S. EPA, Washington, D.C.
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INTRODUCTION
v
Following the promulgation of the General Pretreatment
Regulations, several actions were brought in Federal court
challenging various aspects of these regulations. These
actions were subsequently consolidated in the District of
Columbia Circuit Court of Appeals in the action Natural
Resources Defense Council, Inc. et. al., v. EPA. On May
31, 1979, EPA entered into an agreement with three of the
Petitioners, the Manufacturing Chemists Association, the
D.S. Brewers Association, and the Pacific Legal Found-
ation, which seeks to settle substantially all of the
issues raised by the industry parties in this litigation.
The greater part of the proposed changes to the General
Pretreatment Regulations (40 CFR, Part 403) reflect the
provisions of this settlement. The major proposed modifi-
cations arising out of the Settlement Agreement are dis-
cussed in Section A below.
In addition, certain technical and conforming changes are
proposed. Most of these changes are found in Section
403.11 which has been amended to exclude procedures for
State Pretreatment Program approvals. State Pretreatment
Program approvals will now be subject to the requirements
for State Program modifications found in Section 123.61 of
the NPDES regulations as promulgated June 7, 1979.
A. PROPOSED MODIFICATIONS ARISING ODT OF THE
SETTLEMENT AGREEMENT
1. Section 403.3 Definitions
a. Section 403.3(h) Definition of inter-
ference. Section 403.3(h) of the existing regulation
defines "Interference" with the POTW. The amendements to
this definition are threefold. First, the language has
been modified to include within the definition of inter-
ference only the introduction of those pollutants which
"cause or signficantly contribute" to a violation of the
POTW's NPDES permit. The new language replaces the former
provision requiring that a pollutant simply "contribute"
to a violation of the NPDES permit to be considered to
interfere with the POTW. Thus, this change serves to
narrow the circumstances under which a pollutant is deemed
to cause Interference. It was felt that the "contributes
to" language might be interpreted too broadly to include
pollutants which did not contribute significantly to a
violation of the NPDES permit.
The second sentence in the definition of Interference has
been amended to specify that a pollutant can be considered
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as a source of interference when it causes or significant-
ly contributes to a violation of regulatory requirements
developed under Section 405 of the Clean Water Act or
pursuant to the provisions of the Solid Waste Disposal
Act, the Clean Air Act, the Toxic Substances Control Act,
or any more stringent State regulations. The previously
published language established liability for interference
when pollutants contributed to a POTW's failure to comply
with criteria, guidelines, or regulations developed under
these authorities.
Finally, a new provision has been added at the end of the
definition which exempts pollutants from being considered
as interfering with the POTW when the discharge of such
pollutants into the POTW is in compliance with Federal,
State, or local effluent limits. However, where such
pollutants are nevertheless determined to cause or signif-
icantly contribute to a violation of the POTW's NPDES
permit, the POTW is required to take appropriate action
under Section 403.5(c) to ensure renewed and continued
compliance with its permit. In many instances this will
mean a revision of the industrial discharge limits cur-
rently applicable to the pollutants in question. The POTW
may also determine that corrective .measures are better
instituted at the treatment works itself or may elect to
address non-point or domestic sources of the interfering
pollutants.
b. Section 403.3(n) Definition of POTW
treatment plant. A new provision, Section 403.3(n), de-
fining the term "POTW treatment plant" has been added to
avoid an ambiguity that now exists whenever a reference is
made to a POTW (publicly-owned treatment works). Section
403.3(m) in the existing regulation defines a POTW to
include both the treatment plant and the sewer pipes and
other conveyances leading to it. As a result, it is
unclear whether a particular reference is to the pipes,
the treatment plant, or both. The term a "POTW treatment
plant", will be used to designate that portion of the
municipal system which is actually designed to provide
treatment to the wastes received by the municipal system.
c. Section 403.3(o) Definition of pre-
treatment . Section 403.3(o) [formerly Section 403.3(n)]
which defines the term "pretreatment" has been modified by
adding a comment. This comment identifies equalization
tanks or facilities as appropriate pretreatment tech-
nologies for the purpose of protecting against surges of
influent to the POTW which might interfere with the
operation of the treatment works. The comment also recog-
nizes that equalization tanks or other similar facilities
have potential to be used as a means of achieving compli-
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ance through dilution. Where the use of equalization
tanks or similar facilities results in dilution, it is
suggested that the authority in charge of the local Pre-
treatment Program impose a mass limitation upon the source
employing these tanks or facilities.
2. Section 403.5 General discharge limitations
a. Section 403.5(b)(4) Limitation on high
volume or high concentration flows~ Section 403.5(b)(4)
prohibits Industrial Users from introducing certain
pollutants to a POTW. Subsection (4) has been revised to
make clear that pollutants may not be released in a dis-
charge at a flow rate and/or pollution concentration which
the^-User knows or has reason to know will cause Interfer-
ence in the POTW. Absent notification by the POTW, a User
discharging at a normal flow rate and/or concentration
will not ordinarily know, or have reasons to know, that
the discharge is causing Interference. If, however, a
User discharges pollutants at an unusually heavy flow rate
and/or high concentration, the User should know or have
reason to know that Interference to the POTW will result.
b. Section 403.5(b)(5) Limitation on heat.
Section 403.5(b)(5) prohibits the introduction of heat
into POTWs in amounts which would inhibit biological
activity at the POTW. In no case, according to this pro-
vision, is heat to be contributed in such quantities that
the temperature at the POTW treatment plant exceeds 40°C
(104°F).An additional provision has been inserted which
requires that the temperature or effluent entering the
sewers, pipes, or other conveyances leading to the treat-
ment plant not exceed 65°C (150°F). Both of these temper-
ature limits may be modified if the POTW has received
explicit approval from EPA or the State, as appropriate,
to apply alternate temperature limits to contributions
from Industrial Users. It is anticipated that this new
provision will provide Industrial Users with clearer
notice of the maximum temperature which can be discharged
safely into sewer lines.
c. Section 403.5(c). EPA proposes to
revise the second sentence of Section 40 3.5(c) to give a
POTW flexibility in complying with the terms of its NPDES
permit. Where pollutants contributed by users cause or
significantly contribute to a recurring violation of an
NPDES permit, the POTW must ensure renewed and continued
compliance with its permit by: 1) imposing specific
effluent limits on Industrial Users and all other users,
as appropriate; 2) making modifications-to the treatment
plant's facilities or operation; or 3) a combination of
alternatives 1 and 2. If the POTW does not begin approp-
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riate action to cure an NPDES violation within thirty days
of being notified by EPA of the violation, EPA may take
appropriate action.
3. Section 403,6 EPA determination of indus-
trial subcategories
a. Section 403.6(a)(5). Section 403.6(a)
(5) has been amended to delete the provision allowing for
a hearing on EPA's determination as to a particular
^industry's subcategory classification. EPA does not
believe that it is legally required to provide the oppor-
tunity for a hearing on such determinations. Industries
wishing to challenge EPA's determination may submit a
petition to reconsider the decision to the Regional
Administrator and the Regional Administrator will be
required to respond expeditiously in writing to this
petition.
b. Section 403.6(a)(6). In addition,
subparagraph 403.6(a)(6) has been deleted. This paragraph
had provided that Industrial Users failing to seek a
determination as to the appropriate subcategory within the
prescribed time would be bound by EPA's subsequent .deter-
mination as to the subcategory. It has been determined
that EPA could not legally bar an indirect discharger from
raising as a defense to an enforcement action the allega-
tion that his facility is not in the industrial category
claimed.
4. Section 403.7 Removal allowances. Redefi-
nition of "Consistent Removal"*" Section 403.7 ol the
regulation introduces the concept that a POTW must demon-
strate "consistent removal" of a pollutant over a
specified period of time in order to receive authority to
grant a removal allowance to its industrial users. Only
when the POTW has demonstrated that it has the capacity to
maintain specified levels of removal for industrial
pollutants can the Approval Authority be assured that the
POTW can adhere to a consistent level of environmental
control.
a. Section 403.7(a). Section 403.7(a)
of the existing regulation defines "consistent removal" as
that level of removal observed in 95 percent of the
influent and effluent samples taken at the POTW. In
response to concerns that this criterion for judging
consistency is unnecessarily stringent, EPA is proposing
to redefine "consistent removal". EPA is confident that
the proposed language results in the same 'degree of
assurance as to consistent removal while being less
burdensome on the POTW. The new provision defines con-
1-4
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sistent removal as that removal demonstrated by averaging
the lowest 50 percent of the removals measured by 12 or
more samples. When between 8 and 11 samples are obtained,
the average of the lowest 6 samples is used to calculate
consistent removal. When less than 8 samples are
obtained, the POTW, with the consent of the Approval
Authority, may use alternative means of demonstrating
consistent removal. These alternative means might in-
clude, for example, the use of mass balance data. If in
obtaining the samples the pollutants in question are not
measurable in the effluent from the POTW, the limit of
measurement may be considered to be the effluent level.
Where the pollutant for which the removal allowed is
sought is not detectable in the influent to the POTW
treatment plant, the level of measurement may not be used
to represent the influent concentration.
b. Section 403.7(b)(2) Conditional re-
moval allowances. Section 403.7(b)(2) now provides that
Industrial Users are not eligible for removal allowances
until the POTWs Pretreatment Program has been approved.
Such approval is not required in some instances until
July 1, 1983. Concern has been expressed that this pro-
vision might force Industrial Dsers to make commitments to
comply with Categorical Standards before removal allow-
ances could be obtained, thus resulting in redundant
treatment.
EPA therefore proposes to revise Section 403.7(b)(2) to
provide that, if certain conditions are met, a POTW may
revise discharge limits on a conditional basis prior to
approval of its Pretreatment Program. Industrial Users
who wish to obtain the conditionally revised discharge
limits must compile and submit to the POTW the information
required by Section 403.12(b)(1)—(7), and must submit an
application for Pretreatment Program approval in a timely
manner. If either the POTW or an Industrial User fails to
comply with its commitments, the conditionally revised
limits will be withdrawn in accordance with the conditions
of subsections (v) and (vi) of this section. If the
revised standard is withdrawn due to the POTW's noncompli-
ance, the affected Industrial Users will be given a
reasonable time to install pollution control equipment to
meet the Categorical Standards.
c. Section 403.7(b)(3) Removal allowances
for POTWs that bypass. Section 403.7(b)(3) of the Pre-
treatment Regulation provides that removal allowances may
not be authorized for POTWs which bypass untreated waste-
water at least once annually unless such POTWs are
implementing or have applied for a grant to implement a
plan to minimize bypasses in conformance with the require-
1-5
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ments of "PRM 75-34" (also known as Program Guidance
Memorandum 61). This provision has been modified to allow
authorization of removal allowances if POTWs meet one of
two conditions. First, POTWs with bypasses may receive
removal allowance authorization to revise discharge limits
for Industrial Users which demonstrate that they can
contain or cease discharges to the POTW during circum-
stances in which a bypass event reasonably can be expected
to occur. Secondly, POTWs with more than one bypass
annually may receive removal allowance authorization if
they calculate consistent removal according to an equation
which factors in hours of bypassing and, after July 1,
1983, are making an effort to implement a bypass control
program in accordance with the requirements of "PRM 75-34".
d. Section 403.7(b)(4) Compliance with
sludge disposal requirements as a condition to removal
allowances. EPA is proposing to modify Section 403.7(b)
(4) in three respects. First, the section will be amended
to make clear that EPA will not prohibit revisions to
Categorical Pretreatment Standards where the particular
pollutant(s) for which the revision is sought will not
contribute to the POTW's inability to comply with applic-
able sludge use or disposal regulations. Secondly, a
revision to a discharge limit will be prohibited where the
revision will contribute to a violation of the POTW's
NPDES permit. Finally, EPA has deleted references to
compliance with "guidelines" or "criteria" adopted under
the Solid Waste Disposal Act, the Clean Air Act, and the
Toxic Substances Control Act, that are not subject to
rulemaking procedures including notice and public comment.
The deletion of the word "guidelines" is not meant to
apply to regulations issued under Section 405 of the Act
which the Act refers to as guidelines.
e. Section 403.7(c).When removal allow-
ance applications may be submitted. Section 403.7(c) has
been modified to provide that application for removal
allowance authorization may be requested once a year with
respect to certain pollutants instead of only at the time
of program approval or subsequent permit reissuance as
provided for in the existing regulation. All such
requests for removal allowance authorization submitted
prior to program approval are considered to be "condi-
tional" allowances, as described in Section 403.7(b), if
the Approval Authority does not review and make a decision
on them. The Approval Authority may review and make a
determination on the POTW's authority to revise discharge
limits at any time after the submission of an application
for removal allowance approval up until the time of Pre-
treatment Program approval. At the time of Pretreatment
Program approval the Approval Authority is required to
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review and make a determination on any pending requests
for removal allowance approval. Once the Pretreatment
Program has been approved, the Approval Authority again
may review requests for removal allowance approval at its
discretion until the reissuance of the POTW's permit, at
which time it is required to make a determination on all
pending removal allowance requests.
f. Section 403.7(c)(2), (c)(2)(ii) and
(c)(2)(iv). Amendments have been made to these provisions
giving the POTW flexibility in demonstrating consistent
removal when influent and effluent data are unobtainable.
g. Section 403.7(c)(iii) Sampling to
obtain removal data. Section 403.7(c)(2)(iii) now pro-
vides that data demonstrating removal shall be obtained
through a composite sample taken on each of three consecu-
tive days during each season. EPA proposes to revise this
Section to spread the sampling period, thus rendering the
data less sensitive to short-term variations. A minimum
of 12 composite samples taken at approximately equal
intervals throughout the year will be required. Each
effluent sample will be taken approximately one detention
time later than the corresponding influent sample in order
to determine how much removal the POTW is achieving. If
the prescribed sampling schedule is not representative of
the operation of the POTW, as in treatment systems having
long detention times, the Approval Authority may require
a different schedule. The Approval Authority should use
this authority to allow POTWs which began sampling
programs to acquire removal data according to the existing
requirements of Section 403.7(c)(2)(iii) to modify their
existing sampling schedules to conform with the new
requirements.
h. Section 403.7(c)(2)(v) Provisional
credits for new pollutants. A new paragraph, Section
403.7(c) (2) (v), has been proposed to enable the POTW to
provisionally revise Categorical Standards for new pollu-
tants discharged to its system in the same manner as it
grants conditional revisions for existing discharges under
Section 403.7(b)(2). Under the present regulation, a new
facility or an existing facility discharging a new pollu-
tant would be required to install the full technology
needed to meet applicable pretreatment standards before
the pollutant in question could be discharged to the POTW.
A removal allowance for these pollutants, with the re-
sultant possible reduction in pollution control tech-
nology, could not be granted until a year of operating
data demonstrated the removal claimed. The new provision
allows the POTW to estimate, based on treatability studies
for the pollutants in question or the levels of removal
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for those pollutants obtained by similar municipal treat-
ment systems, the percentage of removal the POTW would
achieve for these pollutants. A reduced dicharge limit
reflecting this estimated percentage of removal is then
applied to the facility. Thus, before commencing dis-
charge, the facility is required to install only that
level of technology needed to meet the pretreatment
standard as amended by this provisional allowance.
As Section 403.7(c) indicates, POTW application for
approval of this estimated or provisional allowance can be
requested only once a year and the Approval Authority is
allowed to exercise its discretion to withhold official
approval of the allowance pending Pretreatment Program
approval, or, if a Program has been approved, POTW permit
reissuance. In order to obtain a provisional removal
allowance, the POTW must comply with the requirements of
Section 403.7(b)(2) and submit to the Approval Authority
the data on treatability or removal at similar POTWs
accompanied by the required certification that the data
are true and accurate.
i. Section 403.7(e)(4) Revoking or modi-
fying removal allowances. Section 403.7(e)(4) in the
present regulation provides that removal allowances be
terminated and technology needed to meet promulgated
effluent limits be installed if the POTW fails to maintain
the consistent removal demonstrated in the removal allow-
ance application or if the approved allowance results in a
violation of the POTW's NPDES permit. This section has
been amended to provide that the removal allowance need
not be terminated but may be modified where such modifica-
tion will not result in a violation of the POTW's NPDES
permit. No removal allowance shall be modified or with-
drawn until there has been notice to the POTW and affected
Industrial Users, and an opportunity for a hearing.
5. Section 403.8 Local Pretreatment Program
requirements
a. Section 403.8(f)(1)(i) POTW's author-
ity to condition industrial contributions. Section 403.8
(f)(1) (i) will be modified to clarify that a POTW must
have legal authority to deny or condition new or increased
contributions of pollutants, or changes in the nature of
pollutants, to the POTW only where such contributions do
not meet applicable pretreatment standards or where such
contributions would cause the POTW to violate its NPDES
permit.
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b. Section 403.8(f)(1)(vi)(B) POTW's
authority to immediately halt contributions from Indus-
trial Users. EPA proposes to amend Section 4 03.8(f)(1)
(vi)(B) to require that POTWs have authority, after
informal notice to the discharger, to prevent or halt
discharges that appear to present an imminent danger to
the health or welfare of persons. Notice is required so
that the discharger will have an opportunity to take steps
necessary to avoid or minimize damage to its equipment
from the shutdown. If a discharge threatens the environ-
ment or the operation of the POTW, notice to affected
Industrial Users and an opporunity to respond is required
before the POTW halts the discharge.
c. Section 403.8(f)(2)(vii) Newspaper
notice of pretreatment violations. Section 403.8(f)(2)
(vii) of the present regulation provides for annual notice
in the municipality's largest daily newspaper of Indus-
trial Users which were not in compliance with pretreatment
standards or other pretreatment requirements during the
preceding 12 months. This provision inspired concern that
the language might be too broadly interpreted to cover
very minor instances of non-compliance, such as the delay
of one day in submitting a status report. In response to
this concern, the provision has been amended to provide
for public notice of significant violations. The amended
language establishes criteria for defining such a viola-
tion.
6. Section 403.9 POTW application for local
Pretreatment Program approval
a. Section 403.9(b)(3) Conditional Pro-
gram approvals. The existing provision requires that
removal allowances be withdrawn if funding is not acquired
to implement the delayed elements of a conditionally
approved local Program within the necessary time period.
This provision has been amended to provide that allowances
may be modified rather than withdrawn.
b. Section 403.9(f) Notice of insuffi-
ciency of local Program application. Section 403.9(f) has
been amended to provide for public notice by EPA or State,
as appropriate, in the event that it is determined that a
Submission for Pretreatment Program approval or removal
allowance approval does not comply with the procedural
application requirements set forth in the regulation. The
present regulation already provides a similar public
notice for the Approval Authority's determination on the
substantive sufficiency of an applcation.
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7. Section 403.11 Approval procedures for
local Pretreatnent Programs and removal
allowances
a. Section 403.11 of the regulation has
been modified so that the procedures set forth therein
apply only to the POTW Pretreatment Program approvals and
approvals of removal allowances. The existing regulation
included State Program approval procedures within this
section. Procedures for State Program approvals will be
governed by the procedural requirements found in Section
123.61 of the NPDES regulations. Section 403.11 has also
been modified to include notice of key steps in the
approval process to those persons requesting individual
notice.
8. a. Section 403.1(b). This section has
been modified to clarify that these reports are required
only from Industrial Users subject to Categorical Pre-
treatment Standards — not users to whom other pretreat-
ment requirements including prohibited discharge limits
under Section 403.5 are applied.
b. Section 403.12(b)(4) Reports required
of Industrial Users within 180 days of Categorical Pre-
treatment Standard promulgation. Section 403.12(b) of the
regulation requires that Industrial Users subject to
Categorical Pretreatment Standards submit certain informa-
tion to the control authority (the POTW, NPDES State or
EPA, as appropriate) within 180 days after the promulga-
tion of an applicable Categorical Pretreatment Standard.
Included among the information required is an indication
of the average and maximum flows from the facility to the
POTW [Section 403.12(b)(4)]. This provision has been
amended to allow for the reporting of estimated flows
rather than measured flows where the control authority
approves of these estimates in recognition of cost or
feasibility considerations. For example, where the
installation of flow monitoring equipment, particularly in
older buildings, would require extensive renovation of the
facility and result in a disruption of operations for a
significant period of time, the control authority could
exercise its discretion to allow reporting of an estimate
of the flow if this estimate is derived through verifiable
techniques.
c. Section 403.12(e)(1). Section 403.12
(e)(1) will be revised to reduce the amount of monitoring
and reporting required of Industrial Users. Under the
existing regulation, a User would have to provide continu-
ous actual flow monitoring. Concern has been expressed
that this would be virtually impossible for some Users,
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and very costly for others. The revised section would
require that the Dser report only its measured or
estimated average and maximum daily flows (from water
bills and other sources) for the reporting period. This
will usually provide sufficient data to enable a POTW to
make planning and operating decisions. The control
authority may require more detailed reporting of flows if
necessary, but in most cases, this should be preserved for
an Industrial Dser who is a major source of inflow to the
POTW or is a significant contributor of pollutants.
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APPENDIX II
SUMMARY OF EXISTING
PRETREATMENT STANDARDS
-------
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES OF
POLLUTION PROHIBITED DISCHARGES
Reference: Federal Register/ Vol. 43, p. 27747, and
unpublished proposed revisions, June 26, 1978
Pollutants introduced into Publicly Owned Treatment Works
(POTW) by any source of a nondomestic discharge shall not
inhibit or interfere with the operation or performance of
the works. These general prohibitions apply to all such
users of a POTW whether or not the user is subject to
other National Pretreatment Standards or any National,
State, or local Pretreatment Requirements.
The following pollutants may not be introduced into a
POTW:
1. Pollutants which create a fire or explosion haz-
ard in the POTW;
2. Pollutants which will cause corrosive structural
damage to the POTW, but in no case discharges
with pH lower than 5.0, unless the works is spe-
cifically designed to accommodate such dis-
charges;
3. Solid or viscous pollutants in amounts which
will cause obstruction to the flow in sewers, or
other interference with the operation of the
POTW;
4. Any pollutant, including oxygen demanding pollu-
tants (BOD, etc.), released in a discharge of
such volume or strength as to cause interference
in the POTW.
5. Heat in amounts which will inhibit biological
activity in the POTW resulting in interference
but in no case heat in such quantities that the
temperature at the treatment works influent
exceeds 40°C (104°F) unless the works is de-
signed to accommodate such heat.
Compliance with Prohibited Discharge Standards was
required beginning August 25, 1978, except for the heat
Standard which must be complied with within three years,
or August 25, 1981.
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TIMBER PRODDCTS INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
•CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register/ Vol. 41/ p. 53930,
December 9, 1976
Categorical Pretreatment Standards specify quantities or,
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcategories. These Standards,
unless specifically noted otherwise, shall be in addition
to the Prohibited Discharge Standards.
All POTW dischargers in the following subcategories must
be in compliance with applicable categorical Pretreatment
Standards before December 9, 1979.
Subpart F - Wood Preserving Subcategory
Discharges resulting from all wood preserving processes in
which steaming or boultonizing is not the predominant
method of conditioning, all non-pressure preserving
processes, and all pressure or non-pressure processes
employing waterborne salts in which steaming or vapor
drying is not the predominant method of conditioning.
Pretreatment Standards: No discharge of process waste-
water pollutants.
Subpart G - Wood Preserving - Steam Subcategory
Discharges resulting from wood preserving processes that
use direct steam impingement on the wood as the method of
conditioning, discharges resulting from wood preserving
processes that use vapor drying as a means of conditioning
any portion of their stock, discharges that result from
direct steam conditioning, wood preserving processes that
use fluor-chromium-arsenic-phenol treating solutions
(FCAP), discharges resulting from direct steam condition-
ing processes and procedures where the same retort is used
to treat with both salt-type and oil-type preservatives,
and discharges from plants which direct steam condition
and apply both salt-type and oil-type treatments to the
same stock.
II-2
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Pretreatment Standard:
Pollutant
Maximum for any 1 day (mq/1)
Oil and grease
Copper
Chromium
Arsenic
100
5
4
4
Subpart H - Wood Preserving - Boultonizinq Subcategory
Discharges resulting from wood preserving processes which
use the boultonizing process as the method of condition-
ing.
Pretreatment Standard: Same as Subpart G
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NONFERROUS METALS INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register/ Vol. 41, p. 54850,
December 15, 1976
Categorical Pretreatment Standards specify quantities or
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcategories. These Standards,
unless specifically noted otherwise, shall be in addition
to the Prohibited Discharge Standards.
All POTW dischargers in the following subcategories must
be in compliance with applicable categorical Pretreatment
Standards before December 15, 1979.
Subpart C - Secondary Aluminum Smelting Subcategory
Discharges resulting from that portion of SIC 3341
(Secondary Nonferrous Metals) which recovers, processes,
and remelts various grades of aluminum bearing scrap to
produce metallic aluminum or an aluminum alloy as a
product. This does not include the casting or alloying of
remelted billets, ingots, or pigs, nor thoe operations of
the primary aluminum industry, which recycle certain
categories of scrap.
Pretreatment Standard:
1. Metal cooling:
Pollutant
Average of daily values
Maximum for any for 30 consecutive days
1 day (mq /1) shal 1 not exceed
Oil and grease
100
2. Demagging fume scrubbers:
Pollutant
Average of daily values
Maximum for any for 30 consecutive days
1 day (mg/1) shall not exceed
PH
Within the range of 5 to 10.
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3. Residue milling:
Pollutant
Average of daily values
Maximum for any for 30 consecutive days
1 day mg/1) shall not exceed
Ammonia (as N)
100
50
Subpart F - Secondary Copper Subcategory
Discharges resulting from that portion of SIC 3341
(Secondary Nonferrous Metals) which recovers, processes,
and remelts new and used copper scrap and residues to
produce copper metal and copper alloys. This includes
establishments melting and refining copper alloys from
secondary brass and secondary bronze scrap sources to
produce alloyed copper, as well as those melting and
refining copper-bearing scrap to recover principally pure
copper (unalloyed copper).
Pretreatment standard:
Pollutant
Average of daily values
Maximum for any for 30 consecutive days
1 day (mg/1) shall not exceed
Oil and grease
Copper
Cadmium
100.0
1.0
0.4
0.5
0.2
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PETROLEUM REFINING INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register, Vol. 42, p. 15684,
March 23, 1977
Categorical Pretreatment Standards specify quantities or
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcategories. These Standards,
unless specifically noted otherwise, shall be in addition
to the Prohibited Discharge Standards.
All POTW dischargers in the following subcategories must
be in compliance with applicable categorical Pretreatment
Standards before March 23, 1980.
Subpart A - Topping Subcategory
Topping and catalytic reforming whether or not the
facility includes any other process in addition to topping
and catalytic reforming. This subcategory is not
applicable to facilities which include thermal processes
(coking, visbreaking, etc.) or catalytic cracking.
Subpart B - Cracking Subcategory
Topping and cracking, whether or not the facility includes
any processes in addition to topping and cracking, unless
specified in one of the subcategories listed below.
Subpart C - Petrochemical Subcategory
Topping, cracking, and petrochemical operations, whether
or not the facility includes any process in addition to
topping, cracking and petrochemical operations,* except
lube oil manufacturing operations.
Subpart D - Lube Subcategory
Topping, cracking and lube oil manufacturing processes,
whether or not the facility includes any process in addi-
tion to topping, cracking and lube oil manufacturing pro-
cesses, except petrochemical* and integrated operations.
Subpart E - Integrated Subcategory
Topping, cracking, lube oil manufacturing, and petrochem-
ical operations, whether or not the facility includes any
II-6
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processes in addition to topping, cracking, lube oil manu-
facturing and petrochemical operations.*
* The term "petrochemical operations" shall mean the pro-
duction of second generation petrochemicals (i.e.,
alcohols, ketones, cumene, styrene, etc.) or first genera-
tion petrochemicals and isomerization products (i.e., BTX,
olefins, cyclohexane, etc.) when 15% or more of refinery
production is as first generation petrochemicals and
isomerization products.
Pretreatment Standard for Subparts A through E:
Pollutant Maximum for 1 day (mg/1)
Ammonia (as N) 100
Oil and grease 100
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STEAM ELECTRIC POWER GENERATING INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register, Vol. 42, p. 15690,
March 23, 1977
Categorical Pretreatment Standards specify quantities or
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcategories. These Standards,
unless specifically noted otherwise, shall be in addition
to the Prohibited Discharge Standards.
All POTW dischargers in the following subcategories must
be in compliance with applicable categorical Pretreatment
Standards before March 23, 1980.
Pretreatment Standards for the Steam Electric Power Gener-
ating Industry are applicable to discharges resulting from
the operation of a generating unit by an establishment
primarily engaged in the generation of electricity for
distribution and sale which results primarily from a pro-
cess utilizing fossil-type fuel (coal, oil, or gas) or
nuclear fuel in conjunction with a thermal cycle employing
the steam-water system as the thermodynamic medium.
- Subpart A - Generating Unit Subcategory
Discharges from any generating unit except those units de-
fined below as small or old.
Subpart B - Small Unit Subcategory
Discharges from any generating unit except a unit defined
below as old, of less than 25 megawatts rated net generat-
ing capacity, or any unit which is part of an electric
utilities system with a total net generating capacity of
less than 150 megawatts.
Subpart C - Old Unit Subcategory
Discharges from any generating unit of 500 megawatts or
greater rated net generating capacity which was first
placed in service on or before January 1, 1970, and any
generating unit of less than 500 megawatts rated net
generating capacity which was first placed in service on
or before January 1, 1974.
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Pretreatment Standards for Subparts A through C:
1. There shall be no discharge to POTW's of polychlori-
nated biphenyl compounds such as those used for trans_
former fluid.
2. The quantity of copper discharged in metal cleaning
wastes to POTW's shall not exceed the quantity determined
by multiplying the flow of metal cleaning wastes time 1
mg/1.
3. The quantity of oil and grease in the plant's combined
discharge to the POTW's shall not exceed the quantity
determined by multiplying the flow of the combined dis-
charge times 100 mg/1.
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INORGANIC CHEMICALS MANUFACTURING INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register/ Vol. 42, p. 37294,
July 20, 1977
Categorical Pretreatment Standards specify quantities or
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcategories. These Standards,
unless specifically noted otherwise, shall be in addition
to the Prohibited Discharge Standards.
All POTW dischargers in the following subcategories must
be in compliance with applicable categorical Pretreatment
Standards before July 20, 1980.
Subpart A - Aluminum Chloride Production Subcategory
Pretreatment Standard: pH within the range of 5.0 to 10.0
Subpart B - Aluminum Sulfate Production Subcategory
Pretreatment Standard:
Subpart L - Potassium Dichromate Production Subcategory
Pretreatment Standard:
Pollutant
Average of daily values
Maximum for any for 30 consecutive days
1 day (mg/1) shall not exceed
Zinc
5.0
2.5
Pollutant
Average of daily values
Maximum for any for 30 consecutive days
1 day (mg/1) shall not exceed
Hexavalent Chromium
Total Chromium
0.25
3.0
0.09
1.0
Subpart AJ - Copper Sulfate Production Subcategory
Pretreatment Standard:
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Average of daily values
Maximum for any for 30 consecutive days
Pollutant 1 day (mg/1) shall not exceed
Copper 1.0 0.5
Nickel 2.0 1.0
Subpart AL - Ferric Chloride Production Subcategory
Pretreatment Standard:
Average of daily values
Maximum for any for 30 consecutive days
Pollutant 1 day (mg/1) shall not exceed
Total Chromium 3.0 1.0
Hexavalent Chromium 0.25 0.09
Copper 1.0 0.5
Nickel 2.0 1.0
Zinc 5.0 2.5
Subpart AR - Lead Monoxide Production Subcategory
Pretreatment Standard:
Average of daily values
Maximum for any for 30 consecutive days
Pollutant 1 day (mg/1) shall not exceed
Lead 2.0 1.0
Subpart AU - Nickel Sulfate Production Subcategory
Pretreatment Standard:
Average of daily values
Maximum for any for 30 consecutive days
Pollutant 1 day (mg/1) shall not exceed
Nickel 2.0 1.0
Copper 1.0 0.5
Subpart BA - Silver Nitrate Production Subcategory
Pretreatment Standard:
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Average of daily values
Maximum for any for 30 consecutive days
Pollutant 1 day (mq/1) shall not exceed
Silver 1.0 0.5
Subpart BC - Sodium Fluoride Production Subcategory
Pretreatment Standard:
Average of daily values
Maximum for any for 30 consecutive days
Pollutant 1 day (mq/1) shall not exceed
Fluoride 50 25
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TEXTILE INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register/ Vol. 42, p. 26979,
May 26, 1977
Categorical Pretreatment Standards specify quantities or
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcategories. These Standards,
unless specifically noted otherwise, shall be in addition
to the Prohibited Discharge Standards.
The Categorical Pretreatment Standards for the following
subcategories are essentially the same as the Prohibited
Discharge Standards.
Subpart Subcategory
Compliance with Textile Industry Pretreatment Standards
was required beginning June 30, 1977.
A
B
C
D
E
F
G
Wool Scouring
Wool Finishing
Dry Processing
Woven Fabric Finishing
Knit Fabric Finishing
Carpet Mills
Stock and Yarn Dyeing
and Finishing
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LEATHER TANNING AND FINISHING INDUSTRY
NATIONAL PRETREATMENT STANDARDS FOR EXISTING SOURCES
CATEGORICAL PRETREATMENT STANDARDS
Reference: Federal Register/ Vol. 42, p. 15896,
March 23, 1977
Categorical Pretreatment Standards specify quantities or
concentrations of pollutants or pollutant properties which
may be discharged or introduced to a Publicly Owned Treat-
ment Works (POTW) by existing or new Industrial Users in
specific industrial subcatgories. These Standards, unless
specifically noted otherwise, shall be in addition to the
Prohibited Discharge Standards.
All POTW dischargers in the following subcategories were
required to be in compliance with applicable categorical
Pretreatment Standards as of April 22, 1977.
Subpart A - Hair Pulp, Chrome Tan, Retan-Wet Finish Sub-
category
Pretreatment Standard: pH within the range of 7.0 - 10.0
Subpart B - Hair Save, Chrome Tan, Retan-Wet Finish Sub-
category
Pretreatment Standard: pH within the range of 7.0 - 10.0
Subpart C - Hair Save, Non-Chrome Tan, Retan-Wet Finish
Subcategory
Pretreatment Standard: pH within the range of 7.0 - 10.0
Subpart D - Retan-Wet Finish Subcategory
Pretreatment Standard: pH within the range of 6.0 - 10.0
Subpart E - No Beamhouse Subcategory
Pretreatment Standard: pH within the range of 6.0 - 10.0
Subpart F - Through-the-Blue Subcategory
Pretreatment Standard: pH within the range of 7.0 - 10.0
Subpart G - Shearling Subcategory
Pretreatment Standard: pH within the range of 6.0 - 10.0
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APPENDIX III
DRAFT MODEL ORDINANCE
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MODEL ORDINANCE
ORDINANCE NO.
SECTION 1 GENERAL PROVISIONS
1.1 Purpose and Policy
This ordinance sets forth uniform requirements for direct
and indirect contributors into the wastewater collection
and treatment system for the City of
and enables the City to comply with all applicable State
and Federal laws required by the Clean Water Act of 1977
and the General Pretreatment Regulations (40 CFR, Part
403).
The objectives of this ordinance are:
(a) To prevent the introduction of pollutants into the
municipality wastewater system which will interfere
with the operation of the system or contaminate the
resulting sludge; ,
(b) To prevent the introduction of pollutants into the
municipal wastewater system which will pass through
the system, inadequately treated, into receiving
waters or the atmosphere or otherwise be incompatible
with the system;
(c) To improve the opportunity to recycle and reclaim
wastewaters and sludges from the system; and
(d) To provide for equitable distribution of the cost of
the municipal wastewater system.
This ordinance provides for the regulation of direct and
indirect contributors to the municipal wastewater system
through the issuance of permits to certain non-domestic
users and through enforcement of general requirements for
the other users, authorizes monitoring and enforcement ac-
tivities, requires user reporting, assumes that existing
customer's capacity will not be preempted, and provides
for the setting of fees for the equitable distribution of
costs resulting from the : program established herein.
This ordinance shall apply to the (City of ) and to
persons outside the (City) who are, by contract or agree-
ment with the (City), Users of the (City) POTW. This
ordinance is a supplement to Ordinance No. as
amended. Except as otherwise provided herein, the (Super-
intendent) of the (City) POTW shall administer, implement,
and enforce the provisions of this ordinance.
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1.2 Definitions
Unless the context specifically indicates otherwise, the
following terms and phrases, as used in this ordinance,
shall have the meanings hereinafter designated:
(1) Act or "the Act". The Federal Water Pollution
Control Act, also known as the Clean Water Act, as
amended, 33 U.S.C. 1251, et. seq.
(2) Approval Authority. The Director in an NPDES state
with an approved State Pretreatment Program and the
Administrator of the EPA in a non-NPDES state or
NPDES state without an Approved State Pretreatment
Program.
(3) Authorized Representative of Industrial User. An au-
thorized representative of an Industrial User may be:
(1) A principal executive officer of at least the
level of vice-president, if the Industrial User is a
corporation; (2) A general partner or proprietor if
the industrial user is a partnership or proprietor-
ship, respectively; (3) A duly authorized represent-
ative of the individual designated above if such
representative is responsible for the overall opera-
tion of the facilities from which the indirect
discharge originates.
(4) Biochemical Oxygen Demand (BOD). The quantity of
oxygen utilized in the biochemical oxidation of
organic matter under standard laboratory procedure,
five (5) days at 20° centigrade expressed in terms of
weight and concentration (milligrams per liter
(mg/1)).
(5) Building Sewer. A sewer conveying wastewater from
the premises of a User to the POTW.
(6) Categorical Standards. National Categorical Pre-
treatment Standards or Pretreatment Standard.
(7) City. The City of or the City
Council of .
(8) Cooling Water. The water discharged from any use
such as airconditioning, cooling or refrigeration,
or to which the only pollutant added is heat.
(9) Control Authority. The term "control authority"
shall refer to the "Approval Authority", defined
hereinabove; or the Superintendent if the City has an
approved Pretreatment Program under the provisions of
40 CFR, 403.11.
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(10) Direct Discharge. The discharge of treated or
untreated wastewater directly to the waters of the
State of .
(11) Environmental Protection Agency, or EPA. The U.S.
Environmental Protection Agency, or where appropriate
the term may also be used as a designation for the
Administrator or other duly authorized official of
said agency.
(12) Grab Sample. A sample which is taken from a waste
stream on a one-time basis with no regard to the flow
in the waste stream and without consideration of
time.
(13) Holding tank waste. Any waste from holding tanks
such as vessels, chemical toilets, campers, trailers,
septic tanks, and vacuum-pump tank trucks.
(14) Indirect Discharge. The discharge or the introduc-
tion of nondomestic pollutants from any source
regulated under section 307(b) or (c) of the Act, (33
U.S.C. 1317), into the POTW (including holding tank
waste discharged into the system).
(15) Industrial User. A source of Indirect Discharge
which does not constitute a "discharge of pollutants"
under regulations issued pursuant to section 402, of
the Act. (33 U.S.C. 1342).
(16) Interference. The inhibition or disruption of the
POTW treatment processes or operations which con-
tributes to a violation of any requirement of the
City's NPDES Permit. The term includes prevention of
sewage sludge use or disposal by the POTW in accord-
ance with 405 of the Act, (33 U.S.C. 1345) or any
criteria, guidelines, or regulations developed pur-
suant to the Solid Waste Disposal Act (SWDA), the
Clean Air Act, the Toxic Substances Control Act, or
more stringent state criteria (including those con-
tained in any State sludge management plan prepared
pursuant to Title IV of SWDA) applicable to the
method of disposal or use employed by the POTW.
(17) National Categorical Pretreatraent Standard or Pre-
treatment Standard. Any regulation containing
pollutant discharge limits promulgated by the EPA in
accordance with section 307(b) and (c) of the Act (33
U.S.C. 1347) which applies to a specific category of
Industrial Users.
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(18) National Prohibitive Discharge Standard or Prohibi-
tive Discharge Standard. Any regulation developed
under the authority of 307(b) of the Act and 40 CFR,
Section 403.5.
(19) New Source. Any source, the construction of which is
commenced after the publication of proposed regula-
tions prescribing a section 307(c) (33 D.S.C. 1317)
Categorical Pretreatment Standard which will be
applicable to such source, if such standard is there-
after promulgated within 120 days of proposal in the
Federal Register. Where the standard is promulgated
later than 120 days after proposal, a new source
means any source, the construction of which is
commenced after the date of promulgation of the
standard.
(20) National Pollution Discharge Elimination System or
NPDES Permit. A permit issued pursuant to section
402 of the Act (33 U.S.C. 1342).
(21) Person. Any individual, partnership, copartnership,
firm, company, corporation, association, joint stock
company, trust, estate, governmental entity or any
other legal entity, or their legal representatives,
agents or assigns. The masculine gender shall in-
clude the feminine, the singular shall include the
plural where indicated by the context.
(22) £H. The logarithm (base 10) of the reciprocal of the
concentration of hydrogen ions expressed in grams per
liter of solution.
(23) Pollution. The man-made or man-induced alteration of
the chemical, physical, biological, and radiological
integrity of water.
(24) Pollutant. Any dredged spoil, solid waste, inciner-
ator residue, sewage, garbage, sewage sludge,
munitions, chemical wastes, biological materials,
radioactive materials, heat, wrecked or discharged
equipment, rock, sand, cellar dirt and industrial,
municipal, and agricultrual waste discharged into
water.
(25) Pretreatment or Treatment. The reduction of the
amount of pollutants, the elimination of pollutants,
or the alteration of the nature of pollutant
properties in wastewater to a less harmful state
prior to or in lieu of discharging or otherwise
introducing such pollutants into a POTW. The reduc-
tion or alteration can be obtained by physical,
III-4
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chemical or biological processes, or process changes
other means, except as prohibited by 40 CFR Section
403.6(d).
(26) Pretreatment Requirements. Any substantive or proce-
dural requirement related to pretreatment, other than
a National Pretreament Standard imposed on an
industrial user.
(27) Publicly Owned Treatment Works (POTW). A treatment
works as defined by section 212 of the Act, (33
D.S.C. 1292) which is, owned in this instance by the
City. This definition includes any sewers that
convey wastewater to the POTW treatment plant, but
does not include pipes, sewers or other conveyances
not connected to a facility providing treatment. For
the purposes of this ordinance, "POTW" shall also
include any sewers that convey wastewaters to the
POTW from persons outside the (city) who are, by
contract or agreement with the (city), users of the
(city's) POTW.
(28) POTW Treatment Plant. That portion of the POTW
designed to provide treatment to wastewater.
(29) Shall is mandatory: May is permissive.
(30) Significant Industrial Dser. Any Industrial User of
the City's wastewater disposal system who (i) has a
discharge flow of 25,000 gallons or more per average
work day, or (ii) has a flow greater than 5% of the
flow in the City's wastewater treatment system, or
(iii) has in his wastes toxic pollutants as defined
pursuant to Section 307 of the Act of (State)
Statutes and rules or (iv) is found by the City,
(State Control Agency) or the U.S. Environmental
Protection Agency (EPA) to have significant impact,
either singly or in combination with other contribut-
ing industries, on the wastewater treatment system,
the quality of sludge, the system's effluent quality,
or air emissions generated by the system.
(31) State. State of .
(32) Standard Industrial Classification (SIC). A classif-
ication pursuant to the Standard Industrial
Classification Manual issued by the Executive Office
of the President, Office of Management and Budget,
1972.
(33) Storm Water. Any flow occurring during or following
any form of natural precipitation and resulting
therefrom.
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(34) Suspended Solids. The total suspended matter that
floats on the surface of, or is suspended in, water,
wastewater or other liquids, and which is removable
by laboratory filtering.
(35) Superintendent. The person designated by the City to
supervise the operation of the publicly owned treat-
ment works and who is charged with certain duties and
responsibilities by this article, or his duly
authorized representative.
(36) Toxic Pollutant. Any pollutant or combination of
pollutants listed as toxic in regulations promulgated
by the Administrator of the Environmental Protection
Agency under the provision of CWA 307(a) or other
Acts.
(37) User. Any person who contributes, causes or permits
the contribution of wastewater into the City's POTW.
(38) Wastewater. The liquid and water-carried industrial
or domestic wastes from dwellings, commercial build-
ings, industrial faciltities, and institutions,
together with may be present, whether treated or
untreated, which is contributed into or permitted to
enter the POTW.
(39) Waters of the State. All streams, lakes, ponds,
marshes, watercourses, waterways, wells, springs,
reservoirs, aquifers, irrigation systems, drainage
systems and all other bodies or accumulations of
water, surface or underground, natural or artificial,
public or private, which are contained within, flow
through, or border upon the State or any portion
thereof.
(40) Wastewater Contribution Permit. As set forth in sec-
tion 4.2 of this ordinance.
1.3 Abbreviations
The following abbreviations shall have the designated
meanings:
• BOD - Biochemical Oxygen Demand.
. CFR - Code of Federal Regulations.
COD - Chemical Oxygen Demand.
EPA - Environmental Protection Agency
• _1 - Liter.
mg - Milligrams.
mg/1 - Milligrams per liter.
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NPDES - National Pollutant Discharge Elimina-
tion System.
POTW - Publicly Owned Treatment Works.
SIC - Standard Industrial Classification.
SWDA - Solid Waste Disposal Act, 42 U.S.C. 6901,
et. seq.
USC - United States Code.
TSS - Total Suspended Solids.
SECTION 2 - REGULATIONS
2.1 General Discharge Prohibitions
No User shall contribute or cause to be contributed,
directly or indirectly, any pollutant or wastewater which
will interfere with the operation or performance of the
POTW. These general prohibitions apply to all such Users
of a POTW whether or not the User is subject to National
Categorical Pretreatment Standards or any other National,
State, or local Pretreatment Standards or Requirements. A
user may not contribute the following substances to any
POTW:
a) Any liquids, solids or gases which by reason of
their nature or quantity are, or may be, suffi-
cient either alone or by interaction with other
substances to cause fire or explosion or be in-
jurious in any other way to the POTW or to the
operation of the POTW. At no time, shall two
successive readings on an explosion hazard
meter, at the point of discharge into the system
(or at any point in the system) be more than
five percent (5%) nor any single reading over
ten percent (10%) of the Lower Explosive Limit
(LEL) of the meter. Prohibited materials
include, but are not limited to, gasoline,
kerosene, naphtha, benzene, toluene, xylene,
ethers, alcohols, ketones, aldehydes, peroxides,
chlorates, perchlorates, bromates, carbides, hy-
drides and sulfides and any other substances
which the City, the State or EPA has notified
the User is a fire hazard or a hazard to the
system.
b) Solid or viscous substances which may cause ob-
struction to the flow in a sewer or other inter-
ference with the operation of the wastewater
treatment facilities such as, but not limited
to: grease, garbage with particles greater than
one-half inch jCs") in any dimension, animal guts
or tissues, paunch manure, bones, hair, hides or
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fleshings, entrails, whole blood, feathers,
ashes, cinders, sand, spent lime, stone or
marble dust, metal, glass, staw, shavings, grass
clippings, rags, spent grains, spent hops, waste
paper, wood, plastics, gas, tar, asphalt
residues, residues from refining, or processing
of fuel or lubricating oil, mud, or glass
grinding or polishing wastes.
c) Any wastewater having a pH less than 5.0, unless
the POTW is specifically designed to accommodate
such wastewater, or wastewater having any other
corrosive property capable of causing damage or
hazard to structures, equipment, and/or person-
nel of the POTW.
d) Any wastewater containing toxic pollutants in
sufficient quantity, either singly or by inter-
action with other pollutants, to injure or
interfere with any wastewater treatment process,
constitute a hazard to humans or animals, create
a toxic effect in the receiving waters of the
POTW, or to exceed the limitation set forth in a
Categorical Pretreatment Standard. A toxic
pollutant shall include but not be limited to
any pollutant identified pursuant to Section
307(a) of the Act.
e) Any noxious or malodorous liquids, gases, or
solids which either singly or by interaction
with other wastes are sufficient to create a
public nuisance or hazard to life or are suffi-
cient to prevent entry into the sewers for
maintenance and repair.
f) Any substance which may cause the POTW's
effluent or any other product of the POTW such
as residues, sludges, or scums, to be unsuitable
for reclamation and reuse or to interfere with
the reclamation process. In no case, shall a
substance discharged to the POTW cause the POTW
to be in non-compliance with sludge use or dis-
posal criteria, guidelines or regulations devel-
oped under Section 405 of the Act; any criteria,
guidelines, or regulations affecting sludge use
or disposal developed pursuant to the Solid
Waste Disposal Act, the Clean Air Act, the Toxic
Substances Control Act, or State criteria
applicable to the sludge management method being
used.
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g) Any substance which will cause the POTW to
violate its NPDES and/or State Disposal System
Permit or the receiving water quality standards.
h) Any wastewater with objectionable color not re-
moved in the treatment process, such as, but not
limited to, dye wastes and vegetable tanning
solutions.
i) Any wastewater having a temperature which will
inhibit biological activity in the POTW treat-
ment plant resulting in Interference, but in no
case wastewater with a temperature at the
introduction into the POTW which exceeds 40°C
(104°F) unless the POTW treatment plant is
designed to accommodate such temperature.
j) Any pollutants, including oxygen demanding
pollutants (BOD, etc.) released at a flow rate
and/or pollutant concentration which a user
knows or has reason to know will cause Interfer-
ence to the POTW. In no case shall a slug load
have a flow rate or contain concentration or
qualities of pollutants that exceed for any time
period longer than fifteen (15) minutes more
than five (5) times the average twenty-four (24)
hour concentration, quantities, or flow during
normal operation.
k) Any wastewater containing any radioactive wastes
or isotopes of such halflife or concentration as
may exceed limits established by the Superinten-
dent in compliance with applicable State or
Federal regulations.
1) Any wastewater which causes a hazard to human
life or creates a public nuissance.
When the Superintendent determines that a Dser(s) is
contributing to the POTW, any of the above enumerated
subtances in such amounts as to Interfere with the
operation of the POTW, the Superintendent shall: 1)
Advise the User(s) of the impact of the contribution on
the POTW; and 2) Develop effluent 1imitation(s) for such
Oser to correct the Interference with the POTW.
2.2 Federal Categorical Pretreatment Standards
Upon the promulgation of the Federal Categorical Pretreat-
ment Standards for a particular industrial subcategory,
the Federal Standard, if more stringent than limitations
imposed under this Ordinance for sources in that sub-
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category, shall immediately supersede the limitations
imposed under this Ordinance. The Superintendent shall
notify all affected Users of the applicable reporting
requirements under 40 CFR, Section 403.12.
2.3 Modification of Federal Categorical Pretreatment
Standards
Where the City's wastewater treatment system achieves con-
sistent removal of pollutants limited by Federal Pretreat-
ment Standards, the City may apply to the Approval
Authority for modification of specific limits in the
Federal Pretreatment Standards. "Consistent Removal"
sh^ll mean reduction in the amount of a pollutant or
alteration of the nature of the pollutant by the waste-
water treatment system to a less toxic or harmless state
in the effluent which is achieved by the system 95 percent
of the samples taken when measured according to the pro-
cedures set forth in Section 403.7(c)(2) of (Title 40 of
the Code of Federal Regulations, Part 403) - "General
Pretreatment Regulations for Existing and New Sources of
Pollution" promulgated pursuant to the Act. The City may
then modify pollutant discharge limits in the Federal
Pretreatment Standards if the requirements contained in
40 CFR, Part 403, Section 403.7, are fulfilled and prior
approval from the Approval Authority is obtained.
2.4 Specific Pollutant Limitations (optional)
No person shall discharge wastewater containing in excess
of:
mg/1 arsenic
mg/1 cadmium
mg/1 copper
mg/1 cyanide
mg/1 lead
mg/1 mercury
mg/1 nickel
mg/1 silver
mg/1 total chromium
mg/1 zinc
mg/1 total identifiable chlorinated hydro-
carbons
mg/1 phenolic compounds which cannot be removed
by the City's wastewater treatment processes.
2.5 State Requirements
State requirements and limitations on discharges shall
apply in any case where they are more stringent than
Federal requirements and limitations or those in this
ordinance.
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2.6 City's Right of Revision
The City reserves the right to establish by ordinance more
stringent limitations or requirements on discharges to the
wastewater disposal system if deemed necessary to comply
with the objectives presented in Section 1.1 of this
Ordinance.
2.7 Excessive Discharge
No User shall ever increase the use of process water or,
in any way, attempt to dilute a discharge as a partial or
complete substitute for adequate treatment to achieve
compliance with the limitations contained in the Federal
Categorical Pretreatment Standards, or in any other
pollutant-specific limitation developed by the City or
State. (Comment: Dilution may be an acceptable means of
complying with some of the prohibitions set forth in
Section 2.1, e.g. the pH prohibition.)
2.8 Accidental Discharges
Each User shall provide protection from accidental dis-
charge of prohibited materials or other substances regu-
lated by this Ordinance. Facilities to prevent accidental
discharge of prohibited materials shall be provided and
maintained at the owner or user's own cost and expense.
Detailed plans showing facilities and operating procedures
to provide this protection shall be submitted to the City
for review, and shall be approved by the City before
construction of the facility. All existing Users shall
complete such a plan by January 1, 1983. No user who
commences contribution to the POTW after the effective
date of this ordinance shall be permitted to introduce
pollutants into the system until accidental discharge
procedures have been approved by the City. Review and
approval of such plans and operating procedures shall not
relieve the industrial user from the responsibility to
modify the user's facility as necessary to meet the
requirements of this Ordinance. In the case of an
accidental discharge, it is the responsibility of the user
to immediately telephone and notify the POTW of the
incident. The notification shall include location of
discharge, type of waste, concentration and volume, and
corrective actions.
Written Notice Within five (5) days following an
accidental discharge; the User shall submit to the Super-
intendent a detailed written report describing the cause
of the discharge and the measures to be taken by the User
to prevent similar future occurrences. Such notification
shall not relieve the user of any expense, loss, damage,
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or other liability which may be incurred as a result of
damage to the POTW, fish kills, or any other damage to
person or property; nor shall such notification relieve
the user of any fines, civil penalties, or other liability
which may be imposed by this article or other applicable
law.
Notice to Employees; A notice shall be permanently posted
on the User's bulletin board or other prominent place
advising employees whom to call in the event of a
dangerous discharge. Employers shall insure that all
employees who may cause or suffer such a dangerous
discharge to occur are advised of the emergency notifica-
tion procedure.
SECTION 3 - FEES
3.1 Purpose
It is the purpose of this chapter to provide for the recov
ery of costs from Users of the City's wastewater disposal
system for the implementation of the program established
herein. The applicable charges or fees shall be set forth
the City's Schedule of Charges and Fees.
3.2 Charges and Fees
The City may adopt charges and fees which may include:
a) fees for reimbursement of costs of setting up
and operating the City's Pretreatment Program;
b) fees for monitoring, inspections and surveil-
lance procedures;
c) fees for reviewing accidental discharge pro-
cedures and construction;
d) fees for permit applications;
e) fees for filing appeals;
f) fees for consistent removal (by the City) of
pollutants otherwise subject to Federal Pre-
treatment Standards;
g) other fees as the City may deem necessary to
carry out the requirements contained herein.
These fees relate solely to the matters covered by this
Ordinance and are separate from all other fees chargeable
by the City.
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SECTION 4 - ADMINISTRATION
4.1 Wastewater Dischargers
It shall be unlawful to discharge without a (city) permit
to any natural outlet within the (City of ), or in
any area under the jurisdiction of said (city), and/or to
the POTW any wastewater except as authorized by the Super-
intendent in accordance with the provisions of this
Ordinance.
4.2 Wastewater Contribution Permits
4.2.1 General Permits
All significant users proposing to connect to or to
contribute to the POTW shall obtain a Wastewater Dis-
charge Permit before connecting to or contributing to
the POTW. All existing significant users connected to
or contributing to the POTW shall obtain a Wastewater
Contribution Permit within 180 (optional) days after
the effective date of this Ordinance.
4.2.2 Permit Application
Users required to obtain a Wastewater Contribution
Permit shall complete and file with the City, an
application in the form prescribed by the City, and
accompanied by a fee of . Existing users shall
apply for a Wastewater Contribution Permit within 30
(optional) days after the effective date of this
Ordinance, and proposed new users shall apply at
least 90 (optional) days prior to connecting to or
contributing to the POTW. In support of the applica-
tion, the user shall submit, in units and terms
appropriate for evaluation, the following informa-
tion:
a) Name, address, and^location, (if different from
the address);
b) SIC number according to the Standard Industrial
Classification Manual, Bureau of the Budget,
1972, as amended;
c) Wastewater constituents and characteristics in-
cluding but not limited to those mentioned in
Section 2 of this Ordinance as determined by a
reliable analytical laboratory; sampling and an-
alysis shall be performed in accordance with
procedures established by the EPA pursuant to
Section 304(g) of the Act and contained in 40
CFR, Part 136, as amended;
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d) Time and duration of contribution;
e) Average daily and 3 minute peak wastewater flow
rates, including daily, monthly and seasonal
variations if any;
f) Site plans, floor plans, mechanical and plumbing
plans and details to show all sewers, sewer con-
nections, and appurtenances by the size,
location and elevation;
g) Description of activities, facilities and plant
processes on the premises including all
materials which are or could be discharged;
h) Where known, the nature and concentration of any
pollutants in the discharge which are limited by
any City, State, or Federal Pretreatment
Standards, and a statement regarding whether or
not the pretreatment standards are being met on
a consistent basis and if not, whether
additional Operation and Maintenance (O&M)
and/or additional pretreatment is required for
the User to meet applicable Pretreatment
Standards;
i) If additional pretreatment and/or O&M will be
required to meet the Pretreatment Standards;
the shortest schedule by which the User will
provide such additional pretreatment. The
completion date in this schedule shall not be
later than the compliance date established for
the applicable Pretreatment Standard:
The following conditions shall apply to this
schedule:
(1) The schedule shall contain increments of
progress in the form of dates for the commence-
ment and completion of major events leading to
the construction and operation of additional
pretreatment required for the Dser to meet the
applicable Pretreatment Standards (e.g., hiring
an engineer, completing preliminary plans, com-
pleting final plans, executing contract for
major components, commencing construction, com-
pleting construction, etc.).
(2) No increment referred to in paragraph (1)
shall exceed 9 months.
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(3) Not later than 14 days following each date
in the schedule and the final date for
compliance, the User shall submit a progress
report to the Superintendent including, as a
minimum, whether or not it complied with the
increment of progress to be met on such date
and, if not, the date on which it expects to
comply with this increment of progress, the
reason for delay, and the steps being taken by
the User to return the construction to the
schedule established. In no event shall more
than 9 months elapse between such progress
reports to the Superintendent.
j) Each product produced by type, amount, process
or processes and rate of production;
k) Type and amount of raw materials processed
(average and maximum per day);
1) Number and type of employees, and hours of
operation of plant and proposed or actual hours
of operation of pretreatnent system;
m) Any other information as may be deemed by the
City to be necessary to evaluate the permit
application.
The City will evaluate the data furnished by the user
and may require additional information. After
evaluation and acceptance of the data furnished, the
City may issue a Wastewater Contribution Permit
subject to terms and conditions provided herein.
4.2.3 Permit Modifications
Within 9 months of the promulgation of a National
Categorical Pretreatment Standard, the Wastewater
Contribution Permit of Users subject to such
standards shall be revised to require compliance with
such standard within the time frame prescribed by
such standard. Where a User, subject to a National
Categorical Pretreatment Standard, has not previously
submitted an application for a Wastewater Contribu-
tion Permit as required by 4.2.2, the User shall
apply for a Wastewater Contribution Permit within 180
days after the promulgation of the Applicable
National Categorical Pretreatment Standard. In
addition, the User with an existing Wastewater
Contribution Permit shall submit to the Superin-
tendent within 180 days after the promulgation of an
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applicable Federal Categorical Pretreatment Standard
the information required by paragraph (h) and (i) of
Section 4.2.2.
4.2.4 Permit Conditions
Wastewater Discharge Permits shall be expressly
subject to all provisions of this Ordinance and all
other applicable regulations, user charges and fees
established by the City. Permits may contain the
following:
a) The unit charge or schedule of user charges and
fees for the wastewater to be discharged to a
community sewer;
b) Limits on the average and maximum wastewater
constituents and characteristics;
c) Limits on average and maximum rate and time of
discharge or requirements for flow regulations
and equalization.
d) Requirements for installation and maintenance of
inspection and sampling facilities;
e) Specifications for monitoring programs which may
include sampling locations, frequency of
sampling, number, typesj and standards for tests
and reporting schedule;
f) Compliance schedules;
g) Requirements for submission of technical reports
or discharge reports (see 4.3);
h) Requirements for maintaining and retaining plant
records relating to wastewater discharge as
specified by the City, and affording City access
thereto;
i) Requirements' for notification of the City or any
new introduction of wastewater constitutents or
any substantial change in the volume or
character of the wastewater constitutents being
introduced into the wastewater treatment system.
j) Requirements for notification of slug discharges
as per 5.2;
1) Other conditions as deemed appropriate by the
City to ensure compliance with this Ordinance.
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4.2.5 Permits Duration
Permits shall be issued for a specified time period,
not to exceed five (5) (optional) years. A permit
may be issued for a period less than a year or may be
stated to expire on a specific date. The user shall
apply for permit reissuance a minimum of 180 days
prior to the expiration of the user's existing
permit. The terms and conditions of the permit may
be subject to modification by the City during the
term of the permit as limitations or requirements as
identified in Section 2 are modified or other just
cause exists. The User shall be informed of any
proposed changes in his permit at least 30 days prior
to the effective date of change. Any changes or new
conditions in the permit shall include a reasonable
time schedule for compliance.
4.2.6 Permit Transfer
Wastewater Discharge Permits are issued to a specific
User for a specific operation. A wastewater
discharge permit shall not be reassigned or trans-
ferred or sold to a new owner, new User, different
premises, or a new or changed operation without the
approval of the City. Any succeeding owner or User
shall also comply with the terms and conditions of
the existing permit.
4.3 Reporting Requirements for Permittee
4.3.1 Compliance Date Report
Within 90 days following the date for final
compliance with applicable Pretreatment Standards or,
in the case of a New Source, following commencement
of the introduction of wastewater into the POTW, any
User subject to Pretreatment Standards and Require-
ments shall submit to the Superintendent a report
indicating the nature and concentration of all
pollutants in the discharge from the regulated
process which are limited by Pretreatment Standards
and Requirements and the average and maximum daily
flow for these process units in the User facility
which are limited by such Pretreatment Standards or
Requirements. The report shall state whether the
applicable Pretreatment Standards or Requirements are
being met on a consistent basis and, if not, what
additional O&M and/or pretreatment is necessary to
bring the User into compliance with the applicable
Pretreatment Standards or Requirements. This state-
ment shall be signed by an authorized representative
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of the Industrial User, and certified to by a
qualified professional.
4.3.2 Periodic Compliance Reports
(1) Any User subject to a Pretreatment Standard,
after the compliance date of such Pretreatment
Standard, or, in the case of a New Source, after
commencement of the discharge into the POTW,
shall submit to the Superintendent during the
months of June and December, unless required
more frequently in the Pretreatment Standard or
by the superintendent, a report indicating the
nature and concentration, of pollutants in the
effluent which are limited by such Pretreatment
Standards. In addition, this report shall
include a record of all daily flows which during
the reporting period exceeded the average daily
flow reported in paragraph (b)(4) of this
section. At the discretion of the superin-
tendent and in consideration of such factors as
local high or low flow rates, holidays, budget
cycles, etc., the superintendent may agree to
alter the months during which the above reports
are to be submitted.
(2) The Superintendent may impose mass limitations
on Users which are using dilution to meet
applicable Pretreatment Standards or Require-
ments, or in other cases where the imposition of
mass limitations are appropriate. In such
cases, the report required by subparagraph (1)
of this paragraph shall indicate the mass of
pollutants regulated by Pretreatment Standards
in the effluent of the User. These reports
shall contain the results of sampling and
analysis of the discharge, including the flow
and the nature and concentration, or production
and mass where requested by the Superintendent,
of pollutants contained therein which are
limited by the applicable Pretreatment Stan-
dards. The frequency of monitoring shall be
prescribed in the applicable Pretreatment
Standard. All analysis shall be performed in
accordance with procedures established by the
Administrator pursuant to section 304(g) of the
Act and contained in 40 CFR, Part 136 and
amendments thereto or with any other test
procedures approved by the Administrator.
Sampling shall be performed in accordance with
the techniques approved by the Administrator.
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(Comment: VThere 40 CFR, Part 136 does not
include a sampling or analytical technique for
the pollutant in question sampling and analysis
shall be performed in accordance with the pro-
cedures set forth in the EPA publication,
Sampling and Analysis Procedures for Screening
of Industrial Effluents for Priority Pollutants,
April, 1977, and amendments therto, or with any
other sampling and analytical procedures
approved by the Administrator.)
4.4 Monitoring Facilities
The City shall require to be provided and operated at the
User's own expense, monitoring facilities to allow inspec-
tion, sampling, and flow measurement of the building sewer
and/or internal drainage systems. The monitoring facility
should normally be situated on the User's premises, but
the City may, when such a location would be impractical or
cause undue hardship on the User, allow the facility to be
constructed in the public street or sidewalk area and
located so that it will not be obstructed by landscaping
or parked vehicles.
There shall be ample room in or near such sampling manhole
or facility to allow accurate sampling and preparation of
samples for analysis. The facility, sampling, and measur-
ing equipment shall be maintained at all times in a safe
and proper operating condition at the expense of the user.
Whether constructed on public or private property, the
sampling and monitoring facilities shall be provided in
accordance with the City's requirements and all applicable
local construction standards and specifications. Con-
struction shall be completed within 90 days following
written notification by the City.
4.5 Inspection and Sampling
The City shall inspect the facilities of any User to
ascertain whether the purpose of this Ordinance is being
met and all requirements are being complied with. Persons
or occupants of premises where wastewater is created or
discharged shall allow the City or their representative
ready access at all reasonable times to all parts of the
premises for the purposes of inspection, sampling, records
examination or in the performance of any of their duties.
The City, Approval Authority and (where the NPDES State is
the Approval Authority). EPA shall have the right to set
up on the User's property such devices as are necessary to
conduct sampling inspection, compliance monitoring and/or
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metering operations. Where a User has security measures in
force which would require proper identification and
clearance before entry into their premises, the User shall
make necessary arrangements with their security guards so
that upon presentation of suitable identification,
personnel from the City, Approval Authority and EPA will
be permitted to enter, without delay, for the purposes of
performing their specific responsibilities.
4.6 Pretreatment
Users shall provide necessary.wastewater treatment as re-
quired to comply with this Ordinance and shall achieve
compliance with all Federal Categorical Pretreatment
Standards within the time limitations as specified by the
Federal Pretreatment Regulations. Any facilities required
to pretreat wastewater to a level acceptable to the City
shall be provided, operated, and maintained at the User's
expense. Detailed plans showing the pretreatment facili-
ties and operating procedures shall be submitted to the
City for review, and shall be acceptable to the City
before construction of the facility. The review of such
plans and operating procedures will in no way relieve the
user from the responsibility of modifying the facility as
necessary to produce an effluent acceptable to the City
under the provisions of this Ordinance. Any subsequent
changes in the pretreatment facilities or method of
operation shall be reported to and be acceptable to the
City prior to the user's initiation of the changes.
The City shall annually publish in the news-
paper a list of the Users which were not in compliance
with any Pretreatment Requirements or Standards at least
once during the 12 previous months. The notification
shall also summarize any enforcement actions taken against
the user(s) during the same 12 months.
All records relating to compliance with- Pretreatment
Standards shall be made available to officials of the EPA
or Approval Authority upon request.
4.7 Confidential Information
Information and data on a User obtained from reports, ques-
tionnaires, permit applications, permits and monitoring
programs and from inspections shall be available to the
public or other governmental agency without restriction
unless the User specifically requests and is able to
demonstrate to the satisfaction of the City that the
release of such information would divulge information,
processes or methods of production entitled to protection
as trade secrets of the User.
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When requested by the person furnishing a report, the por-
tions of a report which might disclose trade secrets or
secret processes shall not be made available for inspec-
tion by the public but shall be made available upon
written request to governmental agencies for uses related
to this Ordinance, the National Pollutant Discharge
Elimination System (NPDES) Permit, State Disposal System
permit and/or the Pretreatment Programs; provided,
however, that such portions of a report shall be available
for use by the State or any state agency in judicial
review or enforcement proceedings involving the person
furnishing the report. Wastewater constituents and
characteristics will not be recognized as confidential
information.
Information accepted by the City as confidential, shall
not be transmitted to any governmental agency or to the
general public by the City until and unless a ten-day
notification is given to the User.
SECTION 5 - ENFORCEMENT
5.0 Harmful Contributions
The City may suspend the wastewater treatment service
and/or a Wastewater Contribution Permit when such suspen-
sion is necessary, in the opinion of the City, in order to
stop an actual or threatened discharge which presents or
may present an imminent or substantial endangerment to the
health or welfare of persons, to the environment, causes
Interference to the POTW or causes the City to violate any
condition of its NPDES Permit.
Any person notified of a suspension of the wastewater
treatment service and/or the Wastewater Contribution
Permit shall immediately stop or eliminate the contribu-
tion. In the event of a failure of the person to comply
voluntarily with the suspension order, the City shall take
such steps as deemed necessary including immediate
severance of the sewer connection, to prevent or minimize
damage to the POTW system or endangerment to any
individuals. The City shall reinstate the Wastewater
Contribution Permit and/or the wastewater treatment
service upon proof of the elimination of the non-complying
discharge. A detailed written statement submitted by the
user describing the causes of the harmful contribution and
the measures taken to prevent any future occurrence shall
be submitted to the City within 15 days of the date of
occurrence.
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5.2 Revocation of Permit
Any User who violates the following conditions of this Or-
dinance , or applicable state and federal regulations, is
subject to having his permit revoked in accordance with
the procedures of Section 5 of this Ordinance:
a) Failure of a User to factually report the wastewater
constituents and characteristics of his discharge;
b) Failure of the User to report significant changes in
operations/ or wastewater constituents and charac-
teristics ;
c) Refusal of reasonable access to the User's premises
for the purpose of inspection or monitoring; or,
d) Violation of conditions of the permit.
5.3 Notification of Violation
Whenever the City finds that any User has violated or is
violating this Ordinance, wastewater contribution permit,
or any prohibition, limitation of requirements contained
herein, the City may serve upon such person a written
notice stating the nature of the violation. Within 30
days of the date of the notice, a plan for the satis-
factory correction thereof shall be submitted to the City
by the User.
5.4 Show Cause Hearing
5.4.1
The City may order any User who causes or. allows an
unauthorized discharge to enter the POTW to show
cause before the City Council why the proposed
enforcement action should not be taken. A notice
shall be served on the User specifying the time and
place of a hearing to be held by the City Council
regarding the violation, the reasons why the action
is to be taken, the proposed enforcement action, and
directing the User to show cause before the City
Council why the proposed enforcement action should
not be taken. The notice of the hearing shall be
served personally or by registered or certified mail
(return receipt requested) at least (ten) days before
the hearing. Service may be made on any agent or
officer of a corporation.
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5.4.2
The City Council may itself conduct the hearing and
take the evidence, or may designate any of its
members or any officer or employee of the (assigned
department) to:
a) Issue in the name of the City Council notices of
hearings requesting the attendance and testimony
of witnesses and the production of evidence
relevant to any matter involved in such hear-
ings;
b) Take the evidence;
c) Transmit a report of the evidence and hearing,
including transcripts and other evidence, to-
gether with recommendations to the City Council
for action thereon.
5.4.3
At any hearing held pursuant to this Ordinance,
testimony taken must be under oath and recorded
stenographically. The transcript, so recorded, will
be made available to any member of the public or any
party to the hearing upon payment of the usual
charges thereof.
5.4.4
After the City Council has reviewed the evidence, it
may issue an order to the User responsible for the
discharge directing that, following a specified time
period, the sewer service be discontinued unless ade-
quate treatment facilities, devices or other related
appurtenances shall have been installed on existing
treatment facilities, devices or other related appur-
tenances are properly operated. Further orders and
directives as are necessary and appropriate may be
issued.
5.5 Legal Action
If any person discharges sewage, industrial wastes or
other wastes into the city's wastewater disposal system
contrary to the provisions of this Ordinance, Federal or
State Pretreatment Requirements, or any order of the City,
the City Attorney may commence an action for appropriate
legal and/or equitable relief in the (Circuit) Court of
this county.
111-23
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SECTION 6 ~ PENALTY; COSTS
6.1 Civil Penalties
Any User who is found to have violated an Order of the
City Council or who willfully or negligently failed to
comply with any provision of this Ordinance, and the
orders, rules, regulations and permits issued hereunder,
shall be fined not less than (One Hundred Dollars)
(optional) nor more than (One Thousand Dollars) (optional)
for each offense. Each day on which a violation shall
occur or continue shall be deemed a separate and distinct
offense. In addition to the penalties provided herein,
the City may recover reasonable attorneys' fees, court
costs, court reporters' fees and other expenses of
litigation by appropriate suit at law against the person
found to have violated this Ordinance or the orders,
rules, regulations, and permits issued hereunder.
6.2 Falsifying Information
Any person who knowingly makes any false statements,
representation or certification in any application,
record, report, plan or other document filed or required
to be maintained pursuant to this Ordinance, or Wastewater
Contribution Permit, or who falsifies, tampers with, or
knowingly renders inaccurate any monitoring device or
method required under this Ordinance, shall, upon con-
viction, be punished by a fine of not more than $1,000 or
by imprisonment for not more than six (6) months, or by
both.
SECTION 7 - SEVERABILITY
If any provision, paragraph, word, section or article of
this Ordinance is invalidated by any court of competent
jurisdiction, the remaining provisions, paragraphs, words,
sections, and chapters shall not be affected and shall
continue in full force and effect.
SECTION 8 - CONFLICT
All other Ordinances and parts of other Ordinances incon-
sistent or conflicting with any part of this Ordinance are
hereby repealed to the extent of such inconsistency or
conflict.
111-24
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SECTION 9 - EFFECTIVE DATE
This Ordinance shall be in full force and effect (Option
A) from and after its passage, approval and publication,
as provided by law. (Option B) on the day of ,
19 .
INTRODUCED the day of , 19
FIRST READING: , 19 .
SECOND READING: , 19 .
PASSED this day of , 19 .
AYES:
NAYS:
ABSENT:
NOT VOTING:
APPROVED by me this day of , 19_
MAYOR, CITY OF
ATTEST: (Seal) City Clerk
Published the day of , 19 .
SECTION 10 - INDUSTRIAL SEWER CONNECTION APPLICATION
To the (city or town) of :
The undersigned being the of the
property located at
does hereby request a permit to an industrial
sewer connection serving , which
company is engaged in
at said location.
1. A plan to the property showing accurately all
sewers and drains now existing is attached here-
unto as Exhibit "A".
111-25
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2. Plans and specifications covering any work pro-
posed to be performed under this permit is
attached hereunto as Exhibit "B".
3. A complete schedule of all process waters and
industrial wastes produced or expected to be
produced at said property, including a descrip-
tion of the character of each waste, the daily
volume and maximum rates of discharge, repre-
sentative analyses, and compliance with any
applicable Pretreatment Standard or Require-
ments, is attached hereunto as Exhibit "C".
4. The name and address of the person or firm who
will perform the work covered by this permit is
In consideration of the granting of this permit the under-
signed agrees:
1. To furnish any additional information relating
to the installation or use of the industrial
sewer for which this permit is sought as may be
requested by the City.
2. To accept and abide by all provisions of Ordi-
nance No. of the City of ,
and of all other pertinent Ordinances or
regulations that may be adopted in the future.
3. To operate and maintain any waste pretreatment
facilities, as may be required as a condition of
the acceptance into the wastewater treatment
system of the industrial wastes involved, in an
efficient manner at all times, and at no expense
to the City.
4. To cooperate at all times with the City and his
representatives in their inspecting, sampling,
and study of the industrial wastes, and any
facilities provided for pretreatment.
5. To notify the City immediately in the event of
any accident, or other occurrence that occasions
contributor to the wastewater treatment system
of any wastewater or substances prohibited or
not covered by this permit.
111-26
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Date:
Signed
$ inspection fee paid
Application approved and permit granted
Date: Signed
111-27
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SECTION 11 - WASTEWATER DISCHARGE PERMIT
City of
Department of Public Works
WASTEWATER DISCHARGE PERMIT
Permit No.
In accordance with all terms and conditions of the City Code,
Part , Article , , Section et. seq., and also
with any applicable provisions of Federal or state law or regulation;
Permission Is Hereby Granted To
Classified by SIC No.
For the contribution of
into the City of sewer lines at
This permit is granted in accordance with the application filed on
, 19 in the office of the
( ) and in conformity with plans, specifications and
other data submitted to the { ) in support of the above application, all of
which are filed with and considered as part of this permit, together with the
following named conditions and requirements.
Effective this day of , 19
To Expire day of , 19
Super i ntendent
111-28
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Permit No.
Parameters (mg/l)
Limitations on
Wastewater Strength
Mon i tor i ng
Requi rements
(E, SV, SC)
Maximum Cone,
(mg/l) - 2k hour
Flow Proportional
Composite Sample
Maximum
Instantaneous
Concentration
(mg/l) (Grab Sample)
Aluminum-dissolved (Al)
Antimony (Sb)
Arsenic (As)
Barium (Ba)
Boron (B)
Cadmium (Cd)
Chromium-total (Cr)
Chromium-hexavalent (Cr0"1")
Cobalt (Co)
Copper (Cu)
Cyanide (CN)
Fluoride (F)
Iron (Fe)
Lead (Pb)
Manganese (Mn)
Mercury (Hg)
Nickel (Ni)
Phenols
Selenium (Se)
Silver (Ag)
Titanium-dissolved (Ti)
Zinc (Zn)
Total Kjeldahl Nitrogen (TKN)
Oil & Grease (Petroleum 5/or mineral)
MBAS
Total Dissolved Solids
Temperature-maximum (degrees C)
pH-maximum (pH units)
pH-minimum (pH units)
Biochemical Oxygen Demand
¦
Chemical Oxygen Demand
Suspended Solids
Flow - (MGD)
E - Enforcement Monitoring
SV - Surveillance Monitoring
SC - Surcharge Monitoring
111-29
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Permit No.
ADDENDUM I
Monitoring Schedule
111-30
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Compliance Schedule
Permit No.
ADDENDUM II
111-31
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APPENDIX IV
MODEL INDUSTRIAL
WASTE QUESTIONNAIRE
-------
MODEL INDUSTRIAL WASTE QUESTIONNAIRE
GENERAL INFORMATION
Standard Industrial Classification Code (SIC)
Company Name
Mailing Address
Address of Premises
Name and Title of Signing Official
Contact Official
Name
Title
Address
Phone
The information contained in this questionnaire is
familiar to me and to the best of my knowledge and belief,
such information is true, complete, and accurate.
Date Signature of Official
PLANT OPERATIONAL CHARACTERISTICS
Brief description of manufacturing or service activity on
premises:
Principal Raw Materials Used:
Catalysts, Intermediates:
IV-1
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Principal Product or Service (use Standard Industrial
Classification Manual if appropriate)
Type of Discharge: Batch Continuous
If batch, average number of batches/24 hrs
Is there a scheduled shutdown?
When?
Is production seasonal?
If yes, explain indicating month(s) of peak production
Average number of employees per shift: 1st; 2nd;
3rd
Shift start times: 1st; 2nd; 3rd
Shifts normally worked each day:
Sun Mon Tue Wed Thu Fri Sat
1st
2nd
3rd
Describe any wastewater treatment equipment or processes
in use:
Raw Water Sources:
Source
Quantity
gallons per day
gallons per day
gallons per day
Describe any raw water treatment processes in use:
IV-2
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List Water Consumption in Plant
Coolinq water
qallons
per
day
Boiler feed
gallons
per
day
Process water
qallons
per
day
Sanitary system
qallons
per
day
Contained in product
qallons
per
day
Other
qallons
per
day
List average volume of discharge or water loss to
City wastewater sewer
qallons
per
day
Natural outlet
qallons
per
day
Waste hauler
qallons
per
day
Evaporation
qallons
per
day
Contained in product
qallons
per
day
Is discharge to sewer: Intermittent Steady
List plant sewer outlets, size, flow (attach and refer to
map):
Is there a Spill Prevention Control and Countermeasure
Plan in effect for this plant?
Yes No
Are any of the toxic pollutants listed in Table 1 being
used at this facility in manufacturing of the product or
is a by product which may be discharged? If so, please
indicate by a check mark on Table 1.
IV-3
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TABLE - 1
65 Toxic Pollutants Listed In Consent Decree and
Referenced in 307(a) of the CWA of 1977
Acenapthene
Acrolein
Acrylonitrile
Aldrin/Dieldrin
Antimony and compounds
Arsenic and compounds
Asbestos
Benzene
Benzidine
Beryllium and compounds
Cadmium and compounds
Carbon tetrachloride
Chlordane
Chlorinated benzenes
Chlorinated ethanes
Chlorinalkyl ethers
Chlorinated naphthalene
Chlorinated phenols
Chloroform
2-chlorophenol
Chromium and compounds
Copper and compounds
Cyanides
DDT and metabolities
Dichlorobenzenes
Dichlorobenzidine
Dichloroethylenes
2, 4-dichlorophenol
Dichloropropane &
Dichloropropene
2, 4-dimethylphenol
Dinitrotoluene
Diphenylhydrazine
Endosulfan & metabolites
Endrin and metabolites
Ethylbenzene
Fluoranthene
Haloethers
Halomethanes
Heptachlor and metabolites
Hexachlorobutadiene
Hexach1orocyc1opentadi ene
Hexachlorocylohexane
Isophorone
Lead and compounds
Mercury and compounds
Naphthalene
Nickel and compounds
Nitrobenzene
Nitrophenols
Nitrosamines
Pentachlorophenol
Phenol
Phthalate esters
Polychlorinated byphenyls(PCB)
Polynuclear aromatic
hydrocarbons
Selenium and compounds
Silver and compounds
2,3/7,8,-Tetrachlorodibenzo-
p-dioxin (TCDD)
Tetrachloroethylene
Thallium and compounds
Toluene
Toxaphene
Trichloroethylene
Vinyl chloride
Zinc and compounds
List any other toxicants known or anticipated to be present
in the discharge.
IV-4
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PRETREATMENT
Is this plant subject to an existing Federal Pretreatment
Standard? If so, are Pretreatment Standards being
met on a consistent basis?
i
Are additional pretreatment facilities and/or operation
and maintenance required to meet Pretreatment Standards?
If additional pretreatment and/or operation and main-
tenance are required, list the schedule by which they will
be provided:
IV-5
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