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EPA-833-B-98-002
February 1999
Introduction to the National
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Disclaimer
Mention of trade names or commercial products in this
document or associated references does not constitute
an endorsement or recommendation for use.
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Introduction to the National Pretreatment Program Table of Contents
TABLE OF CONTENTS
Preface iii
List of Acronyms v
Glossary of Terms vii
1. POTWs and the Need for the Pretreatment Program 1
Sewage Treatment 1
Need for the Pretreatment Program 2
2. Overview of the National Pretreatment Program 5
The Clean Water Act 5
The General Pretreatment Regulations 6
POTW Pretreatment Programs 7
3. Pretreatment Standards 11
Prohibited Discharge Standards 11
Categorical Standards 12
Local Limits 20
Summary of Standards 22
4. POTW Pretreatment Program Responsibilities 23
Legal Authority 23
Industrial Waste Surveys 24
Permitting 25
Inspections 26
Sampling 27
Enforcement 28
Data Management and Record Keeping 31
Public Participation and POTW Reporting 32
5. Industrial User Pretreatment Program Responsibilities 35
Reporting Requirements 35
Self-Monitoring Requirements 39
Record Keeping Requirements 40
6. Hauled Wastes 43
Nature of Hauled Wastes 43
Control Programs 43
Concerns 45
7. Pollution Prevention 47
Pollution Prevention and the Pretreatment Program 48
Benefits of Pollution Prevention 49
Pollution Prevention Assistance 50
8. Bibliography 51
APPENDICES
A Annotated Summaries of Existing Pretreatment Guidance Material A-1
B Document Ordering Information B-1
C EPA/State Primary Pretreatment Contacts/Addresses C-1
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Introduction to the National Pretreatment Program Preface
PREFACE
The industrial boom in the United States during the 1950s and 60s brought with it a level of pollution
never before seen in this country. Scenes of dying fish, burning rivers, and thick black smog engulfing major
metropolitan areas were images and stories repeated regularly on the evening news. In December of 1970,
the President of the United States created the U.S. Environmental Protection Agency (EPA) through an
executive order in response to these critical environmental problems.
In 1972, Congress passed the Clean Water Act (CWA) to restore and maintain the integrity of the
nation's waters. Although prior legislation had been enacted to address water pollution, those previous
efforts were developed with other goals in mind. For example, the 1899 Rivers and Harbors Act protected
navigational interests while the 1948 Water Pollution Control Act and the 1956 Federal Water Pollution
Control Act merely provided limited funding for State and local governments to address water pollution
concerns on their own.
The CWA required the elimination of the discharge of pollutants into the nation's waters and the
achievement of fishable and swimmable waterquality levels. EPA's National Pollutant Discharge Elimination
System (NPDES) Permitting Program represents one of the key components established to accomplish this
feat. The NPDES program requires that all point source discharges to waters of the U.S. (i.e., "direct
discharges") must be permitted.
To address "indirect discharges" from industries to Publicly Owned Treatment Works (POTWs), EPA,
through CWA authorities, established the National Pretreatment Program as a component of the NPDES
Permitting Program. The National Pretreatment Program requires industrial and commercial dischargers
to treat or control pollutants in their wastewater prior to discharge to POTWs.
In 1986, more than one-third of all toxic pollutants entered the nation's waters from publicly owned
treatment works (POTWs) through industrial discharges to public sewers.1 Certain industrial discharges,
such as slug loads, can interfere with the operation of POTWs, leading to the discharge of untreated or
inadequately treated wastewater into rivers, lakes, etc. Some pollutants are not compatible with biological
wastewater treatment at POTWs and may pass through the treatment plant untreated. This "pass through"
of pollutants impacts the surrounding environment, occasionally causing fish kills or other detrimental
alterations of the receiving waters. Even when POTWs have the capability to remove toxic pollutants from
wastewater, these toxics can end up in the POTWs sewage sludge, which in many places is land applied
to food crops, parks, or golf courses as fertilizer or soil conditioner.
The National Pretreatment Program is unique in that the General Pretreatment Regulations require all
large POTWs (i.e., those designed to treat flows of more than 5 million gallons per day) and smaller POTWs
with significant industrial discharges to establish local pretreatment programs. These local programs must
enforce all national pretreatment standards and requirements in addition to any more stringent local
requirements necessary to protect site-specific conditions at the POTW. More than 1,500 POTWs have
developed and are implementing local pretreatment programs designed to control discharges from
approximately 30,000 significant industrial users.
Since 1983, the Pretreatment Program has made great strides in reducing the discharge of toxic
pollutants to sewer systems and to waters of the U.S. In the eyes of many, the Pretreatment Program,
implemented as a partnership between EPA, States, and POTWs, is a notable success story in reducing
impacts to human health and the environment. These strides can be attributed to the efforts of many
Federal, State, local, and industrial representatives who have been involved with developing and
implementing the various aspects of the Pretreatment Program.
EPA, Environmental Regulations and Technology: The National Pretreatment Program, July 1986,
p.4.
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Preface Introduction to the National Pretreatment Program
EPA has supported the Pretreatment Program through development of numerous guidance manuals.
EPA has released more than 30 manuals that provide guidance to EPA, States, POTWs, and industry on
various pretreatment program requirements and policy determinations. Through this guidance, the
Pretreatment Program has maintained national consistency in interpretation of the regulations.
Nevertheless, turnover in pretreatment program staff has diluted historical knowledge leaving new staff
and other interested parties unaware of existing materials. With this in mind, the intent of this guidance
manual, Introduction to the National Pretreatment Program, is to:
(1) provide a reference for anyone interested in understanding the basics of pretreatment program
requirements, and
(2) provide a roadmap to additional and more detailed guidance materials for those trying to
implement specific elements of the Pretreatment Program.
While the Pretreatment Program has demonstrated significant reductions in pollutants discharged to
POTWs, Congress' goals of zero discharge of toxic pollutants and fishable/swimmable water quality have
not been realized. EPA is currently working to establish more cost-effective and common sense approaches
to environmental protection (e.g., using watershed, streamlining, and reinvention concepts), creating new
responsibilities for all those involved in the National Pretreatment Program. Many current challenges
remain, while many new ones likely lie ahead. This guidance manual is intended to provide an
understanding of the basic concepts that drive the Program, the current status of the Program and program
guidance, and an insight into what the future holds for all those involved with implementing the Pretreatment
Program.
As noted above, this guidance manual is organized to provide an overview of program requirements and
to referthe readerto more detailed EPA guidance that exists on specific program elements. To accomplish
this, the guidance manual incorporates two key features: 1) the first page of each chapter contains a list of
EPA references applicable to the topics discussed in that chapter, and 2) abstracts of each reference are
provided in Appendix A with document ordering information provided in Appendix B. Addresses of EPA and
State pretreatment staff are provided in AppendixC. Additionally, Chapters contains a bibliography of these
guidance materials, and other materials that may be useful to the reader and describes how to obtain them.
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Introduction to the National Pretreatment Program
List of Acronyms
LIST OF ACRONYMS
Acronym Full Phrase
AA Approval Authority
AO Administrative Order
BAT Best Available Technology Economically Achievable
BCT Best Conventional Pollutant Control Technology
BMP Best Management Practices
BMR Baseline Monitoring Report
BOD5 5-day Biochemical Oxygen Demand
BPJ Best Professional Judgment
BPT Best Practicable Control Technology Currently Available
CA Control Authority
CFR Code of Federal Regulations
CIU Categorical Industrial User
CSO Combined Sewer Overflow
CWA Clean Water Act (formerly referred to as the Federal Water Pollution Control Act or Federal
Water Pollution Control Act Amendments of 1972) Pub. L. 92-500, as amended by Pub. L. 95-
217, Pub. L. 95-576, Pub. L. 96-483, Pub. L. 97-117, and Pub. L. 100-4, 33 U.S.C. 1251 etseq.
CWF Combined Wastestream Formula
CWT Centralized Waste Treater
DMR Discharge Monitoring Report
DSE Domestic Sewage Exclusion
DSS Domestic Sewage Study
ELG Effluent Limitations Guideline
EPA Environmental Protection Agency
EPCRA Emergency Preparedness and Community Right to Know Act
ERP Enforcement Response Plan
FDF Fundamentally Different Factors
FR Federal Register
FWA Flow Weighted Average
gpd Gallons per Day
ID Industrial User
LEL Lower Explosive Limit
MAHL Maximum Allowable Headworks Loading
MAIL Maximum Allowable Industrial Loading
MGD Million Gallons per Day
MSDS Material Safety Data Sheet
NAICS North American Industry Classification System (replaces SIC coding system in 1998)
NOV Notice of Violation
NPDES National Pollutant Discharge Elimination System
NRDC Natural Resources Defense Council
NSPS New Source Performance Standard
O&G Oil and Grease
Acronym Full Phrase
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List of Acronyms
Introduction to the National Pretreatment Program
O&M Operations and Maintenance
OCPSF Organic Chemicals, Plastics, and Synthetic Fibers
P2 Pollution Prevention
PCI Pretreatment Compliance Inspection
PCS Permit Compliance System
PIRT Pretreatment Implementation Review Task Force
POTW Publicly Owned Treatment Works
PSES Pretreatment Standards for Existing Sources
PSNS Pretreatment Standards for New Sources
QA/QC Quality Assurance/Quality Control
RCRA Resource Conservation and Recovery Act
SIC Standard Industrial Classification
SIU Significant Industrial User
SPCC Spill Prevention Control and Countermeasures
SNC Significant Noncompliance
SSO Sanitary Sewer Overflow
SUO Sewer Use Ordinance
TCLP Toxicity Characteristic Leaching Procedure
TIE Toxicity Identification Evaluation
TOMP Toxic Organic Management Program
TRE Toxicity Reduction Evaluation
TRI Toxic Release Inventory
TSS Total Suspended Solids
TTO Total Toxic Organics
USC United States Code
UST Underground Storage Tank
WET Whole Effluent Toxicity
WWTP Wastewater Treatment Plant
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Introduction to the National Pretreatment Program Glossary of Terms
GLOSSARY OF TERMS
This glossary includes a collection of terms used in this manual and an explanation of each term. To
the extent that definitions and explanations provided in this glossary differ from those in EPA regulations or
other official documents, the definitions used herein are intended for use in understanding this manual only.
Act or "the Act" [40 CFR §403.3(b)]
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251
et.seq.
Approval Authority [40 CFR §403.3(c)]
The Director in an NPDES State with an approved State Pretreatment Program and the appropriate EPA
Regional Administrator in a non-NPDES State or State without an approved pretreatment program.
Approved POTW Pretreatment Program or Program [40 CFR §403.3(d)]
A program administered by a POTW that meets the criteria established in 40 CFR Part 403 and which
has been approved by a Regional Administrator or State Director.
Approved State Pretreatment Program
A program administered by a State that meets the criteria established in 40 CFR §403.10 and which has
been approved by a Regional Administrator
Approved/Authorized State
A State with an NPDES permit program approved pursuant to section 402(b) of the Act and an approved
State Pretreatment Program.
Baseline Monitoring Report (BMR) [paraphrased from 40 CFR §403.12(b)]
A report submitted by categorical industrial users (CILJs) within 180 days after the effective date of an
applicable categorical standard, or at least 90 days prior to commencement of discharge for new sources,
which contains specific facility information, including flow and pollutant concentration data. For existing
sources, the report must also certify as to the compliance status of the facility with respect to the categorical
standards.
Best Available Technology Economically Achievable (BAT)
A level of technology based on the best existing control and treatment measures that are economically
achievable within the given industrial category or subcategory.
Best Management Practices (BMPs)
Schedules of activities, prohibitions of practices, maintenance procedures, and other management
practices to prevent or reduce the pollution of waters of the U.S. BMPs also include treatment requirements,
operating procedures and practices to control plant site runoff, spillage or leaks, sludge or waste disposal,
or drainage from raw material storage.
Best Practicable Control Technology Currently Available (BPT)
A level of technology represented by the average of the best existing wastewatertreatment performance
levels within an industrial category or subcategory.
Best Professional Judgment (BPJ)
The method used by a permit writer to develop technology-based limitations on a case-by-case basis
using all reasonably available and relevant data.
Slowdown
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Glossary of Terms Introduction to the National Pretreatment Program
The discharge of water with high concentrations of accumulated solids from boilers to prevent plugging
of the boilertubes and/or steam lines. In cooling towers, blowdown is discharged to reduce the concentration
of dissolved salts in the recirculating cooling water.
Bypass [40 CFR §403.17(a)]
The intentional diversion of wastestreams from any portion of an Industrial User's treatment facility.
Categorical Industrial User (CIU)
An industrial user subject to National categorical pretreatment standards.
Categorical Pretreatment Standards
Limitations on pollutant discharges to POTWs promulgated by EPA in accordance with Section 307 of
the Clean Water Act, that apply to specific process wastewater discharges of particular industrial categories
[40 CFR § 403.6 and 40 CFR Parts 405-471].
Chain of Custody (COC)
A record of each person involved in the possession of a sample from the person who collects the sample
to the person who analyzes the sample in the laboratory.
Chronic
A stimulus that lingers or continues for a relatively long period of time, often one-tenth of the life span
or more. Chronic should be considered a relative term depending on the life span of an organism. The
measurement of chronic effect can be reduced growth, reduced reproduction, etc., in addition to lethality.
Clean Water Act (CWA)
The common name for the Federal Water Pollution Control Act. Public law 92-500; 33 U.S.C. 1251 et
seq.: legislation which provides statutory authority for both NPDES and Pretreatment Programs.
Code of Federal Regulations (CFR)
A codification of Federal rules published annually by the Office of the Federal Register National Archives
and Records Administration. Title 40 of the CFR contains the regulations for Protection of the Environment.
Combined Sewer Overflow (CSO)
A discharge of untreated wastewater from a combined sewer system at a point prior to the headworks
of a publicly owned treatment works. CSOs generally occur during wet weather (rainfall or snowfall). During
periods of wet weather, these systems become overloaded, bypass treatment works, and discharge directly
to receiving waters.
Combined Wastestream Formula (CWF) [paraphrased from 40 CFR §403.6(e)]
Procedure for calculating alternative discharge limits at industrial facilities where a regulated
wastestream from a categorical industrial user is combined with other wastestreams prior to treatment.
Compliance Schedule
A schedule of remedial measures included in a permit or an enforcement order, including a sequence
of interim requirements (for example, actions, operations, or milestone events) that lead to compliance with
the CWA and regulations.
Composite Sample
Sample composed of two or more discrete samples. The aggregate sample will reflect the average
water quality covering the compositing or sample period.
Concentration-based Limit
A limit based upon the relative strength of a pollutant in a wastestream, usually expressed in mg/l.
Continuous Discharge
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Introduction to the National Pretreatment Program _ Glossary of Terms
A discharge that occurs without interruption during the operating hours of a facility, except for infrequent
shutdowns for maintenance, process changes or similar activities.
Control Authority [paraphrased from 40 CFR § 403. 12(a)]
A POTWwith an approved pretreatment program or the approval authority in the absence of a POTW
pretreatment program.
Conventional Pollutants
BOD, TSS, fecal coliform, oil and grease, and pH
Daily Maximum Limitations
The maximum allowable discharge of pollutants during a 24 hour period. Where daily maximum
limitations are expressed in units of mass, the daily discharge is the total mass discharged over the course
of the day. Where daily maximum limitations are expressed in terms of a concentration, the daily discharge
is the arithmetic average measurement of the pollutant concentration derived from all measurements taken
that day.
Detection Limit
The minimum concentration of an analyte(substance) that can be measured and reported with a 99%
confidence that the analyte concentration is greater than zero as determined by the procedure set forth in
40 CFR Part 1 36, Appendix B.
Development Document
Detailed report of studies conducted by the U.S. EPAforthe purpose of establishing effluent guidelines
and categorical pretreatment standards.
D i I ute Wastestream [paraphrased from 40 CFR §403. 6(e) (1) (i)]
For purposes of the combined wastestream formula, the average daily flow (at least a 30-day average)
from : (a) boiler blowdown streams, non-contact cooling streams, storm water streams, and demineralized
backwash streams; provided, however, that where such streams contain a significant amount of a pollutant,
and the combination of such streams, prior to treatment, with an industrial user's regulated process
wastestream(s) will result in a substantial reduction of that pollutant, the Control Authority, upon application
of the industrial user, may exercise its discretion to determine whether such stream(s) should be classified
as diluted or unregulated. In its application to the Control Authority, the industrial user must provide
engineering, production, sampling and analysis, and such other information so the control authority can make
its determination; or (b) sanitary wastestreams where such streams are not regulated by a categorical
pretreatment standard; or (c) from any process wastestreams which were, or could have been, entirely
exempted from categorical pretreatment standards pursuant to paragraph 8 of the NRDC v. Costle Consent
Decree (12 ERG 1833) for one more of the following reasons (see Appendix D of 40 CFR Part 403):
a. the pollutants of concern are not detectable in the effluent from the industrial user (paragraph
b. the pollutants of concern are present only in trace amounts and are neither causing nor likely to
cause toxic effects (paragraph (8)(a)(iii));
c. the pollutants of concern are present in amounts too small to be effectively deduced by technologies
known to the Administrator (paragraph (8)(a)(iii)); or
d. the wastestream contains only pollutants which are compatible with the POTW (paragraph (8)(b)(l)).
Effluent Limitations Guideline
Any effluent limitations guidelines issued by EPA pursuant to Section 304(b) of the CWA. These
regulations are published to adopt or revise a national standard prescribing restrictions on quantities, rates,
and concentrations of chemical, physical, biological, and other constituents which are discharged from point
sources, in specific industrial categories (e.g., metal finishing, metal molding and casting, etc).
Enforcement Response Plan [paraphrased from 40 CFR §403.8(f)(5)]
Step-by-step enforcement procedures followed by Control Authority staff to identify, document, and
respond to violations.
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Glossary of Terms Introduction to the National Pretreatment Program
Existing Source
Any source of discharge, the construction or operation of which commenced prior to the publication by
the EPA of proposed categorical pretreatment standards, which will be applicable to such source if the
standard is thereafter promulgated in accordance with Section 307 of the Act.
Federal Water Pollution Control Act (FWPCA)
The title of Public law 92-500; 33 U.S.C. 1251 et seq., also known as the Clean Water Act (CWA),
enacted October 18, 1972.
Flow Weighted Average Formula (FWA) [paraphrased from 40 CFR §403.6(e)]
A procedure used to calculate alternative limits where wastestreams regulated by a categorical
pretreatment standard and nonregulated wastestreams combine after treatment but prior to the monitoring
point.
Flow Proportional Composite Sample
Combination of individual samples proportional to the flow of the wastestream at the time of sampling.
Fundamentally Different Factors [paraphrased from 40 CFR §403.13]
Case-by-case variance from categorical pretreatment standards based on the factors considered by EPA
in developing the applicable category/subcategory being fundamentally different than factors relating to a
specific industrial user.
General Prohibitions [40 CFR §403.5(a)(1)]
No user shall introduce into a POTWany pollutant(s) which cause pass through or interference.
Grab Sample
A sample which is taken from a wastestream on a one-time basis with no regard to the flow of the
wastestream and without consideration of time. A single grab sample should be taken over a period of time
not to exceed 15 minutes.
Indirect Discharge or Discharge [40 CFR §403.3(g)]
The introduction of pollutants into a POTW from any non-domestic source regulated under section
307(b), (c), or (d) of the Act.
Industrial User (IU) or User [40 CFR §403.3(h)]
A source of indirect discharge.
Industrial Waste Survey
The process of identifying and locating industrial users and characterizing their industrial discharge.
Inhibition Concentration
Estimate of the toxicant concentration that would cause a given percent reduction (e.g., IC25) in a
nonlethal biological measurement of the test organisms, such as reproduction or growth.
Interference [paraphrased from 40 CFR §403.3(i)]
A discharge which, alone or in conjunction with a discharge or discharges from other sources, both: (1)
inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal;
and (2) therefore is a cause of a violation of any requirement of the POTWs NPDES permit (including an
increase in the magnitude or duration of a violation) or of the prevention of sewage sludge use or disposal
in compliance with ... [applicable] statutory provisions and regulations or permits issued thereunder (or more
stringent State or local regulations) ...
Local Limits [paraphrased 40 CFR § 403.5(c)]
Specific discharge limits developed and enforced by POTWs upon industrial or commercial facilities to
implement the general and specific discharge prohibitions listed in 40 CFR §§403.5(a)(1) and (b).
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Introduction to the National Pretreatment Program Glossary of Terms
Monthly Average
The arithmetic average value of all samples taken in a calendar month for an individual pollutant
parameter. The monthly average may be the average of all grab samples taken in a given calendar month,
or the average of all composite samples taken in a given calendar month.
National Pollutant Discharge Elimination System (NPDES)
The national program for issuing, modifying, revoking and reissuing, terminating, monitoring and
enforcing discharge permits from point sources to waters of the United States, and imposing and enforcing
pretreatment requirements, under sections 307, 402, 318, and 405 of the CWA.
National Pretreatment Standard or Pretreatment Standard or Standard [40 CFR §403.3(j)]
Any regulation containing pollutant discharge limits promulgated by the EPA in accordance with section
307(b) and (c) of the Act, which applies to Industrial Users. This term includes prohibitive discharge limits
established pursuant to §403.5.
New Source [40 CFR §403.3(k)]
Any building, structure, facility or installation from which there is or may be a discharge of pollutants, the
construction of which commenced after the publication of proposed Pretreatment Standards under section
307(c) of the Act which will be applicable to such source if such standards are thereafter promulgated in
accordance with that section provided that
(a) The building, structure, facility or installation is constructed at a site at which no other discharge
source is located; or
(b) The building, structure, facility or installation totally replaces the process or production equipment
that causes the discharge of pollutants at an existing source; or
(c) The production or wastewater generating processes of the building, structure, facility, or installation
are substantially independent of an existing source at the same site. In determining whether these
are substantially independent, factors such as the extent to which the new facility is integrated with
the existing plant, and the extent to which the new facility is engaged in the same general type of
activity as the existing source, should be considered.
Construction on a site at which an existing source is located results in a modification rather than a new
source if the construction does not create a new building, structure, facility, or installation meeting the criteria
of paragraphs (k)(1)(ii), or (k)(1)(iii) of this section but otherwise alters, replaces, or adds to existing process
or production equipment.
Construction of a new source, as defined under this paragraph has commenced if the owner or operator has:
(i) Begun, or caused to begin as part of a continuous onsite construction program:
(A) Any placement, assembly, or installation of facilities or equipment; or
(B) Significant site preparation work including clearing, excavation, or removal of existing buildings,
structures, or facilities which is necessary for the placement, assembly, or installation of new
source facilities or equipment, or
(C) Entered into a binding contractual obligation for the purchase of facilities or equipment which
are intended to be used in its operation within a reasonable time. Options to purchase or
contracts which can be terminated or modified without substantial loss, and contracts for
feasibility, engineering, and design studies do not constitute a contractual obligation under this
paragraph.
90-Day Final Compliance Report [40 CFR §403.12(d)]
A report submitted by categorical industrial users within 90 days following the date for final compliance
with the standards. This report must contain flow measurement (of regulated process streams and other
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Glossary of Terms Introduction to the National Pretreatment Program
streams), measurement of pollutants, and a certification as to whether the categorical standards are being
met.
Nonconventional Pollutants
Any pollutant that is neither a toxic pollutant nor a conventional pollutant (e.g., manganese, ammonia,
etc.)
Non-Contact Cooling Water
Water used for cooling which does not come into direct contact with any raw material, intermediate
product, waste product, or finished product. The only pollutant contributed from the discharge is heat.
Non-Regulated Wastestream
Unregulated and dilute wastestreams (not regulated by categorical standards).
Pass Through [40 CFR §403.3(n)]
A discharge which exits the POTW into waters of the United States in quantities or concentrations which,
alone or in conjunction with a discharge or discharges from other sources, is a cause of a violation of any
requirement of the POTWs NPDES permit (including an increase in the magnitude or duration of a
violation).
Periodic Compliance Report [paraphrased from 40 CFR §403.12(e) & (h)]
A report on compliance status submitted by categorical industrial users and significant noncategorical
industrial users to the control authority at least semiannually (once every six months).
Point Source [40 CFR 122.2]
Any discernible, confined, and discrete conveyance, including but not limited to any pipe, ditch, channel,
tunnel, conduit, well, discrete fixture, container, rolling stock concentrated animal feeding operation vessel,
or other floating craft from which pollutants are or may be discharged.
Pollutant [40 CFR 122.2]
Dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage, sewage sludge,
munitions, chemical wastes, biological materials, radioactive materials (except those regulated under the
Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.)), heat, wrecked or discarded equipment,
rock, sand, cellar dirt, and industrial, municipal and agricultural waste discharged into water.
Pretreatment [paraphrased from 40 CFR §403.3(q)]
The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature
of pollutant properties in wastewater prior to or in lieu of discharging or otherwise introducing such pollutants
into a POTW.
Pretreatment Requirements [40 CFR §403.3(r)]
Any substantive or procedural requirement related to Pretreatment, otherthan a National Pretreatment
Standard, imposed on an Industrial User.
Pretreatment Standards for Existing Sources (PSES)
Categorical Standards and requirements applicable to industrial sources that began construction prior
to the publication of the proposed pretreatment standards for that industrial category.(see individual
standards at 40 CFR Parts 405-471.)
Pretreatment Standards for New Sources (PSNS)
Categorical Standards and requirements applicable to industrial sources that began construction after
the publication of the proposed pretreatment standards forthat industrial category, (see individual standards
at 40 CFR Parts 405-471.)
Priority Pollutant
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Introduction to the National Pretreatment Program Glossary of Terms
Pollutant listed by the Administrator of EPA under Clean Water Act section 307(a). The list of the current
126 Priority Pollutants can be found in 40 CFR Part 423 Appendix A.
Process Wastewater
Any water which, during manufacturing or processing, comes into contact with or results from the
production or use of any raw material, intermediate product, finished product, byproduct, or waste product.
Production-Based Standards
A discharge standard expressed in terms of pollutant mass allowed in a discharge per unit of product
manufactured.
Publicly Owned Treatment Works (POTW) [40 CFR §403.3(o)]
A treatment works as defined by section 212 of the Act, which is owned by a State or municipality (as
defined by section 502(4) of the Act). This definition includes any devices or systems used in the storage,
treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature. It also
includes sewers, pipes or other conveyances only if they convey wastewaterto a POTW Treatment Plant.
The term also means the municipality as defined in section 502(4) of the Act, which has jurisdiction over the
Indirect Discharges to and the discharges from such a treatment works.
Regulated Wastestream
For purposes of applying the combined wastestream formula, a wastestream from an industrial process
that is regulated by a categorical standard.
Removal Credit [paraphrased from 40 CFR §403.7]
Variance from a pollutant limit specified in a categorical pretreatment standard to reflect removal by the
POTW of said pollutant.
Representative Sample
A sample from a wastestream that is as nearly identical as possible in composition to that in the larger
volume of wastewater being discharged and typical of the discharge from the facility on a normal operating
day.
Sanitary Sewer Overflow (SSO)
Untreated or partially treated sewage overflows from a sanitary sewer collection system.
Self-Monitoring
Sampling and analyses performed by a facility to ensure compliance with a permit or other regulatory
requirements.
Sewer Use Ordinance (SUO)
A legal mechanism implemented by a local government entity which sets out, among others,
requirements for the discharge of pollutants into a publicly owned treatment works.
Significant Industrial User (SIU) [paraphrased from 40 CFR §403.3(t)]
(1) All users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR chapter
I, subchapter N; and (2) Any other industrial user that: discharges an average of 25,000 gallons per day or
more of process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown
wastewater); contributes a process wastestream which makes up 5 percent or more of the average dry
weather hydraulic or organic capacity of the POTW treatment plant; or is designated as such by the Control
Authority as defined in 40 CFR403.12(a) on the basis that the industrial user has a reasonable potential for
adversely affecting the POTWs operation or for violating any pretreatment standard or requirement (in
accordance with 40 CFR 403.8(f)(6)].
Significant Noncompliance (SNC) [40 CFR §403.8(f)(2)(vii)]
Industrial user violations meeting one or more of the following criteria:
1) Chronic violations of wastewater discharge limits, defined here as those in which sixty-six
percent or more of all of the measurements taken during a six month period exceed (by any
magnitude) the daily maximum limit or the average limit for the same pollutant parameter;
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Glossary of Terms Introduction to the National Pretreatment Program
2) Technical Review Criteria (TRC) violations, defined here as those in which thirty-three percent
or more of all of the measurements for each pollutants parameter taken during a six-month period
equal or exceed the product of the daily maximum limit or the average limit multiplied by the
applicable TRC (TRC=1.4 for BOD, TSS, fats, oil, and grease, and 1.2 for all other pollutants except
PH);
3) Any other violation of a pretreatment effluent limit (daily maximum or longer-term average) that
the Control Authority determines has caused, alone or in combination with other dischargers,
interference or pass through (including endangering the health of POTW personnel or the general
public);
4) Any discharge of a pollutant that has caused imminent endangerment to human health, welfare
or to the environment or has resulted in the POTW's exercise of its emergency authority under
paragraph (f)(1)(vi)(B) of this section to halt or prevent such a discharge;
5) Failure to meet, within 90 days after the schedule date, a compliance schedule milestone
contained in a local control mechanism or enforcement order for starting construction, completing
construction, or attaining final compliance;
6) Failure to provide, within 30 days after the due date, required reports such as baseline
monitoring reports, 90-day compliance reports, periodic self-monitoring reports, and reports on
compliance with compliance schedules;
7) Failure to accurately report noncompliance;
8) Any other violation or group of violations which the Control Authority determines will adversely
affect the operation or implementation of the local pretreatment program.
Slug Discharge [40 CFR §403.8(f)(2)(v)]
Any discharge of a non-routine, episodic nature, including but not limited to, an accidental spill or a
noncustomary batch discharge.
Specific Prohibitions [40 CFR §403.5(b)]
The following pollutants shall not be introduced into a POTW:
1) Pollutants which create a fire or explosion hazard in the POTW, including but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR Part 261.21;
2) Pollutants which will cause corrosive structural damage to the POTW, but in no case discharges
with pH lowerthan 5.0, unless the works is specifically designed to accommodate such discharges;
3) Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in interference;
4) Any pollutant, including oxygen demanding pollutants(BOD, etc.) Released in a discharge at a
flow rate and/or concentration which will cause interference with 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 POTW treatment plant exceeds
40°C(104°F) unless the Approval Authority, upon request of the POTW, approves alternative
temperature limits;
6) Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
7) Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems;
8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
Standard Industrial Classification (SIC)
A system developed by the U.S. Office of Management and Budget that is used to classify various types
of business entities. Effective in 1998, the SIC scheme is replace by the North American Industry
Classification System (NAICS), although EPA has not yet implemented this change.
Storm Water
Rain water, snow melt, and surface runoff and drainage.
Time Proportional Composite Sample
A sample consisting of a series of aliquots collected from a representative point in the discharge stream
at equal time intervals over the entire discharge period on the sampling day.
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Introduction to the National Pretreatment Program Glossary of Terms
Toxic Pollutant
Any pollutant listed as toxic under section 307(a)(1) oftheCWA, or in the case of sludge useordisposal
practices, any pollutant identified in regulations implementing section 405(d) of the CWA.
Toxicity Reduction Evaluation
A site-specific study conducted in a stepwise process designed to identify the causative agent(s) of
effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and then
confirm the reduction in effluent toxicity.
Toxicity Test
A procedure to determine the toxicity of a chemical or an effluent using living organisms. A toxicity test
measures the degree of effect on exposed test organisms of a specific chemical or effluent.
Toxicity Identification Evaluation
Set of procedures to identify the specific chemicals responsible for effluent toxicity.
Unregulated Wastestream
For purposes of applying the combined wastestream formula, a wastestream not regulated by a
categorical standard nor considered a dilute wastestream.
Upset [paraphrased from 40 CFR §403.16(a)]
An exceptional incident in which there is unintentional and temporary noncompliance with categorical
Pretreatment Standards because of factors beyond the reasonable control of the Industrial User. An Upset
does not include noncompliance to the extent caused by operational error, improperly designed treatment
facilities, inadequate treatment facilities, lack of preventative maintenance, or careless or improper
operation.
Water Quality Criteria
Comprised of both numeric and narrative criteria. Numeric criteria are scientifically derived ambient
concentrations developed by EPA or States for various pollutants of concern to protect human health and
aquatic life. Narrative criteria are statements that describe the desired water quality goal.
Water Quality Standard
A statute or regulation that consists of the beneficial designated use or uses of a waterbody, the numeric
and narrative water quality criteria that are necessary to protect the use or uses of that particular waterbody,
and an antidegradation statement.
Whole Effluent Toxicity
The total toxic effect of an effluent measured directly with a toxicity test.
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Introduction to the National Pretreatment Program POTWs and the Need for the Pretreatment Program
1. POTWs AND THE NEED FOR THE
PRETREATMENT PROGRAM
The average American uses
roughly 100 to 200 gallons of
water a day, with less than one
percent of that water actually
Chapter 1. Applicable EPA References
Environmental Regulations and Technology: The National Pretreatment Program
National Pretreatment Program: Report to Congress
Report to Congress on the Discharge of Hazardous Wastes to POTWs
being consumed. The rest is
used for activities such as
washing, preparing food, watering
lawns, heating and cooling,
transporting wastes, and fire protection. The public is very conscious about the quality of water that comes out
of their tap each day, quickly notifying authorities of changes in appearance, odor, and taste. These same
Americans, on average, discharge about the same amount of wastewater to local sewage treatment plants
daily.3 This wastewater (commonly referred to as "domestic sewage") receives much less attention than drinking
water, likely the result of an "out of sight, out of mind" attitude.
Most people take it for granted that once down the drain, wastes will be handled appropriately. In fact, this
attitude has carried over to industry as well, as can be seen by reading the labels of many household products.
These labels often recommend that waste or excess product be disposed of down the drain. Other toxic or
hazardous products are actually designed to be disposed of down the drain (e.g., drain clog remover). Recall
the phosphate detergent problems of the late 1960s and early 70s; large doses of phosphate, found in most
detergents at the time, were passing through municipal treatment plants and overloading lakes, causing large
algal blooms to form and subsequently reducing available light, food and oxygen for fish and other aquatic
organisms. While great strides have been taken to address the phosphate problem, it is possible that other
problematic pollutants are being dumped down the drain at the expense of human health and the environment.
SEWAGE TREATMENT
Publicly owned treatment works (POTWs) collect wastewater from homes, commercial buildings, and
industrial facilities and transport it via a series of pipes, known as a collection system, to the treatment plant.
Collection systems may flow entirely by gravity, or may include lift stations that pump the wastewater via a force
main to a higher elevation where the wastewater can then continue on via gravity. Ultimately, the collection
system delivers this sewage to the treatment plant facility. Here, the POTW removes harmful organisms and
other contaminants from the sewage so it can be discharged safely into the receiving stream. Without
treatment, sewage creates bad odors, contaminates water supplies, and spreads disease. Today, more than
16,000 sewage treatment plants exist in the U.S. treating more than 32 billion gallons per day of wastewater.4
Generally, POTWs are designed to treat domestic sewage only. Simply defined, the typical POTW
treatment process consists of primary and secondary treatment, along with some form of solids handling.
Primary treatment is designed to remove large solids (e.g., rags and debris) and smaller inorganic grit. Typical
primary treatment operations include screening and settling. Secondary treatment removes organic
contaminants using microorganisms to consume biodegradable organics. Activated sludge, trickling filters, and
rotating biological contactors are examples of common secondary treatment operations. Depending on effluent
discharge requirements, POTWs may perform other "advanced treatment" operations such as nitrification (to
convert ammonia and nitrite to the less toxic nitrate), denitrification (to convert nitrate to molecular nitrogen),
2 The Nalco Water Handbook, ed. Frank N. Kemmer (New York: McGraw-Hill Book Company,
1988), pp. 35.1.
3 Ibid, p. 36.1.
4 1996 Clean Water Needs Survey Report to Congress: Assessment of Needs for Publicly
Owned Wastewater Treatment Facilities, Correction of Combined Sewer Overflows, and
Management of Stormwater and Nonpoint Source Pollution in the United States.
Chapter 1 -1-
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POTWs and the Need for the Pretreatment Program
Introduction to the National Pretreatment Program
physical-chemical treatment (to remove dissolved metals and organics), and disinfection (to kill any remaining
pathogens). After treatment is complete, effluent is discharged to the receiving stream, typically a creek, river,
lake, estuary or ocean. Some POTWs may apply treated effluent directly to golf courses, parkland, or
croplands.
Both primary and secondary treatment processes generate waste solids, known as sewage sludge or
biosolids. Sludges from the treatment process may be either used productively (i.e., as fertilizer or soil
conditioner) ordisposed of in a landfill or incinerated in a dedicated sewage sludge incinerator with the ash also
disposed of in a landfill.
As described above, POTWs are designed to treat typical
household wastes and biodegradable commercial and biodegradable
industrial wastes. The Clean Water Act (CWA) and EPA define the
contaminants from these sources as conventional pollutants.
Conventional pollutants are identified in Figure 1 and include those
specific pollutants that are expected to be present in domestic
discharges to POTWs. Commercial and industrial facilities may,
however, discharge toxic pollutants that the treatment plant is neither
designed for nor able to remove.
NEED FOR THE PRETREATMENT PROGRAM
Biochemical Oxygen Demand (BOD)
Total Suspended Solids
Fecal Coliform
PH
Oil and Grease (O&G)
Figure 1. Conventional Pollutants
As noted above, POTWs are not designed to treat toxics in industrial waste. As such, these discharges,
from both industrial and commercial sources, can cause serious problems. The undesirable outcome of these
discharges can be prevented using treatment techniques or management practices to reduce or eliminate the
discharge of these contaminants. The act of treating wastewater prior to discharge to a POTW is commonly
referred to as "pretreatment." The National Pretreatment Program, published in Title 40 Code of Federal
Regulations (CFR) Part 403, provides the regulatory basis to require non-domestic dischargers to comply with
pretreatment standards (effluent limitations) to ensure that the goals of the CWA are attained. As noted in 40
CFR §403.2, the objectives of the National Pretreatment Program are to:
a. Prevent the introduction of pollutants into POTWs which will interfere with the operation of a
POTW, including interference with its use or disposal of municipal sludge;
b. Prevent the introduction of pollutants into POTWs which will pass thro ugh the treatment works or
otherwise be incompatible with such works; and
c. Improve opportunities to recycle and
reclaim municipal and industrial
wastewaters and sludges.
The two key terms used in EPA's objectives for the
National Pretreatment Program, "interference" and
"pass through," are defined in Figure 2.
As outlined in EPA's objectives, toxic pollutants
may pass through the treatment plant into the
receiving stream, posing serious threats to aquatic
life, to human recreation, and to consumption of
fish and shellfish from these waters. Pass through
can make waters unswimmable or unfishable in
direct contrast to the goals of the CWA. Or, these
discharges can interfere with the biological activity
of the treatment plant causing sewage to pass
through the treatment plant untreated or
inadequately treated.
Interference - a discharge which, alone or in conjunction with
a discharge or discharges from other sources, both:
Inhibits or disrupts the POTW, its treatment
processes or operations, or its sludge processes, use
or disposal, and
therefore is a cause of a violation of any NPDES
permit requirement or of the prevention of sewage
sludge use or disposal in compliance with any
applicable requirements.
Pass Through - a discharge which exits the POTW into
waters of the U.S. in quantities or concentrations which,
alone or in conjunction with a discharge or discharges from
other sources, is a cause of a violation of any NPDES permit
requirement.
Figure 2. Interference and Pass Through
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Chapter 1
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Introduction to the National Pretreatment Program
POTWs and the Need for the Pretreatment Program
Even where the POTW has the capability to remove these toxics, the pollutants may end up in the sewage
sludge, thereby limiting sludge disposal options or escalating the cost of disposal. Incinerated contaminated
sludge may release toxic emissions into the atmosphere. Toxic metals removed in primary treatment, while
itself not an inhibitory process, can impact sludge digestion, a process that does utilize bacteria to stabilize
sludge solids. For example, chromium can inhibit reproduction of aerobic digestion microorganisms, thereby
disrupting sludge treatment and producing sludges that must be disposed of with special treatment.
Uncontaminated sludge, on the other hand, can be used as fertilizer or soil conditioner, thereby improving the
productivity of our land. Many municipalities apply sewage sludge to pastureland or parkland, that they could
not do if the sludge were contaminated.
Volatile organics discharged to sewers can accumulate in the head space of sewers, increasing the
likelihood of explosions that can cause significant damage. Probably the most well known impact from industrial
discharges to POTWs in the U.S. is the explosion in Louisville, KY that occurred in 1981 as the result of
excessive discharges of hexane into the collection system, eventually igniting and destroying more than 3 miles
of sewers and causing $20 million in damage. Discharge limitations and management practices to control slug
discharges have significantly reduced the likelihood of future catastrophes such as the explosion in Louisville.
Discharges of toxic organics can also result in the release of poisonous gas. This occurs most often when
acidic wastes react with other wastes in the discharge. For example, cyanide and acid, both present in many
electroplating operations, react to form highly toxic hydrogen cyanide gas. Similarly, sulfides from leather
tanning can combine with acid to form hydrogen sulfide, another toxic gas. These can be highly dangerous to
POTW collection system operators exposed to such conditions in the performance of their duties. Other
problems associated with toxic discharges are summarized in Figure 3 and further document the urgency of
keeping toxics out of collection systems and POTWs.
The National Pretreatment Program is charged with
controlling the 126 Priority Pollutants from industries
that discharge into sewer systems as described in the
CWA (see Figure 4). These pollutants fall into two
categories; metals and organics:
- Metals, including lead, mercury, chromium, and
cadmium cannot be destroyed or broken down
through treatment or environmental
degradation. Toxic metals can cause different
human health problems such as lead poisoning
and cancer. Additionally, consumption of
contaminated seafood and agricultural food
crops has resulted in exposures exceeding
recommended safe levels.
- air pollution can occur from volatilization of toxic
chemicals in the POTW collection system or
treatment plant, or through incineration of sewage
sludge
- corrosion of collection system and treatment plant
from acidic discharges or discharges containing
elevated levels of sulfate (forming toxic and corrosive
hydrogen sulfide)
- groundwater pollution can occur from leaks in the
collection system or pollutants from contaminated
sewage sludge.
Figure 3. Problems Associated With Toxic Discharges
- Toxic organics, including solvents, pesticides,
dioxins, and polychlorinated biphenyls (PCBs) can be cancer-causing and lead to other serious
ailments, such as kidney and liverdamage, anemia, and heart failure. In 1996, EPA's Office of Science
and Technology (OST) identified 2,193 waterbodies with fish and wildlife advisories, up more than 25
percent from 1995.5
Reductions in pollutants can ensure that industrial development vital to the economic well-being of a
community is compatible with a healthy environment. As will be noted in Chapter 2, many POTWs are
responsible for ensuring that industrial and commercial facilities do not cause problems resulting from their
discharges. In 1991, EPA estimated that 190 to 204 million pounds of metals and 30 to 108 million pounds of
organics were removed each year as a result of pretreatment program requirements.6 This is substantiated by
EPA Office of Science and Technology, Listing of Fish and Wildlife Advisories (LFWA)
database, 1998.
U.S. Environmental Protection Agency, National Pretreatment Program: Report to
Congress, 1991.
Chapter 1
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POTWs and the Need for the Pretreatment Program
Introduction to the National Pretreatment Program
many POTWs that report significant reductions in the loadings of toxics to their treatment plants that is directly
attributable to implementation of the National Pretreatment Program.
Figure 4. Priority Pollutants
001 Acenaphthene
002 Acrolein
003 Acrylonitrile
004 Benzene
005 Benzidine
006 Carbon tetrachloride
007 Chlorobenzene
008 1,2,4-trichlorobenzene
009 Hexachlorobenzene
010 1,2-dichloroethane
Oil 1,1,1 -trichloreothane
012 Hexachloroethane
013 1,1-dichloroethane
014 1,1,2-trichloroethane
015 1,1,2,2-tetrachloroethane
016 Chloroethane
018 Bis(2-chloroethyl) ether
019 2-chloroethyl vinyl ethers
020 2-chloronaphthalene
021 2,4,6-trichlorophenol
022 Parachlorometa cresol
023 Chloroform
024 2-chlorophenol
025 1,2-dichlorobenzene
026 1,3-dichlorobenzene
027 1,4-dichlorobenzene
028 3,3-dichlorobenzidine
029 1,1-dichloroethylene
030 1,2-trans-dichloroethylene
031 2,4-dichlorophenol
032 1,2-dichloropropane
033 1,2-dichloropropylene
034 2,4-dimethylphenol
035 2,4-dinitrotoluene
036 2,6-dinitrotoluene
037 1,2-diphenylhydrazine
038 Ethylbenzene
039 Fluoranthene
040 4-chlorophenyl phenyl ether
041 4-bromophenyl phenyl ether
042 Bis(2-chloroisopropyl) ether
043 Bis(2-chloroethoxy) methane
044 Methylene chloride
045 Methyl chloride
046 Methyl bromide
047 Bromoform
048 Dichlorobromomethane
051 Chlorodibromomethane
052 Hexachlorobutadiene
053 Hexachlorocyclopentadiene
054 Isophorone
055 Naphthalene
056 Nitrobenzene
057 2-nitrophenol
058 4-nitrophenol
059 2,4-dinitrophenol
060 4,6-dinitro-o-cresol
061 N-nitrosodimethylamine
062 N-nitrosodiphenylamine
063 N-nitrosodi-n-propylamine
064 Pentachlorophenol
065 Phenol
066 Bis(2-ethylhexyl) phthalate
067 Butyl benzyl phthalate
068 Di-N-Butyl Phthalate
069 Di-n-octyl phthalate
070 Diethyl Phthalate
071 Dimethyl phthalate
072 benzo(a) anthracene
073 Benzo(a)pyrene
074 Benzo(b) fluoranthene
075 Benzo(b) fluoranthene
076 Chrysene
077 Acenaphthylene
078 Anthracene
079 Benzo(ghi) perylene
080 Fluorene
081 Phenanthrene
082 Dibenzo(,h) anthracene
083 Indeno (1,2,3-cd) pyrene
084 Pyrene
085 Tetrachloroethylene
086 Toluene
087 Trichloroethylene
088 Vinyl chloride
089 Aldrin
090 Dieldrin
091 Chlordane
092 4,4-DDT
093 4,4-DDE
094 4,4-DDD
095 Alpha-endosulfan
096 Beta-endosulfan
097 Endosulfan sulfate
098 Endrin
099 Endrin aldehyde
100 Heptachlor
101 Heptachlor epoxide
102Alpha-BHC
103 Beta-BHC
104 Gamma-BHC
105 Delta-BHC
106PCB-1242
107PCB-1254
108PCB-1221
109PCB-1232
110PCB-1248
111PCB-1260
112PCB-1016
113 Toxaphene
114 Antimony
115 Arsenic
116 Asbestos
117 Beryllium
118 Cadmium
119 Chromium
120 Copper
121 Cyanide, Total
122 Lead
123 Mercury
124 Nickel
125 Selenium
126 Silver
127 Thallium
128 Zinc
129 2,3,7,8-TCDD
Chapter 1
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Introduction to the National Pretreatment Program
Overview of the National Pretreatment Program
2. OVERVIEW OF THE NATIONAL
PRETREATMENT PROGRAM
THE CLEAN WATER ACT
On October 18, 1972, the 92nd
Congress of the United States
passed the Federal Water Pollution
Control Act Amendments of 1972,
declaring the restoration and
maintenance of the chemical,
physical, and biological integrity of
the Nation's water as a National
objective (see Figure 5). While
procedures for implementing this act (more commonly referred to as the Clean Water Act (CWA)) have
been re-evaluated and modified overtime, the 1972 objective has remained unchanged in its 25 year history.
Chapter 2. Applicable EPA Guidance
Control Authority Pretreatment Audit Checklist and Instructions
Guidance for Conducting a Pretreatment Compliance Inspection
Guidance for Reporting and Evaluating POTW Noncompliance with
Pretreatment Implementation Requirements
Guidance Manual for POTW Pretreatment Program Development
Pretreatment Compliance Inspection and Audit Manual For Approval Authorities
Procedures Manual for Reviewing a POTW Pretreatment Program Submission
The 1972 Amendments to the CWA established a water quality regulatory approach along with EPA-
promulgated industry-specific technology-based effluent limitations. The National Pollutant Discharge
Elimination System (NPDES) permit program was established under the CWA to control the discharge of
pollutants from point sources and served as a vehicle to implement the industrial technology-based
standards. To implement pretreatment requirements, EPA promulgated 40 CFR Part 128 in late 1973,
establishing general prohibitions against treatment plant interference and pass through and pretreatment
standards for the discharge of
incompatible
pollutants from
specific industrial categories.
In 1975, several environmental
groups filed suit against EPA
challenging EPA's criteria for
identifying toxic pollutants, EPA's
failure to promulgate effluent
standards, and EPA's failure to
promulgate pretreatment standards
for numerous industrial categories.
As a result of this litigation, EPA
promulgated the General
Pretreatment Regulations at 40
CFR Part 403 on June 26, 1978,
replacing the 40 CFR Part 128
requirements. Additionally, as a
result of the suit, EPA agreed to
regulate the discharge of 65
categories of pollutants (making up
the 126 priority pollutants presented
in Figure 4) from 21 industrial
categories. The list of priority
pollutants is still in effect today (the
original list actually had 129
pollutants, three of which have
since been removed from that list)
while the list of regulated industrial
categories has grown to more than 51
provided in Chapter 3.
To restore and maintain the chemical, physical, and biological integrity of the
Nation's waters:
(1) it is the national goal that the discharge of pollutants into the
navigable waters be eliminated by 1985;
(2) it is the national goal 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;
(3) it is the national policy that the discharge of toxic pollutants in
toxic amounts be prohibited;
(4) it is the national policy that Federal financial assistance be provided
to construct publicly owned waste treatment works;
(5) it is the national policy that Area wide waste treatment management
planning processes be developed and implemented to assure
adequate control of sources of pollutants in each State;
(6) it is the national policy that a major research and demonstration
effort be made to develop technology necessary to eliminate the
discharge of pollutants into the navigable waters, waters of the
contiguous zone, and the oceans; and
(7) it is the national policy that programs for the control of nonpoint
sources of pollution be developed and implemented in an
expeditious manner so as to enable the goals of this Chapter to be
met through the control of both point and nonpoint sources of
pollution.
Figure 5. Section 101 of the Clean Water Act (CWA)
distinct industries. A discussion of industry specific requirements are
Chapter 2
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Overview of the National Pretreatment Program
Introduction to the National Pretreatment Program
THE GENERAL PRETREATMENT REGULATIONS
The General Pretreatment Regulations establish responsibilities of Federal, State, and local government,
industry and the public to implement Pretreatment Standards to control pollutants which pass through or
interfere with POTWtreatment processes or which may contaminate sewage sludge. The regulations, which
have been revised numerous times since originally published in 1978, consist of 18 sections and several
appendices. A copy of the overall framework for the General Pretreatment Regulations is provided in Figure
6.
The General Pretreatment Regulations apply to all nondomestic sources which introduce pollutants into
a POTW. These sources of "indirect discharge" are more commonly referred to as industrial users (IDs).
Since IDs can be as simple as an unmanned coin operated car wash to as complex as an automobile
manufacturing plant or a synthetic
organic chemical producer, EPA
developed four criteria that define a
Significant Industrial User (SIU). Many
of the General Pretreatment
Regulations apply to SlUs as opposed
to lUs, based on the fact that control of
SlUs should provide adequate
protection of the POTW.
These four criteria are as follows:
- an IU that discharges an
average of 25,000 gallons
per day or more of process
wastewaterto the POTW;
- an IU that contributes a
process wastestream
making up 5 percent or
more of the average dry
weather hydraulic or
organic capacity of the
POTWtreatment plant;
- an IU designated by the
Control Authority as such
because of its reasonable
potential to adversely
affect the POTW's
operation or violate any
pretreatment standard or
requirement; or
- an IU subject to Federal
categorical pretreatment
standards.
i 403.1
i 403.2
1403.3
i 403.4
1403.5
1403.6
1403.7
1403.8
1403.9
1403.10
1403.11
1403.12
1403.13
1403.14
1403.15
1403.16
1403.17
1403.18
Purpose and applicability
Objectives of general pretreatment regulations
Definitions
State or local law
National pretreatment standards: Prohibited discharges
National pretreatment standards: Categorical pretreatment
standards
Removal credits
Pretreatment program requirements: Development and
implementation by POTW
POTW pretreatment programs and/or authorization to revise
pretreatment standards: Submission for approval
Development and submission of NPDES State pretreatment
programs
Approval procedures for POTW pretreatment programs and
POTW granting of removal credits
Reporting requirements for POTW's and industrial users
Variances from categorical pretreatment standards for
fundamentally different factors
Confidentiality
Net/Gross calculation
Upset provision
Bypass
Modification of POTW pretreatment programs
Appendix A: Program Guidance Memorandum
Appendix B: [Reserved]
Appendix C: [Reserved]
Appendix D: Selected Industrial Subcategories Considered Dilute for
Purposes of the Combined Wastestream Formula
Appendix E: Sampling Procedures
Appendix F: [Reserved]
Appendix G: Pollutants Eligible for a Removal Credit
Figure 6. The General Pretreatment Regulations
Unlike other environmental programs that rely on Federal or State governments to implement and
enforce specific requirements, the Pretreatment Program places the majority of the responsibility on local
municipalities. Specifically, section 403.8(a) of the General Pretreatment Regulations states that any POTW
(or combination of treatment plants operated by the same authority) with a total design flow greater than 5
million gallons per day (MGD) and smaller POTWs with SlUs must establish a local pretreatment program.
As of early 1998, 1,578 POTWs are required to have local programs. While this represents only about 15
percent of the total treatment plants nationwide, these POTWs account for more than 80 percent (i.e.,
approximately 30 billion gallons a day) of the national wastewater flow.
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Chapter 2
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Introduction to the National Pretreatment Program Overview of the National Pretreatment Program
The General Pretreatment Regulations define the term "Control Authority" as a POTWthat administers
an approved pretreatment program since it is the entity authorized to control discharges to its system.
Section 403.10(e) provides States authority to implement POTW pretreatment programs in lieu of POTWs.
Five States have elected to assume this responsibility (Vermont, Connecticut, Alabama, Mississippi, and
Nebraska). In these instances, the State is defined as the Control Authority.
As described above, all Control Authorities must establish a local pretreatment program to control
discharges from non-domestic sources. These programs must be approved by the "Approval Authority" who
is also responsible for overseeing implementation and enforcement of these programs. As noted in Figure
7 , a total of 44 States/Territories are authorized to implement State NPDES Permit Programs, but only 27
are authorized to be the Pretreatment Program Approval Authority (i.e, those with approved State
pretreatment programs excluding the five §403.10(e) States). In all other States and Territories (including
the 403.10(e) States), EPA is considered to be the Approval Authority.
POTW PRETREATMENT PROGRAMS
The actual requirement for a POTW to develop and implement a local pretreatment program is a
condition of its NPDES permit. Once the Approval Authority determines that a POTW needs a pretreatment
program, the POTWs NPDES permit is modified to require development of a local program and submission
of the program to the Approval Authority for review and approval. Consistent with §403.8(f), POTW
pretreatment programs must contain the six minimum elements presented in Figure 8.
In addition to the six specific elements, pretreatment program submissions must include:
a statement from the City Solicitor (or the like) declaring the POTW has adequate authority to
carry out program requirements;
copies of statutes, ordinances, regulations, agreements, or other authorities the POTW relies
upon to administerthe pretreatment program including a statement reflecting the endorsement
or approval of the bodies responsible for supervising and/or funding the program;
a brief description and organizational chart of the organization administering the program; and
a description of funding levels and manpower available to implement the program.
Pretreatment program submissions found to be complete proceed to the public notice process, as
described in Chapter 4, Public Participation and POTW Reporting. Upon program approval, the Approval
Authority is responsible for modifying the POTWs NPDES permit to require implementation of the approved
pretreatment program. Once approved, the Approval Authority oversees POTW pretreatment program
implementation via receiving annual reports and conducting periodic audits and inspections. As of early
1998, of the 1,578 POTWs required to develop pretreatment programs, 97 percent (1,535) have been
approved.
The National Pretreatment Program regulates IDs through three types of regulatory entities: EPA,
Approval Authorities, and Control Authorities. As noted above, Approval Authorities oversee Control
Authorities while Control Authorities regulate IDs. General responsibilities of each of these three regulatory
entities are presented in Figure 9.
Chapter 2 -7-
-------
Overview of the National Pretreatment Program
Introduction to the National Pretreatment Program
State
Alabama
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wvomina
* - Denotes 403
Approved State
NPDES Permit Program
10/19/79
11/01/86
05/14/73
03/27/75
09/26/73
04/01/74
05/01/95
06/28/74
11/28/74
10/23/77
01/01/75
08/10/78
06/28/74
09/30/83
08/27/96
09/05/74
10/17/73
06/30/74
05/01/74
10/30/74
06/10/74
06/12/74
09/19/75
04/13/82
10/28/75
10/19/75
06/13/75
03/11/74
11/19/96
09/26/73
06/30/78
09/17/84
06/10/75
12/30/93
12/28/77
09/14/98
07/07/87
03/11/74
06/30/76
03/31/75
11/14/73
05/10/82
02/04/74
01/30/75
10(e) State Approval
Approved State Pretreatment
Program
10/19/79*
11/01/86
09/22/89
-
06/03/81*
-
05/01/95
03/12/81
08/12/83
-
-
06/03/81
-
09/30/83
08/27/96
09/30/85
04/16/85
07/16/79
05/13/82*
06/03/81
-
09/07/84*
-
04/13/82
-
06/14/82
-
07/27/83
11/19/96
03/12/81
-
09/17/84
04/09/82
12/30/93
08/10/83
09/14/98
07/07/87
03/16/82*
-
04/14/89
09/30/86
05/10/82
12/24/80
—
Figure 7. State Program Approval Status
Chapter 2
-------
Introduction to the National Pretreatment Program Overview of the National Pretreatment Program
1. Legal Authority
The POTW must operate pursuant to legal authority enforceable in Federal, State or local courts,
which authorizes or enables the POTW to apply and enforce any pretreatment regulations developed
pursuant to the CWA. At a minimum, the legal authority must enable the POTW to:
I. deny or condition discharges to the POTW;
ii. require compliance with pretreatment standards and requirements;
iii. control IU discharges through permits, orders, or similar means;
iv. require IU compliance schedules when necessary to meet applicable
pretreatment standards and/or requirements and the submission of
reports to demonstrate compliance;
v. inspect and monitor lUs;
vi. Obtain remedies for IU noncompliance; and
vii. comply with confidentiality requirements.
2. Procedures
The POTW must develop and implement procedures to ensure compliance with pretreatment
requirements, including:
I. identify and locate all lUs subject to the pretreatment program;
ii. identify the character and volume of pollutants contributed by such
users;
iii. notify users of applicable pretreatment standards and requirements;
iv. receive and analyze reports from lUs;
v. sample and analyze IU discharges and evaluate the need for IU slug
control plans;
vi. investigate instances of noncompliance; and
vii. comply with public participation requirements.
3. Funding
The POTW must have sufficient resources and qualified personnel to carry out the authorities and
procedures specified in its approved pretreatment program.
4. Local limits
The POTW must develop local limits or demonstrate why these limits are not necessary.
5. Enforcement Response Plan (ERP)
The POTW must develop and implement an ERP that contains detailed procedures indicating how the
POTW will investigate and respond to instances of IU noncompliance.
6. List of SIUs
The POTW must prepare, update, and submit to the Approval Authority a list of all Significant
Industrial Users (SIUs).
Figure 8. Six Minimum Pretreatment Program Elements
Chapter 2 -9-
-------
Overview of the National Pretreatment Program
Introduction to the National Pretreatment Program
EPA
Headquarters
> Oversees program implementation at all levels
> Develops and modifies regulations for the program
> Develops policies to clarify and further define the program
> Develops technical guidance for program implementation
> Initiates enforcement actions as appropriate
Regions
> Fulfill Approval Authority responsibilities for States without
a State pretreatment program
> Oversee State program implementation
> Initiate enforcement actions as appropriate.
Approval Authorities (EPA Regions and delegated States)
> Notify POTWs of their responsibilities
> Review and approve requests for POTW pretreatment
program approval or modification
> Review requests for site-specific modifications to categorical
pretreatment standards
> Oversee POTW program implementation
> Provide technical guidance to POTWs
> Initiate enforcement actions, against noncompliant POTWs or
industries.
Control Authorities (POTWs, States, or EPA Regions)
> Develop, implement, and maintain approved pretreatment
program
> Evaluate compliance of regulated lUs
> Initiate enforcement action against industries as appropriate
> Submit reports to Approval Authorities
> Develop local limits (or demonstrate why they are not
needed)
> Develop and implement enforcement response plan.
Industrial Users
Comply with applicable pretreatment standards and reporting
requirements.
Figure 9. Roles and Responsibilities
-10-
Chapter 2
-------
Introduction to the National Pretreatment Program
Pretreatment Standards
3. PRETREATMENT STANDARDS
As described in Chapters 3 and
4, the National Pretreatment Program
identifies specific requirements that
apply to all IDs, additional
requirements that apply to all SILJs,
and certain requirements that only
apply to CILJs. The objectives of the
National Pretreatment Program are
achieved by applying and enforcing
three types of discharge standards:
- prohibited discharge standards
- categorical standards
- local limits.
PROHIBITED DISCHARGE
STANDARDS
All IDs, whether or not subject to
any other National, State, or local
pretreatment requirements, are
subject to the general and specific
prohibitions identified in 40 CFR
§§403.5(a) and (b), respectively.
General prohibitions forbid the
discharge of any pollutant(s) to a
POTW that cause pass through or
interference (Figure 10). Specific
prohibitions forbid eight categories of
pollutant discharges as follows:
(1) discharges containing pollutants which create a fire or explosion hazard in the POTW, including
but not limited to, wastestreams with a closed cup flashpoint of less than 140°F (60°C) using the
test methods specified in 40 CFR §261.21;
(2) discharges containing pollutants causing corrosive structural damage to the POTW, but in no
case discharges with a pH lower than 5.0, unless the POTW is specifically designed to
accommodate such discharges;
(3) discharges containing pollutants in amounts causing obstruction to the flow in the POTW
resulting in interference;
(4) discharges of any pollutants released at a flow rate and/or concentration which will cause
interference with the POTW;
(5) discharges of 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 POTWtreatment
plant exceeds 40°C(104°F) unless the Approval Authority, upon request of the POTW, approves
alternative temperature limits;
(6) discharges of petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in
amounts that will cause interference or pass through;
Chapter 3. Applicable EPA Guidance
Guidance Manual For Implementing Total Toxic Organics (TTO) Pretreatment
Standards
Guidance Manual for Preparation and Review of Removal Credit Applications
Guidance Manual for Preventing Interference at POTWs
Guidance Manual for the Identification of Hazardous Wastes Delivered to
Publicly Owned Treatment Works by Truck, Rail, or Dedicated Pipe
Guidance Manual for the Use of Production-Based Pretreatment Standards
and the Combined Wastestream Formula
Guidance Manual on the Development and Implementation of Local Discharge
Limitations Under the Pretreatment Program
Guidance to Protect POTW Workers From Toxic And Reactive Gases And
Vapors
Prelim User's Guide, Documentation for the EPA Computer Program/Model
for Developing Local Limits for Industrial Pretreatment Programs at
Publicly Owned Treatment Works
Supplemental Manual On the Development And Implementation of Local
Discharge Limitations Under The Pretreatment Program: Residential and
Commercial Toxic Pollutant Loadings And POTW Removal Efficiency
Estimation
Industry-Specific Guides
Aluminum, Copper, And Nonferrous Metals Forming And Metal Powders
Pretreatment Standards: A Guidance Manual
Guidance Manual For Battery Manufacturing Pretreatment Standards
Guidance Manual for Electroplating and Metal Finishing Pretreatment
Standard
Guidance Manual For Iron And Steel Manufacturing Pretreatment Standards
Guidance Manual for Leather Tanning and Finishing Pretreatment Standards
Guidance Manual for Pulp, Paper, and Paperboard and Builders' Paper and
Board Mills Pretreatment Standards
Chapter 3
-11-
-------
Pretreatment Standards Introduction to the National Pretreatment Program
(7) discharges which result in the
Pass through - A discharge which exits the POTW into waters of
the US in quantities or concentrations which, alone or in
conjunction with a discharge or discharges from other sources, is a
cause of a violation of any requirement of the POTW's NPDES
permit (including an increase in the magnitude or duration of a
violation.
Interference - A discharge which, alone or in conjunction with a
discharge or discharges from other sources, both (1) inhibits or
presence of toxic gases, vapors,
or fumes within the POTW in a
quantity that may cause acute
worker health and safety
problems; and
(8) discharges of trucked or hauled
pollutants, except at discharge points
designated by the POTW.
uiscnaige o
Compliance with the general and specific dlsmpts the POTW'lts treatment processes or °Peratlons'or lts
...... . . . , .[" . sludge processes, use or disposal; and (2) therefore is a cause of a
prohibitions is mandatory for all ILJs, although ..,.,, . r ,a T,,-.™^ ^m™^ •+ *•
r , .... . * .. ' , . violation of any requirement of the POTW s NPDES permit or of
a facihty may have an affirmative defense in ,, ,• f , •, •,• ,
•'.•'. . . .... the prevention of sewage sludge use or disposal.
any action brought against it a egmg a
violation of the general prohibitions or of Figure 10. Interference and Pass Through
certain specific prohibitions [(3), (4), (5), (6)
and (7) above] where the ID can demonstrate
it did not have reason to know that its discharge, alone or in conjunction with a discharge or discharges from
other sources, would cause pass through or interference, and the ID was in compliance with a technically-
based local limit developed to prevent pass through or interference.
These prohibited discharge standards are intended to provide general protection for POTWs. However,
their lack of specific pollutant limitations creates the need for additional controls, namely categorical
pretreatment standards and local limits.
CATEGORICAL STANDARDS
Categorical pretreatment standards (i.e., categorical standards) are national, uniform, technology-based
standards that apply to discharges to POTWs from specific industrial categories (i.e., indirect dischargers)
and limit the discharge of specific pollutants. Categorical jDretreatment standards for both existing and new
sources (PSES and PSNS, respectively) are promulgated by EPA pursuant to Section 307(b) and (c) of the
CWA. Limitations developed for indirect discharges are designed to prevent the discharge of pollutants that
could pass through, interfere with, or otherwise be incompatible with POTW operations. Effluent limitations
guidelines (ELGs), developed in conjunction with categorical standards, limit the discharge from facilities
directly to waters of the U.S. (i.e., direct dischargers) and do not apply to indirect dischargers. ELGs
include Best Practicable Control Technology Currently Available (BPT), Best Conventional Pollutant Control
Technology (BCT), and Best Available Technology Economically Achievable (BAT) limitations and New
Source Performance Standards (NSPS). ELGs (i.e., BPT, BCT, BAT, and NSPS) do not apply to indirect
dischargers. The significant difference between categorical standards and effluent limitations guidelines
is that categorical standards account for any pollutant removal that may be afforded through treatment at
the POTW while effluent limitations guidelines do not.
Industries identified as major sources of toxic pollutants are typically targeted for effluent guideline and
categorical standard development. If limits are deemed necessary, EPA investigates affected IDs and
gathers information regarding process operations and treatment and management practices, accounting for
differences in facility size and age, equipment age, and wastewater characteristics. Subcategorization within
an industrial category is evaluated based on variability in processes employed, raw materials used, types
of items produced, and characteristics of wastes generated. Availability and cost of control technologies,
non-water quality environmental impacts, available pollution prevention measures7, and economic impacts
are then identified prior to EPA's presentation of findings in proposed development documents and
publishing a notice of the proposed regulations in the Federal Register. Based on public comments on the
proposed rule, EPA promulgates (i.e., publishes) the standards (Figure 11).
7 EPA's Considerations of Pollution Prevention in EPA's Effluent Guideline Development
Process may be consulted for more information on this topic.
-12- Chapter 3
-------
Introduction to the National Pretreatment Program
Pretreatment Standards
Data
Collection
Regu
Tas
i
atory
ks
r
Proposed
Development
Document
Proposed
Regulations
'
Public
Comment
L_^^
— ^-V. Revisions
^\^
Promulgation of
Final
Regulations
Final
Development
Document
i
>-
As noted above, categorical pretreatment
standards are developed both for existing
(PSES) and new sources (PSNS). Facilities are
classified as either PSES or PSNS based on the
definition of "new source" set out in 40 CFR
§403.3(k) of the General Pretreatment
Regulations (see Figure 12). Dischargers
subject to PSES are required to comply with
those standards by a specified date, typically no
more than three years afterthe effective date of
the categorical standard. Users subject to
PSNS, however, are required to achieve
compliance within the shortest feasible time, not Figure 11. Development Process of Effluent Guidelines
to exceed 90 days from commencement of
discharge. PSNS are often more stringent than
PSES based on the opportunity for new sources to install the best available demonstrated technology and
operate the most efficient production processes.
Congress established an initial list of
21 categorical industries under Section
306 of the CWA of 1972. As a result of
various court decrees and settlement
agreements resulting from litigation, and
from EPA's internal work plan devel-
opment process, EPA has developed
effluent guidelines (for direct dischargers)
and/or categorical pretreatment standards
(for indirect dischargers) for 51 industrial
categories. Of these industrial categories,
EPA implements pretreatment standards
for 32 categories, and either requires
compliance solely with 40 CFR Part 403
General Pretreatment Regulations ordoes
not address pretreatment standards forthe
remaining categories. Plans for EPA's
expansion and modification of the list is
detailed in the Effluent Guidelines Plan,
published in the Federal Register
biennially as required in section 304(m) of
the CWA. A list of the industrial
categories that have categorical standards
is provided as Figure 13.
Categorical pretreatment standards
developed can be concentration-based or
mass-based. Concentration-based
standards are expressed as milligrams of
pollutant allowed per liter (mg/l) of wastewater discharged and are issued where production rates for the
particular industrial category do not necessarily correlate with pollutant discharges. Mass-based standards
are generally expressed on a mass per unit of production (e.g., milligrams of pollutant per kilogram of
product produced, pounds of pollutant per million cubic feet of air scrubbed, etc.) and are issued where water
conservation is an important component in the limitation development process. For a few categories where
reducing a facility's flow volume does not provide a significant difference in the pollutant load discharged,
EPA has established both mass- and concentration-based standards. Generally, both a daily maximum
limitation and a long-term average limitation (e.g., average daily values in a calendar month) are established
for every regulated pollutant.
New Source is defined at 40 CFR §403.3 (k)(l) to mean any building, structure, facility
or installation from which there is or may be a discharge of pollutants, the construction of
which commenced after publication of proposed Pretreatment Standards under Section
307(c) of the Act which will be applicable to such source if Standards are thereafter
promulgated in accordance with that section, provided that:
(i) the building, structure, facility, or installation is constructed at a site at which no
other source is located; or
(ii) the building, structure, facility, or installation totally replaces the process or
production equipment that causes the discharge of pollutants at an existing source; or
(iii) the production or wastewater generating processes of the building, structure, facility
or installation are substantially independent of an existing source at the same site. In
determining whether these are substantially independent, factors such as the extent to
which the new facility is integrated with the existing plant, and the extent to which
the new facility is engaged in the same general type of activity as the existing source
should be considered.
(2) Construction on a site at which an existing source is located results in a modification
rather than a new source if the construction does not create a new building, structure,
facility, or installation meeting the criteria of paragraphs (k)(l)(ii), or (k)(l)(iii) of this
section but otherwise alters, replaces, or adds to existing process or production
equipment.
(3) Construction of a new source as defined under this paragraph has commenced if the
owner or operator has:
(i) begun, or caused to begin as part of a continuous onsite construction program:
(ii) any placement, assembly or installation of facilities or equipment, or
(B) significant site preparation work, including clearing, excavation, or removal of
existing buildings, structures, or facilities which is necessary for the placement,
assembly, or installation of new source facilities or equipment; or
(ii) entered into a binding contractual obligation for the purchase of facilities or
equipment which are intended to be used in its operation within a reasonable time.
Options to purchase or contracts which can be terminated or modified without
substantial loss, and contracts for feasibility, engineering, and design studies do not
constitute a contractual obligation under this paragraph.
Figure 12. Definition of New Source (40 CFR 403.3(k))
Chapter 3
-13-
-------
Pretreatment Standards
Introduction to the National Pretreatment Program
Figure 13. Summary of Categorical Pretreatment Standards
Category
Aluminum Forming
Battery Manufacturing
Builders' Paper and
Board Mills
Carbon Black
Manufacturing
Coil Coating
Copper Forming
Electrical and Electronic
Components
Electroplating
Feedlots
Fertilizer Manufacturing
Glass Manufacturing
Grain Mills
Ink Formulating
Inorganic Chemicals
Manufacturing
Iron and Steel
Manufacturing
Leather Tanning and
Finishing
Metal Finishing
40CFR
Part
467
461
431
458
465
468
469
413
412
418
426
406
447
415
420
425
433
Subparts
A-F
A-G
A
A-D
A-D
A
A-D
A-B, D-H
B
A-G
H, K-M
A
A
A-BO
A-F, H-J, L
A-l
A
Type of
Standard
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
Overview of Pretreatment Standards
Limits are production-based, daily maximums and monthly averages.
Subpart C prohibits discharges from certain operations.
Limits are production-based, daily maximums and monthly
averages. No discharge is allowed from any process not specifically
dentified in the regulations.
Limits are production-based daily maximums. These facilities may
certify they do not use certain compounds in lieu of performing
nonitoring to demonstrate compliance.
Limits are for Oil & Grease only (no limit duration specified).
Limits are production-based, daily maximums and monthly averages.
Limits are production-based, daily maximums and monthly averages.
Limits are concentration-based, daily maximums and 30 day
averages or monthly averages (varies per subpart and pollutant
Darameter). Certification is allowed in lieu of monitoring for certain
Dollutants when a management plan is approved and implemented.
Limits are concentration-based (or alternative mass-based
equivalents), daily maximums and four consecutive monitoring days
averages. Two sets of limits exist, depending on if facility
discharges more or less than 1 0,000 gallons per day of process
wastewater. Certification is allowed in lieu of monitoring for certain
Dollutants when a management plan is approved and implemented.
Discharge of process wastewater is prohibited, except when there is
an overflow resulting from a chronic or catastrophic rainfall event.
Limits may specify zero discharge of wastewater pollutants (Subpart
A), production-based daily maximums and 30-day averages
(Subparts B-E) or concentration-based (Subparts F-G) with no limit
duration specified.
Limits are either concentration- or production-based, daily
•naximums and monthly averages.
Discharge of process wastewater is prohibited at a flow rate or mass
oading rate which is excessive over any time period during the peak
oad at a POTW.
Regulations specify no discharge of process wastewater pollutants
to the POTW.
Limits vary for each subpart with a majority of the limits
concentration-based, daily maximums and 30-day averages, or may
specify no discharge of wastewater pollutants. Numerous subparts
nave no pretreatment standards.
Limits are production-based, daily maximums and 30 day averages.
Limits are concentration-based, daily maximums and monthly
averages. In certain instances, production volume dictates
applicable pretreatment standards.
Limits are concentration-based, daily maximums and monthly
averages. Certification is allowed for certain pollutants where a
•nanagement plan is approved and implemented.
-14-
Chapter 3
-------
Introduction to the National Pretreatment Program
Pretreatment Standards
Figure 13. Summary of Categorical Pretreatment Standards
Category
Metal Molding and
Casting
Nonferrous Metals
Forming and Metal
Powders
Nonferrous Metals
Manufacturing
Organic Chemicals,
Plastics, and Synthetic
Fibers
Paint Formulating
Paving and Roofing
Materials (Tars and
Asphalt)
Pesticide Chemicals
Petroleum Refining
Pharmaceutical
Manufacturing
Porcelain Enameling
Pulp, Paper, and
Paperboard
Rubber Manufacturing
Soap and Detergent
Manufacturing
Steam Electric Power
Generating
Timber Products
Processing
40CFR
Part
464
471
421
414
446
443
455
419
439
466
430
428
417
423
429
Subparts
A-D
A-J
B-AE
B-H, K
A
A-D
A, C, E
A-E
A-D
A-D
A-G, I-L
E-K
O-R
N/A
F-H
Type of
Standard
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSES
PSNS
PSNS
PSNS
PSES
PSNS
PSES
PSNS
Overview of Pretreatment Standards
Limits are primarily production-based, daily maximums and monthly
averages. Discharges from certain processes are prohibited
(Subparts A-C).
Jmits are production-based, daily maximums and monthly averages.
In some instances, the regulations prohibit the discharge of
wastewater pollutants.
Jmits are production-based, daily maximums and monthly averages.
The majority of the Subparts have both existing and new source
imits, with others having solely new source requirements.
Limits are mass-based (concentration-based standards multiplied by
Drocess flow), daily maximums and monthly averages. Standards
br metals and cyanide apply only to metal- or cyanide-bearing
wastestreams.
Regulations specify no discharge of process wastewater pollutants
to the POTW.
Limits are for Oil & Grease only (no limit duration specified).
Limits are mass-based (concentration-based standards multiplied by
Drocess flow), daily maximums and monthly averages. Subpart C
specifies no discharge of process wastewater pollutants but provides
for pollution prevention alternatives. Subpart E specifies no
discharge of process wastewater pollutants.
Limits are concentration-based (or mass based equivalent), daily
•naximums.
Limits are concentration-based, daily maximums and monthly
averages. These facilities may certify they do not use or generate
cyanide in lieu of performing monitoring to demonstrate compliance.
Limits are concentration-based (or alternative production-based),
daily maximums and monthly averages. Subpart B prohibits
discharges certain operations.
Jmits are production-based daily maximums and monthly averages.
These facilities may certify they do not use certain compounds in
ieu of performing monitoring to demonstrate compliance. Facilities
subject to Subparts B and E must also implement Best Management
Practices as identified.
Limits are concentration- or production-based, daily maximums and
nonthly averages.
Regulations specify no discharge of process wastewater pollutants
to the POTW.
Jmits are either concentration-based, daily maximums, or
'maximums for any time", or compliance can be demonstrated
through engineering calculations.
All PSNS (and PSES for Subpart F) prohibit the discharge of
wastewater pollutants. PSES for Subparts G and H are
concentration-based, daily maximums (with production-based
alternatives).
Chapter 3
-15-
-------
Pretreatment Standards
Introduction to the National Pretreatment Program
Categorical standards apply to regulated wastewaters, i.e. wastewater from an industrial process that
is regulated for a particular pollutant by a categorical pretreatment standard. Therefore, demonstrating
compliance with categorical pretreatment standards is intended to be based on measurements of
wastestreams containing only the regulated process wastewater. However, recognizing isolation of regulated
wastestreams from nonregulated wastestreams was not always practicable nor desirable, EPA developed
the combined wastestream formula (CWF) and flow
weighted average (FWA) approach for determining
compliance with combined wastestreams.
Pursuant to 40 CFR §403.6(e), the CWF is
applicable where a regulated wastestream combines with
one or more unregulated or dilute wastestreams (Figure
14) prior to treatment. Where nonregulated
wastestreams combine with process streams after
pretreatment, the more stringent approach (whether
CWF or FWA) is used to adjust the limits8 (Figure 15).
The CWF and FWA approaches differ primarily in their
allowances for nonregulated wastestreams. While the
CWF provides a "full credit" (i.e., same pollutant levels
as regulated wastestreams) for unregulated
wastestreams yet no credit for dilute wastestreams, the
FWA requires sampling and analysis of the untreated,
nonregulated wastestreams to determine the credit to be
granted (not to exceed that allowed for the regulated
wastestreams).
Regulated
Unregulated
Dilute
Monitoring^ _
location J
CWF
Figure 14. Combined Wastestream Formula
Regulated Unregulated
Unregulated
Dilute
Application of the CWF and FWA requires proper identification, classification, and quantification of the
three wastestream types (Figure 16.) Note: in circumstances where boiler blowdown, noncontact cooling
water, stormwater, or demineralized wastestreams
contain a significant amount of a regulated pollutant, and
the treatment of the wastewater with the regulated
wastestream results in substantial reduction of the
regulated pollutant, the Control Authority can classify the
wastestream as unregulated rather than as a dilute
wastestream. Clarification on category-specific
wastestream classifications may be provided by
consulting the applicable regulation(s) and associated
development documents, since wastestream types are
addressed in the effluent guideline and categorical
standard development process. When in doubt, the
Control Authority can always require the CIU to monitor
the wastestream(s) in question to quantify the presence
(or lack thereof) of categorically regulated pollutants.
Reasonably accurate flow data must also be obtained for
each wastestream type flowing through the monitoring
point to ensure categorical pretreatment standards are
adjusted accordingly. Proper application of the CWF or
FWA will result in:
Figure 15. CWF vs. FWA
alternative limits being established for each regulated pollutant in each regulated processes;
both daily maximum and long-term average (i.e., 4-day, 30-day, or monthly) alternative limits
being calculated for each regulated pollutant;
Where commingled wastestreams combine with nonregulated wastestreams after
treatment, the CWF adjusted limitations are further adjusted by use of the CWF or FWA to
address the untreated, nonregulated wastestreams (Figure 17.) For more detailed
discussion of FWA, see Federal Register preamble language, 51 FR 21454 (June 12,1986).
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Introduction to the National Pretreatment Program
Pretreatment Standards
- 4-day average limits being adjusted to equivalent monthly average limits when two or more
categorical pretreatment standards apply to the facility and one of the applicable standards is
40 CFR Part 413; and
- calculated alternative limits remaining above the analytical detection limit for that pollutant.
NOTE: If adjusted limit(s) are below the detection limit, the Control Authority shall instruct the
ID to either:
separate the dilute wastestreams from the regulated wastestreams prior to the combined
treatment facility, or
segregate all wastestreams entirely.
EPA's Guidance Manual for the Use of Production Based Pretreatment Standards and the Combined
Wastestream Formula should be consulted for more information on the proper application and adjustment
of categorical pretreatment standards.
Regulated
Wastewaterfroman
industrial process that is
regulated for a particular
pollutant by a categorical
pretreatment standard
Nonregulated
Unregulated
Wastestreams from an industrial process that are not regulated for a
particular pollutant by a categorical pretreatment standard and are not
defined as a dilute wastestream, e.g.:
• a process wastestream for which categorical standards
have been promulgated but for which the deadline for
compliance has not yet been reached
• a process wastestream that currently is not subject to
categorical pretreatment standards
• a process wastestream that is not regulated for the pollutant
in question but is regulated for other pollutants.
Dilute
Wastestreams which have no more than trace or
non-detectable amounts of the regulated pollutant.
Defined in 40 CFR § 403.6(e)(1) of the General
Pretreatment Regulations to include sanitary wastestreams,
demineralized backwash streams, boiler blowdown,
noncontact cooling water, storm water, and process
wastestreams from certain standards based on the findings
that these wastewaters contained none of the regulated
pollutant or only trace amounts of it.
Figure 16. Wastestream Types
Although categorical standards are established based on a particular industrial category, EPA provides
several options for unique circumstances that justify adjustment of categorical standards for an individual
facility:
Removal Credits 40 CFR §403.7 details the
conditions by which a Control Authority may
demonstrate consistent removal of pollutants
regulated by categorical standards at their
POTW, and in so doing, may extend removal
credits to industries on a pollutant-specific basis
to prevent redundant treatment. Removal
credits are available for a pollutant if the
pollutant is regulated by the sewage sludge use
or disposal option employed by the POTW
making the application request, or if the pollutant
is listed in 40 CFR Part 403, Appendix G. Also,
the availability of removal credits is not limited to
Appendix G pollutants for POTWs that dispose
of sewage sludge in municipal solid waste
landfills. Steps for developing such a request
are detailed in EPA's Guidance Manual for the
Preparation and Review of Removal Credit
Applications.
Regulated
Unregulated
Unregulated
Dilute
Figure 17. Multiple use of the CWF/FWA
Chapter 3
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Pretreatment Standards
Introduction to the National Pretreatment Program
Fundamentally Different Factors Variance Section 301 (n) of the CWA authorizes adjustments of
categorical pretreatment standards for existing sources who demonstrate they have factors which
are fundamentally different from the factors EPA considered during standards development (40 CFR
§403.13). Variance requests must be based solely on information and data submitted during the
development of the categorical standards (Figure 18) and the adjusted effluent limitations must
neither be more nor less stringent than justified by the fundamental difference nor result in a
nonwater quality environmental impact markedly more adverse than the impact considered by EPA
when developing the categorical standard.
Successful requests must detail factors well outside the range considered by EPA in establishing the
standard and not merely factors deviating from the average. Further, differences must not be similar
to a significant number of other facilities in the category. A facility must request a variance in writing
no later than 180 days after publication of a categorical Pretreatment Standard in the Federal
Register.
Figure 18. Factors to Consider for an FDF Variance Request
Net/Gross Adjustment Categorical pretreatment standards can be adjusted to reflect the presence of
pollutants in a ClU's intake waters (40 CFR §403.15). To obtain a net/gross credit, the CIU must submit
a formal written request to the Control Authority that demonstrates:
- its intake water is drawn from the same body of water that the POTW discharges into (this
can be waived if the Control Authority finds no environmental degradation will result);
- the pollutants present in the intake water will not be entirely removed by the treatment
system operated by the CIU; and
- the pollutants in the intake water do not vary chemically or biologically from the pollutants
limited by the applicable standard.
Inherent in this provision is the requirement that the CIU employ a treatment technology capable of
meeting the categorical pretreatment standard(s). Net/gross adjustments should not be granted to
ClUs that have no treatment. Further, credits are only granted to the extent necessary to meet the
applicable standard(s), up to a maximum value equal to the influent value.
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Introduction to the National Pretreatment Program Pretreatment Standards
Innovative Technology In accordance with 307(e) of the CWA, existing CILJs choosing to install an
innovative treatment system may receive approval from the Control Authority for up to a two year
extension to their applicable categorical pretreatment standards compliance deadline, provided:
- the innovative treatment has a reasonable potential to result in significantly greater pollutant
removal or equivalent removal at a substantially lower cost than the technologies
considered by EPA when developing the categorical standard;
- the innovative technique has the potential for industry-wide application; and
- the proposed compliance extension will not cause or contribute to the violation of the
POTWs NPDES permit.
While policy has been established for universal categorical variance requests, occasionally, a Control
Authority may merely need assistance to classify a CIU and/or to determine applicable categorical
limitations. Provisions in the General Pretreatment Regulations allow POTWs and IDs to request an EPA
category determination for a specific ID within 60 days after the effective date of the standard in question
[40 CFR §403.6(a)]. Even afterthe formal timeframe for requesting a categorical determination, EPA (and
states) will assist POTWs and IDs with categorization issues. Such requests, however, do not affect
applicable reporting requirements, including timely requests submitted under 40 CFR §403.6(a).
Additionally, EPA has addressed universal CIU questions posed by Control Authorities in various
memoranda and guidance:
Research and Development (R&D) Facilities Unless specifically addressed in the categorical
regulation or associated development document, R&D facilities where there is no commercial sale
of products from the facility, are not subject to categorical standards.9 Should an R&D facility need
pollution controls to comply with prohibited discharge standards and/or local limits, the development
documents may serve as guidance on the performance of pollution control technologies.
Certification Statements In lieu of requiring self-monitoring, some standards allow ClUs to certify
that they do not use, generate or discharge a regulated pollutant [e.g. Pulp, Paper and Paperboard
facilities can certify that chlorophenolic compounds are not used (40 CFR Part 430) and
Pharmaceutical Manufacturing facilities can certify that cyanide is not used or generated (40 CFR
Part 439)]. Facilities providing such certifications are still considered ClUs, and therefore are subject
to other pretreatment standards and requirements.
Lack of specific categorical effluent limitations lUs subject to PSES or PSNS that merely require
compliance with 40 CFR Part 403 are not considered ClUs. However, these users may still be
classified as SlUs and are still subject to the general and specific prohibitions and any local limits.
Total Toxic Organics (TTO) Seven categorical regulations currently limit the discharge of TTO:
- 40 CFR Part 413 - Electroplating
- 40 CFR Part 433 - Metal Finishing
- 40 CFR Part 464 - Metal Molding and Casting
- 40 CFR Part 465 - Coil Coating
- 40 CFR Part 467 - Aluminum Forming
- 40 CFR Part 468 - Copper Forming
- 40 CFR Part 469 - Electrical and Electronic Components (Phase I and II)
For each of these standards, TTO refers to the sum of the masses or concentrations of certain toxic
organic pollutants found in the regulated discharge at a concentration greater than 0.01 milligrams
per liter (mg/l). However, the toxic organic pollutants regulated by the TTO limit are specific to each
industrial category. Further, industrial categories may provide some flexibility with regard to
monitoring and/or reporting requirements as follows:
9 June 26, 1987 letter from Ms. Rebecca W. Hanmer, Deputy Assistant Administrator for
Water.
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Pretreatment Standards
Introduction to the National Pretreatment Program
- 40 CFR Parts 413 and 433 allow development and implementation of a Toxic Organic
Management Plan (TOMP) in lieu of routine monitoring while 40 CFR Part 469 allows
development and implementation of a Solvent Management Plan. Upon approval of
these plans by the Control Authority, the CIU can demonstrate compliance with TTO
requirements by certifying that the facility is adhering to this Plan to prevent organics
from being discharged to the POTW. A specific certification statement must be signed
and provided to the Control Authority on a regular basis.
- 40 CFR Parts 464, 465, 467, and 468 allow an option to demonstrate compliance with
an Oil and Grease limit in lieu of demonstrating compliance with a TTO limit. The
option chosen by the CIU must be utilized for all reports required (i.e., BMR, 90-day
compliance report, and periodic compliance reports).
EPA's Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreatment Standards
should be consulted for more information on TTO.
LOCAL LIMITS
Prohibited discharge standards are designed to protect against pass-through and interference generally.
Categorical pretreatment standards, on the other hand, are designed to ensure that lUs implement
technology-based controls to limit the discharge of pollutants. Local limits, however, address the specific
needs and concerns of a POTW and its receiving waters. Federal regulations at 40 CFR §§403.8(f)(4) and
122.21 (j)(4) require Control Authorities to evaluate the need for local limits and, if necessary, implement and
enforce specific limits as part of pretreatment program activities.
Local limits are developed for pollutants (e.g. metals, cyanide, BOD5, TSS, oil and grease, organics) that
may cause interference, pass through, sludge contamination, and/or worker health and safety problems if
discharged in excess of the receiving POTW treatment plant's capabilities and/or receiving water quality
standards. Typically, local limits are developed to regulate the discharge from all lUs, not just to ClUs, and
are usually imposed at the "end-of-pipe" discharge from an IU (i.e., at the point of connection to the POTWs
collection system). In evaluating the need for local limit development, it is recommended that Control
Authorities:
conduct an industrial waste survey to identify
all lUs that might be subject to the
pretreatment program;
determine the character and volume of
pollutants contributed to the POTW by these
industries;
determine which pollutants have a reasonable
potential for pass through, interference, or
sludge contamination;
conduct a technical evaluation to determine
the maximum allowable POTW treatment
plant headworks (influent) loading for at least
arsenic, cadmium, chromium, copper, cyanide,
lead, mercury, nickel, silver, and zinc (Figure
19);
identify additional pollutants of concern;
determine contributions from unpermitted sources to determine the maximum allowable treatment plant
headworks loading from "controllable" industrial sources (Figure 20);
implement a system to ensure these loadings will not be exceeded.
Maximum Allowable Headworks Loading Method
(MAHL) Pollutant by pollutant, treatment plant data are
used to calculate removal efficiencies, before applying the
most stringent criteria (i.e., water quality, sludge quality,
NPDES permit, or pollutant inhibition levels) to back
calculate the MAHLs. Subtracting out contributions from
domestic sources, the available industrial loading is then
either evenly distributed among the lUs, or allocated on an
as needed basis to those lUs discharging the pollutant
above background levels.
Figure 19. MAHL
Other local limit approaches available to Control
Authorities include:
Collection System Approach Pollutants found
to be present which may cause fire and
Maximum Allowable Industrial Load (MAIL) The
MAIL is the total daily mass that a POTW can accept from
all permitted lUs and ensure the POTW is protecting
against pass through and interference.
Figure 20. MAIL
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Introduction to the National Pretreatment Program Pretreatment Standards
explosion hazards or other worker health and safety concerns, are evaluated for their propensity to
volatilize and are modeled to evaluate their expected concentration in air. Comparisons are made with
worker health exposure criteria and lower explosive limits. Where values are of concern, the Control
Authority may set limits or require development of management practices to control undesirable
discharges. The collection system approach may also considerthe prohibition of pollutants with specific
flashpoints to prevent discharges of ignitable wastes. EPA's Guidance to Protect POTW Workers from
Toxic and Reactive Gases and Vapors details strategies for developing such local limits.
Industrial User Management Practice Plans These plans typically consist of narrative local limits
requiring IDs to develop management practices (e.g., chemical management practices, best
management practices, and spill prevention plans) for the handling of chemicals and wastes. The
need for and suggested contents of such plans may be found in EPA's Control of Slug Loadings to
POTWs: Guidance Manual, and Spill Prevention, Control, and Countermeasure (SPCC) Information
Guide.
Case-by-Case Discharge Limits These numeric local limits are based on best professional
judgement (BPJ) and available pollution prevention and treatment technologies which are known
to be economically feasible. This approach is most often used when insufficient data are available
to employ the methods outlined above.
Local Specific Prohibitions POTW specific prohibitions may be imposed in addition to the
prohibitions detailed in 40 CFR § 403.5 (a) & (b) to address hydraulic, pollutant specific, and/or
aesthetic concerns; e.g.:
- noxious or malodorous liquids, gases, or solids creating a public nuisance
- wastestreams which impart color and pass through the POTW treatment plant
- storm water, roof runoff, swimming pool drainage
- wastewaters containing radioactive wastes or isotopes
- removed substances from pretreatment of wastewater.
Regardless of the approaches taken by a Control Authority, local limits should correct existing problems,
prevent potential problems, protect the receiving waters, improve sludge use options, and protect POTW
personnel. Additional existing EPA guidance on the subject includes:
- Guidance for Preventing Interference at POTWs
- Guidance Manual on the Development and Implementation of Local Discharge Limitations Under
the Pretreatment Program
- Supplemental Manual on the Development and Implementation of Local Discharge Limitations
Under the Pretreatment Program: Residential and Commercial Toxic Pollutant Loadings and
POTW Removal Efficiency Estimation
- Toxicity Identification Evaluation: Characterization of Chronically Toxic Effluents.
Additionally, many EPA Regions and States have developed local limits guidance to address regional and
state issues.
Chapters -21-
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Pretreatment Standards
Introduction to the National Pretreatment Program
SUMMARY OF STANDARDS
A summary of all of the pretreatment standards, including general and specific prohibitions, categorical
pretreatment standards, and local limits, is provided as Figure 21.
General and Specific Prohibitions
Categorical Pretreatment Standards
Local Limits
Oevelopment
established at the Federal level
Established at the Federal level
Developed by Control Authorities
Reference
K) CFR 403.5(a) & (b)
40 CFR Parts 405-471
Requirements for development found in
40 CFR §§403.5(c) & 403.8(f)(4)
Applicability
1 lUs
CIUs
Commonly all lUs or all SIUs, but
depends on allocation method used
when developing limits.
Purpose
-"rovide for general protection of the
'OTW. May be superseded by
nore stringent categorical
)retreatment standards or local
imits.
Minimum standards based on available
treatment technology and pollution prevention
measures for controlling nonconventional and
toxic pollutants that may cause pass through,
interference, etc. at the POTW. May be
superseded by more stringent local limits.
Provide site specific protection for a
POTW and its receiving waters. May
be superseded by more stringent
categorical standards.
411 standards are considered pretreatment standards for the purpose of section 307(d) of the Clean Water Act. A POTW is responsible for
identifying standard(s) applicable to each industrial user and applying the most stringent requirements where multiple provisions exist. Compliance
with imposed standards can be achieved through implementation of best management practices, development of a pollution prevention program,
and/or installation of pretreatment.
Figure 21. Summary of Standards
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Introduction to the National Pretreatment Program
POTW Pretreatment Program Responsibilities
4. POTW PRETREATMENT PROGRAM
RESPONSIBILITIES
Chapter 4. Applicable EPA Guidance
CERCLA Site Discharges to POTWs Guidance Manual
Control of Slug Loadings To POTWs: Guidance Manual
Guidance For Developing Control Authority Enforcement Response
Plans
Guidance Manual for POTWs to Calculate the Economic Benefit of
Noncompliance
Industrial User Inspection and Sampling Manual For POTWs
Industrial User Permitting Guidance Manual
Model Pretreatment Ordinance
Multijurisdictional Pretreatment Programs: Guidance Manual
NPDES Compliance Inspection Manual
POTW Sludge Sampling and Analysis Guidance Document
Pretreatment Compliance Monitoring and Enforcement Guidance
RCRA Information on Hazardous Wastes for Publicly Owned
Treatment Works
U.S. EPA Pretreatment Compliance Monitoring and Enforcement
System: Version 3.0, User's Guide
Chapter 2 describes the basis
for POTWs to develop pretreatment
programs that implement Federal
pretreatment standards and
requirements, in addition to
protecting any local concerns. This
Chapter provides an overview of
these POTW programs, highlighting
each of the specific program areas
that are to be addressed.
LEGAL AUTHORITY
As discussed in Chapter 2,
POTWs seeking pretreatment
program approval must develop
policy and procedures for program
implementation and establish the
legal authority to implement and
enforce program requirements. The
General Pretreatment Regulations do not provide Control Authorities with the legal authority to carry out their
pretreatment programs; rather the regulations do set forth the minimum requirements for POTWs with
pretreatment programs.
A Control Authority's legal authority actually derives from State law. Therefore, State law must confer the
minimum Federal legal authority requirements on a Control Authority. Where deficient, State law must be
modified to grant the minimum requirements.
In order to apply regulatory authority provided by State law, it is generally necessary for the Control
Authority to establish local regulations to legally implement and enforce pretreatment requirements. Where the
Control Authority is a municipality, legal authority is detailed in a Sewer Use Ordinance (SUO), which is usually
part of city or county code. Regional Control Authorities frequently adopt similar provisions in the form of "rules
and regulations." Likewise, State agencies implementing a State-wide program under 40 CFR §403.10(e) set
out pretreatment requirements as State regulations, rather than as an SUO. [Local regulations cannot give the
Control Authority greater authority than that
provided by State law.] EPA's 1992 guidance,
EPA Model Pretreatment Ordinance provides
a model for POTWs that are required to
develop pretreatment programs.
As POTW service areas expand, new
contributions may arise from
"extrajurisdictional" lUs located outside of the
Control Authority's legal jurisdiction (see
Figure 22). Multijurisdictional arrangements
require special legal/contractual mechanisms
to ensure adequate authority to implement
and enforce program requirements in these
other jurisdictions. Some state statutes may
provide for general extraterritorial powers
(i.e., a Control Authority is automatically
allowed to regulate extrajurisdictional lUs
City A
CityB
POTW
Figure 22. Multijurisdictional Programs
Chapter 4
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POTW Pretreatment Program Responsibilities Introduction to the National Pretreatment Program
contributing to their system). However, the extent to which authorities (i.e., to permit, inspect, enforce, monitor,
etc.) are granted may be somewhat limited, thereby, restricting a Control Authority's ability to implement and
enforce a program. Where obtaining authority from the State to regulate extrajurisdictional IDs is not feasible,
other options may be pursued:
Districts The creation of an independent organization (by affected municipalities orthe State) which
is authorized to administer and enforce an approved pretreatment program for the entire area in
which it provides services is common in areas where multiple POTWs each serve various
jurisdictions.
Agreements Affected Control Authorities may opt to enter into agreements requiring each
municipality to implement and enforce the approved pretreatment program covering all IDs within
their jurisdiction. The Control Authority must retain the means to regulate extrajurisdictional IDs
where the contributing jurisdiction's efforts are inadequate. It is essential that agreements clearly
define the roles of each party.
Annexation Where extrajurisdictional IDs lie in unincorporated areas, a Control Authority may
annex or utility annex the service area.
Contracts A Control Authority may enter into a contract with an extrajurisdictional ID, although
contracts generally limit the enforcement capabilities of the Control Authority. As such, contracts
should only be pursued when all other means fail.
Since procedures for obtaining jurisdiction, creating sanitary districts, annexing service areas, etc. vary
among states, Control Authority personnel should consult with their legal staff to thoroughly examine options
allowed. This may include requesting State legislative changes if necessary. EPA's 1994 Multijurisdictional
Pretreatment Programs - Guidance Manual provides more information on these jurisdictional issues, including
sample language for agreements and contracts.
INDUSTRIAL WASTE SURVEYS
As part of program development and maintenance, the Federal regulations [40 CFR §403.8(f)(2)(l)] require
Control Authorities to identify and locate all lUs that might be subject to the pretreatment program. While the
General Pretreatment Regulations do not specify how a Control Authority is to accomplish this, it is beneficial
to conduct an initial in-depth survey, then institute measures to update the list continuously. Control Authorities
must ensure that the entire service area is reviewed. This may include lUs located outside the jurisdictional
boundaries of the POTW. In these instances, it may be appropriate to solicit assistance from other jurisdictions
in developing the list of potential dischargers. The types of resources that may be consulted in compiling and
updating the master list include:
Water and sewer billing records
Applications for sewer service
Local telephone directories
Chamber of Commerce and local business directories
Business license records
POTW and wastewater collection personnel and field observations
Business associations
Internet
Once lUs are identified, the Control Authority must classify these users to determine if pretreatment
standards and requirements should apply to these facilities. Typically, the Control Authority develops and
distributes an Industrial Waste Survey (IWS) questionnaire to the identified lUs. The IWS questionnaire
requests information regarding IU activities and the nature of wastes discharged. The Control Authority may
opt to send a detailed IWS questionnaire initially or conduct the survey in two phases (i.e., send a screener
requesting basic information to eliminate obvious facilities and then send a detailed IWS to those facilities with
greater potential to be SlUs). Key to the IWS is to identify facilities that are subject to categorical standards
(i.e., ClUs) or otherwise have the potential to impact the POTW (i.e., SlUs).
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Introduction to the National Pretreatment Program POTW Pretreatment Program Responsibilities
A POTW's ID inventory should include the name, location, classification, applicable standards, basis for
limits imposed, volume of discharge, control mechanism status, compliance dates and other special
requirements for each ID. The IWS should provide most of the information required to develop the inventory,
although some supplementary information might be required from othersources, such as the permit application
or monitoring data.
The ID inventory must be updated as needed [40 CFR §403.8(f)(2)(l)] and provided to the Approval
Authority as part of the annual report requirement (see POTW Reports section in this Chapter). The on-going
task of maintaining a complete list of IDs requires the Control Authority to implement a system to track existing
ID information and/or classification changes and new user information. Some Control Authorities may
proactively opt to institute a "utility connect questionnaire" program. These types of forms are completed when
a customer applies for new utility service (e.g., water, sewerage, or electricity).
PERMITTING
The General Pretreatment Regulations require all IDs be controlled through permit, order, orsimilar means
to ensure compliance with applicable pretreatment standards and requirements. Section 403.8(f)(1)(iii)(A-E)
clarifies this requirement to specify that all SILJs be issued a permit or equivalent individual control mechanism
which contains, at a minimum:
- statement of duration (not to exceed five years);
- statement of nontransferabililty (unless outlined provisions are met);
- effluent limitations based on applicable standards;
- self-monitoring, sampling, reporting, notification, and record keeping requirements;
- statement of applicable civil and criminal penalties; and
- a schedule of compliance (where appropriate).
EPA's 1989 Industrial User Permitting Guidance Manua/details procedures fordrafting ID discharge permits.
SIU permits issued are site specific and tailored to the unique circumstances of the ID. Permit conditions must
establish clear and explicit requirements for the permittee, to include using such terms such as "shall" and
"must" in lieu of vague terms such as "recommend" or "may". The Control Authority must document its decision-
making process when developing permits to ensure defensibility and enforceability. Adherence to sound,
documented procedures will prevent any arbitrary and capricious claims by the permittee. Whether developing
or reissuing a permit, the permitting process consists of three phases:
- Phase I - Collection and verification of information
- Phase II - Data interpretation and fact sheet development
- Phase III - Permit development and issuance.
As part of Phase I, Control Authorities may review and verify information contained in the permit application,
perform an inspection of the ID for confirmation of facts, tally data, and potentially sample and analyze the ILJ's
wastestream. Knowledgeable Control Authority personnel, effective communication, and SIU cooperation are
essential to collection of complete and accurate information.
Phase II requires that the Control Authority interpret data and other information and document the permit
decision-making rationale, preferably in a permit fact sheet. Although the contents of a fact sheet will vary by
permittee, fact sheets should provide a justification of all permitting decisions. Typical components of a fact
sheet are provided in Figure 23. Completed fact sheets should be included as part of the permit and provided
to the Permittee to document the soundness of permitting decisions.
Chapter 4 -25-
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POTW Pretreatment Program Responsibilities
Introduction to the National Pretreatment Program
After all permitting decisions are made, the Control
Authority must incorporate those decisions into a
permit. The permit, signed by the specified Control
Authority official is provided to the Permittee for
comment and after comments are addressed, a final
permit is issued to the ID. While many comments may
be easily addressed/resolved by the Control Authority,
occasionally resolution must be obtained through a
formal adjudicatory hearing process where both the
Permittee and Control Authority present their case to a
third party.
Many POTWs also control contributions from non-
SILJs using various means, such as through general
permits issued to an entire industrial sector. These
types of control mechanisms may not necessarily
require compliance with specific pollutant limitations.
For example:
- grease trap maintenance and record keeping
requirements for food establishments;
For CIUs:
• the basis for the categorical determination(s)
• the identity and flow volume of all wastestreams
generated and discharged to the POTW, and classified
accordingly (i.e., regulated, unregulated, or dilution)
• data used and/or justification for estimates used to
determine categorical limitations
• basis for limits imposed for categorical parameters.
For SIUs/CIUs:
• basis for limits imposed for non-categorical parameters
• rationale for compliance schedules, special plans
required, special conditions, etc.
• basis for monitoring and reporting frequencies.
Figure 23. Components of Permit Fact Sheet
- maintenance and record keeping requirements for photo processors' silver reclamation units;
- best management practices for mercury recovery by hospitals and dentists.
Industrial sector general permitting programs are common where a real or potential POTW problem is linked
to a particular pollutant discharged (e.g., collection system blockages caused by the discharge of excess oils
and grease from food establishments). POTWs do have authority to enforce their SUO or rules or regulations
against non-SIUs without the need for any type of individual control mechanism. Control Authorities do have
the authority to require non-SIUs to comply with pretreatment standards and requirements contained in their
local regulations and then take appropriate actions against IDs as noncompliance is identified.
INSPECTIONS
Control Authorities are required to inspect and
sample all SILJs a minimum of once per year pursuant
to 40 CFR §403.8(f)(2(v). The frequency with which a
Control Authority actually inspects an SIU may vary
depending on issues such as the variability of an SlU's
effluent, the impact of their discharge on the POTW,
and their compliance history. Inspection
considerations (see Figure 24) will hinge upon the type
of inspection performed (i.e., scheduled, unscheduled
or demand). EPA's 1994 Industrial User Inspection
and Sampling Manual for POTWs provides a detailed
reference for inspection procedures and protocols.
Scheduled inspections are useful when the Control
Authority wants to gather specific information from the
facility that necessitates meeting with specific SIU
contacts. However, since scheduled inspections may
interrupt normal operations (e.g., altered production
schedule as a result of preparative work undertaken by
the IU), unscheduled inspections may more accurately
reflect IU compliance status when the inspection is
performed for that reason.
Provide current data on lUs
Confirm or determine IUs' compliance status
Determine completeness and accuracy of the lU's
performance/compliance records
Assess the adequacy of the lU's self-monitoring and
reporting requirements
Assess the adequacy of monitoring locations and lU's
sampling techniques
Assess the adequacy of imposed limitations and
pollutants of concern
Develop rapport with IUs
Evaluate operation and maintenance and overall
performance of an lU's pretreatment system
Assess the potential for spills and slug loadings
Evaluate the effectiveness of slug control plan
Reveal issues requiring action
Identify noncompliance needing resolution
Suggest pollution prevention opportunities
Collect samples
Obtain data to support enforcement actions
Figure 24. Inspection Considerations
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Introduction to the National Pretreatment Program POTW Pretreatment Program Responsibilities
POTWs must evaluate, at least once every two years, whether each SIU needs a plan to control slug
discharges (i.e., a discharge of a non-routine, episodic nature, including but not limited to an accidental spill or
non-customary batch discharge). To accurately evaluate the slug potential, Control Authorities likely will have
to examine the SIU during normal operating conditions. If undetected, slug discharges can have serious
impacts on the POTW. EPA's 1991 Control of Slug Loadings to POTWs Guidance Manual provides a
description of procedures for development, implementation, and review of slug control plans.
Demand inspections are non-routine in nature and occur in response to a concern (e.g., POTW collection
problems downstream from an ID, elevated enforcement actions against an ID, suspicious ID behavior, or an
informer complaint).
Routine Control Authority inspections of SILJs typically consist of three activities; preparation, on-site
assessment, and follow-up.
Preparation - Control Authority personnel should review POTW records for SILJs to be inspected to
familiarize themselves with the facility. Information reviewed may include compliance status, compliance
schedule activities, reports and plans, upcoming report and plan due dates, enforcement activities, permit
applications, waste surveys, previous inspection summaries, categorical regulations, water use/billing
records, and POTW collection system maps. Control Authority personnel should also be familiar with any
specific issues and concerns regarding the POTW treatment plant or collection system problems receiving
the SlU's discharge.
On-site Assessment - Control Authority personnel typically discuss ID operations with ID contacts and
perform a walkthrough of the facility to: update ID information regarding contacts, processes, production
rates, pretreatment, and other waste management activities; review records required to be kept by the ID;
visually verify the need for a slug control plan; and review pretreatment system maintenance, categorical
standards applicable to processes employed, metering and sampling equipment, sampling procedures,
chemicals used, processes employed, management practices, containment structures, locations of floor
drains, etc. Many POTWs have developed a standard inspection questionnaire to facilitate the interview
process and promote consistency during the inspection.
Follow-up - An inspection report should be prepared as soon as possible after the inspector returns to the
office. Unanswered questions, required permit modifications, and/or necessary enforcement actions should
be processed in a timely manner.
Non-routine inspections (e.g., demand) may not encompass all the activities and steps specified above, but,
like routine inspections, these activities may provide the Control Authority an opportunity to collect samples of
the ILJ's discharge.
SAMPLING
The General Pretreatment Regulations require Control Authorities to monitor each SIU at least annually and
each SIU to self-monitor semi-annually. As with inspections, the Control Authority should assess site-specific
issues, such as SIU effluent variability, impact of this effluent on the POTW, and the SlU's compliance history
to determine appropriate sampling frequencies (i.e., if more frequent monitoring is necessary). A more detailed
discussion of IU monitoring requirements is provided in Chapter 5. For more detailed information on sampling
frequencies, consult EPA's 1994 Industrial User Inspection and Sampling Manual for POTWs.
Sampling is the most appropriate method for verifying compliance with pretreatment standards. Monitoring
location(s) are designated by the Control Authority and must be such that compliance with permitted discharge
limits can be determined. Where possible, the Control Authority should not designate monitoring locations that
are confined spaces or that are difficult to access or difficult to place the automated sampling equipment.
Monitoring locations should:
- be appropriate for waste stream conditions;
- be representative of the discharge;
- have no bypass capabilities; and
- allow for unrestricted access at all times.
Chapter 4 -27-
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POTW Pretreatment Program Responsibilities
Introduction to the National Pretreatment Program
Control Authorities should measure flow to allow for collection of flow-proportioned composite samples,
which are required, unless flow-proportional sampling is not feasible. Flow-proportional composite samples are
preferred overtime composite samples particularly where the monitored discharge is intermittent or variable.
Desired analyses dictate the preparation protocols, equipment, and collection bottles to use to avoid
contamination of samples or loss of pollutants through improper collection. Sampling for such pollutants as pH,
cyanide, oil and grease, flashpoint, and volatile organic compounds require manual collection of grab samples.
Similarto composite samples, grab samples must be representative of the monitored discharge and are to be
collected from actively flowing wastestreams. Fluctuations in flow or the nature of the discharge may require
collection of and hand-compositing of more than one grab sample to accurately access compliance. To ensure
defensibility of data, Control Authorities should develop and implement standard operating procedures and
policies detailing sample collection and handling protocols in accordance with 40 CFR Part 136.
Adherence to proper sample collection and handling protocols, 40 CFR Part 136 approved analytical
methodologies, and record keeping requirements [40 CFR §403.12(o)(1)] (see Figure 25) can be verified
through review of field measurement records, chain of custodies, and lab reports. Field measurement records
may require information regarding sample location, condition of and programmed settings for sampling
equipment, wastewater meter readings, and information for such parameters as pH and temperature which
require analysis in the field. Chain of custody forms serve as a link between field personnel and the laboratory
and contain information regarding sample matrix, type, and handling. Lab reports should contain the minimum
information specified in 40 CFR §403.12(o)(1)(ii-iv) as well as any additional information necessary to
demonstrate compliance with 40 CFR Part 136 requirements (e.g., analytical methodology, sample preparation
date and time, time of analysis). Use of standardized forms which prompt recording of information necessary
for demonstrating compliance with applicable requirements, will aid in ensuring it can be used as admissible
evidence in enforcement proceedings or in judicial actions.
Figure 25. Sample Collection Techniques
Parameter
PH
BOD
TSS
NH3asN
Oil and Grease
Cyanide, total
Metals (total) excl. Cr+6,
B, andHg
624 (volatiles organics)
625 (semi-volatile
organics)
Sample type
Grab
Composite
Composite
Composite
Grab
Grab
Composite
Grab
Composite
Container
Polyethylene or Glass
Polyethylene or Glass
Polyethylene or Glass
Polyethylene or Glass
Glass
Polyethylene or Glass
Polyethylene or Glass
Amber glass, w/ teflon septum
lid and zero headspace
Amber glass w/ teflon lined lid
Preservative
N/A
chilled to 4°C
chilled to 4°C
chilled to 4°C, H2SO4 to pH<2
chilled to 4°C, HC1 or H2SO4 to pH<2
chilled to 4°C, NaOH to a pH >12, and 0.6g
of ascorbic acid if residual chlorine is present
HN03 to pH<2
chilled to 4°C (additional laboratory
preservation required)
chilled to 4°C (additional laboratory
preservation required)
Holding time
analyze immediately
48 hours
7 days
28 days
28 days
14 days
6 months
7 or 14 days, depending on
specific organic
7 days for sample prep; 40
days for extract
ENFORCEMENT
In addition to requirements for permitting, sampling, and inspecting IDs, the General Pretreatment
Regulations also require Control Authorities to review ID reports and plans, and respond to instances of ID
noncompliance in a timely, fair, and consistent manner. Enforcement of pretreatment requirements is a critical
element of the Pretreatment Program, but in the past extenuating circumstances may have prevented POTWs
from taking adequate enforcement. For example, political and economic pressures from local officials could
keep POTW personnel from taking appropriate actions. After this was identified as a major concern, EPA
promulgated regulations in 1990 (55 FR 30082) that require all POTWs with approved pretreatment programs
to adopt and implement an Enforcement Response Plan (ERP). These ERP regulations, at 40 CFR
§403.8(f)(5), establish a framework for POTWs to formalize procedures for investigating and responding to
instances of ID noncompliance. With an approved ERP in place, POTWs can enforce against IDs on a more
objective basis and minimize outside pressures.
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Introduction to the National Pretreatment Program POTW Pretreatment Program Responsibilities
To evaluate ID compliance, Control Authorities must first identify applicable requirements for each ID. In
general, ID reports (discussed in Chapter 5) and POTW monitoring activities are the basis for POTWevaluation
of ID compliance. Discharge permit limit exceedances, discrepancies, deficiencies, and lateness are all
violations that must be resolved.
To ensure enforcement response is appropriate and that the Control Authority actions are not arbitrary or
capricious, EPA strongly recommends that an Enforcement Response Guide (ERG) be included as part of the
approved ERP. The ERG identifies responsible Control Authority officials, general time frame for actions,
expected ID responses, and potential escalated actions based on:
- the nature of the violation
pretreatment standards
reporting (late or deficient)
compliance schedules
- magnitude of the violation
- duration of the violation
- frequency of the violation (isolated or recurring)
- (potential) impact of the violation (e.g., interference, pass through, or POTW worker safety)
- economic benefit gained by the violator
- attitude of the violator
The types of questions that dictate whether an
ERP is adequate are presented in Figure 26.
Factors that should be considered in
determining appropriate enforcement responses
to noncompliance events are discussed in detail
in EPA's 1989 Guidance for Developing Control
Authority Enforcement Response Plans.
The General Pretreatment Regulations set
as an enforcement priority, facilities that meet
the criteria for "Significant Noncompliance
Is a Control Authority response required for all violations
identified?
Is the IU notified by the Control Authority when a violation is
found?
Is the IU required to respond to each violation with an explanation
and, as appropriate, a plan to correct the violation within a
specified time period?
Where noncompliance continues and/or the IU response is
inadequate, does the Control Authority's response become more
formal and commitments (or schedules, as appropriate) for
compliance established in an enforceable document?
Is the enforcement response selected related to the seriousness of
(SNC)" as defined in 40 CFR §403.8(f)(2)(vii) - ^?,viol!'ion? , ,. ... , OM_ .. . . ,.
^ ' ° w\/\/q. Where the violation constitutes SNC, and is ongoing, is the
minimum response an administrative order?
and depicted in Figure 27. A decision to seek
formal enforcement is generally triggered by an
unresolved instance of SNC, failure to achieve Figure 26. How Complete is Your ERG?
compliance in a specified time period through
less formal means, or the advice of legal
counsel. SNC evaluations are to be conducted in six-month increments; names of IDs found to be in SNC must
be published in the local newspaper (see Public Participation in this Chapter).
Formal enforcement must be supported by well-documented records of the violations and of any prior efforts
by the Control Authority to obtain compliance. Where effluent limitations have been exceeded, records must
be reviewed to verify compliance with 40 CFR Part 136 test methods. If the IU has received conflicting
information from the Control Authority regarding its compliance status, its status must be clarified in writing.
Although not required, the Control Authority may consider a "show cause" meeting with the IU before
commencing formal enforcement action. Similarly, the regulations do allow, in certain instances, an affirmative
defense for violations.
The range of enforcement mechanisms available to a Control Authority depends on the specific legal
authorities it has been given by city, county, and State legislatures. These mechanisms may range from a
simple telephone call to suits seeking significant criminal penalties. Common enforcement mechanisms include:
Chapter 4 -29-
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POTW Pretreatment Program Responsibilities
Introduction to the National Pretreatment Program
Informal notice to ID - This may consist of
a telephone call or "reminder" letter to an
appropriate ID official to notify them of a
minor violation and to seek an explanation.
Such informal notice may be used to
correct minor instances of noncompliance.
Informal meetings - Used to obtain an
ILJ's commitment to comply with their
pretreatment obligations or to inform the ID
of stronger enforcement mechanisms
available for unresolved and/or continued
noncompliance.
Warning letter or Notice of Violation
(NOV) - Written notice to the IU in
response to a violation of pretreatment
standards or requirements. These notices
should request an explanation of the
noncompliance and measures that will be
taken to eliminate future violations.
Administrative orders and compliance
schedules - These require an ID to "show
cause" to the Control Authority as to why
formal enforcement action should not be
taken and/or sewer service discontinued, or
actions that will be taken to comply with
pretreatment standards or requirements.
Orders as such may be negotiated (i.e.,
Consent Order) or issued at the reasonable
discretion of the Control Authority (i.e.,
Compliance Order). For more egregious or
serious violations, the Control Authority
may issue a Cease and Desist Order.
Administrative fines - Assessed by
Control Authorities against IDs for violations
and intended to recapture partial or full
economic benefit for the noncompliance
and to deter future violations.
Civil suits - Formal process of filing
lawsuits against IDs to correct violations
and to obtain penalties for violations. Civil
penalty amounts are generally limited
through State or municipal laws. However, 40 CFR §403.8(f)(1)(vi) requires that Control Authorities have
the legal authority to seek or assess civil or criminal penalties of at least $1,000 per day for each violation.
A civil suit for injunctive relief may be used when the ID is unlikely to successfully execute the steps that
the Control Authority believes are necessary to achieve or maintain compliance, when the violation is
serious enough to warrant court action to deter future similar violations, or when the danger presented by
an ILJ's lengthy negotiation of a settlement is intolerable.
NOTE: Surcharges are not penalties or fines. Surcharges are intended to recoup the cost of treatment
of wastes by the POTW and must not be used to allow discharges of toxic pollutants that cause
interference or pass through.
An IU is in SNC if its violation meets one or more of
the following criteria (40 CFR 403.8(f)(2)(vii):
(A) Chronic violations of wastewater discharge limits, defined
here as those in which sixty-six percent or more of all of the
measurements taken during a six-month period exceed (by any
magnitude) the daily maximum limit or the average limit for the
same pollutant parameter;
(B) Technical Review Criteria (TRC) violations, defined here as
those in which thirty-three percent or more of all of the
measurements for each pollutant parameter taken during a six-
month period equal or exceed the product of the daily maximum or
the average limit multiplied by the applicable TRC (TRC = 1.4 for
BOD5, TSS, fats, oil, and grease, and 1.2 for all other pollutants
except pH);
(C) Any other violation of a pretreatment effluent limit (daily
maximum or longer-term average) that the Control Authority
determines has caused, alone or in combination with other
discharges, interference or pass through (including endangering the
health of POTW personnel or the general public);
(D) Any discharge of a pollutant that has caused imminent
endangerment to human health, welfare or to the environment or
has resulted in the POTW's exercise of its emergency authority
under 40 CFR § 403.8(i)(l)(vi)(B) of this section to halt or prevent
such a discharge;
(E) Failure to meet, within 90 days after the schedule date, a
compliance schedule milestone contained in a local control
mechanism or enforcement order for starting construction,
completing construction, or attaining final compliance;
(F) Failure to provide, within 30 days after the due date, required
reports such as baseline monitoring reports, 90-day compliance
reports, periodic self-monitoring reports, and reports on
compliance with compliance schedules;
(G) Failure to accurately report noncompliance;
(H) Any other violation or group of violations which the Control
Authority determines will adversely affect the operation or
implementation of the local pretreatment program.
Figure 27. Definition of Significant Noncompliance (SNC)
Chapter 4
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Introduction to the National Pretreatment Program
POTW Pretreatment Program Responsibilities
- Criminal prosecution - This type of enforcement is a formal judicial process where sufficient admissible
evidence exists to prove beyond a reasonable doubt that a person has willfully or negligently violated
pretreatment standards or that a person has knowingly made a false statement regarding any report,
application, record, or otherdocument required by the General Pretreatment Regulations. As noted above,
Control Authorities must have the legal authority to seek or assess civil or criminal penalties of at least
$1,000 per day for each violation. Examples of criminal violations include falsification of data and
tampering with sampling results or equipment.
- Termination of service (revocation of permit) - These actions may be pursued by Control Authorities to
immediately halt an actual or threatened discharge to the POTW that may represent an endangermentto
the public health, the environment, or the POTW. Use of these remedies may also be used in bringing
recalcitrant users into compliance.
Regardless of the response taken, the Control Authority should document and track all contact, notices, and
meetings with IDs and ID responses. Control Authority responses and ID responses (or lack thereof) should be
documented and include a record of any direct contact with the ID to attempt to resolve the noncompliance.
Control Authorities must take timely and effective enforcement against violators. Unresolved ID noncompliance
may result in the Approval Authority enforcing directly against the ID and/or the Control Authority. EPA may
also take enforcement action where it deems action by the State or the Control Authority is inappropriate. An
Approval Authority will routinely review the overall performance of a Control Authority in monitoring IDs,
identifying violations, and in enforcing regulations. Performance will be evaluated based on POTW self-
monitoring data, written enforcement response plans, audits, inspections, and pretreatment program reports.
Therefore, it is essential for Control Authorities to effectively manage program information to demonstrate
proper implementation.
Section 505 of the CWA allows citizens to file suit against a Control Authority that has failed to implement
its approved pretreatment program as required by its NPDES permit. The Control Authority may be fined as
well as required to enforce against violations of pretreatment standards and requirements in a court order.
DATA MANAGEMENT AND RECORD KEEPING
Any ID subject to pretreatment program reporting requirements is required to maintain records resulting from
monitoring in a readily accessible manner for a minimum of 3 years (longer if during periods of any ongoing
litigation). While the means for maintaining files is usually at the discretion of the POTW, all pretreatment
activities should be documented and the documents maintained. Types of ID records that the Control Authority
should maintain are summarized in Figure 28.
Tracking due dates, submissions, deficiencies,
notifications, etc. and calculating effluent limitation
noncompliance may be facilitated by a computerized data
management system. Similarly, many Control Authorities
use standardized forms (e.g., inspection questionnaires,
chains-of-custody, field measurement records) and
procedures (e.g..sampling, periodic compliance report
reviews) to promote consistency and organization of
program data.
In addition to specific ID records, Control
Authorities should also maintain general program files
that document specific program development and
implementation activities that are not ID-specific (see
Figure 29). All information should be filed in an orderly
manner and be readily accessible for inspection and
copying by EPA and State representatives or the
public. The pretreatment regulations specify that all
information submitted to the Control Authority or State
must be available to the public without restriction,
except for confidential business information.
Industrial waste questionnaire
Permit applications, permits and fact sheets
Inspection reports
IU reports
Monitoring data (including laboratory
reports)
Required plans (e.g., slug control, sludge
management, pollution prevention)
.eg
Drograrttlpcwe&pSfldence to and from the IU
Sopy of POTW NPDES pormit(o)
EtgWBraae dypKUpflfeJU Records Retained
ERP
Correspondence to and from EPA/State
Annual reports to the Approval Authority
Public notices
Funding and resource changes
Applicable Federal and State regulations
IU compliance and permitting records
Figure 29. Types of POTW Records Retained
Chapter 4
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POTW Pretreatment Program Responsibilities
Introduction to the National Pretreatment Program
PUBLIC PARTICIPATION AND POTW REPORTING
Section 101 (e) of the CWA establishes public participation as one of its goals, in the development, revision,
and enforcement of any regulation, standard, effluent limitation, plan, or program established by EPA or any
State. The General Pretreatment Regulations encourage public participation by requiring public notices and/or
hearings for program approval, removal credits, program modifications, local limits development and
modifications, and IDs in SNC.
POTW pretreatment program approval requests
require the Approval Authority to publish a notice
(including a notice for a public hearing) in a newspaper
of general circulation within the jurisdiction served by
the POTW. All comments regarding the request as
well as any request for a public hearing must be filed
with the Approval Authority within the specified
comment period, which generally last 30 days. The
Approval Authority is required to account for all
comments received when deciding to approve or deny
the submission. The decision is then provided to the
POTW and other interested parties, published in the
newspaperwith all comments received available to the
public for inspection and copying.
Once a local pretreatment program is approved,
the Control Authority must implement that program as
approved. Before there is a significant change in the
operation of a POTW pretreatment program, a program
modification must be initiated.
For substantial program modifications (see Figure
30), the Control Authority is required to notify the
Approval Authority of the desire to modify its program
and the basis for the change. These changes become
effective upon approval. Approval Authorities (or
POTWs) are required to public notice the request for a
modification, but are not required to public notice the
decision if no comments are received and the request
is approved without changes.
6.
7.
Modifications that relax POTW legal authorities (as
described in 40 CFR §403.8(f)(l)), except for
modifications that directly reflect a revision to 40
CFR Part 403, and are reported pursuant to 40 CFR
§403.18(d) - Approval procedures for nonsubstantial
modifications;
Modifications that relax local limits, except for
modifications to local limits for pH and reallocations
of the Maximum Allowable Industrial Loading of a
pollutant that do not increase the total industrial
loadings for a pollutant, which are reported pursuant
to 40 CFR §403.18(d) - Approval procedures for
nonsubstantial modifications;
Changes to POTWs control mechanism, as
described in 40 CFR §403.(f)(l)(iii);
A decrease in the frequency of self-monitoring or
reporting required of industrial users;
A decrease in the frequency of industrial user
inspections or sampling by the POTW;
Changes to the POTWs confidentiality procedures;
and
Other modifications designated as substantial
modifications by the Approval Authority on the basis
that the modification could have a significant impact
on the operation of the POTWs Pretreatment
Program; could result in an increase in pollutant
loadings at the POTW; or could result in less
stringent requirements being imposed on Industrial
users of the POTW.
Figure 30. Substantial Modifications of POTW
Pretreatment Programs (40 CFR §403.18)
Nonsubstantial modifications must also be
submitted to the Approval Authority for review and
approval, but these changes do not require public notice. And unlike substantial modifications, nonsubstantial
modifications become effective 45 days after submission unless the Approval Authority notifies the POTW
otherwise.
The POTW is also required to provide annual publication, in the largest daily newspaper in the municipality
in which the POTW is located, of IDs that at any time during the previous twelve months were in SNC.
In accordance with 40 CFR §403.12(1), Control Authorities are required to submit annual reports to the
Approval Authority documenting program status and activities performed during the previous calendar year.
At a minimum, these reports must contain the following information:
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Chapter 4
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Introduction to the National Pretreatment Program POTW Pretreatment Program Responsibilities
1. List of all POTWs IDs including names, addresses, pretreatment standards applicable to each user,
IDs subject to categorical pretreatment standards or a brief explanation of deletions and a list of
additions (with the aforementioned information) keyed to a previously submitted list;
2. A summary of the status of the ID compliance during the reporting period;
3. A summary of compliance and enforcement activities (including inspections) conducted by the
POTW during the reporting period;
4. A summary of changes to the POTWs pretreatment program that have not been previously
reported to the Approval Authority; and
5. Any other relevant information requested by the Approval Authority.
The first report is due within one year after program approval and at least annually thereafter. Approval
Authorities may require additional information, or require that the reports be submitted in a specific format
and/or at an increased frequency (e.g., semi-annually).
Chapter 4 -33-
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Introduction to the National Pretreatment Program
Industrial User Pretreatment Program Responsibilities
5. INDUSTRIAL USER PRETREATMENT
PROGRAM RESPONSIBILITIES
Chapters. Applicable EPA Guidance
Guidance Manual For Implementing Total Toxic Organics (TTO)
Pretreatment Standards
Guidance Manual for the Identification of Hazardous Wastes Delivered
to Publicly Owned Treatment Works by Truck, Rail, or Dedicated
Pipe
Guidance Manual for the Use of Production-Based Pretreatment
Standards and the Combined Wastestream Formula
Industrial User Inspection and Sampling Manual for POTWs
RCRA Information on Hazardous Wastes for Publicly Owned Treatment
Works
Industry-Specific Guides
Aluminum, Copper, And Nonferrous Metals Forming And Metal Powders
Pretreatment Standards: A Guidance Manual
Guidance Manual For Battery Manufacturing Pretreatment Standards
Guidance Manual for Electroplating and Metal Finishing Pretreatment
Standard
Guidance Manual For Iron And Steel Manufacturing Pretreatment
Standards
Guidance Manual for Leather Tanning and Finishing Pretreatment
Standards
Guidance Manual for Pulp, Paper, and Paperboard and Builders' Paper
and Board Mills Pretreatment Standards
Industrial Users (IDs) are required to
comply with all applicable pretreatment
standards and requirements.
Demonstration of compliance requires
certain IDs to submit reports, self-
monitor, and maintain records. A
summary of the reporting requirements
are provided in Figure 32, with details of
each of these requirements discussed
below.
REPORTING REQUIREMENTS
Minimum Federal Pretreatment
Program reporting requirements for IDs
are specified in 40 CFR §403.12. Since
Control Authorities are responsible for
communicating applicable standards and
requirements to IDs and for receiving and
analyzing reports, it is essential for
Control Authority personnel to understand
ID reporting and notification requirements
contained in the General Pretreatment
Regulations. These requirements are
summarized below.
Categorical Industrial User (CIU) Reporting Requirements
Baseline Monitoring Report (BMR) [40 CFR §403.12(b)1
Each existing ID that is subject to a categorical pretreatment standard (identified as a Categorical
Industrial User, or CIU) is required to submit a BMR within 180 days after the effective date of the standard.
If a category determination has been requested, the BMR is not due until 180 days after a final administrative
decision has been made concerning the industry's inclusion in the category. The BMR must contain the
following information:
- name and address of the facility and names of the operator and owners
- list of all environmental control permits held by or for the facility
- description of operations, including the average rate of production, applicable Standard Industrial
Classification (SIC) codes, schematic process diagrams, and points of discharge to the POTWfrom
regulated processes
- flow measurements (average daily and maximum daily) for regulated process wastestreams and
nonregulated wastestreams, where necessary
- pollutant measurements [daily maximum, average concentration, and mass (where applicable)]and
applicable standards
- certification, by a qualified professional, reviewed by a representative of the CIU, of whether
applicable pretreatment standards are being met and, if not, a description of the additional operation
and maintenance (O&M) or pretreatment facilities that are needed to comply with the standards
- a schedule by which the IU will provide the additional O&M or pretreatment needed to comply with
the applicable pretreatment standards.
Chapter 5
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Industrial User Pretreatment Program Responsibilities Introduction to the National Pretreatment Program
In addition to the certification noted above, BMRs must be signed and certified as detailed in 40 CFR
§403.12(1) and as described later in this Chapter. If a CIU has already submitted the specific information
required in a permit application or data disclosure form and this information is still current, it need not be
reproduced and resubmitted in the BMR. The BMR is a one-time report, unless changed Federal categorical
standards require submission of a new BMR.
At least 90 days prior to commencement of discharge, new sources are required to submit the above
information, excluding the certification and compliance schedule, and information on the method that the
source intends to use to meet the applicable pretreatment standards.
Compliance Schedule Progress Report [40 CFR §403.12(c)(3)1
A CIU that is not in compliance with applicable categorical standards by the time the standards are
effective often will have to modify process operations and/or install end-of-pipe treatment to comply. Federal
regulations require that the Control Authority develop and impose a compliance schedule for the CIU to
install technology to meet applicable standards. As part of the BMR, a CIU that is unable to comply with
the categorical standards must include a schedule for attaining compliance with the discharge standards.
In no case can the final or completion date in the schedule be later than the final compliance date specified
in the categorical standards. If deemed appropriate, the Control Authority may require compliance earlier
than the final compliance date specified in the Federal regulations.
Compliance schedules are to contain increments of progress in the form of dates (not to exceed nine
months per event) for commencement and completion of major actions leading to construction and operation
of a pretreatment system and/or in-plant process modifications. Major activities could include hiring an
engineer, completing preliminary analysis and evaluation, finalizing plans, executing a contract for major
components, commencing construction, completion of construction, or testing operation.
In addition, the CIU must submit progress reports to the Control Authority no laterthan 14 days following
each date in the compliance schedule (and final date for compliance), that include:
- a statement of the ClU's status with respect to the compliance schedule
- a statement of when the CIU expects to be back on schedule if it is falling behind, and the reason
for the delay and steps being taken by the IU to return to the established schedule.
The Control Authority should review these reports as quickly as possible. When a CIU is falling behind
schedule, the Control Authority should maintain close contact with the CIU. If the CIU fails to demonstrate
good faith in meeting the schedule, the Control Authority may consider initiating appropriate enforcement
action to correct the problem(s).
90-Day Compliance Reports [40 CFR §403.12(d)
Section 403.12(d) of the General Pretreatment Regulations requires a CIU to submit a final compliance
report to the Control Authority. An existing source must file a final compliance report within 90 days following
the final compliance date specified in a categorical regulation or within 90 days of the compliance date
specified by the Control Authority, whichever is earlier. A new source must file a compliance report within
90 days from commencement of discharge to the POTW. These reports must contain:
- flow measurements (average daily and maximum daily) for regulated process wastestreams and
nonregulated wastestreams, where necessary
- pollutant measurements [daily maximum, average concentration, and mass (where applicable)] and
applicable standards
- certification, by a qualified professional, reviewed by a representative of the CIU, of whether
applicable pretreatment standards are being met and, if not, a description of the additional operation
and maintenance (O&M) or pretreatment facilities that are needed to comply with the standards.
In addition to the certification noted above, 90-day final compliance reports must be signed and
certified as detailed in 40 CFR §403.12(1) and as described later in this Chapter.
Upset Reports [40 CFR §403.161
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Introduction to the National Pretreatment Program Industrial User Pretreatment Program Responsibilities
Upset is defined as an exceptional incident in which there
is unintentional and temporary noncompliance with
categorical standards due to factors beyond the reasonable
control of the CIU. An upset does not include
noncompliance to the extent caused by operational error,
improperly designed or inadequate treatment facilities, lack
of preventative maintenance, or careless or improper
operation.
CILJs are allowed an affirmative defense for
noncompliance with categorical standards if they
can demonstrate that the noncompliance was the
result of an upset (Figure 31). Conditions
necessary to demonstrate an upset has occurred
are detailed in 40 CFR §403.16 and require the CIU
to submit at least an oral report to the Control
Authority within 24 hours of becoming aware of the
upset and containing the following information:
Figure 31. Definition of Upset (40 CFR §403.16)
- a description of the indirect discharge and
the cause of the noncompliance
- the date(s) and times of the noncompliance
- steps being taken and/or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
If this notification is provided orally, a written report must also be submitted within five days. In any
enforcement action, the ID has the burden of proof in establishing that an upset has occurred. EPA is
responsible for determining the technical validity of this claim.
Categorical and Significant Industrial User (SIU) Reporting Requirements
Periodic Compliance Reports [40 CFR §403.12 (e) & (h)1
After the final compliance date, CILJs are required to report, during the months of June and December,
the self-monitoring results of their wastewater discharge(s). The Control Authority must also require
semi-annual reporting from SILJs not subject to categorical standards. EPA established a minimum
frequency of once every six months, determining this to be adequate for small SILJs or other facilities that
have little potential to cause pass-through or interference or to contaminate the sewage sludge. EPA
assumed that larger ILJs and those that have more potential to cause problems would be required by the
Control Authority to sample and report more often. All results for self-monitoring performed must be reported
to the Control Authority, even if the ILJ is monitoring more frequently than required. Periodic compliance
reports must include:
- nature and concentration of pollutants limited by applicable categorical standards or required by the
Control Authority
- flow data (average and maximum daily) as required by the Control Authority
- mass of pollutants discharged (applicable to CILJs where mass limits have been imposed)
- production rates (applicable to CILJs where equivalent limits have been imposed or where limits
imposed are expressed in allowable pollutant discharged per unit of production).
A Control Authority may choose to monitor ILJs in lieu of the ILJ performing the self-monitoring.
Additionally, 40 CFR §403.12(e) and (h) require compliance with 40 CFR Part 136 (Guidelines for
Establishing Test Procedures for the Analysis of Pollutants). To demonstrate compliance with these
requirements, ILJs may have to submit information regarding sample handling and analytical procedures to
the Control Authority. Development of standardized forms for use by ILJs and theirtesting labs can facilitate
documentation and submission of all required information and can streamline the ILJ and Control Authority
review process.
Bypass [40 CFR §403.171
The General Pretreatment Regulations define "bypass" as the intentional diversion of wastestreams from
any portion of a users treatment facility. If a bypass results in noncompliance, even if it was due to essential
maintenance, the ILJ must provide a report to the Control Authority detailing a description of the bypass and
the cause, the duration of the bypass, and the steps being taken and/or planned to reduce, eliminate, and
prevent reoccurrence of the bypass.
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Industrial User Pretreatment Program Responsibilities Introduction to the National Pretreatment Program
Oral notice must be provided to the Control Authority within 24 hours of the detection of an unanticipated
bypass, with a written follow-up due within 5 days. For an anticipated bypass, the ID must submit notice to
the Control Authority, preferably 10 days prior to the intent to bypass.
Notification of Potential Problems [40 CFR §403.12(f)1
All IDs are required to notify the Control Authority immediately of any discharges which may cause
potential problems. These discharges include spills, slug loads, or any other discharge which may cause a
potential problem to the POTW.
Noncompliance Notification [40 CFR §403.12 (g) (2)1
If monitoring performed by an ID indicates noncompliance, the ID is required to notify the Control
Authority within 24 hours of becoming aware of the violation. In addition, the ID must repeat sampling and
analysis and report results of the resampling within 30 days. The repeat sampling is not required if the
Control Authority samples the ID at least once per month or if the Control Authority samples the ID between
the time of the original sample and the time the results of the sampling are received.
Notification of Changed Discharge [40 CFR §403.12(i)1
All IDs are required to promptly notify the Control Authority in advance of any substantial changes in the
volume or character of pollutants in their discharge.
Notification of Discharge of Hazardous Wastes [40 CFR §403.12(p)1
IDs discharging more than 15 kilograms per month of a waste, which if otherwise disposed of, would be
a hazardous waste pursuant to the RCRA requirements under 40 CFR Part 261 are required to provide a one
time written notification of such discharge to the Control Authority, State, and EPA. IDs discharging any
amount of waste, which if disposed of otherwise, would be an acutely hazardous waste pursuant to RCRA
must also provide this notification. This written notification must contain the EPA hazardous waste number
and the type of discharge (i.e., batch, continuous). If the ID discharges more than 100 kilograms per month
of the hazardous waste, the written notification must also include:
- an identification of the hazardous constituent in the ILJ's discharge,
- an estimate of the mass and concentration of the constituents in the ILJ's discharge, and
- an estimate of the mass and concentration of constituents in the ILJ's discharge in a year.
ILJs must also provide a certification accompanying this notification that a waste reduction program is in
place to reduce the volume and toxicity of hazardous wastes to the greatest degree economically practical.
Within 90 days of the effective date of the listing of any additional hazardous wastes pursuant to RCRA, ILJs
must provide a notification of the discharge of such wastes.
Signatory and Certification Requirements [40 CFR §403.12(1)1
Pursuant to 40 CFR §403.12(1), BMRs, 90-day compliance reports and periodic compliance reports from
CILJs must be signed by an authorized representative of the facility and contain a certification statement
attesting to the integrity of the information reported. The reports should be signed by one of the following:
- a responsible corporate officer if the ILJ is a corporation
- a general partner or proprietor if the ILJ is a partnership or sole proprietorship
- a duly authorized representative of the above specified persons if such authorization is in writing,
submitted to the Control Authority and specifies a person or position having overall responsibility for
the facility where the discharge originates or having overall responsibility of environmental matters
for the facility.
As required in 40 CFR §403.6(a)(2)(ii), the certification statement must read as follows:
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Introduction to the National Pretreatment Program Industrial User Pretreatment Program Responsibilities
"I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
I am aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations."
While Federal regulations only require Control Authorities to require these signatures and certifications from
CILJs, many POTWs have found it important to impose these requirements for all ID reports. To facilitate
compliance, many Control Authorities have developed forms that include the certification statement and
signatory requirements for use by all IDs.
SELF-MONITORING REQUIREMENTS
All SILJs, including CILJs must conduct self-monitoring as part of several different reporting requirements
as noted above. For CILJs, this includes the BMR, 90-day compliance report and periodic compliance reports
(40 CFR §§403.12(b),(d), and (e), respectively). Non-categorical SILJs are required to self-monitor as part
of the periodic reporting requirements (40 CFR §403.12(h)). As noted in 40 CFR §§403.12(g)(4), sample
collection and analysis for all required pretreatment program reports must be conducted using 40 CFR Part
136 procedures and amendments thereto. Refer to Chapter 4 of this manual and EPA's 1994 Industrial User
Inspection and Sampling Manual for POTWs for additional information on sample collection and analysis
procedures.
Based on the specific pollutants regulated by categorical standards, different types of samples may have
to be collected. For BMR and 90-day compliance reports, a minimum of four grab samples must be
collected for pH, cyanide, total phenols, oil and grease, sulfide, and volatile organics. If these pollutants are
not regulated by the specific categorical standard, monitoring is not required. Twenty-four hour flow-
proportional composite samples must be collected for all other pollutants. The Control Authority may waive
flow-proportional composite sampling if an ILJ demonstrates that flow-proportional is not feasible. In these
cases, time-proportional composite samples may be collected.
Self-monitoring for periodic compliance reports must be conducted in accordance with the ILJ's discharge
permit requirements. The Control Authority must ensure that these permits specify sampling location(s),
required sampling frequencies, sample types to be collected, sampling and analytical procedures (40 CFR
Part 136), and associated reporting requirements. At a minimum, CILJs must monitor for all categorically
regulated pollutants at least once every six months, although, permits issued by the local Control Authority
may require more frequent monitoring.
In certain instances, CILJs subject to TTO standards may implement alternatives in lieu of monitoring
all regulated toxic organic compounds. A listing of categories that contain TTO standards is provided in
Chapters. For example, the electroplating and metal finishing standards allow ILJsto monitor only forthose
toxic organic compounds that are reasonably expected to be present. Additional TTO guidance related to
the electroplating and metal finishing categories can be found in EPA's 1984 Guidance Manual for
Electroplating and Metal Finishing Pretreatment Standards.
For certain industries (i.e., electroplating, metal finishing, and electrical and electronic components)
Control Authorities have the option of allowing the CIU to prepare and implement a Toxic Organic
Management Plan (TOMP) in lieu of periodic monitoring. In those instances, the TOMP should identify all
potential sources from which toxic organic materials could enter the wastestream and propose control
measures to eliminate the possibility. Where a TOMP is allowed, an ILJ can demonstrate compliance through
adherence to the TOMP and submission of periodic certification statements attesting to the fact that:
"no dumping of concentrated toxic organic pollutants has occurred and that the facility's
TOMP is being implemented."
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Industrial User Pretreatment Program Responsibilities Introduction to the National Pretreatment Program
TOMPs cannot be used in lieu of monitoring for BMRs and 90-day compliance reporting requirements.
The categorical standards forsome industries (i.e., aluminum forming, copperforming, coil coating, and
metal molding and casting) allow IDs to monitor oil and grease (O&G) as an alternative to TTO monitoring.
This option may be used to fulfill TTO monitoring requirements of the BMR, 90-day compliance report, and
periodic compliance reports and allows the ID to determine whether it wants to demonstrate compliance with
the TTO orthe O&G standards. A detailed description of TTO monitoring requirements is provided in EPA's
1985 Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreatment Standards.
RECORD KEEPING REQUIREMENTS
IDs are required to maintain records of their monitoring activities [40CFR§403.12(o)]. Information, at
a minimum, shall include the following:
- sampling methods, dates and times
- identity of the person(s) collecting the samples and of the sampling location(s)
- the dates the analyses were performed and the methods used
- the identity of the person(s) performing the analyses and the results of the analyses.
These records shall be retained for at least 3 years, or longer in cases where there is pending litigation
involving the Control Authority or ID, or when requested by the Approval Authority. These records must be
available to the Control Authority and Approval Authority for review and copying. Historically, most Control
Authorities do not dispose of any records, rather older records are archived at an off-site location.
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Introduction to the National Pretreatment Program
Industrial User Pretreatment Program Responsibilities
Figure 32. Industrial User Reporting Requirements
REQUIRED REPORT AND
CITATION
Baseline Monitoring Report
(BMR)
40CFR§403.12(b)(l-7)
Compliance Schedule Progress
Reports
40 CFR §403. 1 2(c) (1 -3)
90-Day Compliance Report
40CFR§403.12(d)
Periodic Compliance Report
40 CFR §403.1 2 '(e)
Notice of Potential Problems
40CFR§403.12(f)
Noncompliance Notification
40 CFR § 403.1 2(g)(2)
Periodic Compliance Reports
for Noncategorical Users
40CFR§403.12(h)
Notification of Changed
Discharge
40CFR§403.12(j)
Notification of Hazardous
Wastes Discharge
40CFR§403.12(p)
Upset
40 CFR §403. 16
Bypass
40 CFR §403. 17
APPLY
TO
CIUs
All lUs
CIUs
CIUs
All lUs
All lUs
Non-Cat.
SIUs
All lUs
All lUs
CIUs
All lUs
REPORT DUE DATE
Existing Source - Within 180 days of
effective date of the regulation or an
administrative decision on category
determination.
New Source - At least 90 days prior to
commencement of discharge.
Within 14 days of each milestone date on
the compliance schedule; at least every 9
months.
Within 90 days of the date for final
compliance with applicable categorical
pretreatment standard; for new sources, the
compliance report is due within 90 days
following commencement of wastewater
discharge to the POTW.
Every June and December after the final
compliance date (or after commencement
of a discharge for new sources) unless
frequency is increased by the Control
Authority.
Notification of POTW immediately after
occurrence of slug load, or any other
discharge that may cause problems to the
POTW.
Notification of POTW within 24 hours of
becoming aware of violation.
Every six months on dates specified by the
Control Authority.
In advance of any substantial changes in
the volume or character of pollutants in the
discharge.
For new discharges, within 1 80 days after
commencement of discharge.
24 hours of becoming aware of the upset
(5 days where notification was provided
orally)
10 days prior to date of the bypass or oral
notice within 24 hours of the IU becoming
aware of the bypass with written
notification within 5 day
PURPOSE OF REPORT
- To provide baseline information on
industrial facility to Control Authority
- To determine wastewater discharge
sampling points
- To determine compliance status with
categorical pretreatment standards
- To track progress of the industrial
facility through the duration of a
compliance schedule.
- To notify Control Authority as to
whether compliance with the applicable
categorical pretreatment standards has
been achieved
- If facility is noncompliant, to specify
how compliance will be achieved.
- To provide the Control Authority with
current information on the discharge of
pollutants to the POTW from
categorical industries.
- To alert the POTW to the potential
hazards of the discharge.
- To alert the POTW of a known
violation and potential problems which
may occur.
- To provide the POTW with current
information on the discharge of
pollutants to the POTW from industrial
users not regulated by categorical
standards.
- To notify POTW of anticipated changes
in wastewater characteristics and flow
which may affect the POTW.
- To notify POTW, EPA, and State of
discharges of hazardous wastes under
40 CFR Part 261.
- To notify the POTW of unintentional
and temporary noncompliance with
categorical standards.
- To notify the POTW of noncompliance
and potential problems which may
occur
Chapter 5
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Introduction to the National Pretreatment Program
Hauled Wastes
6. HAULED WASTES
Chapter 6. Applicable EPA Guidance
CERCLA Site Discharges to POTWs Guidance Manual
Guidance Manual for the Identification of Hazardous Wastes
Delivered to Publicly Owned Treatment Works by
Truck, Rail, or Dedicated Pipe
Industrial User Inspection and Sampling Manual for POTWs
Industrial User Permitting Guidance Manual
RCRA Information on Hazardous Wastes to Publicly Owned
Treatment Works
Guidance Manual for the Control of Waste Hauled to
Publicly Owned Treatment Works
In addition to receiving wastes through the
collection system, many POTWs accept trucked
wastes, and in a few instances, wastes received
via train. As specified in 40 CFR §403.1(b)(1),
pollutants from non-domestic sources which are
transported to the POTW by truck or rail are also
subject to the General Pretreatment Regulations.
Hauled wastes, like wastes received through the
collection system, have the potential to impact the
POTW, making regulatory control of these wastes
necessary. Recent studies have shown an
increasing frequency of uncontrolled discharges to
POTWs from waste haulers. Because of their
unique nature, waste haulers are not regulated in the same way as other types of IDs. Since no specific
Federal regulatory controls exist, some POTWs have developed hauled waste control programs. For more
information on hauled waste, refer to EPA's 1998 Guidance Manual for the Control of Waste Hauled to
Publicly Owned Treatment Works.
NATURE OF HAULED WASTES
Wastes are hauled to POTWs for several reasons. By far, the majority of hauled waste is domestic
septage (Figure 33). Since these wastes are domestic in nature, treatment at a POTW is the most
appropriate disposal method. Other types of wastes are also regularly hauled to POTWs for a variety of
reasons, such as:
the facility is located outside the
jurisdictional boundaries of the POTW (e.g.,
located in rural areas) and is not connected
to the collection system,
the wastes may be known to cause
collection system problems, but can be
treated at the POTW (e.g., grease trap
cleanout wastes),
Domestic septage is defined as either the liquid or solid
material removed from a septic tank, cesspool, portable
toilet, Type III marine sanitation device, or similar
treatment works that holds only domestic sewage.
Domestic septage does not include liquid or solid material
removed from these systems that receives either
commercial wastewater or industrial wastewater and does
not include grease removed from a restaurant grease trap.
[40 CFR Part 503.9(f)]
Figure 33. Definition of Domestic Septage
- the facility is connected to the sewer but
does not have the capacity to discharge the volume of waste generated (e.g., groundwater
remediation activities at an IU),
- a POTW rejects acceptance of a waste from an IU forcing the IU to haul the waste to a different
POTW that agrees to accept the waste.
Common to all these wastes is the fact that the POTW does not know for certain the nature and
concentration of these wastes, as hauled, without implementing some type of control or surveillance
program.
CONTROL PROGRAMS
Section 403.5(b)(8) of the General Pretreatment Regulations specifically prohibits the introduction of any
trucked or hauled pollutants to the POTW, except at discharge points designated by the POTW. This is the
Chapter 6
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Hauled Wastes Introduction to the National Pretreatment Program
only pretreatment requirement specifically addressing hauled wastes. However, many POTWs have
determined that additional controls are necessary to further limit these discharges and to prevent adverse
impacts from these discharges. These control programs include practices such as permitting, sampling,
manifesting, surveillance, and other forms of hauler documentation. In many instances, these control
programs have shifted the hauling of waste from one POTWto other POTWs that are not implementing such
a program. Most often, it is the smaller POTWs that do not have hauler control programs, including many
POTWs that are not even required to implement Pretreatment Programs. The effect of this change from
larger to smaller POTWs and from more to less control is that there has been an increase in negative
impacts to POTWs and receiving streams. Two apparent options for addressing this concern are for: (1)the
smaller and non-pretreatment POTWs to initiate waste hauler control programs; or (2) the larger POTWs
to institute sound control programs that will adequately regulate these wastes yet not drive these haulers to
search for other less sound disposal alternatives. POTWwaste hauler control programs should address the
following six elements:
Impact to POTW - Prior to acceptance of a new waste from a hauler, the POTW needs to evaluate the
potential impacts to the POTW from this waste. POTWs may require haulers or generators of hauled waste
to perform a treatability study to demonstrate the effectiveness of treatment on this waste. POTWs must
evaluate the impacts of these waste when evaluating the adequacy of local limits as well as when developing
or revising local limits.
Permitting - A permit is the most direct and efficient method of regulating waste haulers. Permits
provide the opportunity to monitor and regulate haulers based on the nature of the hauled waste and the
potential impacts of that waste on the POTW. Unique permit conditions may include: right of refusal, daily
flow limitations, discharge time limitations, and manifesting requirements.
Discharge Point - As specified in the General Pretreatment Regulations, hauled waste can only be
discharged at points designated by the POTW. This option is to provide the POTWwith the ability to control
and observe these discharges at specified locations thereby minimizing the potential for adverse impacts.
Monitoring - The POTWshould institute a monitoring program to evaluate the nature and concentration
of discharges. Both POTW monitoring and hauler self-monitoring may be appropriate. Many POTWs
require that all loads of hauled waste must be sampled, but analyses are only performed on a predetermined
percentage of these wastes or when problems occur. Unanalyzed samples are refrigerated and kept for
several weeks or months until the POTW is certain that the waste has not impacted the POTW. The
frequency of sampling may also be dependent on the variability of the waste. Each load from a haulerthat
delivers highly variable loads may have to be sampled and analyzed; whereas, a much smaller percentage
may be appropriate for more consistent waste types. As noted earlier, all Federal, State, and local discharge
limitations apply to these wastes. The POTW may also consider inspecting the waste generators to confirm
the source of these wastes.
Hauler Documentation - The POTWshould require waste haulers to document the source of wastes
being discharged, potentially including manifests. Manifests should include general hauler information,
information on the waste generator (e.g., name, address, and phone number), the type of wastes collected,
volumes, known or suspected pollutants, and certification that the load is not a hazardous waste. A useful
technique is to contact the waste generators to verify the information on the manifest.
Legal Authority - If not already in place, the POTWs local ordinance (and approved pretreatment
program) should be modified to add language specifying all of the controls that are applicable to waste
haulers. This will ensure that waste haulers and POTW personnel will know the procedures, expectations,
liabilities, etc. associated with the control program.
In addition to the specific controls described above, POTWs should implement procedures to identify
and eliminate illegal discharges. Procedures may include periodic sewer line sampling, surveillance of
suspected illegal discharge points, education of industries regarding hauled waste, increased enforcement,
and public awareness of illegal dumping.
Chapter 6
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Introduction to the National Pretreatment Program Hauled Wastes
CONCERNS
Every hauled waste discharge has the potential to impact the POTW. Unlike discharges from IDs
connected to the POTW, the makeup of a load of hauled waste is virtually unknown without some type of
monitoring, be it visual or analytical. Even loads of domestic septage can cause problems at a POTW. The
majority of waste haulers are reputable business people who provide a valuable service to the public and
industry; however, the unique attributes of hauled waste can be devastating when unethical haulers dump
incompatible wastes at POTWs. Domestic septage can be partially digested, higher in metals concentrations
than normal domestic wastes, or contain small amounts of household contaminants (e.g., cleaners).
Similarly, disinfectants used in portable toilets have the potential to impact POTW operations.
Receipt of hauled hazardous waste (as defined in the Resource Conservation and Recovery Act (RCRA))
may not only impact POTW operations, but subject the POTW to additional reporting requirements. The
Domestic Sewage Exclusion, specified in 40 CFR §261.4(a)(1)(ii), provides that hazardous wastes mixed
with domestic sewage are exempt from the RCRA waste regulations. However, hazardous wastes received
by truck or rail (or dedicated pipe) are not exempt from the regulations. POTWs that accept hazardous
wastes from these sources are granted "permit by rule" status under RCRA (40 CFR §270.60(c)) provided
that certain requirements are met. The two most significant conditions are that the POTW must be in
compliance with all of its NPDES permit requirements and the waste must comply with all Federal, State,
and local pretreatment requirements. Nationwide, very few POTWs are knowingly accepting hauled
hazardous waste.
POTWs should be aware that hauled process wastes from facilities subject to Federal categorical
pretreatment standards are still subject to those standards. This condition highlights the need for POTWs
to have a clear understanding of the source of the waste since applicable standards may be based on the
origin of that waste.
Another potential problematic waste is that from remedial site clean-up operations. Groundwater
contaminated with gasoline or diesel fuel is by far the most common type of waste from these operations.
While these wastes may contain flammable and toxic compounds (e.g., benzene and toluene), another
concern is that large volumes of this waste at a small POTW may actually "flush" the treatment plant,
thereby interfering with treatment operations. Similar concerns also exist for landfill leachate, another
commonly hauled wastestream. Remedial wastes may also come from Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) sites, also known as Superfund sites. ForCERCLA
guidance, refer to EPA's 1990 CERCLA Site Discharges to POTWs Guidance Manual.
Other concerns for POTWs that accept hauled wastes include:
- Illegal dischargers may be discharging toxic pollutants that can pass through or interfere with the
POTW ope rations;
- Grease trap wastes can coat and inhibit POTW treatment operations;
- Local limits may not account for pollutants in hauled wastes;
- Hauled wastes may contain pollutants for which local limits do not exist; thus, the impacts of this
waste are not readily identifiable;
- Hauled wastes may be unmixed and/or highly concentrated.
For further information on the acceptance of hazardous waste at POTWs, refer to the Guidance Manual for
the Identification of Hazardous Wastes Delivered to Publicly Owned Treatment Works by Truck, Rail, or
Dedicated Pipe.
Chapter 6 -45-
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Introduction to the National Pretreatment Program Pollution Prevention
7. POLLUTION PREVENTION
Chapter 7. Applicable EPA Guidance
Guides to Pollution Prevention: Municipal Pretreatment Program
NPDES Compliance Inspection Manual
As the nation's environmental laws and
regulations have developed over the past
three decades, a new paradigm has shifted
the approach to waste management. Initially,
EPA focused on managing the pollution
generated through treatment and disposal in
an environmentally safe manner. However, we have learned that conventional treatment and disposal can
transfer pollutants from one medium to another with no net reduction.10 In striving to meet new and often
more stringent environmental laws, industries have found ways to reduce or prevent pollution at the source.
Recognizing that source reduction is more desirable than treatment and disposal, EPA now emphasizes
preventing or eliminating the generation of waste. The Pollution Prevention Act of 1990 (PPA) established
pollution prevention (referred to as "P2") as a national objective.
Pollution prevention is indirectly defined in the PPA as source reduction. Source reduction is any
practice that reduces or eliminates the creation of pollutants. Thus, the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or otherwise released into the environment (including
fugitive emissions) is reduced priorto recycling, treatment, or disposal. Source reduction can be achieved
through equipment or technology modifications, process or procedural modifications, reformulation or
redesign of products, substitution of raw materials, or improvements in housekeeping, maintenance, training,
or inventory control.
The PPA established a pollution prevention hierarchy as national policy, declaring that:
- Pollution should be prevented or reduced at the source.
- Pollution that cannot be prevented should be recycled in an environmentally safe manner.
- Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner.
- Disposal or other release into the environment should be employed only as a last resort and should
be conducted in an environmentally safe manner.
Thus, under the Pollution Prevention Act, recycling, energy recovery, treatment, and disposal are not
included within the definition of pollution prevention. However, some practices commonly described as "in-
process recycling" may qualify as pollution prevention. Although recycling is not pollution prevention, as
indicated in the hierarchy, it is the next desirable practice where pollution cannot be prevented or reduced.
Recycling conducted in an environmentally sound manner shares many of the advantages of prevention for
it can reduce the need for treatment or disposal and conserve energy and resources.
EPA's Office of Pollution Prevention and Toxic Substances (OPPTS) developed a pollution prevention
strategy for incorporating pollution prevention concepts into EPA's ongoing environmental protection efforts.
The specific objectives of the strategy are to provide guidance and direction for efforts to incorporate
pollution prevention within EPA's existing regulatory and nonregulatory programs, and to set forth an
initiative to achieve specific objectives in pollution prevention within a reasonable time frame. EPA's
numerous activities include the following:
10 For example, a wet scrubber is used to remove most of the metal emissions to the air. The
metals are captured in the scrubber water. This water must be treated to remove the metals
prior to discharge. The treatment process produces a sludge that contains most of the metals
that were once in the water. The sludge is disposed in a landfill. The metals have been
dispersed to the air, water, and land.
Chapter 7 -47-
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Pollution Prevention Introduction to the National Pretreatment Program
- Coordinating development of regulations that will help identify the potential for multi-media
prevention strategies and that reduce end of pipe compliance costs
- Examining the use of pollution prevention in enforcement actions and negotiations
- Investigating the feasibility of overcoming identified regulatory barriers to encourage cost
effective(source reduction) strategies
- Working with State and local governments and trade associations to promote pollution prevention
among small and medium size business that often lack the capital to make changes
- Investing in outside programs, usually States, by providing grant funds for the reduction of target
chemicals, the agricultural and transportation industry, etc.
- Providing scientific and technical knowledge necessary to implement pollution prevention initiatives
on a cross media basis, pursuant to the Pollution Prevention Research Strategic Plan.
POLLUTION PREVENTION AND THE PRETREATMENT PROGRAM
Although pollution prevention is not a required element of the National Pretreatment Program, source
reduction is not new to the Program. The Pretreatment Program is designed to prevent toxic pollutants from
being discharged to POTWs through controls on the sources that discharge these pollutants. Thus, pollution
prevention may be considered an extension of current pretreatment program implementation activities. For
example, Pretreatment Programs have the authority to require and enforce waste management practices
in order to meet NPDES permit requirements and eliminate interference with treatment facilities. Requiring
slug control plans and developing compliance schedules for improved operation and maintenance (O&M
procedures are examples of pollution prevention activities that have long been required by many Control
Authorities. Other pretreatment program implementation tools available to make pollution prevention a more
integral part of a pretreatment program include:
- Inspections - Pretreatment personnel are usually quite familiar with processes performed at their
local industrial facilities and have exposure to a variety of industries performing the same or similar
processes; therefore, they can easily disseminate (nonconfidential) information about actual pollution
prevention measures implemented as well as identify new P2 opportunities.
- Permits - Where local regulations allow, questions about pollution prevention measures and plans
can be made part of the permit application process. Also, a permittee may be required to undergo
a pollution prevention assessment and /or develop a pollution prevention plan as a condition of the
permit.
- Local limits- POTWs near or above maximum allowable headworks loadings may institute POTW
wide-pollution prevention programs to reduce specific pollutants.
- Enforcement negotiations - A pollution prevention audit may be required through a consent or
compliance order, or implementation of pollution prevention measures may be required as part of
a settlement.
Several Control Authorities have implemented these pollution prevention activities. For example, the
City of Palo Alto, CA established a silver local limit for photoprocessors and Best Management Practices
(BMPs) for automotive facilities. To reduce mercury loadings from dental offices, Western Lake Superior
Sanitary Sewer District (WLSSD) in Duluth, MN developed and implemented pollution prevention BMPs.
These and many other POTWs that have successfully integrated pollution prevention into their pretreatment
programs have become recognized environmental leaders in their communities.
While pollution prevention activities can be unique to each POTW, the following are key elements of
successful pollution prevention programs:
- Integrate pollution prevention into existing activities - POTWs that view pollution prevention
as an enhancement (instead of an additional requirement) to their existing pretreatment programs
make small modifications to existing pretreatment activities efficiently and effectively.
- Start small - POTWs that slowly phase in new pollution prevention activities overcome impediments
such as limited resources and resistance. Implementing small changes gradually can be done with
-48- Chapter 7
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Introduction to the National Pretreatment Program Pollution Prevention
minimal resources. This approach enables pollution prevention activities to become an accepted
integral part of the pretreatment program.
- Define attainable goals and measure success - Short-term, narrowly focused efforts have a
greater chance of succeeding. For example, POTWs have targeted a specific pollutant and group
of industries, established specific pollution prevention activities, and monitored the progress and
success of these activities. With each new success recorded, the benefits of pollution prevention
are illustrated and the demand for further activities will grow.
- Provide incentives - Incentives are effective tools for persuading users to investigate pollution
prevention opportunities. POTWs have used a wide range of tools such as public recognition of
pollution prevention achievements and reduction of regulatory requirements.
BENEFITS OF POLLUTION PREVENTION
For both IDs and POTWs, pollution prevention has many benefits (Figures 34 and 35) that can be
broadly categorized under tangible economic rewards and public goodwill and support. For example,
pollution prevention:
Creates cost savings
Enhances process efficiency
Avoids or reduces regulatory costs
Improves protection of worker health
Improves public image.
Decrease pollutant loadings to water, air, and sludge
Decrease pollutant loadings to POTW that result in lower
O&M costs and reduces or eliminates need for capital
_ . , .. ...... expenditures for POTW treatment plant expansions
Keduces future liabilities Enableg contmued or expanded growth m me commumty
without harm to the environment.
Figure 34. Benefits of Pollution Prevention to POTWs
Although the numerous benefits make
pursuing pollution prevention attractive, implementation of source reduction in some situations may not be
possible. Before implementing a pollution prevention practice, the benefits and barriers of the potential
opportunity must be evaluated. Common impediments include the following:
- Technology
Decrease product quality
Unable to change raw materials because of currently available technology
- Financial
Incur high costs associated with implementing alternatives (i.e., new equipment or materials,
or personnel and training)
Loss due to downtime during switch overs and start ups
Foreign competitors may have an economic advantage if they are not obligated to comply with
US regulations
Binding contracts with existing waste haulers and Treatment, Storage and Disposal (TSD)
facilities may exist
- Organizational
Lack of or poor communication between persons possessing the knowledge and ideas for
improvements and those that can actually implement the changes
Limited personnel or internal resources available to investigate and/or make changes
Lack of coordination and cooperation among divisions in the corporation
Behavioral
Alternatives may be considered inconvenient by personnel (e.g., dry sweeping then a wet wash
down as opposed to just a wet wash down)
Chapter 7 -49-
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" Regulatory
Concentrating a pollutant for recycling
may classify it as a hazardous waste
(e.g., silver). As such, an industrial
user may choose to discharge the
pollutant rather than be subject to
regulations regarding the handling,
treatment and disposal of a hazardous
waste.
POLLUTION PREVENTION ASSISTANCE
With the creation of the PPA came an
abundance of pollution prevention related
assistance. This includes direct technical
assistance, training courses, and a variety of
publications. POTWs can find further information
on integrating pollution prevention into their
pretreatment programs in EPA's 1993 Guides to
Pollution Prevention - Municipal Pretreatment
Programs. Specific industry trade associations and
university technology transfer and outreach
departments usually are aware of pollution
prevention assistance materials, specific pollution
prevention opportunities, and the costs and
success of implementing these. Some further
sources that disseminate pollution prevention
information include:
- Pollution Prevention Information
Clearinghouse (PPIC) - a free, nonregulatory
clearinghouse available to the public which
focuses on source reduction and recycling for
industrial toxic wastes.
- State Programs-provide technical assistance
to conduct pollution prevention assessments,
develop guidance manuals on conducting
Regulatory
- Elimination of regulated wastewater discharges, and
hence, monitoring requirements
- Reduced paperwork requirements for waste hauling
and treatment
- Compliance with RCRA reports on waste reduction
(i.e., companies generating RCRA wastes are required
to certify that they have a program to reduce the
volume and toxicity of hazardous waste generated)
- Compliance with land disposal restrictions and bans
Environmental
- Minimization of material emissions to all media
resulting in reduced health risks to workers and the
community
Financial
- Reduced landfill and treatment costs due to less waste
being generated (includes reduced transportation costs
as well)
- Reduced raw material and manufacturing costs (e.g.,
by preventing spills or leaks, improving equipment
maintenance and inventory control techniques, reuse,
etc. raw materials are handled more efficiently and do
not have the chance to become waste. With a greater
percentage of raw material going into process, raw
material use goes down in relation to volume of
product produced)
- Increased manufacturing efficiency and productivity
and improved product quality with fewer offspec
products
Compliance and public relations
- Achieving compliance with local limits and categorical
standards
- Reducing waste and implementing best management
practices can improve public and community relations.
Figure 35. Benefits of Pollution Prevention to Ills
these assessments, actually conduct these assessments, provide assistance in developing POTW-wide
pollution prevention plans, provide training for industry, State and POTW personnel, and offer grants
for pollution prevention projects.
Envirosense - an on-line computer system (internet address: es.inel.gov) of summary information for
PPIC documents, includes pollution prevention news, upcoming events, and mini-exchanges (discrete
pollution prevention topic areas, pollution prevention databases, and message center).
National Institute of Standards and Technology (NIST) - an office of the Department of Commerce,
NIST develops technology to improve product quality, modernize manufacturing processes, ensure
product reliability, and facilitate rapid commercialization of products based on new scientific discoveries.
NIST web sites for different industry sectors are available. For example, the metal finishing web site
(i.e., the National Metal Finishing Resource Center) is found at "www.nmfrc.org."
8. BIBLIOGRAPHY
-50-
-------
Introduction to the National Pretreatment Program
Bibliography
TITLE
Aluminum, Copper, And Nonferrous Metals Forming And
Metal Powders Pretreatment Standards: A Guidance
Manual
CERCLA Site Discharges to POTWs Guidance Manual
Control Authority Pretreatment Audit Checklist and
Instructions
Control of Slug Loadings To POTWs: Guidance Manual
Environmental Regulations and Technology: The
National Pretreatment Program
Guidance for Conducting a Pretreatment Compliance
Inspection
Guidance For Developing Control Authority Enforcement
Response Plans
Guidance for Reporting and Evaluating POTW
Noncompliance with Pretreatment Implementation
Requirements
Guidance Manual For Battery Manufacturing
Pretreatment Standards
Guidance Manual for Electroplating and Metal Finishing
Pretreatment Standard
Guidance Manual For Implementing Total Toxic
Organics (TTO) Pretreatment Standards
Guidance Manual For Iron And Steel Manufacturing
Pretreatment Standards
Guidance Manual for Leather Tanning and Finishing
Pretreatment Standards
Guidance Manual for POTW Pretreatment Program
Development
Guidance Manual for POTWs to Calculate the Economic
Benefit of Noncompliance
Guidance Manual for Preparation and Review of
Removal Credit Applications
Guidance Manual for Preventing Interference at POTWs
Guidance Manual for Pulp, Paper, and Paperboard and
Builders' Paper and Board Mills Pretreatment Standards
Guidance Manual for the Identification of Hazardous
Wastes Delivered to Publicly Owned Treatment Works
by Truck, Rail, or Dedicated Pipe
Guidance Manual for the Use of Production-Based
Pretreatment Standards and the Combined Wastestream
Formula
Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the
Pretreatment Program
Guidance on Evaluation, Resolution, and Documentation
of Analytical Problems Associated with Compliance
Monitoring
Guidance to Protect POTW Workers From Toxic And
Reactive Gases And Vapors
Guides to Pollution Prevention: Municipal Pretreatment
Programs
DATE
December 1989
August 1990
May 1992
February 1991
July 1986
September 1991
September 1989
September 1987
August 1987
February 1984
September 1985
September 1985
September 1986
October 1 983
September 1990
July 1985
September 1987
July 1984
June 1987
September 1985
December 1987
June 1993
June 1992
October 1 993
EPA Number
800-B-89-001
540-G-90-005
-
21W-4001
625-10-86-005
300-R-92-009
-
-
440-1-87-014
440-1 -84-09 1-G
440-1 -85-009-T
821-B-85-001
800-R-86-001
-
833-B-93-007
833-B-85-200
833-B-87-201
-
-
833-B-85-201
833-B-87-202
821-B-93-001
812-B-92-001
625-R-93-006
NTIS Number
PB91 -145441
PB90-274531
-
-
PB90-246521
PB94-1 20631
PB90-185083/AS
PB95-1 57764
PB92-1 17951
PB87-1 92597
PB93-1 67005
PB92-1 14388
PB92-232024
PB93-186112
-
-
PB92-1 17969
PB92-231638
PB92-1 49251
PB92-232024
PB92-129188
-
PB92-1 73236
-
ERIC Number
W119
W150
-
-
W350
W273
-
W304
W195
W118
W339
W103
W117
W639
-
-
W106
W196
W202
U095
W107
-
W115
-
Chapter 8
-51-
-------
Bibliography
Introduction to the National Pretreatment Program
TITLE
Industrial User Inspection and Sampling Manual For
POTWs
Industrial User Permitting Guidance Manual
Model Pretreatment Ordinance
Multijurisdictional Pretreatment Programs: Guidance
Manual
National Pretreatment Program: Report to Congress
NPDES Compliance Inspection Manual
POTW Sludge Sampling and Analysis Guidance
Document
Prelim User's Guide, Documentation for the EPA
Computer Program/Model for Developing Local Limits for
Industrial Pretreatment Programs at Publicly Owned
Treatment Works, Version 5.0
Pretreatment Compliance Inspection and Audit Manual
For Approval Authorities
Pretreatment Compliance Monitoring and Enforcement
Guidance and Software (Version 3.0)
Procedures Manual for Reviewing a POTW Pretreatment
Program Submission
RCRA Information on Hazardous Wastes for Publicly
Owned Treatment Works
Report to Congress on the Discharge of Hazardous
Wastes to Publicly Owned Treatment Works
Supplemental Manual On the Development And
Implementation of Local Discharge Limitations Under
The Pretreatment Program: Residential and Commercial
Toxic Pollutant Loadings And POTW Removal Efficiency
Estimation
DATE
April 1994
September 1989
June 1992
June 1994
July 1991
September 1994
August 1989
January 1997
July 1986
(Manual)
September 1986
(Software)
September 1992
October 1 983
September 1985
February 1986
May 1991
EPA Number
831-B-94-001
833-B-89-001
833-B-92-003
833-B-94-005
21-W-4004
300-B-94-014
833-B-89-100
~~
833-B-86-100
(Software)
831-F-92-001
833-B-83-200
833-B-85-202
530-SW-86-004
21W-4002
NTIS Number
PB94-1 70271
PB92-123017
PB93-122414
PB94-203544
PB91 -228726
-
-
~~
PB90-1 83625
(Software)
PB94-1 18577
PB93-209880
PB92-1 14396
PB86-184017&
PB95-1 57228
PB93-209872
ERIC Number
W305
W109
W108
W607
W694
-
-
~~
W277
(Software)
W269
W137
W351
W922&
W692
W113
-52-
Chapter 8
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Introduction to the National Pretreatment Program Bibliography
OTHER REFERENCE MATERIAL
CERCLA Site Discharges to POTWs CERCLA Site Sampling Program: Detailed Data Report, EPA 540-2-90-008
CERCLA Site Discharges to POTWs Treatability Manual, EPA 540-2-90-007
Considerations of Pollution Prevention in EPA's Effluent Guideline Development Process, EPA 820-R-95-008
Domestic Septage Regulatory Guidance: A Guide to the EPA 503 Rule, EPA 832-B-92-005
Effluent Guidelines, Leather Tanning, and Pollution Prevention: A Retrospective Study, EPA 820-R-95-006
Environmental Regulations and Technology: The Electroplating Industry, EPA 625/10-80-001
Environmental Regulations and Technology: The Electroplating Industry, EPA/625/10-85/001
EPA'S Whole Effluent Toxicity (WET) Control Policy (Information Sheet and Nonpoint Source Bulletin Board System
Instructions), EPA 833-F-94-005
Everything You Wanted to Know About Environmental Regulations...But Were Afraid to Ask: A Guide for Small
Communities, Region 7 EPA 907-R-92-002
Fact Sheet: Effluent Guidelines: Protecting Our Nation's Waters from Industrial Discharges, EPA 821-F-93-005
Guidance on Evaluation, Resolution, and Documentation of Analytical Problems Associated with Compliance
Monitoring, EPA 821-B-93-001
Guidance to POTWs for Enforcement of Categorical Standards (Memorandum), November 5, 1984, EPA
Introduction to Water Quality-Based Toxic Control for the NPDES Program, EPA 831-S-92-002
NPDES Basic Permits Writer's Course Manual, EPA 833-B-97-001
Plain English Guide to the EPA Part 503 Biosolids Rule, EPA 832-R-93-003
Pretreatment Compliance Monitoring and Enforcement Guidance, September 1986, EPA
Pretreatment Implementation Review Task Force: Final Report to the Administrator, January 30, 1985, EPA
Spill Prevention, Control, and Countermeasure (SPCC) Information Guide, EPA 903-B-93-001
State and Local Government Guide to Environmental Program Funding Alternatives, EPA 841-K-94-001
Toxicity Identification Evaluation: Characterization of Chronically Toxic Effluents, Phase 1, EPA 600-6-91-005-F
U.S. EPA NPDES Permit Writers' Manual, EPA-833-B-96-003
User Documentation: POTW Expert, Version 1.1, EPA 625-1-19-000-1
Utility Manager's Guide to Water and Wastewater Budgeting, EPA 832-B-94-010
Chapter 8 -53-
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