Summary
Publicly owned treatment plants (POTWs) from large, medium and small communities may be required to develop a pretreatment program if they meet certain regulatory criteria. There are specific requirements for certain types of industries. Other industries or commercial businesses may not have specific requirements due to the volume of their discharge to municipal treatment plants, or their individual flow may not significantly impact the wastewater treatment plant. This fact sheet provides an overview of pretreatment programs, general steps in developing a pretreatment program, and resources for additional information.
What is a pretreatment program?
The Pretreatment Program, sometimes referred to as the Industrial Pretreatment Program (IPP), represents a partnership in the regulatory community which includes Federal, State and local regulatory agencies established to protect water quality. The term "pretreatment" refers to requirements to control pollutants from non-domestic sources discharging wastewater to sewer systems that are connected to POTWs. The U.S.EPA, the State or the local authority establishes limits on the amount of pollutants allowed to be discharged.
What is Source Control?
Source control is a term used to describe activities which reduce or eliminate wastewater and pollutants that would otherwise exit the manufacturing process and enter the wastewater treatment facility. One approach to source control, pollution prevention, focuses on preventing the generation of wastes, while waste minimization refers to reducing the volume or toxicity of hazardous wastes.
Pretreatment limits may be met by industry through pollution prevention/waste minimization (e.g. material substitution, recycling and reuse of materials, treatment or process modification). These efforts may also be termed source control.
The benefits of source control in addition to protection of the public and the environment are cost savings to the industry as a result of reduced chemical and water use, reduction in disposal costs and liability, and potential reduction in the size of a pretreatment system.
What are the objectives of the Pretreatment Program?
The three primary objectives are:
- To prevent the introduction of pollutants into POTWs that will interfere with the operation o f the POTW, including interference with its use or disposal of biosolids
- To prevent the introduction of pollutants into POTWs that will pass through or are incompatible with the treatment works
- To improve opportunities to recycle and reclaim municipal and industrial wastewater and biosolids
What regulations govern programs?
Two primary regulations govern pretreatment programs:
- 40 CFR Part 122 - National Pollutant Discharge Elimination System (NPDES) program.
- 40 CFR Part 403 - General Pretreatment Regulations for Existing and New Sources of Pollution
What does the NPDES program require?
All point sources discharging pollutants to the waters of the United States must obtain a NPDES permit.
Who must develop a pretreatment program?
The following must develop a program:
- Publicly Owned Treatment Works (POTWs) that receive flows greater than 5 mgd, flow from categorical industrial users, or pollutants that pass through or interfere with treatment plants.
- POTWs that the Approval Authority requires to develop a program regardless of the above.
What industries have specific permitting and reporting requirements defined by the General Pretreatment Regulations?
Two types of industries have specific requirements:
- Categorical Industrial Users (listed by 40 CFR, Part 403.6 and 405-471)
- Significant Industrial Users
What are Significant Industrial Users (SIUs)?
The following are SIUs:
- Industries subject to Categorical Pretreatment Standards
- Industries discharging 25,000 gallons per day (GPD) or more of process water (excluding sanitary, non-contact cooling and boiler blowdown wastewater)
- Industries contributing 5% or more of the average dry weather hydraulic or organic capacity of the POTW
- Industries having a reasonable potential for adversely affecting the POTW or for violating any standard or requirements
Developing an Industry-Specific or Compound-Specific Program
Phase I - Getting Started
Programs are typically developed using a phased approach and are targeted for a specific industry and/or compound. Phase I includes:
- Determining the need for a program and setting goals
- Gaining management approval and staff consensus
- Organizing and consulting with a stakeholders group throughout the entire process
- Continuous consensus building internally within the regulatory agency and externally within the community to avoid or reduce future conflict
- Gathering information about affected industries, treatment technologies available, and pollution prevention practices
- Developing implementation strategies and best management practices
- Establishing the legal authority to enforce regulations and collect fines
See the Phase I flowchart for more details.
Phase II - Implementing the Program
Phase II is the commencement of the implementation strategy, continuation of the consensus building and feedback to the stakeholders, and implementation of the program. Phase II includes:
- Development of implementation schedules
- Marketing internally and externally to management, dischargers and all stakeholders. This involves management approval, feedback and consensus building, and dissemination of information to all stakeholders.
- Setting program milestones and holding training programs for dischargers.
See flowchart for additional Phase II details.
For more Pretreatment information, click on the following: