The Pretreatment Program September 14, 2012 Bethlehem, PA

John Lovell

Other Contacts Steve Copeland Liz Ottinger

Pretreatment Controls industrial discharges into the municipal sewage collection system (POTW) Controls industrial discharges into the municipal sewage collection system (POTW) POTW is generally the primary regulatory agency POTW is generally the primary regulatory agency If no local program, regulatory agency becomes the state or EPA If no local program, regulatory agency becomes the state or EPA 40 CFR 403 – General Pretreatment Regulations 40 CFR 403 – General Pretreatment Regulations

Objectives of the Pretreatment Program Prevent introduction of pollutants into POTWs which will interfere with their operation, including use or disposal of municipal sludge Prevent introduction of pollutants into POTWs which will interfere with their operation, including use or disposal of municipal sludge Prevent the introduction of pollutants into POTWs which will pass-through treatment works or otherwise be incompatible with such works Prevent the introduction of pollutants into POTWs which will pass-through treatment works or otherwise be incompatible with such works Improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges Improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges

Fish kill resulting from industrial waste passing through the POTW.

Collapsed street resulting from sewer explosion caused by industrial waste discharge.

Sewer pipe corrosion caused by acidic discharge from industrial facility.

Sewer pipe blockage caused by oil & grease discharge.

Sewer overflow caused by blockage.

Types of Pretreatment Standards Prohibitions Prohibitions Local Limits Local Limits Categorical Standards Categorical Standards Best Management Practices Best Management Practices

Prohibitions Apply to all industrial users Apply to all industrial users 40 CFR (a) & (b) 40 CFR (a) & (b) Local ordinance Local ordinance

Local Limits Apply to significant industrial users and others designated by POTW Apply to significant industrial users and others designated by POTW Local ordinance Local ordinance Technically based Technically based

Categorical Standards Apply to specific category of industrial users Apply to specific category of industrial users CWA 307(b) and (c) CWA 307(b) and (c) 40 CFR 405 – CFR 405 – 471 Technology-based Technology-based

Best Management Practices Can apply to any industrial users Can apply to any industrial users Categorical Standards Categorical Standards Local Ordinance Local Ordinance Require Activities/Procedures Require Activities/Procedures Install/maintain grease interceptor Install/maintain grease interceptor Slug/spill control plan Slug/spill control plan

Program Implementation Procedures Updating the Industrial Waste Survey Updating the Industrial Waste Survey Permitting of Industrial Users Permitting of Industrial Users Notification to IUs of Pretreatment Requirements Notification to IUs of Pretreatment Requirements Compliance Monitoring – Sampling and Inspections of SIUs by POTW Compliance Monitoring – Sampling and Inspections of SIUs by POTW IU self-monitoring IU self-monitoring Enforcement Response Plan Enforcement Response Plan

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