The Basics

WHAT IS PRETREATMENT? The term PRETREATMENT means the treatment of wastewater by commercial and industrial facilities to remove harmful pollutants before being discharged to a sewer system. POTWs are designed to treat sanitary wastes from households, but not to treat toxic pollutants. The toxic pollutants from industrial and commercial facilities may cause serious problems at POTWs. Problems may be prevented by: – Recycling – waste minimization – chemical substitution – Pretreatment – Best Management Practices to reduce or eliminate the pollutants from commercial or industrial facilities.

CLEAN WATER ACT The Clean Water Act became law in The National goal is: Eliminate pollutants in navigable waters Eliminate pollutants in navigable waters Protect fish, shellfish and wildlife Protect fish, shellfish and wildlife Prohibit discharge of toxic Prohibit discharge of toxic pollutants in toxic amounts Cuyehoga River (Ohio-1969)- The river that caught fire. The fire -- a flare-up of oil- soaked debris likely ignited by either molten steel or a spark from a passing rail car Described as the river that "oozes rather than flows" and in which a person "does not drown but decays." Erupted in fire at least 13 times.

WHY DO WE NEED PRETREATMENT PROGRAMS? Objectives of the Pretreatment Program By placing controls and/or limits on levels of certain pollutants in wastewater discharged to your sewer system, you: prevent interference with the operation of your wastewater treatment plant prevent the introduction of pollutants that could pass through your wastewater treatment plant untreated into the receiving body of water improve opportunities for reuse or recycling of wastewater and sewage sludge prevent the introduction of pollutants that could cause health or safety problems to the public or the environment

Prevent Interference – Prevent harmful effects that toxic industrial compounds can have on POTW operations (killing or inhibiting beneficial microorganisms) – Interferes with POTW’s ability to meet NPDES permit requirements. Heavy metals (copper, nickel, lead, zinc, mercury) Organics (methylene chloride, tetrachlorethylene (TCE), acetone, gasoline…

Pass Through Pass through – Caffeine, which was the highest-volume pollutant – Nicotine – Personal care products sunscreen agents synthetic musks – Pharmaceuticals Codeine Cholesterol-lowering agents, Anti-depressants Estrogen replacement drugs-endocrine disrupters Chemotherapy agents Antibiotics - pathogen resistance

Prevent SANITARY SEWER OVERFLOWS Prevent Sewer overflows – sewage, oil grease. SSO photo – Raleigh, North Carolina

SSOs Untreated sewage released to the environment. Threat to public health - Pathogenic organisms. Affects aquatic life, surface water, recreational water. Clean-up is costly.

Food Service Establishments Restaurants, schools, hospitals, correctional facilities, retirement homes, convenience stores, bakeries, delis. Meats Dairy Products-milk, cheese, sour cream. Soups/gravy Mayonnaise Fried food

Effects of FOG Monitoring Decreased # of sewer back- ups Decreased preventative maintenance to “hot spots” Overall decrease in amount of strong waste fees charged businesses/industries.

WASTEWATER INFRASTRUCTURE Extend life of wastewater infrastructure – controls on corrosives and pipe-damaging liquids – low pH – NO discharges with pH of <5.5 – Hydrogen sulfide

Prohibited Discharges Pollutants that could cause fire/explosion Pollutants that cause corrosive structural damage (never less that 5.0) Pollutants causing obstruction Discharges of oils that could cause interference Discharges of toxic gases that could cause health and safety issues Illicit discharges of trucked or hauled pollutants

Worker safety Prevent formation of dangerous conditions such as toxic vapors and Prevent formation of dangerous conditions such as toxic vapors and depleted oxygen levels within the POTW and the collection system. 1950’s London sewer worker

POTW Pretreatment Program Requirements Legal Authority Legal Authority Ability to deny or condition discharges to POTW Ability to deny or condition discharges to POTW Require compliance with Pretreatment Stds Require compliance with Pretreatment Stds Control industrial discharges through permits, compliance orders Control industrial discharges through permits, compliance orders Inspect Industrial Users Inspect Industrial Users Comply with confidentiality stds Comply with confidentiality stds

GENERAL PRETREATMENT REGULATIONS The General Pretreatment Regulations apply to all non-domestic sources that introduce pollutants into a POTW. An SIU is defined in 40 CFR as: An IU subject to federal categorical pretreatment standards OR An IU that discharges an average of 25,000 gallons per day (gpd) or more of process wastewater to 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 POTW treatment plant An IU designated by the POTW as such because of its reasonable potential to adversely affect the POTW's operation or violate any pretreatment standard or requirement.

How do you locate area Industrial Users? Business licenses – all new and repeat business license applications are required to submit an IW survey. Telephone directory Search internet Drive-bys Utility bills – check volume of discharge

Procedures Identify and locate IUs subject to the PT program Identify the character and volume of discharge Notify IU of pretreatment stds and requirements Receive and analyze reports Sample and evaluate IU discharges Evaluate the need for a spill/slugload plan Investigate non-compliance Comply with public participation

FUNDING The POTW must have sufficient funds to carry out the authorities and procedures – Permit fees – based on WAC – Sampling fees – Testing fees – Sewer Pretreatment charges

Local Limits The POTW must develop local limits – To regulate pollutants that could cause interference, pass through, sludge contamination or worker health and safety if discharged in quantities in excess of the POTW’s ability to remove these pollutants. – Local Limits are developed to regulate industrial users at the end-of-pipe

Enforcement Response Plan Develop and implement an ERP that contains procedures indicating how the POTW will investigate and respond to IU noncompliance. – Verbal notification – Warning letters – Notice of Violation – Administrative Order with penalty

City of Yakima Pretreatment Program Fully delegated by Ecology in Staffing – Pretreatment Supervisor – Environmental Compliance Specialist – Permit writer/Safety officer – 2 Pretreatment crew leaders – 3 Pretreatment technicians

Success Stories Yakima County Jail – Large volume of solids discharged: Clothing, bedding, oranges, Styrofoam cups. – County was billed for additional sewer maintenance (monthly cleaning of sewer lines) – Compliance schedule Installed grinders / holding tanks

Oil Distributor Fuel oil discharged to sewer cleanout – Customer contacted WW because she received a door hanger invoice… – Issued a Notice of Violation plus billed for oil removal/clean-up at plant. – Safety Kleen vactored oil/water separator – Microcat – “Microbial Catalyst” Product of adapted microorganisms and enzymes for use in sewer systems.

Hops Extraction Slugloads in 2007 and Billed for labor and replacement parts. Administrative Order with Penalty in Compliance Plan…monthly reports.

Rags Continuing Issue Public awareness/education – Newspaper articles/interviews – Informational letters/brochures – Rag Chains in main lines

Low pH – Beverage Bottling Headworks low pH – Swing/Graveyard shift Set-up continuous pH monitoring in major lines. Identified general location – Beverage canning facility. From May 14-17, 4,455 pHs readings were recorded. Of these, 668 pHs were below the local limit of 5.5. There appears to be a trend from about midnight to 2 AM where the pH is below 5.5. Cleaning solution used during evening and graveyard shifts caused drop in pH.

Potato Chip/Apple Chip Processor Installation of two dissolved air floatation systems (DAFs) over a four year period. Average FOG concentration decreased from 1027 mg/L in 2003 to 8 mg/L in (49 mg/L in 2011…violation of 225 mg/L – ran out of polymer for DAF. Strong waste charges decreased from $220,000 to $35,000.

BENEFITS OF DELEGATED PRETREATMENT PROGRAM? The ability to inspect and monitor industries Receive DMRs to know the discharge volumes Better understanding of industrial processes to track violations Permit fees

QUESTIONS?