Pretreatment 101 Training Course Sponsored by U.S. Environmental Protection Agency, States of Region 6 And the Region VI Pretreatment Association

“ ” “Why the Pretreatment Program Was Established & Overview of Regulations & Implementation”

History of Water Protection 1899Rivers and Harbors Act 1956Federal Water Pollution Control Act 1962Rachel Carson’s Silent Spring 1963Robert Zimmerman changed his name to? 1965Water Quality Act

History of Water Protection, cont. 1970EPA established through an executive order 1972FWPCA Amendments create NPDES Program 1977Clean Water Act 1987Water Quality Act

How Acts Are Implemented Act passed/signedAct passed/signed Federal Register noticeFederal Register notice Regulations into effectRegulations into effect Appropriate Entities act out provisionsAppropriate Entities act out provisions

Statutory Basis Clean Water Act [33 U.S.C. 1251, et seq.]

Statutory Basis Section Congressional declaration of goals Section 212 – Definitions Section 301 – Effluent limitations Section Toxic and Pretreatment Standards

Statutory Basis Section Records and reports; inspections Section 309 – EnforcementSection 309 – Enforcement Section 402 – NPDESSection 402 – NPDES Section DefinitionsSection Definitions

National Pollutant Discharge Elimination System(“NPDES”) [40 CFR Part 122] NPDES applies to all “point sources discharging pollutants” into “waters of the United States”NPDES applies to all “point sources discharging pollutants” into “waters of the United States” point sources must obtain an NPDES permit from EPA or their delegated Statepoint sources must obtain an NPDES permit from EPA or their delegated State NPDES permits require development of Pretreatment ProgramsNPDES permits require development of Pretreatment Programs

The connection: 40 CFR Part 122 EPA NPDES State NPDES Permit Pretreatment Program Industrial User

Evolution of Pretreatment Regulations CFR Part 128 promulgated CFR Part 403 promulgated POTW program approval deadline Pretreatment Implementation Review Task Force(“PIRT”) report released

Evolution of Pretreatment Regulations (Cont.) Domestic Sewage Study(DSS) Report to Congress PIRT Rules promulgated DSS regulations promulgated Removal credit/pollutant eligibility revised Program Modification Regulation Streamlined 2005 – Pretreatment Streamlining

40 CFR Part 403 U.S. Code of Federal Regulations(CFR)U.S. Code of Federal Regulations(CFR) >Title 40 - Protection of the Environment >Chapter I - Environmental Protection Agency >Subchapter N - Effluent Guidelines and Standards >Part General Pretreatment Regulations for Existing and New Sources of Pollution

Corrosion of Collection System and/or Treatment Plant Explosions Interference with Wastewater Treatment Facility Limitations on Sludge Disposal Options and/or Greater Expense Injury to Workers from Hazardous Fumes Pass-Through of Toxics into Surface Waters

40 CFR Part 403 Objectives 40 CFR Part 403 Objectives To prevent the introduction of pollutants into POTWs which will:To prevent the introduction of pollutants into POTWs which will: –interfere, –pass through, and/or –be incompatible. To improve opportunities to recycle and reclaim wastewaters and sludges.To improve opportunities to recycle and reclaim wastewaters and sludges. To protect POTW workers.To protect POTW workers.

“Why Do We Need a Pretreatment Program”

Region 6 Totals 145 Approved Programs 281 POTW’s 4143 MGD Design Flow 2085 SIU’s