1. Pretreatment Review of TPDES Permit Applications & How to Identify Industrial Users
Jessica Alcoser
May 14, 2019
Water Quality Division
Texas Commission on Environmental Quality
Good Afternoon
My name is Jessica Alcoser and I am with the Pretreatment Team within TCEQ’s Water Quality Division.
Today I will be presenting on pretreatment review of TPDES permit applications and how to identify industrial users.

2. Introduction
All publicly owned treatment works (POTWs) that discharge to a waterbody of Texas, must apply for a Texas Pollutant Discharge Elimination System (TPDES) permit. The application to discharge wastewater goes through a series of administrative and technical reviews before a permit is written and issued.
To begin, lets discuss the permitting process
All P.O.T.W. (POTWs) that discharge to a waterbody of the state, must apply for a T.P.D.E.S. permit. Otherwise known as a TPDES permit.
The application to discharge wastewater goes through a series of administrative and technical reviews before a permit is written and issued.

3. TPDES Permitting Process
Application Received by TCEQ
Administrative Review
Technical Review
Standards and Assessment Review
Draft Permit Sent for Comments
Pretreatment Review
Here we have a diagram that shows an overview of the general permitting process which first begins when an application is received by TCEQ.
The application is administratively reviewed by TCEQ’s Administrative & Review Processing Team (ARP).
Then it receives a review from the WQ Standards & Assessment team.
Next is the technical review – this is where our pretreatment review comes in.
Finally, after technical review, the draft permit is sent out for public comments before it is issued.

4. Pretreatment Review – Domestic Worksheet 6.0
All POTWs must complete Worksheet 6.0 as part of their TPDES permit application
Include Significant Industrial Users (SIUs), Categorical Industrial Users (CIUs), and other IUs discharging to the POTW
Based on total number, average process flow, and other information
The pretreatment review is of Domestic Worksheet 6.0 – the Industrial Waste Contribution form. This worksheet requests information on the numbers and types of industrial users that contribute wastestreams to the POTW as well as any instances of interference or pass through that the WWTP has experienced in the past three years.
All POTWs must complete this Worksheet 6.0 as part of their TPDES permit application
Based on the responses provided on Worksheet 6.0, and whether or not the POTW is receiving discharge from industrial users, the TPDES permit will include one of four pretreatment language options. We will discuss these more in depth in several slides.

5. Pretreatment Review – Worksheet 6.0
Section 1.A:
Use results from water billing records or IU surveys
CIUs, SIUs, or Other IUs:
Enter “0” or “None” if none are discharging.
Do not enter “N/A”
Any issues in the sanitary sewer system or WWTP?
Include dates, duration, description of issue, and sources
Now I would like to walk through several portions of the worksheet where our team sees the most common errors.
Here on the right is copy of the actual Domestic worksheet 6.0 – Industrial Waste Contribution Application Form, page 1.
As a reminder this worksheet was last updated Sept. 1, 2016 and can be found on TCEQ website.
For Section 1 – all WWTPs are required to complete this portion. You can use either water billing records or IU surveys to complete this portion.
For CIUs, SIUs, Other IUs – always put “0” or “None”; NOT “N/A”
If you indicate that there are SIUs and/or CIUs – then Section 3 must be filled out entirely, for each SIU or CIU.
Section B at the bottom asks if the WWTP has experienced any instances of interference. If the answer is yes, please include the date, duration, description of the issue, and if the WWTP has identified sources of the interference

6. Pretreatment Review – Worksheet 6.0
Section 3:
Include required information for all SIUs and CIUs
B. Process Information:
Provide as much detail as possible
Section 3 only needs to be filled out if there are SIUs or CIUs that discharge wastestreams to the POTW.
Make sure to include all required information for all SIUs and CIUs.
Under processing information, make sure to include as much detail as possible.
Note that other IU’s are not included in No. 3.

7. Pretreatment Review – Worksheet 6.0
Section 3, Items C-E:
Describe the product, provide flows, and applicable pretreatment standards
Section 3: Industrial Interruptions
Describe any problems caused by IUs, i.e. interference or pass through
Continuing with Section 3, make sure to include a description of the product manufactured, provide flow rates, and any applicable pretreatment standards
Section 3 is also where you shall include information on any industrial interruptions caused by IUs

8. TPDES Permit - Pretreatment Options
As I mentioned earlier, there are 4 variations of pretreatment language that could be included in your WWTPs TPDES permit.
The Contributing Industries and Pretreatment Requirements section of the TPDES permit will have pretreatment language based on the information in Worksheet 6.0

9. TPDES Pretreatment Permit Language
Option 1
POTWs not required to have an approved pretreatment program
Option 2
POTWs are required to conduct an industrial user survey (IUS) and may be required to develop a pretreatment program
The first two, are Options 1 & 2.
In short, Option 1 is for POTWs that are not required to have an approved pretreatment program
Option 2 is for POTWs who may be required to develop a pretreatment program
I will go over each of these individually over the next couple of slides.

10. TPDES Pretreatment Permit Conditions
Option 1
No approved pretreatment program
No development of a pretreatment program
No formal IUs
Permit Language Requirements
General and Specific Prohibitions
40 CFR §403.5
POTW notification requirements
New introduction of pollutants
Substantial changes in volume or character of pollutants
Require any indirect discharger to:
Comply with the reporting requirements of Sections 204(b), 307, and 308 of the Clean Water Act
Option 1 language is for WWTPs that do not have an approved pretreatment program nor is there ongoing development of a program. Most importantly, WWTPs that receive Option 1 language have no formal IUs. The majority of POTWs fall within this category.
What does this mean in terms of permit language?
Option 1 language will have the general and specific prohibitions listed at 40 CFR 403.5
The permit will also include notification requirements that require the POTW to notify TCEQ when there is a substantial change in the industrial waste contribution to the POTW or anything that may impact the WWTP. Examples include new introduction of pollutants, substantial changes in volume

11. Example of standard Option 1 language

12. TPDES Pretreatment Permit Language
POTWs that are (or may) be required to develop a pretreatment program
Option 2
Activity No. 1
Submit an IUS
Due within 60 days of issued permit
Based on results, TCEQ will determine if program development is required or not
When Option 2 is assigned to a TPDES permit, it triggers what we refer to as Activity No. 1.
What this means is that the POTW will be required, through the TPDES permit, to conduct an IUS.
The POTW is required to conduct and submit an IUS within 60 days of the issued permit.
Based on the results, TCEQ will determine if program development is required or not.

13. TPDES Pretreatment Permit Language
Option 3
POTWs within an approved pretreatment program
SIUs are discharging to the specific WWTP
Option 4
No SIUs are discharging to the specific WWTP
The final two options, Options 3 and 4 are for WWTPs that are within POTWs with an approved pretreatment program.
Option 3 is for WWTPs that receive wastestreams from SIUs
Option 4 is for WWTPs that do not receive wastestreams from SIUs

14. TPDES Pretreatment Permit Language – Options 3 & 4 WWTPs:
Have an approved TPDES pretreatment program
40 CFR Part 403 requirements
Technically based local limits (TBLLs)
Annual Report
Notification Requirements
Option 4
Covered under approved TPDES pretreatment program
No SIUs in the service area of the plant
WWTP Influent/effluent sampling not required
Notification requirements still apply
Now lets tackle each of these individually.
OPTION 3 is for WWTPs that have an approved TPDES pretreatment program and received discharge from IUs. The TPDES permit will include the full set of requirements at 40 CFR Part 403.
The permit will also include T.B.L.L.s. requirement, this can mean either reassessment certification of existing TBLLS or notification to redevelop existing TBLLs
The permit will also include annual report requirements.
The report will be due on a specified month and will need to include WWTP influent/effluent monitoring, a list of SIUs in significant noncompliance (SNC) and proof of newspaper publication of the SIUs in SNC.
Similar to Option 1, the TPDES permit will also include notification requirements such as new introduction of pollutants or substantial changes in volume or character of pollutants
OPTION 4 is for WWTPs that are covered under an approved TPDES pretreatment program, but the specific WWTP does not have SIUs in their service area.
Houston Example
Therefore since there are no SIUs, there is no WWTP influent/effluent monitoring requirement
However the permit will still include notification requirements. These are especially important for these WWTPs because industries may begin discharging during the permit term, and the notification usually comes through the annual report, for example.

15. Industrial Users Identification and Survey
Now that we have discussed pretreatment review and language for TPDES permits, lets go over some tools for identifying IUs and conducting a thorough IUS.

16. How to Identify Industrial Users
Water billing records
Applications for sewer service
Building permits
Property tax records
POTW collection system personnel
POTW treatment plant operators
Here we have some sources for discovering new IUs.
We always recommend one begin by looking at water billing records, applications for sewer service.
We also suggest working with local government/business organizations to look at building permits, and property tax records
It is also important to not overlook treatment plant operators and collection system staff. These individuals can provide insight into problem dischargers and potential new IUs
And finally the last source I want to recommend is industrial users themselves. We see many programs go to their permitted IUs about information on potential competitors. Most often it is the industries themselves who have knowledge on up and coming competitors to the same area

17. How to Identify Industrial Users (cont.)
Business and telephone directories
Texas Manufacturer’s Directory
Chamber of Commerce records
Economic Development organizations
Direct observation (drive-by)
Internet searches
Toxic Release Inventory (TRI)
EPA Envirofacts
Some other examples of resources you can use include
Business and telephone directories such as the Texas Manufacturer’s Directory and chamber of commerce records
Also we have good old fashioned direct observation. So conducting physical drives-by’s within your jurisdiction
And finally, there is the internet. Specifically internet searches such as the TRI and EPA’s Envirofacts that can help identify industries that may discharge toxic or hazardous substances.
Also, don’t forget to consider contributions to the POTW may be from connections outside the service area or City limits.
Once you have exhausted these resources, you will have made a master list of industrial users located in the POTW’s service area

18. Facility Types – Commonly Missed
Small metal plating facilities
Metal Finishing (40 CFR Part 433)
Truck washing facilities
Transportation & Equipment Cleaning (40 CFR Part 442)
Grease & Grit Processing facilities
Centralized Waste Treatment (40 CFR Part 437)
Facilities with no categorical pretreatment standards
Hospitals (40 CFR Part 460)
Meat and Poultry Products (40 CFR Part 432)
Plastic Molding and Forming (40 CFR Part 463)
And several others
Here we have some commonly missed facilities such as
Small metal plating facilities – can sometimes be overlooked but depending on processes could fall under the Metal Finishing Category
There are also some truck washing facilities may be subject to the Transportation & Equipment Cleaning (TEC) category depending on what they hauled and the volume of wash water used.
Similarly, grease and grit trap processing facilities may be subject to CWT categorical pretreatment standards due to grit processing.
Then we have facilities that do not have categorical standards but might impact the collection system as well as the WWTP.
Some examples include meat and poultry facilities – no categorical standards but due to their high strength waste they may impact the POTW.
Hospitals as well have the potential to discharge metals and hazardous wastes. And industrial laundry facilities could also cause problems at the plant due to the volume, temperature, metals, or oily wastes, or high-strength waste.

19. Industrial User or Waste Survey
COMPILE MASTER LIST OF POTENTIAL IUs IN SERVICE AREA – CONSIDER…
IUs with high water usage
IUs that might impact the POTW
Standard Industrial Classification (SIC) code
North America Industrial Classification System (NAICS) code
Compare SIC or NAICS codes to categories: 40 CFR Parts
As you are compiling your IUS, you should also include commercial users that are sources of any pollutants of concern, such as photo processers, dentists, and restaurants.
In order to determine if these facilities use and discharge process wastewater, you will need to obtain additional information about them.
This should be done by either sending out a questionnaire or survey form requesting this information.
Let IUs be aware that they need to provide all relevant information related to the facilities manufacturing and processing areas.
As well, require them to provide the Standard Industrial Classification (SIC) code and/or the NAICS code.
You can compare these codes to the categories found at 40 CFR Parts to determine if the facility should be classified as categorical.

20. Industrial User Survey (cont.)
Survey each IU to collect information
Conduct follow-up inspections
Conduct follow-up telephone calls
Summarize data
Maintain and update IU list
The survey does not end with the paper questionnaire.
Ensure that you are conducting follow up inspections and/or telephone calls to confirm responses provided in the questionnaire.
Once the survey is done, summarize your data and maintain an up to date IU list.

21. How to Identify HW Generators in Your Area
1. Select Geography Search and enter information for:
“Zip Code” or “City,” “County,” and “State.”
Use 5-digit Zip Code
Use state abbreviation (AR, LA, OK, NM, or TX)
For this final portion of the presentation, I will walk through some of the websites we discussed earlier that can be used to identify IUs that discharge hazardous or toxic waste.
The first site we will go over is the EPA EnviroFacts, which has a RCRA search site. This allows you to identify hazardous waste generators in your area.
Once you get to the search page, you can narrow down the area you want to look at. You can enter zip code, city, county and or state.

22. HW Generator Search 1. Select Search Value to use RCRAInfo only.
Then you will want to make sure to that search values are set to use RCRA information only
You can also click on “active/inactive” site option to expand or narrow your search.
Finally, you click search to generate the report.
2. Select Search Box to generate the report.

23. How to Identify TRI Transfers to POTWs
This next website assists in identifying Toxics Release Inventory transfers from facilities to potential POTWs.
Use TRI Transfers to POTW Tool

24. TRI Waste Transfers to POTWs
1. Select “Waste Transfer Reports” then “Facility” tabs.
2. Click on Geographic Location and then select ZIP Code or State or a County in the pop-up menu that will appear.
Using EPAs TRI website, you can search for facilities that transfer waste. You will want to select “waste transfer reports” then choose the “facility” tab.
Next you will select geographic location by either entering a zip code or the city, county and state.
Off to the right, you will want to make sure the two checkboxes stating “TRANSFERS TO POTWs” are selected.
Finally, you will click generate report to generate the list of facilities that transfer waste in the selected service area.
3. Only select the 2 “Transfers to POTWs…” Click on each box to select or deselect.
Note that Total Transfers Off-site for further Waste Management remains selected.
4. Click Generate Report tab to create list.

25. Who reports TRI Waste Transfers to POTWs?
This Waste Transfer Facility Report shows the list of facilities in Travis County, TX that transferred wastes to a POTW in 2015
This particular facility transferred 30,804 pounds of NITRATE COMPOUNDS to a POTW in 2015.
Click on the Name of the Facility. Then click on TRI Reporting Forms link. Scroll down to Section 6 to find out which POTW.
Here is a screenshot of an example report.
The top and center of the report will state for which geographic location the list is based on. See here this report shows…..
In the content of the report, you will see the facilities names BOLDED and underneath will be the correlating compounds transferred. So this particular facility….
You can also scroll further down to find out the which POTW the waste was transferred to.

26. QUESTIONS? Pretreatment Team (512) 239-4671 WQPRET@tceq.Texas.gov
This completes my presentation on pretreatment language in TPDES permits and tools to identify industrial users.
Thank you for joining us for this presentation, AT this time I can answer any questions…
As a reminder we are always available for questions. You can contact the main WATER QUALITY division line at number above. If you ask to speak to a member of the PRET team you will be routed to a team member who is available to assist you.
Recently, we also got a general inbox, so feel free to send s to the above,
THANK YOU