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Pretreatment for SmallBusinesses
Gary F. Kelman
MD State PretreatmentCoordinator
April 14, 2003
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Topics
Pretreatment Program Overview
Elements affecting small businesses
Specialized cases
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Background
1972: Congress passes Clean Water Act
NPDES Permit Program is establishedwith National Pretreatment Program asa component.
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Water Use/WastewaterGeneration
Average Americans use 100-200 gallonsof water a day.
Less than 1% is consumed, the rest iswastewater.
This wastewater is discharged into
wastewater treatment plants.
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Wastewater Treatment Plants
Designed to treat domestic sewage.
Non-biodegradable pollutants will
either: Pass-through untreated
Interfere with plant operations
Contaminate sewage sludge
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Toxics
More than one-third of all toxics enterthe Nations waters through wastewater
treatment plants.190-204 million pounds of metals and30-108 million pounds of organics are
removed each year as a result ofpretreatment requirements.
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How is this accomplished?
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What is Pretreatment ?
It is the treatment of non-domesticwastewater prior to its introduction into
the sanitary sewer to: Reduce pollutant concentrations or
loadings
Eliminate pollutantsAlter pollutant properties or characteristics
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How is the ProgramImplemented?
EPAs General Pretreatment Regulations
(40 CFR Part 403) establish framework,
responsibilities and requirements forimplementing and enforcingpretreatment standards.
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Governmental Partnership
Program is implemented as apartnership between EPA, States and
Local Government.EPA delegates pretreatmentresponsibility to the States.
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How is the ProgramImplemented?
Maryland delegates primaryresponsibility for the implementation of
the pretreatment program to LocalJurisdictions.
Currently 19 areas of the State have
been delegated pretreatment programs.
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Local Government Focus
Unlike other environmental programs,the pretreatment program places the
majority of the responsibility forimplementation with local governments.
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Who Must ImplementPretreatment ?
Not all governments must implement apretreatment program.
POTWs with design flows exceeding5 million gallons per day (MGD) and
receiving industrial wastewater MUST
develop a program.
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What about the smaller plants?
POTWs with 5 MGD design flows or less
and receive industrial wastewater MUST
implement a program IF potential existsfor upsets of treatment processes,violations of NPDES permit
requirements or contamination ofsewage sludge.
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How are Industries Screened?
Industrial Waste Survey
Classify Industries Discovered in Survey
Concentrate on those with mostpotential impact: Significant IndustrialUsers
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Significant Industrial Users25,000 gallons per day process flow;
5% of hydraulic or organic flow ofPOTW;
Reasonable potential to cause pass
through or interference;Categorical industry.
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To Be a Significant IndustrialUser
You dont have to be BIG.
Its all relative and, like politics, its all
local.Just like direct dischargers, it dependson the size of the place receiving the
wastewater.
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Besides SIUs, POTWs may
decide to focus on other usersor groups of users such as:
HospitalsPhoto processors
Dry cleaners
LaundriesAuto body shops
Dentists
GaragesGas Stations
Restaurants
Landfill leachatePrinters
Car Washes
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And
Metal Finishers, a categoricalindustry
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Why?
Several small industries can have the impactof one large industry.
Over time, small discharges can degrade theconveyance system (low pH, blockages dueto FOG, pumping station failures)
If an industry is located at the end of a sewer
interceptor, the effect can be relatively quick.
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How does the programachieve its goals ?
Through the implementation ofpretreatment standards (usually
contained in local sewer useordinances):
Prohibited discharge standards
Federal categorical pretreatment standards Local Limits
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What are general prohibiteddischarge standards ?
Forbid the discharge of pollutants that willpass-through the treatment plantuntreated or will interfere with theoperation of the treatment plant.
Tied to violation of the treatment plantsNPDES permit.
h f h b d
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What are specific prohibiteddischarge standards ?
Forbid the discharge of certainpollutants or the release of wastewater
with certain characteristics.
h ifi hibi d
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What are specific prohibiteddischarge standards ?
Create a fire or explosion hazard in thePOTW;
Have a closed-cup flashpoint of lessthan 140 degrees Fahrenheit;
Have a pH less than 5.0;
Solid or viscous substances that willobstruct flow and create interference;
Wh ifi hibi d
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What are specific prohibiteddischarge standards ?
Flow rates and/or concentrations that willcreate interference
Increase temperature at introduction intotreatment plant greater than 104 degreesFahrenheit;
Petroleum oil, non-biodegradable cutting oil
or products of mineral oil origin in amountsthat create interference or pass-through.
Wh t ifi hibit d
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What are specific prohibiteddischarge standards ?
Result in the presence of toxic gases,vapors or fumes;
Trucked or hauled pollutants, except atdesignated points.
Wh t f d l t i l
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What are federal categoricalpretreatment standards ?
Any regulation containing pollutantdischarge limits promulgated by EPA in
accordance with the Clean Water Actwhich apply to a specific category ofusers and appear in 40 CFR, Chapter I,
Subchapter N, Parts 405-471.
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What are local limits ?
Limits developed by the local sewerauthority to protect the POTW, its
personnel, the receiving stream and thesludge.
Local limits can increase efficiency of
the process and help the POTW to cuttreatment costs.
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What are local limits ?
Local limits apply to a specificwastewater treatment plant taking into
account local conditions such as thetype of treatment, type of conveyancesystem, local industrial/commercialusers, local water quality standards andlocal sludge standards.
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What are local limits ?
Can be developed for conventionalpollutants (BOD, TSS, COD, oil and
grease, total petroleum hydrocarbons,pH, phosphorus)
Can be developed for toxic pollutants
(metals, cyanide, organics)
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Need for local limits
Categorical standards do not address allpollutants.
Do not address many toxics. Do not address many conventional
pollutants.
Do not address all significant industrialusers.
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Need for local limits
As a result, categorical standards willnot adequately protect the POTW.
H th t d d
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How are these standardsapplied?
Through the issuance of an industrialuser permit with specific and general
requirements.
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How is compliance tested ?
Inspections and compliance monitoringperformed by the local authority.
Self-monitoring and reportingperformed by the industrial user.
Enforcement.
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Remember:
"Life is like a sewer. What you get
out of it depends on what you put
into it."
Tom Lehrer.
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Any questions ?
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Contact Information
Gary F. Kelman
Maryland State Pretreatment Coordinator
Industrial Discharge Permit Division
Water Management Administration
Maryland Department of the Environment
1800 Washington Blvd. Suite 455
Baltimore, Maryland 21230-1708 410-531-3630 or [email protected]
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