HISTORY & IMPORTANCE OF

PRETREATMENT Presented by: Courtney Vanous

Industrial Pretreatment Coordinator

City of Carrollton

HISTORY

1899

Congress’ first step to protecting national waters

Known as the “Refuse Act”-intended to protect

navigation

Prohibited discharges without a permit except from

streets and sewers

Basically, don’t throw large stuff in the water that would

impede boat traffic

HISTORY CONTINUED

1948 Water Pollution Control Act

1962 Silent Spring

1965 Water Quality Standards

1969 Cuyahoga fire

1970 EPA established

1972 & 1977 NPDES Program established

1977 Clean Water Act A fire tug fights flames on the Cuyahoga River near

downtown Cleveland on June 25, 1952, Photo by AP

Image as published in Time Magazine

HIERARCHY

EPA • Environmental Protection Agency

TCEQ • Texas Commission on Environmental Quality

TRA • Trinity River Authority

City • City of Carrollton

PRETREATMENT PROGRAMS

Point source vs. Non-point source

Discharged water is later used as drinking water

Wastewater treatment designed for domestic wastewater

Goals:

Prevent interference

Prevent pass through

Improve opportunities to reuse sludge and wastewater

Secondary Goals:

Worker safety

Protect drinking water

Extend life of infrastructure

Protect drinking water sources

PERMITTED & NON-PERMITTED FACILITIES

What causes a facility to be permitted? Discharge over 25,000 gallons per day of process wastewater

Excludes noncontact cooling water

Excludes boiler blowdown

Excludes domestic sewage

Facility subject to the categorical pretreatment standards

Facility that is designated a significant industrial user because of a

“reasonable potential” for a facility to affect the POTW or violate

any pretreatment standard or requirement.

Monitored facilities

Other industries

CATEGORICAL FACILITIES CATEGORY 40 CFR PART CATEGORY 40 CFR PART

Aluminum Forming 467[7] Battery Manufacturing 461[8]

Carbon Black Manufacturing (New

Sources Only) 458[9] Centralized Waste Treatment 437[10]

Coil Coating 465[11] Copper Forming 468[12]

Electrical & Electronic Components 469[13] Electroplating 413[14]

Concentrated Animal Feeding

Operations (New Sources Only) 412[15]

Fertilizer Manufacturing (New Sources

Only) 418[16]

Glass Manufacturing (New Sources Only) 426[17] Grain Mills (New Sources Only) 406[18]

[19]Ink Formulating (New Sources Only) 447[20] Inorganic Chemicals Manufacturing 415[21]

Iron & Steel Manufacturing 420[22] Leather Tanning & Finishing 425[23]

Metal Finishing 433[24] Metal Molding & Casting 464[25]

[26]Nonferrous Metals Forming and

Metal Powders 471[27] Nonferrous Metal Manufacturing 421[28]

Oil & Gas Extraction 435[29] Organic Chemicals, Plastics & Synthetic

Fibers 414[30]

Paint Formulating (New Sources Only) 446[31] Paving & Roofing (Tars and Asphalt) 443[32]

Petroleum Refining 419[33] Pesticide Chemicals 455[34]

Pharmaceuticals Manufacturing 439[35] Porcelain Enameling 466[36]

Pulp, Paper & Paperboard 430[37] Rubber Manufacturing (New Sources

Only) 428[38]

Soap & Detergent Manufacturing (New

Sources Only) 417[39] Steam Electric Power Generating 423[40]

Timber Products Processing 429[41] Transportation Equipment Cleaning 442

CATEGORICAL LIMITS

Sample at end of process

OR

Use combined wastestream formula

Must monitor process vs. dilution flows

Each category has specific limits and requirements

Most Carrollton Facilities fall under “pretreatment standards for new sources”

Examples: Metal Finishing: https://www.epa.gov/eg/metal-finishing-effluent-guidelines

Pharmaceutical: https://www.epa.gov/eg/pharmaceutical-manufacturing-effluent-guidelines

LOCAL LIMITS AND SAMPLING

Local limits – “end of pipe”

Sampling done without

knowledge of facility

Port access, security, and design

Arsenic 0.2

Cadmium 0.1

Chromium 2.9

Copper 2.3

Cyanide 0.5

Lead 0.9

Mercury 0.0004

Molybdenum 0.8

Nickel 4.6

Selenium 0.1

Silver 0.8

Zinc 8.0

Oil and Grease 200

TTO 2.13

TPH 200

BTEX 2.13

BOD5 250*

TSS 250*

COD 625*

pH 5.5 – 11.0

SURCHARGES

Based on TSS and BOD5 results above 250 mg/l

Letter sent semi-annually to notify of new surcharge factor

Surcharge = (Q) {Surcharge Multiplier}

Surcharge = (Q) {(0.001) (8.34) [a(BOD-250) + b(TSS-250)] (c)}

Q Wastewater Flow, 100,00gal/mo

0.001

Conversion Factor, Mgal/mo to

MMgal/mo

8.34

Conversion Factor, mg/L to

lb/MMgal

0.06978 a = $/lb BOD Unit Charge

0.08421 b = $/lb TSS Unit Charge

1.3 c = CoC Admin Overhead Factor

BOD Averaged from Sample Testing 250

TSS Averaged from Sample Testing 250

OTHER SELECTED PROHIBITIONS

Pollutants that create a fire or explosion hazard – waste streams

with a closed-cup flashpoint > 140 F

Solid or viscous substances that will cause obstruction of the

wastewater flow

Wastewater above 150 F

Pollutants resulting in toxic gases, fumes, vapors that could cause

acute health and safety problems

Wastewater that has color that cannot be removed at the plant

Stormwater, ground water, roof runoff, unless authorized by

DCO

Wastewater sludge

Detergents that cause foaming

DE-RAGGING A TRA LIFT STATION

FOG CLOGGING PIPE

SANITARY SEWER OVERFLOW (SSO)

BUILD UP OF SEWER GASSES

FIRE CAUSED BY ILLEGAL DISCHARGE

EFFECT ON WILDLIFE AND WATERS