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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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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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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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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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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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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]

kelman pretreatment 2003

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