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Beneath the streets of every city, a system of sewers and pumps conveys wastewater away from homes and businesses. This wastewater can contain domestic, commercial, and industrial wastes. The sewer and pump systems that convey wastewater are known as municipal sanitary sewers, and wastewater flows through sewers to a wastewater treatment plant. There, pollutants are removed and the cleansed water is discharged into a nearby waterbody. The residues of the wastewater treatment process (once called sludges, now known as biosolids) are either used productively as a soil conditioner or disposed of as a solid waste.
Industrial facilities are one of the sources of wastewater discharged to municipal sanitary sewers. Industrial wastewater often contains toxic substances and it can pose serious hazards.
Because municipal sewage treatment systems are not designed to treat industrial wastes, these wastes can damage sewers and interfere with treatment plants. Industrial wastes can increase the costs and risks of biosolids treatment and disposal, and can pass through municipal systems untreated, resulting in contamination of waterbodies.
The undesirable effects resulting from the discharge of industrial wastewater to municipal sewers can be prevented. Industrial plants, using proven pollution control technologies, can remove significant amounts of pollutants from their wastewater before discharging it to the municipal sewage treatment system. This practice is known as "pretreatment."
Below is a list of potential problems that can arise from the disposal of industrial wastes.
For questions regarding pretreatment, please contact Ben Hucka at 515/725-8406 or Ben.Hucka@dnr.iowa.gov.
National pretreatment standards are uniform national requirements that restrict the level of pollutants in the wastewater from industries. These national standards consist of two sets of rules: "categorical pretreatment standards" and "prohibited discharge standards".
Categorical pretreatment standards: specific requirements for different industries, organized by type of industry. For example, the categorical standard for the iron and steel industry limits pollutants in wastewater discharged by any firm in that industry.
Prohibited discharge standards: prohibit any discharge to municipal sewer systems of certain types of wastes from all sources. For example, the discharge of any wastewater with pH lower than 5.0 is forbidden, since such wastes may corrode the sewer system.
Local pretreatment programs are established by municipalities based on the National Pretreatment Program. The framework for the National Pretreatment Program is contained in EPA's General Pretreatment Regulations. States that have NPDES authority, like Iowa, are required to develop state pretreatment programs for EPA approval. States can be granted pretreatment authority by demonstrating that their program meets all federal requirements. Iowa was delegated pretreatment authority by EPA in 1982.
In a state with pretreatment delegation, large publicly owned treatment works (POTWs) with a design flow more than 5 MGD and smaller POTWs with significant industrial discharges must establish local pretreatment programs. These local pretreatment programs may impose more stringent discharge requirements (local limits) to prevent disruption of the sewage treatment system, adverse environmental impacts, or disruption of biosolids use or disposal. Local pretreatment programs must be approved by the delegated state.
If a POTW does not have an approved local pretreatment program, the national pretreatment standards are enforced by the state. Industries in cities that have not established a local pretreatment program often need to establish a Treatment Agreement with the city. For more information regarding treatment agreements between cities and industries, see the Treatment Agreements page.
To gain approval for a local program, a POTW must prepare several documents for state review. These documents must meet the requirements for local pretreatment programs in 40 CFR 403 and must contain the following elements:
For more information on each of the local pretreatment program elements, see the discussion below.
A local pretreatment program must have four building blocks to succeed. These building blocks are:
Legal Authority - A POTW must have the legal authority to implement a local pretreatment program based on state law and local ordinances. State law authorizes municipalities to regulate industrial users of municipal sewage systems, and a municipality can establish a local ordinance for its program. The legal authority granted by state and local law must authorize the POTW to:
Industrial User Information Base - A POTW must develop a comprehensive database describing its industrial discharges. The database will record pollutant levels in wastewater samples to allow for the automatic detection of violations. Industrial user databases can be used by a POTW to determine the source of problems, to calculate local limits, and to plan for expansions.
Staffing - A local pretreatment program requires adequate staffing. Personnel are required for monitoring, inspections, laboratory analysis, technical assistance, legal assistance, and program administration. The required personnel depend upon the size of the sewage district, the number of industrial users, and POTW policies.
Funding - Funding for a local pretreatment program may be included in a POTW's budget or recovered through industrial user fees or charges. Fees can be based on the amount of POTW services required by an industry, the flow from an industry, or the pollutants discharged by an industry.
A POTW must develop effluent limitations for each industrial facility covered by the local pretreatment program. The effluent limitations may consist of federal standards, local limits, or both. Industrial facilities must comply with federal prohibited discharge standards and applicable federal categorical standards. The POTW may establish local limits more stringent than, or in addition to, the federal standards for some or all of its industrial users.
To identify the need for and the nature of local limits, a POTW must determine if any public health or environmental problems will exist even with full enforcement of the federal pretreatment standards. This determination addresses the following issues:
The calculations must consider the level of pollutants already present, the chemical decomposition of pollutants, and the need to accommodate future industrial growth.
To implement the effluent limits established in their local pretreatment programs, POTWs must undertake the following activities:
Notification - Industrial facilities in cities with local pretreatment programs must be notified of the applicable effluent limits. The effluent limits are incorporated in a pretreatment permit issued by the POTW to the industrial facility.
Permit Administration - POTWs must ensure that industries comply with the effluent limits in their pretreatment permits. To ensure compliance, a POTW will identify sampling locations at an industrial facility and will specify effluent limits for each location. In addition, industries must be required by the POTW to submit monitoring reports at least twice per year.
Inspections & Monitoring Visits - POTWs must inspect and informally visit permitted industrial facilities. Discharge volume and toxicity can be used to determine the timing of inspections and visits. The POTW must conduct both regular and unannounced visits to collect samples. Violations, complaints, or suspected hazardous materials may also trigger an inspection or visit.
Enforcement - If an industrial facility violates its pretreatment permit, the POTW will take enforcement action after verifying the violation. Once a violation is confirmed, the violating facility will be required to comply within a specified period. If compliance deadlines are not met, civil and/or criminal proceedings may be initialed by the POTW.
A local pretreatment program is a public service to protect the public health and environmental quality of a community. Public support for a local pretreatment program depends on public's ability to participate in and access information on the local program. The POTW must hold meetings and work with industries and the community to define the objectives and benefits of the local program. When local limits are developed or revised, all interested parties must be notified and invited to comment.
In general, all information collected by a POTW on industrial dischargers is available to the public and to government agencies. However, if an industry can demonstrate that the release of information would divulge trade secrets, certain records can be labeled as confidential and withheld from the public. Nevertheless, effluent data is always available to the public without restriction. In addition, POTWs must inform the public whenever a significant violation occurs, and must annually publish the names of industries that significantly violated the pretreatment standards during the previous year.