The Basics

WHAT IS PRETREATMENT?• The term PRETREATMENT means the treatment of

wastewater by commercial and industrial facilities to remove harmful pollutants before being discharged to a sewer system.

• POTWs are designed to treat sanitary wastes from households, but not to treat toxic pollutants. The toxic pollutants from industrial and commercial facilities may cause serious problems at POTWs. Problems may be prevented by: – Recycling– waste minimization– chemical substitution– Pretreatment – Best Management Practices to reduce or eliminate the

pollutants from commercial or industrial facilities.

CLEAN WATER ACTCLEAN WATER ACTThe Clean Water Act became law in 1972. The Clean Water Act became law in 1972.

The National goal is:The National goal is:Eliminate pollutants in navigable watersEliminate pollutants in navigable watersProtect fish, shellfish and wildlifeProtect fish, shellfish and wildlifeProhibit discharge of toxic Prohibit discharge of toxic pollutants in toxic amountspollutants in toxic amounts

Cuyehoga River (Ohio-1969)- The river that caught fire. The fire -- a flare-up of oil-soaked debris likely ignited by either molten steel or a spark from a passing rail car Described as the river that "oozes rather than flows" and in which a person "does not drown but decays." Erupted in fire at least 13 times.

WHY DO WE NEED PRETREATMENT PROGRAMS?

Objectives of the Pretreatment ProgramBy placing controls and/or limits on levels of certain

pollutants in wastewater discharged to your sewer system, you:

• prevent interference with the operation of your wastewater treatment plant

• prevent the introduction of pollutants that could pass through your wastewater treatment plant untreated into the receiving body of water

• improve opportunities for reuse or recycling of wastewater and sewage sludge

• prevent the introduction of pollutants that could cause health or safety problems to the public or the environment

Prevent Interference – Prevent harmful effects that toxic industrial

compounds can have on POTW operations (killing or inhibiting beneficial microorganisms) – Interferes with POTW’s ability to meet NPDES permit requirements.

• Heavy metals (copper, nickel, lead, zinc, mercury)

• Organics (methylene chloride, tetrachlorethylene (TCE), acetone, gasoline…

Pass Through• Pass through

– Caffeine, which was the highest-volume pollutant– Nicotine– Personal care products

• sunscreen agents• synthetic musks

– Pharmaceuticals• Codeine• Cholesterol-lowering agents,• Anti-depressants• Estrogen replacement drugs-endocrine disrupters• Chemotherapy agents• Antibiotics - pathogen resistance

Prevent SANITARY SEWER OVERFLOWS• Prevent Sewer overflows – sewage, oil

grease.

SSO photo – Raleigh, North Carolina

SSOs• Untreated sewage released to the

environment.• Threat to public health - Pathogenic

organisms.• Affects aquatic life, surface water,

recreational water.• Clean-up is costly.

SEWER BACK-UP COSTS 2004 - 2007

$5,463 $2,904 $2,728

$68,897

$8,203$15,895

$0$653

3

10

54

11

$0

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

2004 2005 2006 2007

YEAR

CIT

Y'S

CO

STS

# Sewer Back-upsClaimsCollection crew costs

Food Service Establishments• Restaurants, schools, hospitals, correctional facilities,

retirement homes, convenience stores, bakeries, delis.

• Meats• Dairy Products-milk, cheese, sour cream.• Soups/gravy• Mayonnaise• Fried food

Effects of FOG Monitoring• Decreased # of sewer back-ups

• Decreased preventative maintenance to “hot spots”

• Overall decrease in amount of strong waste fees charged businesses/industries.

WASTEWATER INFRASTRUCTURE

• Extend life of wastewater infrastructure– controls on corrosives and pipe-damaging liquids– low pH – NO discharges with pH of <5.5– Hydrogen sulfide

Prohibited Discharges

Pollutants that could cause fire/explosion Pollutants that cause corrosive structural damage

(never less that 5.0) Pollutants causing obstruction Discharges of oils that could cause interference Discharges of toxic gases that could cause health

and safety issues Illicit discharges of trucked or hauled pollutants

Worker safetyWorker safety

Prevent formation of Prevent formation of dangerous conditions dangerous conditions such as toxic vapors and such as toxic vapors and

depleted oxygen levels depleted oxygen levels within the POTW and the within the POTW and the collection system.collection system.

1950’s London sewer worker

POTW Pretreatment Program POTW Pretreatment Program RequirementsRequirements

Legal AuthorityLegal Authority Ability to deny or condition discharges Ability to deny or condition discharges

to POTWto POTW Require compliance with Pretreatment Require compliance with Pretreatment

StdsStds Control industrial discharges through Control industrial discharges through

permits, compliance orderspermits, compliance orders Inspect Industrial UsersInspect Industrial Users Comply with confidentiality stdsComply with confidentiality stds

GENERAL PRETREATMENT REGULATIONS

The General Pretreatment Regulations apply to all non-domestic sources that introduce pollutants into a POTW.

An SIU is defined in 40 CFR 403.3 as:• An IU subject to federal categorical pretreatment standards

OR• An IU that discharges an average of 25,000 gallons per day (gpd)

or more of process wastewater to the POTW • An IU that contributes a process wastestream making up 5 percent

or more of the average dry-weather hydraulic or organic capacity of the POTW treatment plant

• An IU designated by the POTW as such because of its reasonable potential to adversely affect the POTW's operation or violate any pretreatment standard or requirement.

How do you locate area Industrial Users?

• Business licenses – all new and repeat business license applications are required to submit an IW survey.

• Telephone directory• Search internet• Drive-bys• Utility bills – check volume of discharge

Procedures• Identify and locate IUs subject to the PT program• Identify the character and volume of discharge• Notify IU of pretreatment stds and requirements• Receive and analyze reports• Sample and evaluate IU discharges• Evaluate the need for a spill/slugload plan• Investigate non-compliance• Comply with public participation

FUNDING

• The POTW must have sufficient funds to carry out the authorities and procedures– Permit fees – based on WAC 173-224– Sampling fees– Testing fees– Sewer Pretreatment charges

Enforcement Response Plan

• Develop and implement an ERP that contains procedures indicating how the POTW will investigate and respond to IU noncompliance.– Verbal notification– Warning letters– Notice of Violation– Administrative Order with penalty

City of Yakima Pretreatment Program• Fully delegated by Ecology in 2003.• Staffing

– Pretreatment Supervisor– Environmental Compliance Specialist – Permit

writer/Safety officer– 2 Pretreatment crew leaders– 3 Pretreatment technicians

Success Stories• Yakima County Jail

– Large volume of solids discharged: Clothing, bedding, oranges, Styrofoam cups.

– County was billed for additional sewer maintenance (monthly cleaning of sewer lines)

– Compliance schedule• Installed grinders / holding tanks

Oil Distributor• Fuel oil discharged to sewer cleanout

– Customer contacted WW because she received a door hanger invoice…

– Issued a Notice of Violation plus billed for oil removal/clean-up at plant.

– Safety Kleen vactored oil/water separator– Microcat – “Microbial Catalyst”

Product of adapted microorganisms and enzymes for use in sewer systems.

Hops Extraction• Slugloads in 2007 and 2011.• Billed for labor and replacement parts.• Administrative Order with Penalty in 2011.

Compliance Plan…monthly reports.

Rags• Continuing Issue• Public awareness/education

– Newspaper articles/interviews– Informational letters/brochures– Rag Chains in main lines

Low pH – Beverage Bottling• Headworks low pH – Swing/Graveyard shift• Set-up continuous pH monitoring in major lines.• Identified general location – Beverage canning

facility. From May 14-17, 4,455 pHs readings were recorded. Of these, 668 pHs were below the local limit of 5.5. There appears to be a trend from about midnight to 2 AM where the pH is below 5.5.

• Cleaning solution used during evening and graveyard shifts caused drop in pH.

Potato Chip/Apple Chip Processor

1592

2184

1257

1672

560367 309

133

1027859

166 185 72

5195

4180

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

5500

2003 2004 2005 2006 2007

Year

Con

cent

ratio

n (m

g/L)

BOD

TSS

FOG

•Installation of two dissolved air floatation systems (DAFs) over a four year period.

•Average FOG concentration decreased from 1027 mg/L in 2003 to 8 mg/L in 2010. (49 mg/L in 2011…violation of 225 mg/L – ran out of polymer for DAF.

•Strong waste charges decreased from $220,000 to $35,000.

BENEFITS OF DELEGATED PRETREATMENT PROGRAM?

• The ability to inspect and monitor industries• Receive DMRs to know the discharge volumes• Better understanding of industrial processes to

track violations• Permit fees

QUESTIONS?