Pretreatment and Local Source Control Program Tools
The Oregon Association of Clean Water Agencies (ACWA) would like to offer the assistance and experience of our Pretreatment Committee to assist the Oregon Department of Environmental Quality’s (DEQ) water quality standards Rulemaking Workgroup in developing programmatic tools to help municipalities reduce toxics generated from POTW indirect sources. The Committee represents twenty three DEQ approved programs (listed below) across the state of Oregon, with members having over 25 years of experience regulating and working with industrial and commercial users.
DEQ approved Programs:
City of Albany
City of Canby
Clackamas County Service District #1 (Water Environment Services)
Clean Water Services (Durham, Forest Grove, Hillsboro, Rock Creek)
City of Corvallis
City of Dallas
City of Grants Pass
City of Gresham
City of Klamath Falls
City of McMinnville
City of Medford
Metropolitan Wastewater Management Commission- Eugene
Metropolitan Wastewater Management Commission-Springfield
City of Newberg
City of Portland
Roseburg Urban Sanitary Authority
City of Salem
City of St. Helens
City of The Dalles
Tri-City Service District (Water Environment Services)
City of Troutdale
City of Wilsonville
City of Woodburn
Programs awaiting approval:
City of Bend
Oak Lodge Sanitary District
The Pretreatment Committee proposes to develop the details for a series of Toxics Reduction “tool boxes” in the coming months. The “tool boxes” will describe approaches that municipalities may implement to reduce the amount of toxic pollutants generated from indirect sources. This information may then form the basis for further informed discussion with the Rulemaking Workgroup. The “tool boxes” will be described by three areas:
❖ Pretreatment “Fact Sheet” that will describe the history, scope, foundation and program elements of a federally-mandated Pretreatment Program.
❖ Guidance document(s) for POTWs to implement “local”, or source control programs or activities based on EPA Pretreatment Program elements.
❖ Pollution Prevention tools, to implement a variety of regulatory and voluntary programs that may extend beyond source control.
Figure 1 illustrates the relationships of three major program areas that work synergistically in achieving the common goal of reducing pollutants of concern from entering POTWs.
Federal Industrial Pretreatment program
The National Pretreatment Program (as prescribed in 40 CFR 403 – General Pretreatment Regulations for Existing and New Sources) is a long-established federal program that provides for POTWs to systematically regulate and permit discharges from Significant Industrial Users. In Oregon, 23 POTWs have DEQ-approved programs in place.
Local Source Control program
A Local “Source Control” Program includes program elements, or “tools” that are drawn from the National Pretreatment Program that can be beneficial for a POTW that is not required to develop a federally-mandated Industrial Pretreatment Program. These tools would assist a smaller POTW to effectively locate, characterize and control the pollutants discharged from non-domestic sources.
A sewer use ordinance is the foundation for an effective local program and provides for:
❖ Establishing prohibitions and discharge standards
❖ Establishing authority for municipalities to:
o survey and evaluate non-domestic discharges
o issue control documents, such as permits or discharge authorization letters
o require monitoring and reporting from businesses, and
o enter and inspect facilities,
❖ Enforce in instances of non-compliance
Municipalities should consider local programs when:
❖ Effluent from municipal wastewater plant is not meeting water quality standards for certain pollutants
❖ There are industrial/commercial users within the POTW that have the potential to discharge high strength wastewater to the treatment plant
❖ There is an opportunity in the community to economically and effectively prevent pollutants from entering the sewer system
❖ There are industrial facilities in the community that are not classified as Significant Industrial Users, but discharge process or other non-domestic wastewater to the sanitary sewer
Pollution Prevention (P2)
Pollution Prevention (P2) tools incorporate a variety of regulatory and voluntary strategies to prevent pollutants from entering POTWs. Overseers of the National Pretreatment Program and Local Programs use P2 tools to address and control pollutants at the source.
Municipalities in the Pacific Northwest have implemented several pollution prevention programs that target specific pollutants. The programs, some mandated and others voluntary, have successfully resulted in the reduction of pollutants entering sanitary sewer systems and the environment.
❖ Mercury reduction using Amalgam separators and BMP requirements at dental facilities. Recycling programs for switches, bulbs and thermometers have resulted in the prevention of mercury from entering sewers.
❖ Silver reduction with requirements for photo developers in some municipalities to install silver recovery units and employing silver recovery BMP in dental practices prevent silver from entering sewers
❖ The pharmaceutical drug take back events and local programs prevent these drugs from entering our sewers and landfills. The 2010 Oregon state wide drug take back removed 3962 pounds of pharmaceuticals from entering these waste streams.
❖ The Ecological Business Certification program certifies businesses that go above and beyond regulatory requirements to implement P2 and sustainable business practices. Currently the Ecological Business program includes automotive services and landscape design, installation and maintenance (for more information, see www.ecobiz.org ).