Pretreatment Program

What is pretreatment?

Industrial wastewater is often contaminated by a variety of harmful substances (such as industrial process by-products, like copper, lead, nickel and other heavy metals). Because sewage collection and treatment systems are not designed to remove these substances, industrial wastes can damage sewers and interfere with the operation of treatment plants; pass through the systems untreated, resulting in pollution of nearby waters; and increase the costs and environmental risks of sludge management. The practice of removing pollutants from industrial wastewaters before they are discharged into municipal sewage treatment systems is known as "pretreatment." In focusing on industrial sources, pretreatment differs from pollution prevention, which focuses on residential and commercial sources.

The General Pretreatment Regulations at 40 CFR 403.1 et seq. establish the responsibilities of government agencies, industries, and the public to implement pretreatment standards to control industrial pollutants that may pass through or interfere with publicly owned treatment works (POTWs), or contaminate sewage sludge.

What are pretreatment requirements?

In 1978, U.S. EPA promulgated extensive regulations requiring many POTWs to develop and implement local pretreatment programs. U.S. EPA delegated the responsibility to oversee these pretreatment programs to the State Water Board and Regional Water Boards in 1989. As a result, the State and Regional Water Boards are responsible for the review and approval of new and modified POTW pretreatment programs. In the San Francisco Bay Region, there are about 25 local pretreatment programs. The NPDES permits for these POTWs spell out the pretreatment program monitoring and reporting requirements.

POTWs are required to have pretreatment programs when their total design flows are greater than five million gallons per day (5 mgd) and they receive industrial pollutants that could pass through or interfere with POTW operations. POTWs with smaller flows (5 mgd or less) may also be required to implement a pretreatment program if they receive industrial waste and pretreatment is warranted.

How does the Regional Water Board oversee pretreatment compliance?

The Regional Water Board's pretreatment program includes pretreatment compliance audits and inspections, annual and semiannual report reviews, program modifications, and enforcement activities.

Pretreatment compliance inspections verify the compliance status of POTWs, focusing on the POTW's own compliance monitoring and enforcement activities. Pretreatment compliance audits involve a comprehensive review of all elements of a POTW's pretreatment program. Audits take place every five years. Inspections usually occur every year, except when an audit is scheduled.

What agencies have been recognized for pretreatment excellence?

Since 1989, the U.S. Environmental Protection Agency has recognized pretreatment excellence through its annual Pretreatment Program Excellence Awards. Many agencies in the San Francisco Bay Region have received the award. Applications for future awards are available from the U.S. Environmental Protection Agency.