Industrial Pretreatment

The first Federal pretreatment regulations were established in 1972 under Section 307 (b) of the Clean Water Act (Public Law 92-500).

Initially, these regulations controlled only conventional pollutants such as pH, oil & grease, biochemical oxygen demand (BOD), and suspended solids. In 1976, the National Resources Defense Council brought suit against the Environmental Protection Agency (EPA). As a result of this suit, the EPA shifted it's regulation focus from conventional pollutants to toxic waste.

An industrial pretreatment program, governed by EPA, implemented by the EPA, the State, or local municipalities, has a primary goal to protect Wastewater Facilities (WWF), and the environment, from adverse effects when toxic wastes are discharged into a collection (sewage) system. This protection is achieved by regulating the non-domestic users (commercial and industrial entities) of WWF's that discharge toxic or potentially toxic wastes. These sources, regulated through permit issuance containing discharge limitations (Federal, State, and local) are known as industrial users. 

Industrial User's (IU's) permits authorize the discharge of wastewater to a WWF under the stipulation that permit conditions are followed. An industrial user permit is valid for a finite period of time (in Lake City, one to five years) and is revocable by the Control Authority (City of Lake City (City), in this case) at any time, for just cause. 

A typical industrial user permit contains all of the requirements of the permittee. This criteria includes prohibited/conditional discharges, Federal/local limitations, and monitoring/reporting requirements.

Prohibited/conditional discharges of pollutants apply to materials that:

  • create an explosion/fire 
  • are corrosive (<5.5 pH >9.5) 
  • interfere with flow in the sewage system 
  • upset the WWF
  • considerably increase the temperature of wastewater entering the collection system

Federal/local limitations are developed and enforced to protect the treatment facility and insure that the WWF's National Pollutant Discharge Elimination System (NPDES) permit would not be violated even if all IU's discharged the maximum allowable concentration of a particular parameter simultaneously. 

Monitoring/Reporting requirements are placed on those IU's that qualify as Significant Industrial Users (SIU's), by definition: 

All Categorical Industrial Users (industries classified by the EPA in accordance with their manufacturing/waste products) IU's. 

Any non-categorical IU that discharges at least an average of 25,000 gallons of process water per day, contributes a process wastestream that makes up at least five percent of the average dry weather capacity of a treatment plant, has a reasonable potential to adversely affect the WWF or collection system .

Self-Monitoring reports are required from all SIU's. SIU's are mandated to monitor their discharge effluent for specific parameters and at frequencies set in each industry's respective discharge permit. SIU's must report all monitoring data to the City no later than the fifteenth day of the month following sample collection and analysis. Further, all SIU's are required to notify the City within twenty-four hours of a known violation and resample for this non-compliant parameter within thirty days. In addition, all SIU's are subject to, at a minimum, semi-annual sampling/inspecting visits conducted by the City to ensure compliance. 

In 1997, the FDEP "approved" the City's industrial pretreatment program, granting the City the necessary authority to implement this program. 

The minimum implementation responsibilities are to: 

  • Identify all IU's and characterize their pollutant discharges 
  • Notify all IU's of applicable pretreatment standards 
  • Receive and review self-monitoring reports, as well as other correspondence 
  • Investigate instances of non-compliance and take appropriate enforcement action(s) 
  • Publish, at least annually, in the local newspaper, with the largest circulation, a list of those industries that are found to be in Significant Non-Compliance (SNC).

Instances of SNC are IU violations which meet one or more of the following criteria:

  • Violations of wastewater discharge limits. 
  • Discharges that can cause endangerment to life, or upset the WWF. 
  • Failing to adhere to a compliance schedule.
  • Failure to report promptly.
  • Any discharge that the City believes has the potential to have an adverse affect on the WWF.

As a means of identifying all IU's and characterizing their pollutant discharges, mailing/hand distribution of industrial wastewater questionnaires are being forwarded to all commercial/industrial facilities operating in the City to determine if process water is used, and subsequently discharged, into the City's collection system.

Once these surveys are received, the review process begins to determine if an industry needs to be permitted and, if so, what category (categorical, significant, minor, etc. based on manufacturing process and flow), to place an industry in. 

Once a permit is issued, the City is required to notify the permittee of all applicable pretreatment requirements, including changes in, and additions to, regulations. 

All instances of non-compliance, discovered either during review of self-monitoring reports or City scheduled sampling/inspecting rounds, must be addressed. The responses available to the City include informal phone contacts, written notices of violation, show-cause hearings, compliance schedules, administrative orders, penalties, judicial actions, and termination of sewer service. 

A notice of violation to the IU warns that the City has observed a violation of pretreatment standards or reporting requirements and expects the non-compliance to be corrected and explained in order to avoid additional enforcement action. 

At a show-cause hearing, the IU is presented with facts that the City believes, demonstrates non-compliance and is asked to "show cause" why the City should not initiate formal enforcement action. 

A compliance schedule, with milestone dates agreed to by the City and the IU, enforced by the City, represents the shortest schedule of the IU's actions to achieve compliance with pretreatment standards. 

An administrative order issued to an IU, demands compliance with pretreatment standards to avoid penalties and/or civil action. 

Penalties in the amount no less than one thousand dollars per violation per day, nor more than five thousand dollars per violation per day, may be assessed on any IU in accordance with the City's local sewer use ordinance. 

If the City believes that the IU is unlikely to successfully execute the steps necessary to achieve compliance, criminal action may be sought. 

The City has the authority, typically utilized as a last resort, to halt immediately any actual or threatened discharge that may represent an endangerment to public health, or the WWF. 

Through these continued efforts, the City will be able to achieved and maintain a vastly improved effluent quality at it's WWF.

Industrial Pretreatment Ordinance: You may obtain a copy of the Industrial Pretreatment Ordinance by contacting the City of Lake City PO Box 1687 Lake City, Fl 32056 or by calling (386) 752 - 2031.

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