Industrial Pretreatment Program

The Industrial Pretreatment Section

The Industrial Pretreatment Section administers and enforces the Federal Pretreatment Regulations and Local Limits for the City of Abilene Wastewater Treatment Plant. The Industrial Pretreatment Section has fourteen permitted Industrial Users. One of the issued permits covers an EPA Categorical Industrial User. Thirteen permits have been issued to facilities deemed to be either Significant or Non-significant Industrial Users by the section and are covered by local limits.

The Industrial Pretreatment section continuously performs inspections of new and existing facilities in the service area to determine if they have processes defined by EPA as Categorical or if they discharge industrial wastewater, which may be deemed significant, to the Abilene Wastewater Treatment Plant.

The Industrial Pretreatment Section is composed of an Industrial Waste Manager/Pretreatment Coordinator and one Industrial Pretreatment Technician.

Industrial Waste Manager & Pretreatment Coordinator

Larry Baily is involved with the day-to-day management of the Pretreatment Program. His responsibilities include:

• Correspondence
• Data entry
• Enforcement
• Inspections
• Permit writing
• Regulatory review

He is also involved with sampling activities and other environmental projects.

If you or your environmental staff have any regulatory questions, would like to discuss any environmental issues, or need assistance finding an appropriate contact at the State or Federal level, the Industrial Pretreatment Section would be happy to assist you. You may contact us by phone at (325) 676-6042 or email Larry Bailey.

The Industrial Pretreatment Program & The Federal Water Pollution Control Act

The Industrial Pretreatment Program began in 1972 when the Federal Government passed the Federal Water Pollution Control Act amendments (FWPCA) into law. The major objective as stated in the Act was to restore and maintain the chemical, physical and biological integrity of the Nation's waters. The FWPCA called for the Environmental Protection Agency (EPA) to set the basic structure for regulating discharges of pollutants to waters of the United States.

In addition, the Act made it national policy to assist Publicly Owned Treatment Works (POTWs) with federal construction grants. In return for the federal assistance, the POTWs were required to accept certain conditions including the creation of "pretreatment" systems for controlling industrial discharges which would harm a POTW, interfere with its processes and/or pass through the POTW to pollute the receiving waters. EPA had the authority from these amendments to issue a permit to every "point source" in the nation. However, due to the number of industries and the complexity of the regulations, EPA had a difficult time with implementation of the regulations.

Discharge Standards

The EPA enforced two sets of discharge standards: Categorical Standards and Prohibited Discharge Standards. Categorical Standards are organized by the type of industry and the processes they use in their facility. These processes are defined by EPA and the volume of discharge from this process is not taken into consideration.

If an industry uses the defined process, then it must comply with the categorical standard. Since 1972, the EPA has defined and promulgated approximately 51 different categorical standards. The Metal Finishing category is one example of a categorical standard.

The Prohibited Discharge Standards prohibit any discharge to sewer systems of certain types of wastes from all point sources. An example is the discharge prohibition of any hazardous waste as defined in 40 Code of Federal Regulations (CFR) 261. The prohibited standards can be found in your permit.

Domestic Sewage Study Regulations

Although the Clean Water Act was amended in the 1980s a couple of times for minor changes, the major amendment occurred in 1990. Commonly referred to as the Domestic Sewage Study regulations, the Clean Water Act was amended to assure that POTWs were not used improperly for disposal of hazardous waste.

The amendments required local pretreatment programs to incorporate new requirements. The new requirements included a new definition of a Significant Industrial User (SIU). An SIU is a facility, which discharges wastewater that has been defined by EPA as categorical or deemed significant by the local pretreatment program. Other new requirements included:

• Additional prohibitive standards,
• A prohibition against trucked or hauled wastes, except at specifically designated locations,
• A requirement to publish facilities determined to be in Significant Noncompliance,
• A listing of minimum elements required to be in Wastewater Contribution permits,
• A requirement for industrial users to notify the EPA and the state Hazardous Waste division of any discharges to the POTW of any substance, which if otherwise disposed of, would be a hazardous waste,
• A requirement that POTWs must evaluate the SIUs to determine if these users need plans for the control and prevention of slug discharges,
• A requirement to develop a formal Enforcement Response Plan, this plan contains detailed procedures indicating how a POTW will investigate and respond to instances of industrial noncompliance.