Municipalities and Districts wanting to undertake a voluntary pretreatment program will develop an overall approach for the program to ensure all the pieces fit together well and match the needs of the community and provide an easily understood program for commercial and industrial customers.
For many communities, there may be other benefits and goals associated with implementing a voluntary pretreatment program. Developing a logical and systematic approach to developing a voluntary pretreatment program will be useful in approaching this as a project and allow the municipality to involve all stakeholders.
To develop a voluntary pretreatment program, these typical activities will be necessary, in this order:
- Obtain support from municipal managers to develop and implement a voluntary pretreatment program. Include an estimate of needed resources to develop and implement a pretreatment program. (see Project Plan)
- Review the existing local sewer use regulations and draft a local ordinance to control pollutants from businesses and industry with a voluntary pretreatment program. (See Developing a Local Ordinance)
- Establish a list of required activities and documents to be developed. (see Developing an Overall Approach)
- Evaluate the need to establish local limits and Best Management Practices (BMPs) that would be applied to specific commercial and industrial users and incorporated into the municipal legal authority. The Fats, Oil and Grease (FOG) program would be an example of a BMP program. (See Control Mechanisms to Control Industrial Users)
- Develop a process for compiling a list of businesses that discharge to the POTW and a listing of any other jurisdictions that contribute wastewater to the POTW through agreements. (See Conducting an Industrial Survey)
- Decide how the municipality will provide education and outreach to the commercial and industrial users that may be impacted by the voluntary pretreatment program. (See Education and Outreach for Affected Businesses)
- Develop the specific forms and procedures that are needed to implement the program. Examples include industrial waste survey forms, permits and other types of control documents, POTW monitoring procedures, inspection forms, a method for data and file management, and any enforcement-related procedures that are needed. (See Mechanisms to Control Industrial Users)
- Adopt the revised municipal legal authority and establish an implementation schedule. (See Developing a Local Ordinance)
Tracking Program Progress and Success
Consider how you will track and report the success of the voluntary community-based pretreatment program to City leadership and the community. Some ideas for tracking program progress could include:
- Wastewater Treatment Plant Related Monitoring —Track monitoring data for key influent pollutants and Priority Pollutant screening, required quarterly for most Oregon NPDES permit holders. Using this information, update the Reasonable Potential Analysis spreadsheet for domestic facilities routinely to identify areas where there may be reasonable potential to exceed Oregon water quality standards and where there are opportunities for pollution prevention to prevent exceedances. Information on the DEQ RPA spreadsheet for domestic facilities is available online. (see ‘water quality’, (Reasonable Potential Analysis for Toxic Pollutants IMD, Revision 3.1 – Feb. 2012, Transmittal Memo for Reasonable Potential Analysis IMD – Aug. 2011, RPA Calculation Workbook, Domestic, Revision 3.4)
- Improved Biosolids Quality Data —Build and routinely update spreadsheets tracking biosolids quality data for all parameters with a focus on metal concentrations. Where concentrations of metals are increasing, investigate further and develop an action plan to reduce metals concentrations.
- Reducing System Maintenance Costs by Controlling FOG —Develop and track metrics related to collection system maintenance costs and effective FOG control programs. Communities track FOG related maintenance costs in a number of ways including:
- Number of miles of collection system lines that are having to be cleaned more frequently than scheduled
- Reduction in number of overflows due to grease blockages
- Reduction in number of after-hours call outs due to grease blockages
- Improved Overall Knowledge of the Industrial Discharge Base —Communities working collaboratively with their commercial and industrial customers can identify ways to assist in pollution prevention on a routine basis as a way to stabilize sewer costs. Knowledge of the industrial base can be an effective tool to resolve problems before they occur, such as the opportunity for controlling unwanted high strength loading to the treatment plant, or preventing inadvertent slug discharges.