PURPOSE – An Introduction
This Community-Based Voluntary Pretreatment Program tool is intended to assist Oregon municipalities that do not have a DEQ/EPA-approved pretreatment program to identify industrial users, develop a streamlined pretreatment local legal authority, and to provide the basic procedures and forms to assist in controlling commercial and industrial user discharges that may impact the treatment works and collection system. The municipality will find this information useful for protecting wastewater treatment plant operations and the collection system and will allow the POTW to evaluate its discharge against Oregon’s Water Quality Standards.
Voluntary Pretreatment Program – An Element of Good Utility Management
Information about commercial and industrial discharges into the sewerage system is good information for all utilities.
Wastewater treatment plants have a variety of regulatory and utility management reasons for undertaking a community-based, voluntary industrial pretreatment program including:
- Extending the life of the wastewater treatment plant and collection system.
- Expanding the types of businesses that can be recruited for economic development.
- Maintaining high-quality biosolids for beneficial reuse
- Allowing the municipality or district to develop Best Management Practices (BMPs) for similar businesses
- Assisting in investigating Whole Effluent Toxicity (WET) test failures
- Supporting the implementation of pollution prevention plans as part of a water quality variance application
- Protecting employees in the collection system and at the treatment plant
- Assuring that public investment in the sewerage system is equally distributed among the dischargers.
The ACWA Pretreatment Committee is an excellent resource for municipalities wanting to put a voluntary pretreatment program in place. Contact the Pretreatment Committee through the ACWA office.
Pollution Prevention Focus to Meet Permit Limits
Oregon has some of the most stringent Water Quality Standards in the nation for pollutants that may adversely affect human health and fisheries. These Standards, adopted in 2011, are used to set effluent limits for municipal POTWs that discharge to Oregon’s rivers, lakes and streams. Once a POTW has a water quality-based permit limit in its Oregon National Pollutant Discharge Elimination System (NPDES) permit, that limit, with very few exceptions, will always be in the permit.
POTWs are designed to breakdown and treat domestic wastewater. Many smaller POTWs have few controls on what is discharged to the POTW by commercial and industrial users. A variety of pollutants that are toxic to fisheries and other aquatic life or impact the POTW collection system are routinely discharged by businesses and residences. Sinks and drains routinely receive problem pollutants used for cleaning, personal care products, Fats, Oil & Grease (FOG), petroleum compounds, and other materials. A focus on pollution prevention activities and Best Management Practices (BMPs) are the most environmentally sound and cost-effective ways to reduce concentrations of toxins received by the POTW and are discharged to Oregon’s rivers and streams.
Municipalities should be routinely updating the Reasonable Potential Analysis (RPA) spreadsheet developed by DEQ with their quarterly toxics monitoring data to determine if water quality effluent limits might be exceeded and evaluating if pretreatment program might be a useful compliance tool. The Oregon DEQ RPA spreadsheet is available on the State website.
Business Recruitment Tool
Under federal regulations, a local community must develop and implement a formal, Oregon DEQ approved pretreatment program when the municipality accepts discharges from specific categories of industrial users or the flow of the POTW exceeds 5 Million Gallons per Day (MGD). In addition, where a municipality experiences significant Sanitary Sewer Overflows (SSOs) due to non-domestic users or there are other instances of interference or pass through of pollutants, Oregon DEQ may require a formal pretreatment program. For some Oregon communities, such as the City of Newberg, the municipality developed a voluntary pretreatment program to broaden the types of businesses they could recruit to their community while protecting their sewage treatment works and collection system. Having a voluntary pretreatment program in place is a good first step to ensure that the municipality can recruit a variety of new businesses.
Businesses and the municipality benefit from having clear expectations on what is required for a new business to discharge to the POTW. Having an organized approach to providing information and technical assistance to businesses is the most effective way to recruit new businesses and promote existing businesses to expand their operations.
To start developing a voluntary, community-based pretreatment program, develop an overall approach for developing the program elements (link), develop a project plan that addresses resources and staff time (link), and develop an outreach and education program for affected businesses (link). The overall community-based pretreatment program will need to include these elements:
- Developing a Local Ordinance To Control Pollutants from Businesses and Industry
- Mechanisms to Control Industrial Users
- Conducting an Industrial Survey
- Oversight and Reporting Requirements
Additional useful information includes:
The ACWA Pretreatment Committee is the best, most experienced, resource for Oregon communities that want to develop and implement a voluntary pretreatment program. Information on joining ACWA and its Pretreatment Committee is available on our site.
More information on federal and state Pretreatment Programs is available through the State of Oregon and DEQ websites:
This Community-Based Pretreatment Tool was developed by Oregon ACWA for its members and guided by the ACWA Pretreatment Committee and the development working group including:
- Curtis Barton, Clackamas County Water Environment Services
- Clayton Brown, Clean Water Services
- Bill Hamann, City of Springfield
- Shawn Krueger, City of Springfield
- Darvin Tramel, City of Canby
- Shane Sinclair, City of Corvallis
- Randy Watson, City of Wilsonville