The basis for all effective pretreatment control programs is a good survey of existing commercial and industrial businesses that discharge to the municipality. There are two phases to undertaking this activity for the first time:
- Identify and classify existing users
- Set up a process to identify new industrial users and those changing operations.
Identifying Existing Businesses
A municipality has many sources of information to collect information on non-domestic users that contribute wastewater to the POTW. Whichever method to generate the initial list should use a spreadsheet format to facilitate working with the businesses. The best source(s) of information are ranked as follows:
- Water Billing: The POTW would want this data “dumped” to an electronic format that can be used in a spreadsheet. The name, address and water use over the last year are the most useful. It is important to convert the water use data—it will likely be in cubic feet and MGD is most useful.
- Business License/Tax Listings: If the municipality has a listing of businesses operating in its jurisdictional boundaries, it is very useful to get the name, address, and SIC or business code.
- Wastewater Billing: This would be a good source of information, but will not generally provide data on water use.
- Other State/Federal Databases: There are other State and National databases that can be searched or purchased. These are detailed in the technical resources section of the program. Additional resources include:
- Oregon DEQ inventory of large quantity hazardous waste generators. This inventory needs to be requested from DEQ through the Oregon Public Records law. Information about a public records law request is available from DEQ here. Request the business name, business address, contact name, and type of waste generated for all Large Quantity hazardous waste generators within your service territory. It is probably easiest for DEQ if you identify your service territory by zip codes that you want the file for.
- Oregon Fire Marshal inventory of businesses that store over threshold quantities of hazardous materials.
Federal regulations require larger commercial and industrial facilities involved in manufacturing, metal mining, electric power generation, chemical manufacturing, and hazardous waste treatment to report specific chemicals used annually above a threshold amount. Not all industry sectors are covered by the TRI Program, not all facilities in covered sectors are required to report to TRI, and only specific chemicals used in set amounts are covered.
Not all chemicals are covered. Generally, the types of chemicals that trigger reporting:
- Cause cancer or other chronic human health effects
- Have significant adverse acute human health effects
- Have significant adverse environmental effects
Categorization Compile Data and Categorize
The objective is to compile all of the data and categorize the business types and decide what to do to collect information on the business. An example categorization is as follows:
|Category||Type of Discharger||Type of Survey Form to Send|
|1||Industrial users that meet the definition of a Significant Industrial User (SIU) (see 40 CFR Section 403.3)||A long form that requests detailed information on the business activities for those users in Category 1 above.|
|2||Other Industrial users that may be of interest but are not SIUs (radiator shops, dry cleaners, machine shops, medical services, etc.)||A short form that requests general information on manufacturing, production or business activity information that occurs on-site. Also, information on where drains and sinks are located.|
|3||Food service establishments that are expected to be subject to the FOG program||This short form would include type of food production, treatment or other BMPs in-place and other information used in sizing grease interceptors.|
|4||Businesses that have, or should have, an oil/water separator (e.g. carwashes, automotive service garages if they have a drain to the POTW, etc.)||A short form that requests information on the type of waste(s) hauled, how much is hauled and where it is disposed, how they track where they pick up waste, number of trucks, etc.|
|5||Businesses that are dental-related where the business may place or remove amalgam fillings||A short form that requests general information on manufacturing, production or business activity information that occurs on-site. Also, information on where drains and sinks are located.|
|6||Businesses that are dental-related where the business may place or remove amalgam fillings||Short dental specific form: Do they have an amalgam separator in-place and, if so, how often they service it? Do they follow the Oregon Dental Association BMP practices?|
|7||Other businesses that are expected to have a discharge that is domestic-only waste or not expected to be of concern (offices, banks, retail stores, etc.)||No action|
Example industrial surveys in PDF format are included from:
Oregon DEQ has developed Guidance for conducting an Industrial User Survey.
Identify New Businesses and Changes in Operations
The POTW will want to establish a process for identifying new businesses that open or where an existing business makes changes and starts a new, modified, or larger operation. The best sources to identify these new or changed users include:
- Have the Building Permits Department send out a short, general survey form used for Category 2 above.
- Have the Business License Department keep you updated as new licenses are issued.
- Stop in and visit businesses that were not previously identified.
- Watch for articles in the newspaper and review the phone book informational directories.
- This on-going process should be written down as a Standard Operating Procedure (SOP) and should be kept brief so it will be readily used. It is very important to have senior management support since coordination with other municipal departments will be necessary.
Every POTW Must Report to the State DEQ
It is important to remember all POTWs regardless of size, are required to report the name and address of all industrial users that are Categorical Industrial Users to the Oregon DEQ. When a smaller POTW is not able to conclusively identify a process that makes a discharger a Categorical Industrial User, request a determination from Oregon DEQ. The ACWA Pretreatment Committee may also be a resource.
Businesses Making Claims of Confidential Business Information
Some businesses have specific processes or manufacturing information that is unique to their operations and is considered “confidential” or “trade secret.” The POTW receiving such designated information is responsible to review and determine if the information is clearly covered by Confidentiality standards of the Oregon Public Records Law. This requires the City or District’s attorney to review information. Common information that can be considered confidential includes customer lists, financial information for the business, specific chemical or process information if not common knowledge. Effluent data is never considered confidential.
The municipality should review and conform to the Oregon Public Records Law when drafting and adopting its legal authority relating to confidential business information.
It is important to know that the request for confidentiality must be made when the information is filed with the municipality or district, not after.
Confidential information must be segregated into a locked file cabinet.
Additional information is available on the Oregon Department of Justice website.
Categorical Industrial Users
As discussed previously, some types of industrial process are considered to be covered by Federal Standards. These Categorical Industrial Users (CIUs) are defined by EPA and are listed on their website. In this table, any industrial process that has Pretreatment Standard for Existing Sources (PSES) or Pretreatment Standard for New Sources (PSNS) listed in the column labeled “Limitations and Standards” is a Categorical Industrial User. The EPA link provides valuable links to each regulated industry.
The most common industrial process that makes an industry “Categorical” include metal finishing, electroplating, aluminum forming, canned and preserved fruits and vegetables, centralized waste treatment, electrical and electrical components, non-ferrous metals, pharmaceutical manufacturing, transportation equipment cleaning, etc.
The ACWA Pretreatment Committee can provide additional technical assistance in properly identifying and categorizing specific types of industry.