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How Industrial Requirements Affect a Municipal Pretreatment Program

Posted By Amy Harvell on May 22, 2014

"Knowledge is Power"When I graduated from college, I thought I was finished learning. The diploma I held in my hand was proof of the knowledge I possessed, and the world of education was behind me. Little did I realize how off the mark my thoughts were. In this ever-changing world we live in – especially when our work involves regulations – the learning process is never ending!

In a previous blog, we discussed the importance of building relationships between municipal and industrial wastewater treatment operators to communicate the needs and requirements of a treatment facility. Now that you are sharing your knowledge through this partnership and have implemented a solid pretreatment program, it is time to take the next step in this educational process -- understanding how industrial facilities are regulated on the federal, state and local levels. Knowledge of the basic principles of environmental regulations will benefit the municipal wastewater treatment plant operator while conducting inspections.

Industrial facilities are regulated by local requirements, but did you know that many federal rules -- the Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Emergency Response and Community Right-to-Know Act (EPCRA), Clean Air Act (CAA) and Oil Pollution Prevention Act (OPPA) – may also apply? Of course, there are more, but enough of the acronym overload! Understanding these programs will enable municipal operators to better communicate with industrial facility personnel. 

Understanding the Operations and Limitations of an Industrial Pretreatment System

Some industrial facilities are required to build and operate their own system to treat industrial wastewaters before discharging to the publically owned treatment works. These systems could include removing metals, oil/water separation or neutralizing corrosive wastewaters. Being familiar with the operations and limitations of an industrial pretreatment system will help the wastewater treatment plant operator identify the source or cause of a noncompliance issue if a problem should occur. The following are two examples of possible non-compliance situations.

Example 1: In a recent round of monitoring, a wastewater treatment plant operator identifies solvent materials in the industrial discharge. The pretreatment system can only remove metals and neutralize corrosive wastewaters. During the site inspection, the operator identifies a new painting process that is most likely the cause of the solvents. Perhaps the paint system operators are pouring solvent from cleaning equipment into a floor drain that is connected to the pretreatment system or solvent containers are deteriorating and leaking to a floor drain.

Example 2: Analytical results are indicating a higher than normal oil and grease result. The wastewater treatment plant operator has noticed large quantities of oil used around the plant during site inspections and knows that the pretreatment system does not separate oil/grease. Some possible explanations include: not properly storing oil in secondary containment; a recent purchase of a floor cleaner that mops oil residues from the floors and mop water is poured into a sanitary drain or the pretreatment system; or storing leaking oil drums near an open floor drain that collects cooling system condensate.  

Applying Environmental Regulations

Another important part to understanding industrial facilities, is having a basic knowledge of the regulations that govern those sites. Based on site activities, the following regulations may apply:

“Knowledge is power.” By sharing knowledge about the wastewater treatment system and the pretreatment system, everyone is a partner for cleaner water. For a summary of applicable regulations, download the materials below.  

Implement a Municipal Pretreatment Program
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