Overview of Washington State s Pretreatment Program Scott Mallery, P.E. Pretreatment Engineer September 2012

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1 Overview of Washington State s Pretreatment Program Scott Mallery, P.E. Pretreatment Engineer September 2012 State of Washington Department of Ecology Water Quality Program Eastern Regional Office Spokane, Washington

2 Outline Overview of Federal Delegation of Pretreatment Overview of State of Washington s Water Quality and Pretreatment Programs Waters of the State and Permits Delegated Pretreatment Program Partial Pretreatment Program Non-delegated POTW Eastern Regional Pretreatment Program

3 Basis in the Clean Water Act The Clean Water Act forms the basis of three major permitting programs: NPDES, Pretreatment, and Storm water. Pretreatment Permits are for discharges to POTWs: Permits must include all Applicable Pretreatment Standards and Requirements including State Standards, Local Limits and categorical standards

4 What is Pretreatment? Defined in 40 CFR as treatment before or in lieu of discharge to a POTW Intent of the Program: Protect POTWs from harmful discharges Empower POTWs to oversee industries Set uniform standards of treatment Establish standards for local programs Allow states to assume local programs when they have the ability & desire to do so.

5 History of Federal Regulations CWA reauthorization directed a strategy: Develop Categorical Standards for industries Define program for oversight by POTWs & States Pretreatment Standards of 1973 were in 40 CFR 128 Replaced in 1978 by 40 CFR part 403 Significant revisions in 1981, 1988, 1990, 2005

6 Major Areas of Pretreatment Regulation (40 CFR part 403) Prohibited Discharges & Local Limits Implementing Categorical Standards 403.7, 11, 13, 15 - Adjusting standards 403.8, 9, 18 - POTW Program Content, Approval and Modification State (oversight) Program Reporting Requirements

7 Federal Requirements POTWS that must have programs Over 5.0 MGD (max. design flow or combined POTWs) and Receiving Industrial Wastewater, or Under 5.0 MGD and Receiving pollutants that pass through or interfere with POTW, or Approval Authority or EPA finds a local program is needed to protect the POTW.

8 History of State Program Water Pollution Control (RCW 90-48) 1973 Waters of the State Surface and Ground (Land Application, etc) Pollution Disclosure Act of 1971 (RCW 90-52) --AKART: All Know, Available, and Reasonable Treatment Delegation Process ( WAC) 1975 State Waste Discharge Permit Program ( WAC) 1983 Submission of Plans and Reports for Construction of Wastewater Facilities (WAC ) 1983 Engineering Report, Plans and Specifications, and Operations and Maintenance Manual Requirement of Professional Engineer State Pretreatment Program Manual 1986 Program required by EPA agreement Implements state and federal regulations

9 Key Features of the State Pretreatment Program Ecology may permit industries for POTWs POTWs not delegated have certain responsibilities by default POTWs may assume additional responsibilities for their protection and/or to defer developing a full program. NPDES and some State to Ground Permits identify requirements

10 Pretreatment Responsibilities Delegated Programs Implement all federal and state requirements Other (Non-Delegated) POTWs with Industries Have support obligations in NPDES and State permits Dept of Ecology Permits industries to non-delegated POTWs Review Engineering Reports, Plans & Specs, & O & M Manuals Oversees delegated program implementation

11 Fully Delegated Pretreatment Program Components Technical Information IU Survey, Local Limits & Resource Assessment Legal Authorities: Local Ordinance, Interjurisdictional Agreements, & Attorney s Legal Sufficiency Statement Requisite Procedures Detection of businesses covered by program Permitting, Compliance Tracking, Files Sampling, analysis and Inspection Enforcement Response Plan Engineering Reports, Plans and Specifications, and Operations and Maintenance Manual (if delegated)

12 Default Responsibilities of Non-Delegated POTWs Periodic Industrial User Surveys ID Users Support requirement to obtain a permit Enforce discharge prohibitions Take prompt action to halt pass through, interference, or threats to public Monitor influent, effluent, and biosolids

13 Responsibilities of POTWs upon Notification by Ecology Develop local discharge limits Identify Pollutants of concern (Using the IU Survey for information) Implement sampling regime Evaluate data and derive limits Codify Pretreatment Ordinance Identify unpermitted dischargers Investigate and reduce toxicity

14 Voluntary Partial Pretreatment Program Options Outreach and Control of Minor IUs Tracking of IU Monitoring Reports Inspection of Permitted IUs Sampling of Permitted IUs Noncompliance Investigations Review reports for industrial WW facilities Grease Traps/Interceptors Dentists Oil and Water Separators

15 Department of Ecology s Regions Bellevue Spokane Yakima And Southwest Office

16 Delegated Pretreatment Programs Metro/King County (Seattle Area) (NWRO) Everett (NWRO) Lynnwood (NWRO) Tacoma (SWRO) Pierce County (SWRO) Vancouver (SWRO) LOTT (SWRO) Yakima (CRO) Richland (CRO) City of Spokane (ERO) Spokane County (ERO) City of Walla Walla (ERO)

17 City of Walla Walla, Washington Over 5 million gallon a day POTW discharge Delegated Pretreatment as State Waste Discharge Permits (take over State Permits by 2013) (Metal Finisher, Juice, independent, and small city (Prison))

18 Future Delegated Pretreatment Programs (ERO) City of Quincy 2 POTW plants (industrial and municipal) 12 permits (data centers, food processors, fruit packers) Requested delegation of Engineering Report, Plans and Specifications, and O & M Manual Reviews and Approval In process of pretreatment delegation (complete by end of 2012) City of Pasco 2 POTW plants (industrial and municipal) 6 permits (food processors, truck wash) Requesting delegation of Engineering Report, Plans and Specifications, and O & M Manual Reviews and Approval Requesting pretreatment delegation

19 ERO s Delegated Pretreatment Programs and Permits NPDES-Majors 5 (municipal) 4 (industrial) NPDES-Minors 37 (municipal) 6 (industrial) State to Ground 57 ERO s State to POTW permits 34 total Ports and others: 12 Municipals 22 NPDES POTWs- 11 (2 are at Port) (There are some Fruit Packers that go to the sewer) Delegated Pretreatment Programs 3 City of Spokane 15 permits Spokane County 8 permits City of Walla 3 permits soon State reviews Engineering Reports, Plans & Specs, and O & M

20 State to POTWs Permits State to POTWs are to municipal, industrial, and port treatment facility whether or not they are State and/or NPDES Permit Industrial (pretreatment permits) User will be permitted if they meet one or more of the following: Discharges 25,000 gallons per day or more of process wastewater to the POTW; Contributes a process wastewater making up 5 percent or more of the average dry weather hydraulic or organic capacity of the POTW; Designated by the Control Authority as such because of its reasonable potential to adversely affect the POTW s operation or violate any pretreatment standard or requirement; or Subject to Federal categorical pretreatment standards (note: NPDES industrial may also be a categorical industrial and have to meet these standards) Industrial should be sampled and inspected once a year

21 ERO Permit Managers POTWs (municipal, industrial, port) Permits: Monitoring/sampling influent and effluent (metals, priority pollutants, conventional pollutants, ph, and flows) Biosolids (permit or not) Industrial Users Survey Major and Large Once every 5 years Minor and Small Once every 10 years Develop Local Limits Update Model Sewer Use Ordinance Possibility of monitoring and sampling facilities into their sewer system Interjurisdictional Agreements especially if they have another agency on their lines (interlocal agreement many not be enough) Visit with operators and public works directors Visit with facilities that discharge to the sewer system

22 Questions???? Contact information: Scott Mallery, P.E State of Washington Department of Ecology 4601 N. Monroe Street Spokane, WA 99205