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Industrial Pretreatment

The National Pretreatment Program is a cooperative effort of federal, state, and local regulatory environmental agencies established to protect water quality. The program is designed to reduce the level of potentially toxic pollutants discharged by industry and other non-domestic wastewater sources into municipal sewer systems, and thereby, reduce the amount of pollutants released into the environment from these sources.

The U.S. Environmental Protection Agency has delegated DEQ the authority to approve pretreatment programs at the local level and oversee state-wide pretreatment activities. The communities approved to implement the pretreatment program have the legal authority to issue industrial user permits, conduct inspections of industrial and commercial sources, sample industrial discharges and enforce regulations. These programs also routinely perform self monitoring to ensure the protection of worker safety, the sewage treatment plant operations, biosolids and water quality.

The National Pretreatment Program was established by Congress under authority of the Federal Water Pollution Control Act of 1972 (P.L. 92-500) as amended by the Clean Water Act of 1977 (P.L. 95-217). Implementation requirements of the pretreatment portions of these laws were first codified into 40 Code of Federal Regulations (CFR) Part 403 in 1978.

DEQ received authority from the US Environmental Protection Agency on March 12, 1981, to regulate pretreatment programs in Oregon. The Department, as the pretreatment program Approval Authority for Oregon, administers its pretreatment program through the National Pollutant Discharge Elimination System permit program. The Department's pretreatment program authority is established in Oregon Revised Statutes ORS 454.020 and ORS 468B.035 and in Oregon Administrative Rules OAR 340-45-015 and OAR 340-45-063.

Objectives of the pretreatment program:

  1. Protect publicly owned treatment works (POTW) from pollutants that may cause interference with sewage treatment plant operations.

  2. Prevent introducing pollutants into a POTW that could cause pass through of untreated pollutants to receiving waters.

  3. Manage pollutant discharges into a POTW to improve opportunities for reuse of POTW wastewater and residuals (sewage sludge).

  4. Prevent introducing pollutants into a POTW that could cause worker health or safety concerns, or that could pose a potential endangerment to the public or to the environment.

The term "pretreatment" refers to the requirement that non-domestic sources discharging wastewater to POTWs control their discharges, and meet limits established by EPA, the State of Oregon or the local municipality (Control Authority) on the amount of pollutants allowed to be discharged. The control of the pollutants may necessitate treatment prior to discharge to the POTW (therefore the term "pretreatment"). Limits may often be met by the non-domestic source through pollution prevention techniques (product substitution, recycle and reuse of materials, more efficient production practices, improved environmental management systems, etc.), pretreatment of wastewater, or implementation of best management practices.

Approved pretreatment programs in Oregon are managed by local governments including sewerage collection and treatment agencies as defined by ORS Chapter 451, cities and counties. These programs protect the environment by limiting the amount of potentially toxic pollutants entering the waters of Oregon and biosolids applied on the land. They also protect the health and safety of workers and sewage treatment plants from upsets by regulating industrial users that discharge treated wastes into the sewer system. Oregon has about 25 approved programs that oversee more than 300 industrial users. Regulatory oversight of industrial sources by approved programs includes formal permitting, compliance monitoring (routine compliance inspections and sampling), and enforcement. Many pretreatment programs work effectively with industrial users to reduce contaminants in the waste stream through voluntary pollution prevention efforts.

DEQ has broad statutory authority to administer the pretreatment program in Oregon. The state has adopted the following pretreatment regulations by reference. DEQ implements and enforces the pretreatment regulations through the NPDES and WPCF permits issued to approved programs.