US Army Corps 

of Engineers 

Construction Engineering 

Research Laboratory 

Protocol for the Preparation of 

Installation Pretreatment Programs 

Gary L. Gerdes 

Michelle J. Hanson 

Susan J. Bevelheimer 

Steven D. Cosper 

This Protocol was prepared in the anticipation of 

pending USEPA guidance that will require Army 

installations to have formal Pretreatment Programs, 

prepared in accordance to guidance in 40 CFR 403. 

The Protocol is targeted for Army installation environmental program managers. The report is in two parts: 

(1) a written document with step-by-step instructions 

for accumulating the Industrial User information 

necessary for an Installation Pretreatment Program; 

and (2) a Microsoft Access-based program for 

establishing local limits for industrial users, and for 

preparing tables and reports to present Industrial 

User information necessary for the Program. A User 

Guide (Volume 2, unattached Appendix D to this 

report) accompanies the Access database. An 

example Installation Pretreatment Program that 

includes tables generated by the Access program, is 

included as an appendix to the written Protocol. 

CERL Technical Report 99/49, Volume 1

July 1999

Approved for public release; distribution is unlimited. WWW.CECER.ARMY.MIL/PUBLICATIONS/TECHREPORTS

CERL TR 99/49 1 

SF 298 
2 CERL TR 99/49 

Foreword 

This report was prepared for the U.S. Army Environmental Center under AEC 

project EWW (EC) Environmental Support. Funding from that project supported 

CERL work units WF6, “Pretreatment Protocol Alpha Test” WS6, “Reformat Existing Protocol to Step-by-Step Guidance Documentation” and VR8, “Pretreatment Protocol Site Visits.” The AEC technical monitor and Project Officer was 

Billy Ray Scott, SFIM-AEC-ECC. 

The work was performed by the Environmental Processes Branch (CN-E) of the 

Installations Division (CN), U.S. Army Construction Engineering Research 

Laboratory (CERL). Special recognition is given to James Carter, wastewater 

manager for the Fort Leonard Wood DPW Environmental Division. The Alpha 

Test could not have been completed without his assistance, and his efforts are 

much appreciated. The CERL Principal Investigator was Gary L. Gerdes. 

L. Jerome Benson is Chief, CECER-CN-E and John T. Bandy is Chief, CECERCN. The CERL technical editor was William J. Wolfe, Information Technology 

Laboratory. 

The Director of CERL is Dr. Michael J. O’Connor. 
CERL TR 99/49 3 

Contents 

SF 298 .................................................................................................................................................... 1 

Foreword ............................................................................................................................................... 2 

1 Introduction ................................................................................................................................... 5 

Background .........................................................................................................................5 

Regulations Affecting Pretreatment ...............................................................................................5 

Categorical Pretreatment Standards..............................................................................................6 

Prohibited Discharge Standards ....................................................................................................7 

Who Needs a Pretreatment Program..................................................................................8 

Significant Industrial Users ..........................................................................................................10 

Funding To Establish an Installation Pretreatment Program.............................................11 

A106 Submission.........................................................................................................................11 

Doing a Site Survey .....................................................................................................................11 

Objectives..........................................................................................................................12 

Approach...........................................................................................................................12 

Discharging to FOTW...................................................................................................................12 

Discharging to POTW ..................................................................................................................14 

Scope ................................................................................................................................14 

Mode of Technology Transfer ............................................................................................15 

Units of Weight and Measure............................................................................................15 

2 Facility Inventory ........................................................................................................................ 16 

Worksheet 1-1: Significant Industrial User List ................................................................18 

Worksheet 1-2: Individual User Information.....................................................................19 

3 Establishing Discharge Goals/Requirements....................................................................... 21 

Discharge Goals for Facilities Subject to Categorical Standards......................................21 

Discharge Goals for Significant Industrial Users ..............................................................23 

Varying Discharge Limits ..................................................................................................25 

Slug Discharge Control Provision .....................................................................................26 

4 Allowable Changes to Categorical Discharge Limits .......................................................... 27 

Combined Waste Stream Allowance.................................................................................27 

Removal Credit Due to Treatment at FOTW .....................................................................28 

Allowance for Pollutants in Intake Water ...........................................................................29 
4 CERL TR 99/49 

5 Monitoring.................................................................................................................................... 30 

6 Recordkeeping............................................................................................................................ 32 

7 Notifications ................................................................................................................................ 33 

8 Compliance Schedules.............................................................................................................. 37 

9 Ensuring Compliance................................................................................................................ 39 

Pretreatment Program Requirement: Establish Authority ................................................39 

Pretreatment Program Requirement: Establish Responsibilities .....................................39 

Pretreatment Program Requirement: Obtain Resources Necessary To Execute the 

Program ......................................................................................................................40

Training..............................................................................................................................40 

10 Provisions To Update Program ................................................................................................ 41 

11 FOTWs With Flow ≤ 5 MGD....................................................................................................... 42 

Acronyms and Abbreviations.......................................................................................................... 43 

Glossary.............................................................................................................................................. 45 

References.......................................................................................................................................... 50 

Appendix A: Discharge Limits Established by Categorical Pretreatment Standards.......... 51 

Appendix B: Development of Technically Based Local Limits................................................. 56 

Appendix C: Pretreatment Program Example............................................................................. 72 

Distribution 
CERL TR 99/49 5 

1 Introduction 

Background 

Regulations Affecting Pretreatment 

The Clean Water Act, enacted in 1972 as the Federal Water Pollution Control Act 

of 1972 (with amendments in 1977 and 1987) has as its goal the prevention of 

discharges of pollutant into any water of the United States. The Clean Water 

Act (CWA) mandates the National Pretreatment Program. 

The National Pretreatment Program is designed to reduce the amount of pollutants discharged by industry and other nondomestic wastewater sources into mu 

nicipal sewer systems, and thereby reduce the amount of pollutants released into 

the environment from wastewater treatment plants. The program is a cooperative effort of Federal, State, and local regulatory environmental agencies established to protect water quality. The objectives of the program are to protect the 

publicly owned treatment works (POTW) or municipal wastewater treatment facility from pollutants that may interfere with plant operation, or that may pass 

through the plant untreated; and also to improve opportunities for the POTW to 

reuse treated wastewater and biosolids (sludges) that are generated. 

The National Pretreatment Standards do not apply to sources that discharge to a 

sewer not connected to a POTW treatment plant. Therefore, it does not directly 

apply to Army or other Federally owned treatment works (FOTW). The U.S. Environmental Protection Agency (USEPA) approved and enforceable pretreatment 

programs are, for the most part, only found at POTWs because of the definitions 

and applicability (POTWs only) found in the CWA. This situation has caused 

some confusion in regard to the Solid Waste Disposal Act (SWDA). Under the 

SWDA, there is an exclusion from the definition of solid waste (and therefore the 

definition of hazardous waste [HW]) for mixtures of domestic sewage and other 

wastes that discharge to a POTW. The USEPA further expanded this exclusion 

(40 CFR 261.4) to include industrial wastewater point source discharges permitted under Section 402 of the CWA. For Army installations and other Federal facilities, the definition of POTW found in the SWDA, and in the subsequently 

promulgated USEPA regulations, clearly excludes FOTWs. 
6 CERL TR 99/49 

Note that Army installations are not required to have pretreatment programs 

pending further interpretation of the Federal Facility Compliance Act (FFCA). 

One goal of Section 108 of the FFCA (FFCA-108) was to eliminate the discrepancies between the Federal facility aspects of two, sometimes overlapping, environmental statutes (SWDA and the CWA). The FFCA-108 grants a conditional 

HW exclusion for mixtures of HW and domestic sewage discharged to an FOTW 

when one of the following conditions is met: 

• The discharge is subject to a pretreatment standard issued under the CWA, 

and it is in compliance with the standard. 

• The discharge comes from an industrial pretreatment facility in an effluent 

category for which the USEPA has established a schedule for developing a 

standard. 

• The discharge would not be prohibited from land disposal under the SWDA 

because it has been treated accordingly. 

• The discharge is generated by a household or individual that generates less 

than 100 kilograms of HW per month (excluding acutely HW). 

The net effect of FFCA-108 was to allow FOTWs to enjoy some of the benefits 

enjoyed by their publicly owned counterparts. Federal installations operating 

domestic sewage treatment plants (STPs) that accept “industrial wastewater”

can now enjoy some of the regulatory relief from the SWDA given to POTWs. 

However, FFCA-108 does not give FOTWs the same blanket exclusion from the 

definition of HW given to public facilities. Mixtures of solid or dissolved material 

and domestic sewage flowing to a Federally owned STP are not considered HW 

only if the discharge meets one of the aforementioned conditions. 

There are pretreatment programs already in existence as required by NPDES 

permit requirements at several Army installations. Installations without mandatory (e.g., NPDES permit) pretreatment requirements could still use portions 

of the total program to determine compliance with FFCA-108. Those portions 

would include the industrial waste survey and industrial discharge sampling. If 

industrial discharges were found that did conform to the standards, then installations could implement complete pretreatment programs to obtain and maintain compliance. 

Categorical Pretreatment Standards 

The CWA sets forth pretreatment standards for industrial facilities that discharge into POTWs. For Army installations in general, Categorical Pretreatment Standards do not directly apply unless the facility discharges to a local 
CERL TR 99/49 7 

POTW.* Nevertheless, Army Regulation 200-1 requires that discharges to Army 

treatment plants comply with pretreatment standards. 

The Categorical Pretreatment Standards are sets of discharge limits for an entire category of an industry. For example, all facilities that meet the definition 

for “metal finishing and discharge” to a POTW must comply with the applicable 

metal finishing categorical standards. The effluent discharge limits are based on 

the pollutant removal efficiency consistently demonstrated by the best available 

waste control technology economically achievable. 

Prohibited Discharge Standards 

Prohibited discharge standards have been developed to control wastewater produced by industrial users in a more general sense. These compliance requirements are applicable to all nondomestic sources, whether or not they can be considered a categorical industry. 

General Prohibitions 

The general prohibitions state that no industrial user can introduce into a 

POTW any pollutant that causes interference or that will “pass through” untreated. Interference, by definition, occurs if an industrial discharge: (1) inhibits or disrupts a POTW treatment process or adversely affects sludge production 

or, (2) causes the facility to violate its NPDES permit or prevent the disposal or 

reuse of its sewage sludge. 

Specific Discharge Prohibitions 

Specific discharge standards were developed to prevent the following types of 

materials from entering a POTW: 

• ignitable and/or explosive wastes 

• reactive discharges or materials that release hazardous fumes 

• oil and grease in amounts that will adversely affect the POTW 

 

* Categorical effluent standards are written specifically for industrial discharges to POTWs. However, Army installations will often find identical numerical criteria written into their NPDES permits. In many cases a “categorical” activity within an installation’s boundary that discharges to the FOTW will be regulated as an additional “outfall.” Furthermore, the Federal Facility Compliance Act adopted categorical standards for discharges to FOTWs, thereby 

indirectly making them applicable to Army industrial activities. 
8 CERL TR 99/49 

• corrosive materials or discharges with a pH of less than 5 

• solid or viscous pollutants in amounts that obstruct the POTW 

• any pollutant, or heat, in amounts that will cause interference. 

State Program Exception 

FOTWs that meet the above criteria are not required to have pretreatment programs if the NPDES State exercises its option to assume local 

responsibilities as provided for in 40 CFR 403.10(e). 

Who Needs a Pretreatment Program 

At the time of writing this report, Army FOTWs were not required by Federal 

Law to have Pretreatment Programs, though it is anticipated that USEPA will 

issue guidance that will require such programs. Some States with primacy over 

NPDES permitting have required Pretreatment Programs at Federal installations. 

Considering the current requirements, one may fairly ask why an Army installation should have a pretreatment program. In fact, whether required by law or 

not, an Installation Pretreatment Program can be a valuable, cost-saving, tool 

for the installation environmental manager. The Pretreatment Program can be 

used to: 

1. Manage Compliance with Categorical Pretreatment Discharge Requirements. According to the FFCA and AR 200-1, the Army must comply with the specific categorical pretreatment discharge requirements delineated in 40 CFR Part N (discussed in Chapter 3, p 5). These rules establish pollutant limits on discharges 

from specific industrial processes to domestic wastewater treatment systems. 

Most significant of these is the pending Machine Products and Metalworking 

rule, commonly referred to as MP&M. This rule will regulate discharges from 

vehicle maintenance and washing operations.

2. Prepare the Installation for Privatization of the Domestic Wastewater Collection 

and Treatment System. The Army has been directed to privatize all wastewater 

treatment systems wherever feasible. Privatization can involve turning over 

ownership of an installation system to the private sector. In that case, the industrial facilities at that installation will be discharging to a POTW rather than an 

FOTW. It is likely that the new owner of the wastewater system will impose limits on pollutants discharged from those industrial facilities. Implementation of a 

pretreatment program prior to privatization will: (a) identify potential problem 

areas, (b) allow time to correct those problems through pollution prevention or 
CERL TR 99/49 9 

other low-cost methods, and (c) prevent high-cost corrections that could be required by a POTW. 

3. Meet the General Pretreatment Requirements Established in the Clean Water Act. 

The Clean Water Act describes general pretreatment goals that are required for 

all domestic wastewater systems. Most applicable of these is the requirement to 

eliminate discharges of pollutants to the collection system that cause interference 

with the treatment processes or pass through the treatment system untreated. 

Pass-through of toxic pollutants is monitored by the Whole Effluent Toxicity test 

(WET test). Implementation of a Pretreatment Program can achieve the general 

pretreatment goals, and specifically, help to comply with the NPDES permit requirement to pass the WET test. 

4. Maintain Compliance with Pollutant Limitations on Wastewater Treatment 

Sludge Disposal. 40 CFR 503 establishes disposal criteria for domestic sewage 

sludge. Specific pollutants limits are imposed, and those limits depend on the final disposal of the sludge. (Refer to the U.S. Army Environmental Center report: 

Sewage Sludge (Biosolids) Management Manual for Army Facilities.) A Pretreatment Program can be valuable to achieve the pollutant levels desired for existing sludge disposal, or to achieve a higher classification of sludge and decrease 

sludge disposal costs. 

According to most interpretations of the FFCA, FOTWs are currently not required by Federal Law to have Pretreatment Programs to manage the industrial 

discharges. However, it is anticipated that the USEPA will soon issue guidance 

that FOTWs are to be subject to the same pretreatment program requirements 

now imposed on POTWs. In fact, draft guidance implementing the Federal Facilities Compliance Act will require military FOTWs to comply with CWA pretreatment requirements for POTWs, if: 

Any individual activity on the installation generates more than 100 kg 

hazardous waste per month, or any quantity of acutely hazardous waste. 

(MIL-HDBK 1005/17, p 11) 

Note that most Army Installations will meet the above criteria. 

When FOTWs are regulated the same as POTWs by the Clean Water Act, then 

those FOTWs that meet all of the following criteria will be required to have Pretreatment Programs: 

1. At least 50 percent of the influent received is domestic sewage. 

2. The effluent of the treatment works is subject to a permit issued pursuant to Section 402 of the Clean Water Act. 
10 CERL TR 99/49 

3. The treatment works (or combination of treatment works owned/operated by the 

same installation) has a total design flow greater than 5 million gal per day 

(MGD). (Note: In many cases, this requirement may not apply.) 

4. Significant industrial users are discharging nondomestic wastewater to the 

FOTW. 

Note that States may determine the requirement for pretreatment programs using criteria that are more inclusive than those listed above. FOTW that have 

less than 5 MGD design flow, or have no significant industrial users discharging, 

may still be required to have pretreatment programs. Other regulatory requirements, such as the requirement to meet biosolids management or air emissions criteria, may require an installation to establish a pretreatment program. 

Significant Industrial Users 

The sources of industrial wastewater that are to be managed by the installation 

Pretreatment Program are delineated in 40 CFR 403. Those sources are referred 

to as significant industrial users. All sources that are subject to the Categorical 

Standards listed in Subpart N of the Clean Water Act (40 CFR 405-471) are significant industrials users. Over 50 industrial wastewater sources are regulated 

by Subpart N. 

The criteria for a noncategorical source to be defined as a Significant Industrial 

User are: 

1. The industrial user generates more than 100 kg of hazardous waste 

(as defined by RCRA) per month, including that which is sent to the 

FOTW 

and 

2. The industrial user discharges an average of 25,000 gal per day or 

more of process wastewater to the FOTW (excluding sanitary, noncontact cooling, and boiler blowdown wastewater), or the industrial user 

that contributes a process waste stream that makes up 5 percent or 

more of the average dry weather hydraulic or organic capacity of the 

FOTW treatment plant 

or 

3. The industrial user is designated by the pretreatment program control authority as having a reasonable potential to adversely affect the FOTWs operation, including causing noncompliance with NPDES discharge and sludge management requirements. 
CERL TR 99/49 11 

Funding To Establish an Installation Pretreatment Program 

A106 Submission 

An installation may request funding to establish a Pretreatment Program as an 

Environmental Program Requirement project. Guidance to prepare an A106 

submission specifically for developing a Pretreatment Program is included in 

“The U.S. Army EPR Project Catalog,” which is a periodical publication prepared 

by the Special Programs Branch at the U.S. Army Environmental Center (AEC). 

Copies of the catalog may be obtained by calling the EPR Action Officer, AEC 

Special Programs Branch at 410-436-7102. The catalog can also be downloaded 

from DENIX at: 

http://denix.cecer.army.mil/denix/DOD/Interaction/Reporting/EPR/Catalog/catalog.html. 

Doing a Site Survey 

The largest expense in preparing a program is performing the industrial facility 

site survey and doing the baseline wastewater characterization. The cost to prepare a Pretreatment Program depends on the number of industrial wastewater 

sources at an installation. Remember that some facilities, such as DOL maintenance shops, will have several industrial wastewater sources. Because of the 

intermittent nature of most industrial sources at an Army installation, an accurate site survey can be somewhat labor intensive. To prepare the example Pretreatment Program (Appendix C), CERL conducted a site survey at a large troop 

installation. A suggested approach for an outside agency or contractor to perform the site surveys prior to developing a pretreatment program, as done for 

the example (shown in Appendix C), is: 

1. Prior to the survey, give all industrial facilities advance notice to the coming 

site visits. 

2. Do a “windshield tour” with installation person familiar with industrial facilities. 

 Allow 5 minutes per facility. 

3. Perform an initial visit to each industrial facility to obtain background information, i.e., POC, process description, etc. Walk through the facility. 

Identify potential pollutants. Schedule a return visit to do sampling when 

wastewater is representative of typical to worst case. (Note: visits to medical 

facilities usually require appointments.) 
12 CERL TR 99/49 

 Assume two persons per site, five sites per day. 

4. Conduct sampling. If a headworks analysis is done at the sewage treatment 

plant, do sampling at the industrial facilities at the same time. 

 Assume two persons per site, two sites per day 

 Sample analysis cost will depend on pollutants identified for analysis. 

A typical analysis will be for heavy metals, cyanide, and oil and grease. 

 Allow an additional man-week for preparation, i.e., for making arrangements for analysis, organizing sampling equipment, preparing a sampling 

schedule, and for other administrative tasks. 

5. Prepare the report using the automated protocol program (Appendix D) and 

text from the example program. 

 Allow 4 man-weeks to enter data and generate report. 

Objective 

The objective of this Protocol is to provide Army installations with a tool to establish comprehensive wastewater pretreatment programs.

Approach 

Discharging to FOTW 

This Protocol consists of 10 chapters each of which describes specific Pretreatment Program elements, as defined in 40 CFR 403 and Army documents. When 

a Program element is specifically required by regulation, the words “Pretreatment Program Requirement” will appear in the chapter, followed by a statement of the requirement. For clarity, the term “POTW” has been replaced in 

most 403 excerpts with the term “Treatment Works,” or sometimes “FOTW.” The 

terms “Control Authority” and “Approval Authority” are replaced with “Pretreatment Program Manager” (PPM). 

Some chapters in this Protocol contain worksheets and sub-worksheets to help 

develop the installation program. Use these worksheets as tools to collect and 
CERL TR 99/49 13 

collate installation data, and to establish action plans necessary to maintain the 

goals of the program. Four general types of worksheets are provided: 

1. Worksheets to record information specific to each industrial wastewater discharge, including the industrial processes that generate wastewater 

2. Worksheets to establish pretreatment water quality goals, and pretreatment program responsibilities 

3. Worksheets for recordkeeping and reporting the data 

4. Worksheets to generate schedules and resource action plans that will ensure successful accomplishment of the program goals. 

Many of the worksheets depend entirely on entries made on other worksheets. 

Annotations are made on those worksheets where these cross-references occur. 

A Pretreatment Program developed by using this Protocol will have some variations of the program described in 40 CFR 403. For example, one purpose of the 

pretreatment programs that are established through the CFR is to give regulatory authority to the POTWs to control industrial discharges to those treatment 

works. But the Army is owner of both the treatment works (FOTW) and the facilities generating industrial wastewater, and thus does not need regulatory authority in that it already has complete control. That authority is already defined 

in “Military Service Regulations, Installation Instructions and Host/Tenant Support Agreements.” Because of this existing control, the Army installation pretreatment programs shall place emphasis on performance of pretreatment structures and the actions necessary to achieve that performance, of which 

maintenance and pollution prevention are major elements. However, the Army 

pretreatment programs shall focus on the general goals established in 40 CFR 

403. 

A Microsoft Access-based automated version of this Protocol accompanies this 

report. This automated Protocol is useful to prepare the Facility Inventory and 

to establish pretreatment discharge limits. An example Installation Pretreatment Program is included as Appendix C. 

The following checklist of actions must be taken to develop the components of an 

installation’s Pretreatment Program. These actions and other program requirements are described in Chapters 2 through 10.
14 CERL TR 99/49 

Check List (See Chapter 2) 

1. Identify the activities meeting the criteria as “industrial users” in 40 CFR part 

403.3(t)(1) and identify which of those are “significant industrial users.”

2. Prepare a facility inventory for each significant industrial user.

3. Include identifying information such as the facility name and location, and 

point of contact. 

4. List the environmental permits currently held by each location. 

5. Describe the regulated processes that discharge to the treatment works. 

Include the average rates of production and the Standard Industrial 

Classification (SIC) code(s) for the processes. 

6. Diagram the processes to indicate the points of discharge to the treatment 

works.

7. Provide a measurement of the average and maximum daily flows (in GPD) 

from the regulated process streams. If process streams are mixed with other 

waste streams, flow from those streams must be measured as well.

8. Sample and analyze the discharges from each industrial source to identify 

the character and volume of pollutants contributed to the FOTW as required 

by 403.12(b)(5). 

9. Identify the Pretreatment Standards applicable to each regulated process or 

establish pretreatment limits.

10. Submit the results of sampling and analysis identifying the nature and concentration (or mass, where required by the Standard or Pretreatment Program Manager) of regulated pollutants in the discharge from each regulated 

process. 

Discharging to POTW 

Army installations that have industrial facilities that discharge to POTW would 

not be required to develop their own pretreatment program. Those facilities 

would be subject to the pretreatment program of the POTW. The POTW will determine all compliance goals of the pretreatment program with which the installation must comply. The installation will be required to: (1) meet general and 

specific discharge limits for industrial users (including Categorical limits), (2) 

follow a specific monitoring plan, (3) provide industrial user source information, 

and (4) submit results of monitoring and other information to satisfy reporting 

requirements. This Protocol may be valuable to the installation environmental 

manager when establishing an internal program to maintain compliance with 

the POTW pretreatment program. 

Scope 

It is not intended to be a general reference for pretreatment or pretreatment 

programs. Only program elements that are relevant to the Army FOTW are discussed. 
CERL TR 99/49 15 

An Army installation’s treatment works qualifies as an FOTW 

when it is owned or operated by the DoD, the majority of the influent received is domestic sewage, and its effluent is subject to a permit issued pursuant to Section 402 of the CWA (RCRA Section 

3023, 42 USC Section 6939e). 

The information within this manual is based on the pretreatment program guidance for POTWs contained in the General Pretreatment Regulation, 40 CFR 403. 

This regulation was used because draft guidance implementing the Federal Facilities Compliance Act will require military FOTWs to comply with CWA pretreatment requirements for POTWs, if: 

Any individual activity on the installation generates more than 100 kg hazardous 

waste per month, or any quantity of acutely hazardous waste. (p 11, Handbook)

Mode of Technology Transfer 

It is anticipated that this protocol and associated data base program will be 

made available through AEC, Aberdeen Proving Ground, MD. 

Units of Weight and Measure 

U.S. standard units of measure are used throughout this report. A table of conversion factors for Standard International (SI) units is provided below. 

SI conversion factors 

1 in. = 2.54 cm 

1 ft = 0.305 m 

1 yd = 0.9144 m 

1 sq in. = 6.452 cm2

1 sq ft = 0.093 m2

1 sq yd = 0.836 m2

1 cu in. = 16.39 cm3

1 cu ft = 0.028 m3

1 cu yd = 0.764 m3

1 gal = 3.78 L 

1 lb = 0.453 kg 

1 kip = 453 kg 

1 psi = 6.89 kPa 

°F = (°C x 1.8) + 32 
16 CERL TR 99/49 

2 Facility Inventory 

Pretreatment Program Requirement: The installation will prepare a facility 

inventory that identifies, locates, and provides a detailed report on each location 

that is subject to the FOTW Pretreatment Program as a Significant Industrial 

User. 

The facility inventory must contain the following information along with the criteria by which specific facilities are categorized as Significant Industrial Users 

(p 10): 

1. Standard identifying information on each Significant Industrial User such as 

the facility name and location. The POCs and phone numbers should also be 

included. 

2. A listing of environmental permits currently held by the facility. This may 

include NPDES permits, hazardous materials or waste permits, air permits, 

or any other environmental permit pertaining to the individual user. 

3. A description of operations occurring at the facility. This will include the processes occurring at the facility, the rates of production (if applicable), the 

Standard Industrial Classification (SIC code), and a process diagram which 

indicates the points of discharge to the FOTW.*

4. A measurement of the average and maximum daily flows (in gallons per day) 

of the process streams leaving the facility. If process streams are mixed with 

other waste streams, flow from those streams must be measured as well. 

5. Identify the character and volume of pollutants contributed to the FOTW by 

each user. This will involve sampling and analysis of the discharge as required by 403.12(b)(5) listed below. Those pollutants detected in the waste 

 

* Note that, since the printing of 40 CFR 404, the SIC code has been replaced by the NAICS. Information on NAICS 

is available at http://www.webplaces.com/naics/. 
CERL TR 99/49 17 

stream will be monitored as “pollutants of concern.” (See Chapter 5 - Monitoring, p 30). 

a. Identify the Pretreatment Standards applicable to each industrial user. 

b. Perform sampling and analysis to identify the nature and concentration 

(or mass) of regulated pollutants in the discharge from each industrial 

user. Both daily maximum and average concentration (or mass, where 

required) shall be reported. The sample shall be representative of discharges from normal operations. 

c. For most pollutants, 24-hour composite samples should be obtained 

through flow-proportional composite sampling techniques where feasible. 

Where not feasible, the PPM may allow for the collection of samples obtained through time-proportional composite sampling or through a minimum of four grab samples, as long as these samples are considered representative of the discharge. For pH, cyanide, total phenols, oil and grease, 

sulfide, and volatile organics (when measurement of these pollutants is 

required), samples shall be collected through a minimum of four grab 

samples. 
18 CERL TR 99/49 

Worksheet 1-1: Industrial User List 

List all industrial users and those designated as significant industrial users (as defined on p 10) located on 

the installation. Use existing information such as Storm Water Pollution Prevention Plans (SWPPP), spill 

plans, pollution prevention plans, utility plans for wastewater treatment plants, etc., to ensure all sources are 

included. Each user should have a unique identification. Attach additional sheets as necessary.

Bldg. No. Facility POC 

POC 

Phone No. 

Significant 

Industrial 

User? 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
CERL TR 99/49 19 

Worksheet 1-2: Individual User Information 

Complete this worksheet for each of the user listed in Worksheet 1-1. 

1. Complete the following: 

a. Facility name: 

b. Building number: 

c. Operator name and telephone number: 

d. Activity description: 

e. Existing pretreatment device: 

2. List any environmental permits for this facility: 

 

3. Complete the following for the source listed above. 

a. Describe the operation(s) generating wastewater for this source, including why it is a Significant 

Industrial User: 

b. Average rate of production: 

c. Standard Industrial Classification (SIC) or NAICS designation of the operation(s) carried out at 

this source: 

d. Attach a schematic drawing of each of the facility’s existing pretreatment structures to this work 

sheet. Be certain to indicate flow patterns and points of discharge. 
20 CERL TR 99/49 

4. Complete the following for the facility listed above: 

a. For each regulated process stream at this facility, enter the average daily and maximum daily usage 

and flows: 

Process Stream Average Daily Usage (gal/day) Maximum Daily Flow (gpm) 

 

b. Are process streams at this facility combined with other waste streams prior to pretreatment? 

____Yes ____No 

c. If yes, enter the average daily and maximum daily flows for these waste streams in the spaces below: 

Process Stream Average Daily Flow (gal/day) Maximum Daily Flow (gpm) 

 

5. For the facility listed above, provide the following wastewater quality information. All sampling and analysis shall be performed according to techniques described in 40 CFR 136. Samples should be taken immediately 

downstream from pretreatment facilities if they exist, or immediately downstream from the process stream if no pretreatment exists. 

a. List all regulated pollutants generated by or used in the industrial processes at this facility, and that 

can be expected in the wastewater stream: 

1. 4. 7. 

2. 5. 8. 

3. 6. 9. 

b. Obtain a minimum of one 24-hour composite sample from each location as described in 5, above. 

For each pollutant (except those listed in paragraph c below), list the following: 

Date/Time Location Max. Conc. Ave. Conc. Methods Used for Analysis 

1. 

2. 

3. 

4. 

c. If pH, cyanide, total phenols, oil and grease, sulfide, or volatile organics are identified as potential 

pollutants of concern at a location, then obtain a minimum of four grab samples from each location (as 

described in para. 5 above) and test for the identified pollutants. For each sample, list the following: 

Date/Time Location Max. Conc. Ave. Conc. Methods Used for Analysis 

1. 

2. 

3. 

4. 
CERL TR 99/49 21 

3 Establishing Discharge 

Goals/Requirements 

To protect the FOTW from regulated pollutants that will pass through the system untreated, and from pollutants that will interfere with the treatment works 

processes, pretreatment discharge goals are established for each significant industrial user. The established discharge goals will be specific to the industrial 

source generating the wastewater. Those goals will affect both wastewater pollutant concentrations and wastewater flow. 

Discharge goals for some industrial facilities are already specified in Subpart N 

of the Clean Water Act. These are referred to as “Categorical Standards.” The 

goals for the facilities not covered by Subpart N must be established by the installation Pretreatment Program Manager. 

Discharge Goals for Facilities Subject to Categorical Standards 

Discharges from certain industrial facilities specified in Subpart N of 40 CFR are 

subject to Categorical Pretreatment Standards (40 CFR 405-471). Appendix A 

contains portions of 40 CFR dealing with those industrial facilities most likely to 

exist at Army installations. Refer to Appendix A when establishing discharge 

goals for the following types of facilities: 

1. Electroplating (40 CFR 413) 

2. Chemical Manufacturing (40 CFR 415) 

3. Metal Finishing (40 CFR 433) 

4. Metals molding and casting (40 CFR 464). 

Note: The pretreatment regulation for discharges from explosives manufacture 

(40 CFR 457) specifically applies to commercial facilities. However, processes at 

Army ammunition plants may be regulated by one or more of the above categorical standards. 
22 CERL TR 99/49 

40 CFR 403.6(c) provides the following guidance on how the discharge goals are 

to be expressed (concentration/mass limits) in the installation FOTW Pretreatment Program. 

(1) “Pollutant discharge limits in categorical Pretreatment Standards will be either as concentration or mass limits. Wherever 

possible, where concentration limits are specified in standards, 

equivalent mass limits will be provided so that local, State, or 

Federal authorities responsible for enforcement may use either 

concentration or mass limits.”

(2) “When limits in a categorical Pretreatment Standard are expressed only in terms of mass of pollutant per unit of production, 

the [Pretreatment Program Manager] may convert the limits to 

equivalent limitations expressed either as mass of pollutant discharged per day (or) effluent concentration...”

EXAMPLE

Suppose an industrial facility at an Army installation produces the 

chemical RIP. The Categorical Standard for RIP production is 0.01 

grams RIP discharged per kilogram produced. Suppose you wish 

to set a concentration goal rather than a mass goal. Then the concentration goal is: 

[RIP]goal = 0.01gr / kg × ADM / ADF

where: 

ADM = average daily mass produced, based on a reasonable measure of the actual average daily production (not the designed 

production capacity) 

ADF = average daily flow, based on a reasonable measure of the 

actual daily flow rate during a representative year. 
CERL TR 99/49 23 

Discharge Goals for Significant Industrial Users 

40 CFR 403 lists specific prohibitions that must be imposed on all significant industrial users. Those prohibitions are as follows: 

1. Pollutants that create a fire or explosive hazard in the treatment works, including waste streams with closed cup flashpoint of less than 140 °F. 

2. Pollutants that will cause corrosive structural damage to the treatment works. 

In no case discharges with a pH lower than 5.0, unless the treatment works can 

accommodate such discharges. 

3. Solid or viscous pollutants that will obstruct flow in the treatment works. 

4. Any pollutants, including BOD, released at a flow rate or concentration that will 

pass through the FOTW untreated, or that will cause interference with the 

treatment works, including by causing violations of the NPDES permit. 

5. Heat that will inhibit biological activity in the treatment works. In no case heat 

in such quantities that the temperature at the treatment plant exceeds 40 °C 

(104 °F), unless approved by the treatment works manager. 

6. Petroleum Oils and Lubricants (POL), nondegradable cutting oil, or mineral oils 

in amounts that will cause interference or that will pass through untreated. 

7. Pollutants that result in the presence of toxic gases, vapors, or fumes within the 

FOTW in a quantity that may cause acute worker health or safety problems. 

8. Any trucked or hauled pollutants, except at discharge points designated by the 

FOTW manager. 

Pretreatment Program Requirement: The Pretreatment Program shall develop and enforce specific pollutant limits for each Significant Industrial User, to 

implement the prohibitions listed in the above paragraphs. 

The purpose of establishing local discharge limits is to achieve the following 

goals: 

1. Protect the treatment system biological treatment processes from toxic inhibition. 

2. Assure that the treatment system effluent complies with its NPDES permit limitations and applicable water quality standards. 

3. Assure that the quality of biosolids (treatment plant sludge) complies with disposal criteria. 

4. Protect the sewer system from damage and obstruction, and protect workers from 

exposure to toxic or explosive fumes. 

The Pretreatment Program Manager is free to use any reliable method for establishing local discharge limits. General approaches and methodologies for developing local limits are described in the USEPA document, Guidance Manual for 
24 CERL TR 99/49 

the Development and Implementation of Local Discharge Limitations Under the 

Pretreatment Program, EPA-833-B-87-202 (1987). USEPA has also developed 

software for establishing local limits called PRELIM 5.0, which is available on 

the USEPA website. 

Four technical approaches are outlined in the USEPA manual: 

1. Maximum allowable headworks loading (MAHL). This approach is recommended for developing local limits for pollutants that affect treatment system 

performance and regulatory compliance, such as heavy metals and cyanide. This 

approach is described further in Appendix B. 

2. Collection system protection. This approach is recommended as the basis for establishing prohibited discharge standards to protect against fire/explosion, corrosion, flow obstruction, heat effects, and fume toxicity. This approach is described 

further in Appendix B. 

3. Pollution prevention. This approach is an alternative to setting quantifiable discharge limits. Pollution prevention measures are used to minimize or eliminate 

the discharge of toxic or hazardous pollutants to the sewer, or to minimize their 

impacts. It is Army policy to reduce pollutants at the source as the first means 

for achieving compliance. Therefore this approach must be integrated into all Installation Pretreatment Programs, regardless of the method for setting local limits. 

4. Best professional judgement. This approach is recommended to establish limits 

on a case-by-case basis where a rational methodology and technical basis for a 

limit may not exist. A sewage treatment plant manager may be able to set local 

limits using professional judgement augmented by industrial site survey information, sludge disposal requirements, and the toxicity information in Appendix 

B. This approach may be adequate at many Army installations with few Significant Industrial Users. 

The automated version of this Protocol establishes limits for specific pollutants 

based on the capacity of the treatment plant to accept those pollutants and meet 

permit requirements. Note that this method does not evaluate the effect pollutants have on specific treatment processes. The steps used to establish those limits are: 

1. Establish the removal efficiency at the treatment plant, using PRELIM 5.0, or 

another reasonable method. 

2. Use this data to determine the maximum concentration of each pollutant allowable in the influent without violating the NPDES Permit. 
CERL TR 99/49 25 

3. Determine the total mass of each pollutant allowable in the WWTP influent using the following equation: 

TPM = AIF × SF × [P]

where: 

TPM = the total mass for a given pollutant per day 

AIF = the average daily influent flow to the WWTP in liters/minute 

[P] = the maximum allowable concentration of a given pollutant in the 

WWTP influent 

SF = a safety factor to allow for pollutants from uncontrolled sources (suggest using a SF of 0.9 or less). 

4. Determine the discharge limit for each pollutant using the following equation: 

PDL = TPM ÷ TPF

where: 

PDL = the discharge limit for a specific pollutant 

TPM = the total pollutant mass per day allowed to enter the treatment plant 

(calculated above) 

TPF = sum of all maximum daily flows containing that pollutant. 

Varying Discharge Limits 

It is the total mass for a particular pollutant that is important to the wastewater 

treatment plant operator. Therefore the Pretreatment Program Manager may 

raise and lower the calculated discharge limits for given sources, as long as the 

total allowable mass remains the same. There may be an economic advantage to 

requiring a greater degree of treatment at one source and less treatment at another, due to economies of scale, etc. 

The concept of varying discharge limits should only be applied to facilities directly under the control of the Garrison Commander. This concept may not be 

practical for installations that have large tenants that build and maintain their 

own facilities. 
26 CERL TR 99/49 

Slug Discharge Control Provision 

Pretreatment Program Requirement: The Pretreatment Program shall 

evaluate, at least every 2 years, whether each significant industrial user needs a 

plan to control slug discharges. 

A slug discharge is any nonroutine discharge of a high concentration pollutants, 

such as would occur due to an accidental spill or noncustomary batch discharge. 

The installation Pollution Prevention Plan, the Installation Spill Prevention 

Control and Countermeasure Plan, and the Installation Spill Contingency Plan 

all should address the prevention of accidental spill causing slug discharges to 

the FOTW. The installation Pretreatment Program manager should determine if 

these plans are adequate to provide reasonable slug control. If these plans are 

not adequate, the Program manager could provide input during the renewal of 

one or more of the existing plans, or decide that a separate slug control plan is 

necessary. 

Typical noncustomary batch discharges are: (1) the disposal of septage and portable toilet waste from vacuum collection trucks, and (2) dumping of spent cleaning liquid from recycle parts washers. The Pretreatment Program manager 

should ensure that discharges from batch disposal will not cause interference or 

pass-through of pollutants at the sewage treatment plant. 

According to 40 CFR 403.8, a plan that controls slug discharges should include: 

1. A description of discharge practices, including nonroutine batch discharges 

2. A description of stored chemicals 

3. A provision to immediately notify the FOTW of slug discharges, with procedures 

for a follow-up written notification within 5 days 

4. If necessary, procedures to prevent adverse impact from accidental spills. Those 

procedures would include inspection and maintenance of storage areas, handling 

and transfer of materials, loading and unloading operations, worker training, 

building of containment structures, measures for containing toxic organic pollutants (including solvents), and/or measures and equipment for emergency response. 
CERL TR 99/49 27 

4 Allowable Changes to Categorical 

Discharge Limits 

40 CFR 403 allows the discharge limits stated in the Categorical Discharge 

Standards to be altered under certain circumstances. The following paragraphs 

describe those circumstances, as well as the calculations necessary to determine 

the alternative discharge limits. 

Note: While 40 CFR 403 allows variations to established Categorical discharge 

limits, a State or regional regulatory authority may have primacy, and not allow 

the variation. 

Combined Waste Stream Allowance 

When wastewater from a Categorical industrial process is mixed with wastewaters other than those generated by the regulated process, alternative discharge 

limits may be applied to the mixed waste stream. The alternative discharge 

limit will account for the dilution caused by the noncategorical waste stream. 

The noncategorical waste streams that are applicable are: 

• Boiler blowdown 

• Noncontact cooling water 

• Storm water 

• Demineralizer backwash 

• Domestic wastewater 

• Waste streams containing pollutants of concern: 

 Not detectable in the effluent 

 Present in trace amount not likely to cause toxic effects 

 Present in amounts too small to be removed by known technologies 

• Waste streams containing pollutants compatible with the FOTW. 
28 CERL TR 99/49 

Removal Credit Due to Treatment at FOTW 

Some pollutants regulated by categorical standards are removed, to some extent, 

by the treatment processes at the FOTW treatment plant. The effluent goal(s) 

for a specific pollutant(s) for a significant industrial user can be reduced, depending on the extent of removal of that pollutant(s) by the FOTW, if the following 

requirements (stated in 40 CFR 403.7) are met: 

1. “The (FOTW) demonstrates and continues to achieve consistent removal of the 

pollutant...”

2. “The granting of removal credits will not cause the (FOTW) to violate the local, 

State, and Federal Sludge Requirements which apply to the sludge management 

method chosen by the (FOTW).”

3. “The granting of removal credits will not cause a violation of the (FOTWs) permit 

limitations or conditions.”

Quantifying consistent removal by the FOTW. Results of influent and effluent analysis shall be used to justify and quantify removal credits. Sampling and 

analysis shall be conducted according to the following criteria: 

1. The data shall be representative of normal influent and effluent flow and quality 

characteristics. 

2. Monthly, 24-hour flow-proportional, composite samples shall be taken throughout 

1 full year. 

3. The 12 sampling days should be evenly distributed over the days of the week, to 

include nonwork days as well as work days. Historical data of this nature is acceptable. 

4. Sampling and analysis shall be performed in accordance with 40 CFR 136. 

5. Any day when the pollutant is not detectable in the influent may not be used as a 

sample day. 

6. Samples shall be taken on days when influent is representative of normal discharge from the significant industrial user. 

7. The pollutant concentration is always recorded at the level of detection or above. 

[influent]

[influent] [effluent] Percent Removal − =

“Consistent Removal” shall mean the average of the lowest six removals recorded during the 12 sampling days. 
CERL TR 99/49 29 

Calculation of revised discharge goals. Revised discharge goals for a specific 

pollutant shall be derived by use of the following formula: 

y = x ( ) 1− r

where: 

 x = the pollutant discharge limit specified in the categorical standard 

 r = removal credit for the pollutant, the “consistent removal” percentage 

 y = revised discharge limit for the specified pollutant. 

Allowance for Pollutants in Intake Water 

The Categorical Pretreatment Standard for the discharge of a specific pollutant 

to the FOTW may be increased because the pollutant is in the user’s intake water. The amount of the increase may be up to, but not exceed, the amount that is 

in the intake water. For this adjustment to be made, the following conditions, 

stated in 40 CFR 403.15, must be met: 

1. The Industrial User must demonstrate that the control system it proposes or 

uses would meet the Standards if the pollutants were not in the intake water. 

2. Credit for generic pollutants (such as BOD, TSS, and Oil and Grease) are granted 

if the generic pollutant concentrations are essentially the same in the user’s intake and discharge. 

3. The intake water is drawn from the same body of water as that into which the 

FOTW discharges. This requirement may be waived if no environmental degradation will result. 

4. The applicable categorical pretreatment standards contained in 40 CFR subchapter N specifically provide that they shall be applied on a net basis (i.e., adjusted 

to reflect credits). 

5. The Industrial User has received from the USEPA a variance from categorical 

pretreatment standards for fundamentally different factors. 

The procedures and criteria for obtaining a variance from the USEPA are described in 40 CFR 403. It is unlikely that an Army industrial facility would pursue such a variance, but it would be pursued on the DA level. Details for obtaining this change to the categorical standards will not be provided here. 
30 CERL TR 99/49 

5 Monitoring 

Pretreatment Program Requirement: Each facility is required to demonstrate compliance with the discharge standards at least twice a year. This includes reporting the nature and concentration of pollutants and average daily 

and maximum daily flow rates. The frequency of reporting for an individual facility may be increased if the user/facility has a history of noncompliance or for 

any other reason that the installation feels is necessary. These regulations are 

found in 40 CFR 403.12(e) for categorical pretreatment standards, and 40 CFR 

403.12 (h) for users not subject to categorical pretreatment standards: 

403.12(e) “Periodic reports on continued compliance. (1) Any Industrial 

User subject to a categorical Pretreatment Standard, after the compliance date of such Pretreatment Standard, or, in the case of a New Source, 

after commencement of the discharge into the (Treatment Works), shall 

submit to the [Pretreatment Program Manager] during the months of 

June and December, unless required more frequently in the Pretreatment 

Standard or by the [Pretreatment Program Manager] or the Approval Authority, a report indicating the nature and concentration of pollutants in 

the effluent which are limited by such categorical Pretreatment Standards. In addition, this report shall include a record of measured or estimated average and maximum daily flows for the reporting period for 

the Discharge reported in paragraph (b)(4) of this section except that the 

[Pretreatment Program Manager] may require more detailed reporting of 

flows. At the discretion of the [Pretreatment Program Manager] and in 

consideration of such factors as local high or low flow rates, holidays, 

budget cycles, etc., the [Pretreatment Program Manager] may agree to alter the months during which the above reports are to be submitted.”

403.12(h). “Reporting requirements for Industrial Users not subject to 

categorical Pretreatment Standards. The [Pretreatment Program Manager] shall require appropriate reporting from those Industrial Users 

with discharges that are not subject to categorical Pretreatment Standards. Significant Noncategorical Industrial Users shall submit to the 

[Pretreatment Program Manager] at least once every 6 months (on dates 

specified by the [Pretreatment Program Manager]) a description of the 

nature, concentration, and flow of the pollutants required to be reported 

by the [Pretreatment Program Manager].”

Note that, at most installations, the Pretreatment Program Manager will assume responsibility for some or all monitoring. 
CERL TR 99/49 31 

Worksheet 5-1: Monitoring 

Reference: 403.12. The following monitoring information should be completed 

for each Significant Industrial User two times per year. 

a. Facility name: 

b. Building number: 

c. Operator name and telephone number: 

d. For each regulated process stream at this facility, enter the average daily and maximum daily flows: 

Process Stream Average Daily Usage (gal/day) Maximum Daily Flow (gpm) 

 

e. Are process streams at this facility combined with other waste streams prior to pretreatment? 

____Yes ____No 

f. If yes, enter the average daily usage and maximum daily flows for these waste streams in the 

spaces below: 

Process Stream Average Daily Flow (gal/day) Maximum Daily Flow (gal/day) 

 

g. Samples shall be taken to measure pollutants of concern. At each location where pH, cyanide, total 

phenols, oil and grease, sulfide, or volatile organics are identified as pollutants of concern, a minimum 

of four grab samples shall be taken. For other pollutants of concern, a minimum of one 24-hour composite sample shall be taken from each location as described in 5, above. For each sample, list the 

following: 

Sample ID Date Time Location 

h. For each sample listed above, list all pollutants found and the level of each. 

Sample ID Pollutant Level Methods Used for Analysis 

 

 
32 CERL TR 99/49 

6 Recordkeeping 

Pretreatment Protocol Requirement: The Pretreatment Program Manager 

must keep a record of each activity that discharges to the FOTW. This record 

must include the activity’s name, location, and type and quantity of pollutant 

discharged to the FOTW. Instructions for gathering this information are found 

in the “Facility Inventory” section of this manual (Chapter 2, p 16). 

The Pretreatment Program Manager must formally document all industrial discharges to the FOTW. Records must be kept of all sampling and monitoring activities (as described in the “Monitoring” section of this manual) conducted at 

either the discharging activities or the FOTW. For each sample, the following 

information must be recorded: 

The worksheets in the previous sections of this manual are sufficient records 

once they have been completely filled out according to the instructions. The Pretreatment Program Manager must keep these records at least 3 years. This period of retention shall be extended during the course of any regulatory action or 

litigation regarding an Industrial User or FOTW or when requested by any Federal, State, or regional regulator. The USEPA may request copies of these records. 

403.12(o). Record-keeping requirements. 

For any Industrial User and FOTW subject to the reporting requirements 

established in this section [the Pretreatment Program Manager] shall 

maintain records of all information resulting from any monitoring activities required by this section. Such records shall include for all samples: 

• The date, exact place, method, and time of sampling and the 

names of the person or persons taking the samples; 

• The dates analyses were performed; 

• Who performed the analyses; 

• The analytical techniques/methods used; and 

• The results of such analyses. 

[Note that §403.12(i) says that annual reports must be submitted to regulatory agencies. The Department of the Army is currently negotiating 

with the USEPA to waive this requirement for Army facilities.] 
CERL TR 99/49 33 

7 Notifications 

Pretreatment Program Requirement: In the event of a sudden change in 

industrial processes, a spill, or other emergency, the discharging activity must 

notify the FOTW, and, under certain circumstances, notify the appropriate regulatory agency. 

These situations are spelled out in various sections of 40 CFR 403: 

1) Ref: §403.8(f)(2)(v). If the FOTW decides that a slug control plan is 

needed, the plan shall contain procedures for immediately notifying the 

FOTW of slug discharges, with procedures for follow-up written notification within 5 days. 

2) Ref: §403.12(j). All Industrial Users shall promptly notify the (FOTW) 

in advance of any substantial change in the volume or character of pollutants in the discharge, including any listed or characteristic hazardous 

wastes. 

3) Ref: §403.12(p)(1). The industrial user shall notify the (FOTW), the 

USEPA Regional Waste Management Division Director, and State hazardous waste authorities in writing of any discharge into the FOTW of a 

substance, which, if otherwise disposed of, would be a hazardous waste 

under 40 CFR 261. Such notification must include the name of the hazardous waste as set forth in 40 CFR 261, the USEPA hazardous waste 

number, and the type of discharge (continuous, batch, or other). If the industrial user discharges more than 100 kg of such waste per calendar 

month to the (FOTW), the notification shall also contain the following information to the extent such information is known and readily available 

to the industrial user: An identification of the hazardous constituents 

contained in the wastes, an estimation of the mass and concentration of 

such constituents in the waste stream discharged in during that calendar 

month, and an estimation of the mass of constituents in the waste stream 

expected to be discharged during the following 12 months. All notifications must take place within 180 days of the effective date of this rule. 

Industrial users who commence discharging after the effective date of this 
34 CERL TR 99/49 

rule shall provide the notification no later than 180 days after the discharge of the listed characteristic hazardous waste. Any notification under this paragraph need be submitted only once for each hazardous waste 

discharged. However, notifications of changed discharges must be submitted under 40 CFR 403.12(j). The notification requirement in this section does not apply to pollutants already reported under the selfmonitoring requirements of 40 CFR 403.12 (b), (d), and (e) (see Chapter 5, 

p 30). 

4) §403.12(p)(3). In the case of any new regulations under section 3001 

of RCRA identifying additional characteristics of hazardous waste (or) 

listing any additional substance as a hazardous waste, the industrial user 

must notify the (FOTW), the USEPA Regional Waste Management Division Director, and State hazardous waste authorities of the discharge of 

such substance within 90 days of the effective date of such regulations. 

5) §403.12(p)(2). Dischargers are exempt from the requirements of paragraph (p)(1) of this section during a calendar month in which they discharge no more than 15 kg of hazardous wastes, unless the wastes are 

acute hazardous wastes as specified in 40 CFR 261.30(d) and 261.33(e). 

Discharge of more than 15 kg of nonacute hazardous wastes in a calendar 

month, or of any quantity of acute hazardous wastes as specified in 40 

CFR 261.30(d) and 261.33(e), requires a one-time notification. 

6) §403.12(p)(4). In the case of any notification made under paragraph 

(p) of this section, the industrial user shall certify that it has a program in 

place to reduce the volume and toxicity of hazardous wastes generated to 

the degree it has determined to be economically practical. 

7) §403.16(c). Conditions necessary for a demonstration of upset. An Industrial User who wished to establish the affirmative defense of Upset 

shall demonstrate, through properly signed, contemporaneous operating 

logs, or other relevant evidence that: 

§403.16(c)(3) The Industrial User has submitted the following information to the (FOTW) and Pretreatment Program Manager within 

24 hours of becoming aware of the Upset (if this information is 

provided orally, a written submission must be provided within 5 

days): 

(i) A description of the Indirect Discharge and cause of noncompliance; 
CERL TR 99/49 35 

(ii) The period of noncompliance, including exact dates and times

or, if not corrected, the anticipated time the noncompliance is expected to continue; 

(iii) Steps being taken and/or planned to reduce, eliminate, and 

prevent recurrence of the noncompliance. 

8) §403.17(c)(1). If an Industrial User knows in advance of the need for a 

bypass, it shall submit prior notice to the (FOTW), if possible at least 10 

days before the date of the bypass. 

§403.17(c)(2) An Industrial User shall submit oral notice of an unanticipated bypass that exceeds applicable Pretreatment Standards 

to the (FOTW) within 24 hours from the time the Industrial User 

becomes aware of the bypass. A written submission shall also be 

provided within 5 days of the time the Industrial User becomes 

aware of the bypass. The written submission shall contain a description of the bypass and its cause; the duration of the bypass, 

including exact dates and times; and, if the bypass has not been 

corrected, the anticipated time it is expected to continue; and the 

steps taken or planned to reduced, eliminate, and prevent reoccurrence of the bypass. The Pretreatment Program Manager may 

waive the written report on a case-by-case basis if the oral report 

has been received within 24 hours. 

Under certain circumstances (as discussed in Chapter 2 and 8 of this protocol), a 

slug control plan is necessary. As part of that plan, the industrial user must notify the FOTW immediately after a slug discharge. Formal written notification 

must also be given to the FOTW. 

The user must also notify the FOTW if the volume or the pollutants in the discharge from your activity substantially change. This notification must be ahead 

of time if possible. 

The user must notify the FOTW, State hazardous waste regulators, and the 

USEPA regional director if they are discharging any pollutant that the USEPA 

considers a hazardous waste (per 40 CFR 261). You must tell them which pollutants, the frequency discharged, and the quantity to be released in the next 12 

months. If any new pollutants that you discharge are added to the USEPA’s list 

in the future, you must notify the same agencies. Pollutants that the USEPA 

considers “acute hazardous wastes” (per 40 CFR 261.30(d)) must be reported in 

any quantity. Activities can discharge up to 15 kg/month of nonacute hazardous 
36 CERL TR 99/49 

wastes without notifying the agency. If you do make a notification for a specific 

pollutant as described above, you must have a plan to reduce the discharge of 

that pollutant, where practical. 

In the event of an upset condition, or a bypass of the industrial activity’s pretreatment plant, the FOTW must be immediately notified. This notification 

must be properly documented. The records must show that the activity notified 

the FOTW of the upset condition or bypass within 24 hours, followed up by formal written notification. You must tell the FOTW what was discharged and 

when; how long will it/did it last; and what you are doing to solve the problem 

and prevent it happening in the future. 
CERL TR 99/49 37 

8 Compliance Schedules 

During the preparation and initial execution of an installation Pretreatment 

Program, the Program Manager must prepare schedules for achieving compliance with pretreatment regulatory requirements. Two schedules are required, 

one containing the steps for the preparation of the Pretreatment Plan, and the 

second schedule containing steps to achieve compliance with categorical Pretreatment Standards, where violations of those standards occur: 

1. Pretreatment Program Requirement: Prepare a schedule for the development of the Pretreatment Program (Ref 40 CFR 403.12(k). 

This schedule will include dates for the commencement and completion of major 

events leading to the development and implementation of an FOTW Pretreatment Program. The major events included in the schedule generally correspond 

to the guidance set forth in this Protocol. The schedule of major events should 

include, but not be limited to: 

• Preparation of the facility inventory (Chapter 2) 

• Establishing discharge goals (Chapter 3) 

• Establishing a monitoring program (Chapter 5)

• Preparing funding request documents (Chapter 9) 

• Establishing Program responsibilities (Chapter 9) 

• Establishing Program authority (Chapter 9)

• Preparing a Program organizational chart 

• Determining manpower and funding requirements 

• Establishing a training program. 

2. Pretreatment Program Requirement: Prepare a schedule for meeting 

Categorical Pretreatment Standards at industrial facilities in noncompliance 

(Ref 40 CFR 403.12(c). 

The Pretreatment Program manager shall prepare a schedule for meeting Categorical Pretreatment Standards at facilities where initial discharge testing show 

noncompliance with those standards. The schedule shall contain dates for the 

commencement and completion of major events leading to meeting the applicable 
38 CERL TR 99/49 

categorical Pretreatment Standard. No increment in the schedule shall exceed 9 

months. Major events in the schedule shall include, but not be limited to: 

• Hiring a consultant 

• Initiating pollution prevention measures 

• (include significant events to accomplish pollution prevention) 

• Initiating construction of additional pretreatment 

• Prepare A106 and 1398 documents 

• Contract with private design firm or Corps of Engineer District 

• Complete preliminary plans 

• Complete final plans 

• Commence construction 

• Complete construction 

• Industrial facility coming into compliance. 
CERL TR 99/49 39 

9 Ensuring Compliance 

The installation Pretreatment Program manager must include in the Program 

measures to ensure compliance with the Program. These measures include: 

• establishing authority within the installation 

• establishing responsibilities within the installation 

• obtaining funding and/or manpower necessary to initiate and execute the 

program 

• training 

• where necessary, maintaining pretreatment performance. 

Pretreatment Program Requirement: Establish Authority 

The Program shall be established by a directive from the Installation Commander (or his designee), naming and empowering a Pretreatment Program 

manager to establish a Pretreatment Program to comply with Federal, State, local, and Army (AR200-1) regulations. This directive shall be provided to all facilities or persons within the installation affected by the Program. 

Pretreatment Program Requirement: Establish Responsibilities 

The Program shall include an organization chart of the FOTW and other personnel who will administer the Program. The chart shall establish responsibilities 

of specific individuals for carrying out all requirements of the Program. These 

responsibilities shall include signatory authority, if required by State or local 

law. Requirements to be assigned to personnel include, but are not limited to: 

• Managing the Program 

• Preparation and updating the Facility Inventory 

• Establishment (and modification) of discharge goals 

• Maintaining a monitoring program, including sampling and analysis 

• Recordkeeping 

• Public notifications 

• Preparation of an annual report 
40 CERL TR 99/49 

• Updating the Pretreatment Program document 

• Preparing funding request documents 

• Operation and maintenance of pretreatment structures, including scheduling 

• Establishing and executing training programs. 

Also, each significant industrial user must designate persons responsible for operation of the industrial processes, operation of the pretreatment, and compliance with the Program discharge goals for that user. 

Pretreatment Program Requirement: Obtain Resources Necessary To 

Execute the Program 

Funding request and planning documents, such as the A106, shall be prepared to 

obtain the resources necessary to establish and execute the program (see Sect 1-

5). A106 funding requests may include, but not be limited to: 

• Surveys of industrial facilities and preparation of the Facility Inventory. 

• Upgrades to pretreatment 

• Implementation of pollution prevention measures 

• Engineering studies 

• Program initiation costs, including temporary funding for sampling, analysis, 

and pretreatment O&M. 

It may be necessary to initiate requests to augment the O&M/BASOPS funding 

for the installation to cover additional sampling and analysis to monitor discharge goals, provide additional O&M to pretreatment structures, and provide 

additional manpower to manage/execute the Program. 

Training 

Training of affected personnel is not required by regulation. However, training 

should be an integral part of any Army installation Pretreatment Program. At 

most installations, environmental divisions or directorates already execute some 

type of training program for the military and civilian tenants. It is recommended that these existing programs be augmented to include instruction to enhance awareness and compliance with pretreatment regulation. 
CERL TR 99/49 41 

10 Provisions To Update Program 

Changes such as the addition or deletion of users or changes in discharge limits 

can greatly affect the influent to the FOTW. Therefore, it is recommended that 

the installation update their pretreatment program annually. Areas to look for 

changes when preparing an update to the pretreatment program are: 

1. The addition of new users or facilities. If new users or facilities exist, the installation should update the list of sources worksheet and prepare new facility information worksheets. Both of these are found in the “Facilities Inventory” section 

(p 16) of this manual. 

2. The removal of users or facilities. If a significant industrial user is no longer discharging to the FOTW, that user may be removed from the list of sources worksheet. This is found in the “Facilities Inventory” section of this manual. 

3. Change in mission. If a significant industrial user adds or changes a process or 

operation, the installation should update the facility information worksheets for 

that user. These are found in the “Facility Inventory” section (p 16) of this manual. 

4. Changes in discharge limits/requirements. If the installation determines that it 

must set more restrictive discharge limits or requirements, it should update 

those limits according to the “Establish Discharge Goals/Requirements” section 

(p 21) of this manual. 

5. New categorical standards. If Subpart N of 40 CFR is changed to include new 

types of industrial facilities, the installation should review user information to 

determine if it is affected by the change. If so, the installation should update the 

information in the “Establishing Discharge Goals/Requirements” section (p 21) of 

their program. 

6. Changes in production. If an industrial user significantly increases or decreases 

production, the installation should update the facility information worksheets 

and the worksheets found in the “Establish Discharge Goals/Requirements” section (p 21) of this manual. 

7. Pretreatment structure upgrades. The upgrade of an existing pretreatment structure, or the addition of a new pretreatment structure at an existing industrial 

source will impact both the site information data sheets and the eventually the 

discharge data. It may be beneficial to update general discharge limits. 
42 CERL TR 99/49 

11 FOTWs With Flow ≤ 5 MGD 

The program requirements specified in the previous sections of this manual were 

for FOTWs with a total design flow greater than 5 million gal per day (MGD). 

This section specifies requirements for those FOTWs with flow less than or equal 

to 5 MGD. 

For those FOTWs with a total design flow of 5 MGD or less, the Military Services 

headquarters or USEPA may recommend adherence to the standards for FOTWs 

with flow greater than 5 MGD, which have been previously described in this 

manual. This recommendation may be made based on the nature or volume of 

the industrial influent, upsets in treatment processes at the FOTW, violations of 

FOTW effluent limitations, contamination of municipal sludge, or other when 

other circumstances warrant to prevent interference with the FOTW or its pass 

through. 

To ensure the adequacy of pretreatment programs on DoD installations, for those 

FOTWs with a design flow of 5 MGD or less that are not required to comply with 

the standards described in the previous chapters, the following requirements will 

be implemented: 

1. Identify and locate each facility that might be subject to the FOTWpretreatment 

program. Instructions for preparing this information can be found in the “Introduction” (p 5) and “Chapter 1 Facility Inventory” (p 16) sections of this manual. 

2. Identify the character and volume of pollutants contributed to the FOTW by the 

facility identified in 1 above. Procedures for this can be found in the “Facility Inventory” section of this manual. 

3. Investigate instances of noncompliance with the general and categorical pretreatment standards and requirements as indicated by surveillance activities. 

Categorical limits can be found in Appendix A of this manual. 

The installation, in the process of administering the pretreatment program described in this section for the various industrial process waste streams it monitors, will incorporate pollution prevention activities to reduce the volume or toxicity of the wastes it is receiving. 
CERL TR 99/49 43 

Acronyms and Abbreviations 

AEC Army Environmental Center 

AMC Army Materiel Command 

BOD5 Biochemical Oxygen Demand 

CFR Code of Federal Regulations 

COD Chemical Oxygen Demand 

CWA Clean Water Act 

DoD Department of Defense 

USEPA Environmental Protection Agency 

FEMA Federal Emergency Management Agency 

FFCA Federal Facility Compliance Act 

FOTW Federally Owned Treatment Works 

GOCO Government-Owned, Contractor-Operated 

MACOM Major Command (Army) 

MDW Military District of Washington 

MGD Million Gallons per Day 

NPDES National Pollutant Discharge Elimination System 

POTW Publicly Owned Treatment Works 

PSES Pretreatment Standards for Existing Sources 
44 CERL TR 99/49 

PSNS Pretreatment Standards for New Sources 

QA/QC Quality Assurance/Quality Control 

RCRA Resource Conservation and Recovery Act 

SPDES State Pollutant Discharge Elimination System 

SIC Standard Industrial Classification 

STP Sewage Treatment Plant 

TTO Total Toxic Organics 

TSS Total Suspended Solids 

USC United States Code 
CERL TR 99/49 45 

Glossary 

Approval Authority - The Director in an NPDES State with an approved State 

pretreatment program and the appropriate Regional Administrator in a nonplus 

State or NPDES State without an approved State pretreatment program. This is 

not established for FOTWs. 

Average Daily Flow - A reasonable measure of the average daily flow over a 30-

day period. 

Bioassay – The exposure of test organisms to a concentration of an effluent or 

toxicant within a predefined time under controlled conditions to determine an 

identifiable effect. 

BOD5 - Five day biochemical oxygen demand. 

Bypass - The intentional diversion of waste streams from any portion of an Industrial User’s treatment facility. 

BTEX - Benzene, Toluene, Ethylbenzene, and Xylene. 

Categorical Pretreatment Standards - National pretreatment standards 

specifying quantities or concentrations of pollutants or pollutant properties 

which may be discharged to a POTW by existing or new industrial users in specific industrial subcategories. Established as separate regulations under the appropriate subpart of 40 CFR chapter I, subchapter N. These standards, unless 

specifically noted otherwise, are in addition to all applicable pretreatment standards and requirements. 

COD - Chemical Oxygen Demand. 

Composite Sample - Sample composed of two or more discrete samples. 

Control Authority - The Treatment Works if the Treatment Works’ submission 

for its pretreatment program (§§403.3(t)(1)) has been approved in accordance 

with the requirements of §403.11; or the Approval Authority if the submission 

has not been approved. 
46 CERL TR 99/49 

CWA - Federal Water Pollution Control Act, also known as the Clean Water Act, 

as amended, 33 U.S.C. 1251, et seq. 

Discharge or Indirect Discharge - The introduction of pollutants into a 

Treatment Works from any nondomestic source regulated under section 307(b), 

(c) or (d) of the CWA. 

Domestic Sources - Wastewater contributed to the sanitary sewer from strictly 

residential areas. 

FOTW or Federally Owned Treatment Works – A DoD wastewater treatment 

works qualifies for FOTW status under RCRA Section 3023, 42 USC Section 

6939e, if it meets all of the following requirements: 

 The treatment works is owned or operated by the DoD; 

 The majority of the influent received at the treatment works is domestic sewage from such sources as housing areas, bachelor officer quarters, bachelor 

enlisted quarters, recreational areas, and sanitary sewage from workplaces; and 

 The effluent of the treatment works is subject to a permit issued pursuant to 

Section 402 of the CWA. 

gpm - Gallons per minute. 

Grab Sample - Sample which is taken on a one time basis without regard to 

flow or time. 

Industrial User - A source of Indirect Discharge; any facility discharging 

wastewater which is not of comparable strength, origin and/or flow of typical 

domestic sources. 

Interference - A discharge which, alone or in conjunction with a discharge or 

discharges from other sources, both: 

 (1) Inhibits or disrupts the Treatment Works, its treatment processes or 

operations, or its sludge processes, use or disposal; and 

 (2) Therefore is a cause of a violation of any requirement of the NPDES 

permit or of the prevention of sewage sludge use or disposal in compliance with 

Section 503 of the Clean Water Act, the Solid Waste Disposal Act (SWDA) (including title II, more commonly referred to as the Resource Conservation and 
CERL TR 99/49 47 

Recovery Act (RCRA), the Clean Air Act, the Toxic Substances Control Act, and 

the Marine Protection, Research and Sanctuaries Act. 

mg/L - Milligrams per liter 

New Source - Any building, structure, facility or installation from which there 

is or may be a discharge of pollutants, the construction of which commenced after the publication of proposed Pretreatment Standards under section 307(c) of 

the CWA which will be applicable to such source if such Standards are thereafter 

promulgated in accordance with that section, provided that: 

 (1) The building, structure, facility, or installation is constructed at a site at 

which no other source is located; or 

 (2) The building, structure, facility, or installation totally replaces the process or production equipment that causes the discharge of pollutants at an existing source; or 

 (3) The production or wastewater generating processes of the building, 

structure, facility, or installation are substantially independent of an existing 

source at the same site. In determining whether these are substantially independent, factors such as the extent to which the new facility is integrated with 

the existing plant, and the extent to which the new facility is engaged in the 

same general type of activity as the existing source should be considered. 

NPDES - National Pollutant Discharge Elimination System. 

Pass Through – A discharge which exits the Treatment Works into waters of 

the United States in quantities or concentrations which, alone or in conjunction 

with a discharge or discharges from other sources, is a cause of a violation of any 

requirement of the NPDES permit. 

Pretreatment - The reduction of the amount of pollutants, the elimination of 

pollutants, or the alteration of the nature of pollutant properties in wastewater 

prior to or in lieu of discharging or otherwise introducing such pollutants into a 

Treatment Works. The reduction or alteration may be obtained by physical, 

chemical or biological processes, process changes or by other means, except as 

prohibited by §§403.6(d). 

Pretreatment Standard or National Pretreatment Standard - Any 

regulation containing pollutant discharge limits promulgated by the USEPA in 

accordance with section 307 (b) and (c) of the CWA, which applies to Industrial 
48 CERL TR 99/49 

Users. This term includes prohibitive discharge limits established pursuant to 

§403.5. 

POTW or Publicly Owned Treatment Works - A treatment works as defined 

by section 212 of the CWA, which is owned by a State or municipality (as defined 

by section 502(4) of the CWA). This definition includes any devices and systems 

used in the storage, treatment, recycling and reclamation of municipal sewage or 

industrial wastes of a liquid nature. It also includes sewers, pipes, and other 

conveyances only if they convey wastewater to a POTW Treatment Plant. The 

term also means the municipality as defined in section 502(4) of the CWA, which 

has jurisdiction over the discharges to and the discharges from such a treatment 

works. 

POTW Treatment Plant - That portion of the POTW which is designed to 

provide treatment (including recycling and reclamation) of municipal sewage and 

industrial waste. 

RCRA - Resource Conservation and Recovery Act. 

Significant Industrial User or SIU - 

 (1) All industrial users subject to Categorical Pretreatment Standards under 40 CFR part 403.6 and 40 CFR chapter I, subchapter N; and 

 (2) Any other industrial user that: discharges an average of 25,000 gal per 

day or more of process wastewater to the Treatment Works (excluding sanitary, 

noncontact cooling and boiler blowdown wastewater); contributes a process 

waste stream which makes up 5 percent or more of the average dry weather hydraulic or organic capacity of the treatment plant; or is designated as such by the 

Pretreatment Program Manager as defined in 40 CFR 403.12(a) on the basis that 

the industrial user has a reasonable potential for adversely affecting the Treatment Works’ operation or for violating any pretreatment standard or requirement (in accordance with 40 CFR part 403.8(f)(6)). 

Total Toxic Organics - The summation of the organic compounds listed in 

appendix A which are present in quantities greater than 0.01 mg/L. 

Treatment Works - A wastewater collection and treatment system that 

primarily accepts domestic wastewater. 

TSS - Total suspended solids. 
CERL TR 99/49 49 

Upset - An exceptional incident in which there is unintentional and temporary 

noncompliance with the discharge standards established by this regulation 

because of factors beyond the reasonable control of the industrial user. 

WWTP or Wastewater Treatment Plant - Treatment facility which receives 

both domestic and industrial wastewater. Can also be referred to as POTW or 

FOTW treatment plant, or a sewage treatment plant (STP). 

Whole-Effluent Toxicity (WET) – Testing which involves performing bioassays 

using two or more aquatic species as test organisms to determine any acute or 

chronic toxicity, as defined by test results. The USEPA has published methods 

for measuring the acute and chronic toxicity of effluents and receiving water to 

freshwater, marine, and estuarine organisms. 
50 CERL TR 99/49 

References 

Aberdeen Proving Ground (APG) Regulation No. 200-41 “Wastewater Discharge Management”

(APG, MD, 20 May 1996). 

Code of Federal Regulations, Chapter 40, Part 403 (40 CFR 403). 

FOTW Position/Comment Paper – Phase 1 and 2, Final Report prepared for the U.S. Army Environmental Center (AEC), APG, MD (Horne Engineering Services, Inc, September 30, 1997). 

U.S. Army Wastewater Pretreatment Programs Development Protocol, prepared for AEC (U.S. Army 

Center for Health Promotion and Preventive Medicine, undated). 

Military Handbook (for) Wastewater Pretreatment Design and Control, Draft MIL-HDBK-1005/17 

(Headquarters, Department of the Army [HQDA], 22 May 1998). 

Guidance Manual for the Development and Implementation of Local Discharge Limitations Under 

the Pretreatment Program, U.S. Environmental Protection Agency (EPA)-833-B-87-202 (1987). 

Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors, EPA-812-B-92-001 

(June 1992). 

U.S. Army Environmental Center report: Sewage Sludge (Biosolids) Management Manual for 

Army Facilities (AEC, APG, MD, 26 April 1996). 

The U.S. Army EPR Project Catalog, which is a periodical publication prepared by the Special Programs Branch at AEC. Copies of the catalog may be obtained by calling the EPR Action Officer, AEC Special Programs Branch at 410-436-7102. The catalog can also be downloaded from 

DENIX at: 

http://denix.cecer.army.mil/denix/DOD/Interaction/Reporting/EPR/Catalog/catalog.html. 
CERL TR 99/49 51 

Appendix A: Discharge Limits Established 

by Categorical Pretreatment Standards 

1. ELECTROPLATING

40 CFR Part 413 – Electroplating Point Source Category 

NOTE: Part 413 applies only to “job shops” in existence since 7 September 

1997. Job shops are defined as those facilities that in a calendar year do not own 

more than 50 percent (by surface area) of the material undergoing metal finishing. Electroplating facilities that do not meet that criteria are covered by 40 

CFR 433 that regulates metal finishing. 

Part 413 limits the pollutants in process wastewater from the plating of 

metal with copper, nickel, chromium, zinc, tin, lead, cadmium, iron, aluminum, 

or any combination these. Part 413 establishes discharge limits for each of six 

types of electroplating subcategories: 

1. Electroplating of common metals 

2. Electroplating of precious metals 

3. Anodizing 

4. Coatings processes – chromating, phosphating, or immersion plating 

5. Chemical etching and milling 

6. Electroless plating. 

Discharge limits are placed on some or all of the following pollutants in the process wastewater for the above facilities: Ag; CN,A (amenable to chlorination); 

CN,T (total); Cu; Ni; Cr; Zn; Pb; Cd; Total Metals; Total Suspended Solids; and 

pH. Limits are also established for Total Toxic Organics (TTO). A list of these 

organic chemicals is presented in Section 413.02 “General Definitions.”

Discharge limits are expressed in terms of mass per volume (usually mg/L) 

and/or mass per area of metal electroplated (usually mg/m2

). Limits are expressed as the maximum for any 1 day, and as the average of daily values for 4 

consecutive monitoring days. 
52 CERL TR 99/49 

Because inclusion of all discharge limits for this subcategory would be quite 

lengthy, and because application of this subcategory is somewhat limited, not all 

specific discharge parameters are included in this report. Facilities having electroplating processes should refer to 40 CFR Section 413. 

2. INORGANIC CHEMICALS

40 CFR Part 415 — Inorganic Chemicals Manufacturing Point Source Category. 

Sixty-seven chemicals are listed in Subparts A through BO in Part 415. 

Twenty of these chemicals are designated as [Reserved], i.e., no pretreatment 

criteria have been established for them. Because the information in this regulation is so extensive, and because there is limited application to most Army facilities, pretreatment criteria for inorganic chemicals manufacturing will not be included here. Army facilities which manufacturer the chemicals in the following 

list of subcategories should refer to 40 CFR Part 415. 

 A. Aluminum Chloride 

 B. Aluminum Sulfate 

 C. Calcium Carbide 

 D. Calcium Chloride 

 E. Calcium Oxide 

 F. Chlor-alkali (Chlorine and Sodium or Potassium Hydroxide) 

 H. Hydrofluoric Acid 

 I. Hydrogen Peroxide 

 K. Potassium Metal 

 L. Potassium Dichromate 

 M. Potassium Sulfate 

 N. Sodium Bicarbonate 

 P. Sodium Chloride 

 Q. Sodium Dichromate and Sodium Sulfate 

 T. Sodium Sulfite 

 V. Titanium Dioxide 

 W. Aluminum Fluoride 

 X. Ammonium Chloride 
CERL TR 99/49 53 

 AA. Borax 

 AB. Boric Acid 

 AC. Bromine 

 AD. Calcium Carbonate 

 AE. Calcium Hydroxide 

 AG. Carbon Monoxide and By-product Hydrogen 

 AH. Chrome Pigments 

 AI. Chromic Acid 

 AJ. Copper Salts 

 AL. Ferric Chloride 

 AN. Fluorine 

 AO. Hydrogen 

 AP. Hydrogen Cyanide 

 AQ. Iodine 

 AR. Lead Monoxide 

 AS. Lithium Carbonate 

 AU. Nickel Salts 

 AW. Oxygen and Nitrogen 

 AX. Potassium Chloride 

 AY. Potassium Iodide 

 BA. Silver Nitrate 

 BB. Sodium Bisulfate 

 BC. Sodium Fluoride 

 BH. Stannic Oxide 

 BK. Zinc Sulfate 

 BL. Cadmium Pigments 

 BM. Cobalt Salts 

 BN. Sodium chlorate 

 BO. Zinc Chloride 
54 CERL TR 99/49 

Note: 40 CFR 457 — “Explosives Manufacturing Point Source Category” applies 

to point source discharge (not pretreatment) of effluent from commercial manufacture of explosives, including load, assembly, and pack (LAP) plants. 

3. METAL FINISHING

 40 CFR Part 433 — Metal Finishing Point Source Category 

 Part 433 applies to the following six metal finishing operations: (1) Electroplating, (2) Electroless Plating, (3) Anodizing, (4) Coating (chromating, phosphating, and coloring), (5) Chemical Etching and Milling, and (6) Printed Circuit 

Board Manufacture — if they are not covered by Part 413 Electroplating. If any 

of those six operations are present, then Part 433 also applies to the following 40 

process operations: Cleaning, Machining, Grinding, Polishing, Tumbling, Burnishing, Impact Deformation, Pressure Deformation, Shearing, Heat Treating, 

Thermal Cutting, Welding, Brazing, Soldering, Flame Spraying, Sand Blasting, 

Other Abrasive Jet Machining, Electric Discharge Machining, Electrochemical 

Machining, Electron Beam Machining, Laser Beam Machining, Plasma Arc Machining, Ultrasonic Machining, Sintering, Laminating, Hot Dip Coating, Sputtering, Vapor Plating, Thermal Infusion, Salt Bath Descaling, Solvent Degreasing, 

Paint Stripping, Painting, Electrostatic Painting, Electropainting, Vacuum 

Metalizing, Assembly, Calibration, Testing, and Mechanical Plating. 

 Part 433 does NOT apply to Metal Molding and Casting, which is covered by 

Part 464 (described below). 

Because inclusion of all discharge limits for this subcategory would be quite 

lengthy, and because application of this subcategory is somewhat limited, specific 

discharge parameters are not included in this report. Facilities having metal 

finishing processes should refer to 40 CFR Part 433. 

4. METALS MOLDING AND CASTING

 40 CFR Part 464 — Metal Molding and Casting Point Source Category. 

 This regulation is divided into four Subparts: 

 Subpart A — Aluminum Casting Subcategory 

 Subpart B — Copper Casting Subcategory 
CERL TR 99/49 55 

 Subpart C — Ferrous Casting Subcategory 

 Subpart D — Zinc Casting Subcategory. 

Each subpart contains effluent limitations for the various operations involved in 

metal molding and casting. For each operation, separate limitations are listed 

for the degree of reduction achievable using the best practicable control technology (BPT) currently available, and for the degree of reduction economically 

achievable using the best available technology (BAT). Those operations are as 

follows: 

 Casting Cleaning Operations 

 Casting Quench Operations 

 Die Casting Operations 

 Dust Collection Scrubber Operations 

 Grinding Scrubber Operations 

 Investment Casting 

 Melting Furnace Scrubber Operations 

 Mold Cooling Operations 

Because inclusion of all discharge limits for this subcategory would be quite 

lengthy, and because application of this subcategory is somewhat limited, specific 

discharge parameters are not included in this report. Facilities having metal 

molding and casting processes should refer to 40 CFR Part 464. 
56 CERL TR 99/49 

Appendix B: Development of Technically 

Based Local Limits 

Note: This appendix has been taken in its entirety from the (draft) Military 

Handbook (for) Wastewater Pretreatment Design and Control, MIL-HDBK1005/17 (22 May 1998). 

Overview. The purpose of this section is to provide guidance for the development 

of technically based local limits to control pollutant discharges from nondomestic 

military sources FOTWs. For military installations that discharge to a POTW, 

the guidance will be useful in assessing whether local limits developed by the 

POTW are reasonable and defensible. 

 The MAHL Approach. A schematic diagram of the development process for 

local limits based on the maximum allowable headworks loading approach is 

given in Figure 1. The process is further described in the following subsections. 

 Regulatory Criteria. The regulatory guidelines and criteria that serve as the 

technical basis for developing local limits encompass process inhibition, biosolids 

disposal, and effluent disposal. 

3.4.1.1 Process Inhibition. Any biological treatment process is potentially 

subject to toxic inhibition, including the activated sludge process, the trickling 

filter process, and the anaerobic digestion process. Threshold inhibition levels 

for these processes are given in the previously referenced USEPA-833-B-87-202 

and are summarized in Table 4. The aerobic digestion process is not included in 

this table because it apparently is rarely, if ever, subject to toxic inhibition as 

long as the biological process feeding it is free of toxicity. 

3.4.1.2 Biosolids Disposal. Allowable pollutant concentrations in biosolids 

disposed by a treatment plant depend on the final use or disposal destination of 

the solids. Table 5 presents the allowable pollutant concentrations for landspreading and surface disposal of biosolids, based on Federal regulations (40 

CFR 503). State requirements generally follow the Federal regulations, but may 

be more stringent. For lagoon treatment systems, biosolids regulations would 

not apply unless sludge is removed from the lagoons for disposal. 
CERL TR 99/49 57 

Figure 1. Schematic for development of local limits. 

3.4.1.3 Effluent Discharge. Allowable pollutant concentrations in treatment 

system effluent are sometimes specified in the system’s NPDES permit. If not, 

they may be derived from applicable receiving water quality criteria. Table 6 

presents the USEPA’s water quality criteria under 

	



	

			

	

	
	

	
	


	

	
		
	 	

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58 CERL TR 99/49 

Table 4. Toxic pollutant inhibition threshold levels. 

Pollutant Activated Sludge Nitrification Trickling Filters Anaerobic Digestion 

Arsenic 0.1 1.5 — 1.6 

Cadmium 1-10 5.2 — 20 

Chromium (total) 1-100 0.25-1.9 1-100 — 

Chromium (III) 10-50 — 3.5-67.6 130 

Chromium (VI) 1 1-10 — 110 

Copper 1 0.05-0.48 — 40 

Lead 1 0.5 — 340 

Nickel 1 0.25-5 — 10-36 

Zinc 0.3-10 0.08-0.5 — 400 

Mercury 0.1 — — — 

Silver 0.25-5 — — 13-65 

Cyanide 0.1-5 0.34-0.5 30 1-100 

Acrylonitrile — — — 5 

Anthracene 500 — — — 

Benzene 100 — — 

Carbon Tetrachloride — — — 2-159.4 

Chlorobenzene — — — 0.96-3 

Chloroform — 10 — 1-16 

2-Chlorophenol 5-200 — — — 

1,2 Dichlorobenzene 5 — — 0.23-3.8 

1,3 Dichlorobenzene 5 — — — 

1,4 Dichlorobenzene 5 — — 1.4-5.3 

2,4 Dichlorophenol 64 64 — — 

2,4 Dinitrophenol 150 — — 

2,4 Dimethylphenol 40-200 — — — 

2,4 Dinitrotoluene 5 — — — 

1,2 Diphenylhydrazine 5 — — — 

Ethylbenzene 200 — — — 

Hexachlorobenzene 5 — — — 

Pentachlorophenol 0.95-150 — — 0.2-1.8 

Phenanthrene 500 — — — 

Phenol 50-200 4-10 — — 

Tetrochloroethylene — — — 2- 

Trichloroethylene — — — 1-20 

Toluene 200 — — — 

2,4,6 Trichlorophenol 50-100 — — — 

Surfactants 100-500 — — — 

Source: EPA-833-B-87-202, Tables 3-2 through 3-5, EPA Office of Water, December 1987. 

Note: All units are in mg/L. 
CERL TR 99/49 59 
Table 5. USEPA sludge pollutant limitations for land application. Condition 2b Condition 4d Condition 1a Alternate 1 Alternate 2 Condition 3c Alternate 1 Alternate 2 Co

Pollutant Ceiling Con- centration (mg/kg) Maximum Cumulative Loads (kg/ha) Maximum Concentrations (mg/kg) Maximum Concentrations (mg/kg) Maximum Concentrations (mg/kg) Maximum Annual Pollutant Loading Rates (kg/ha/yr) 

Co

Arsenic 75 41 41 41 41 2.0 Cadmium 85 39 39 39 39 1.9 Chromium 00 00 00 00 00 00 Copper 4,300 1,500 1,500 1,500 1,500 75 Lead 840 300 300 300 300 15 Mercury 57 17 17 17 17 0.85 Molybdenum 75 

—

—

—

—

—

Nickel 420 420 420 420 420 21 Selenium 100 100 36 100 36 5.0 Zinc 7,500 2,800 2,800 2,800 2,800 140 

—

a Condition 1:Bulk sewage sludge or sewage sludge sold or given away in a bag or container [40 CFR 503.13(a)(1) - Table 1]. b Condition 2: Bulk sewage sludge applied to agricultural land, forest, a public contact site, or a reclamation site [40 CFR 503.13(a)(2) 

and 3]. 

c Condition 3: Bulk sewage sludge applied to a lawn or home garden [40 CFR 503.13(a)(3) - Table 3]. d Condition 4: Sewage sludge sold or given away in a bag or other container [40 CFR 503.13(a)(4) 

– Tables 3 and 4]. 

e Condition 5: Sewage sludge placed in a surface disposal site (sludge-only landfill) [40 CFR 503.13(a)(1) - Table 6]. Note: Maximum concentrations are less than those shown if distance from sludge unit to property line is less than 150 meters. 
Table 6. Water quality criteria for selected pollutants. Freshwater Saltwater Human Health Pollutant Criterion Maximum Concentration (μg/L) Criterion Continuous Concentration (μg/L) Criterion Maximum Concentration (μg/L) Criterion Continuous Concentration (μg/L) Criterion Maximum Concentration (μg/L) Crite

Contin

Concen

(μg/

Antimony 14 4,300 Arsenic 360 190 69 36 0.018 0Cadmium 3.9 a 1.1 a 43 9.3 16 170 Chromium (III) 1,700 a 210 a — — 33,000 670,000 Chromium (VI) 16 11 1,100 50 170 3,400 Copper 18 a 12 a 2.9 2.9 — — Lead 82 a 3.2 a 220 8.5 — — Mercury 2.4 0.012 2.1 0.025 0.14 0Nickel 1,400 a 160 a 75 8.3 610 4,600 Selenium 20 5 300 71 — — Silver 4.1 a — 2.3 — – — Thallium — — — — 1.7 6Zinc 120 a 110 a 95 86 — — Cyanide 22 5.2 1 1 700 220,000 Benzene — — — — 1.2 7Ethylbenzene — — — — 3,100 29,000 Methylene Chloride — — — — 4.7 1,600 Toluene — — — — 6,800 200,000 Pentachlorophenol 20 b 13 b 13 7.9 0.28 8Phenol — — — — 21,000 4,600,00Source: National Toxics Rule, Federal Register, December 22, 1992. a Freshwater criteria are a function of total hardness; values shown correspond to a total hardness of 100 mg/L. b Freshwater criteria are a function of pH; values shown correspond to a pH of 7.8. 
62 CERL TR 99/49 
CERL TR 99/49 63 

Section 304(a) of the Clean Water Act for some key priority toxic pollutants. 

These criteria are applicable in states that have not developed their own water 

quality criteria and are the basis for the criteria developed and enforced individually by other states. Some differences in the values of individual parameters 

may exist from State to State. 

The approach used to derive allowable treatment system effluent concentrations 

from water quality criteria also varies from State to State. The basic approach is 

to assume that the effluent must comply with the Criterion Maximum Concentrations (CMCs) at or near the point of discharge and comply with the Criterion 

Continuous Concentrations (CCCs) and Human Health Concentrations (HHCs) 

after dilution in a mixing zone. However, a number of different factors should be 

discussed with regulatory authorities in implementing this approach, including 

the following: 

a) Establishment of the dimensions of the mixing zone to which the CCCs and 

HHCs apply, or the dimensions of the zone of initial dilution (ZID), the smaller 

area within the mixing zone, to which the CMCs apply. 

b) If the discharge is to a flowing stream, determination of the low stream flow 

available for dilution. 

c) Determination of the bioavailability of the pollutants of concern, recognizing 

that some processes discharge heavy metals that are organically bound or otherwise not bioavailable. The USEPA and some states recognize and accept various approaches to account for metals bioavailability, including chemical translator ratios, bioassay water effects ratios, and significant indigenous species 

evaluations. 

d) Establishment of the hardness, pH, and chloride content of the receiving water, which impact the toxicity of some metals and hence the magnitude of some 

water quality criteria. 

e) Establishment of the background concentrations of pollutants in the receiving water; the lower the background concentration, the greater the allowable effluent discharge concentration. 

f) Consideration of the practical quantitative level of a pollutant in cases where 

the water quality criterion may actually be lower than USEPA’s approved 

method detection limit for the pollutant. 
64 CERL TR 99/49 

3.4.1.4 Air Emissions. Hazardous air pollutants (HAPs) at wastewater treatment plants are regulated under the Federal Clean Air Act Amendments (CAAA) 

of 1990. Four titles under the CAAA of 1990 may apply to WWTPs, but only one 

of these, Title III, has potential ramifications on the development and setting of 

local limits. Title III requires implementation of maximum achievable control 

technology (MACT) for major sources of HAPs at WWTPs. Major sources are defined as those that have the potential to emit at least 10 tons/year of any individual HAP, or 25 tons/year total HAPs. The USEPA has designated 189 compounds and elements as Federal HAPs, but only about 26 of these have been 

detected at WWTPs. For practical purposes, the conventional priority pollutant 

scans address the HAPs of concern at WWTPs. 

The USEPA has issued guidance to assist in determining whether a WWTP is a 

major source of HAPs and therefore subject to implementation of MACT. Under 

this guidance, a WWTP would be subject to installing MACT if it met two of the 

following three criteria: 

1. It has a capacity greater than 50 MGD 

2. It accepts more than 30 percent industrial waste contribution 

3. It has influent priority pollutant volatile organic chemical (VOC) concentrations 

greater than 5 mg/L. 

Few FOTWs and POTWs are expected to exceed these criteria and thus be subject to implementation of MACT. However, under Section 112(r) of Title III, even 

nonmajor sources of HAPs must prepare a Risk Management Plan if they use or 

store acutely hazardous material in quantities above specified threshold limits. 

The threshold limits are 2,500 lb for chlorine, 5,000 lb for sulfur dioxide, and 

10,000 lb for ammonia and methane. 

Pollutants of Concern. “Pollutants of concern” are those having the potential to 

cause treatment system upset, interference, permit violations, or endangerment 

of worker health and safety. Local limits must be developed for all pollutants of 

concern. 

The USEPA has provided guidance for identifying pollutants of concern, which is 

described in EPA-833-B-87-202. Pollutants of concern must generally include 

cadmium, chromium, copper, lead, nickel, zinc, silver, arsenic, mercury, and cyanide. In addition, USEPA guidance directs that a toxic pollutant may be classified as a pollutant of concern if it meets any one of the following screening criteria: 
CERL TR 99/49 65 

a) The maximum concentration of the pollutant in the WWTP influent is more 

than 1/500th of the allowable biosolids concentration, or more than onefourth of the inhibition threshold for the biological process. 

b) The maximum concentration of the pollutant in the WWTP biosolids is more 

than half of the allowable biosolids concentration. The allowable biosolids 

concentration will depend on the method of disposal. (See Table 5 and 40 

CFR 503 for further details.) 

c) The maximum concentration of the pollutant in the diluted mixture of WWTP 

effluent and receiving water is more than half of the allowable receiving water concentration. 

Treatment Plant Removal Efficiencies. Treatment plant removal efficiencies 

must be determined to compute MAHLs from effluent and biosolids criteria. Site 

specific data collected over a period of at least a year are preferred for this purpose. The removal efficiency, R, for any given pollutant may be computed as follows: 

InfluentConcentration

InfluentConcentration EffluentConcentration R ( − ) =

The measured influent and effluent concentrations are frequently near, or even 

less than, the method detection limit. Consequently, computed removal efficiencies can be erratic. 

Where adequate data is lacking to establish reliable percentage removals, regulatory agencies may allow USEPA national survey values to be used. These are 

summarized in Table 7. 

Table 7. Literature values for POTW pollutant removal efficiencies. 

Pollutant 

Removal Through 

Primary Treatment 

(median value, %) 

Removal Through 

Activated Sludge Treatment (median value, %) 

Removal Through Trickling Filter Treatment 

(median value, %) 

Arsenic — 45 — 

Cadmium 15 67 68 

Chromium 27 82 55 

Copper 22 86 61 

Cyanide 27 69 — 

Lead 57 61 55 

Mercury 10 60 50 

Nickel 14 42 29 

Selenium — 50 — 
66 CERL TR 99/49 

Pollutant 

Removal Through 

Primary Treatment 

(median value, %) 

Removal Through 

Activated Sludge Treatment (median value, %) 

Removal Through Trickling Filter Treatment 

(median value, %) 

Silver 20 75 66 

Zinc 27 79 67 

Benzene 25 80 75 

Chloroform 14 67 73 

1,2 trans-Dichloroethylene 36 67 50 

Ethylbenzene 13 86 80 

Methylene chloride — 62 70 

Tetrachloroethylene 4 80 80 

Toluene — 93 93 

1,1,1-Trichloroethane 40 85 89 

Trichloroethylene 20 89 94 

Anthracene — 67 — 

Bis (2-ethylhexyl) phthalate — 72 58 

Butyl benzyl phthalate 62 67 60 

Di-n-butyl phthalate 36 64 60 

Diethyl phthalate 56 62 57 

Naphthalene 44 78 71 

Phenanthrene — 68 — 

Phenol 8 90 84 

Pyrene — 86 — 

Source: EPA-833-B-87-202, Tables 3-9 and 3-10, EPA Office of Water, December 1987. 

Calculation of MAHLs. The MAHL of a treatment plant is the maximum pollutant load in pounds per day that the plant can receive without exceeding effluent, 

biosolids, or process inhibition criteria. The MAHL for any given pollutant of 

concern is the smallest value computed from these equations. 

MAHL based on effluent discharge criteria: 

RT

Allowable effluent concentration mg L Q MAHL −× × = 1( / ) 8.34

MAHL based on biosolids criteria: 

T

T

R

Allowablebiosolids concentration mg kg P MAHL

6 10− × × = ( / )

MAHL based on activated sludge or trickling filter inhibition criteria: 

RP

Inhibitionlevel mg L Q MAHL −

× × = 1

( / ) 8.34
CERL TR 99/49 67 

MAHL based on anaerobic digestion inhibition criteria: 

T

D

R

Inhibitionlevel mg kg P MAHL

6 10− × × = ( / )

where: 

MAHL = Maximum Allowable Headworks Loading, lb/day 

 Q = Average daily treatment plant flow (MGD) 

 RT = Total plant pollutant removal rate 

 RP = Primary treatment removal rate 

 PT = Plant average daily biosolids disposal rate (lb/day) 

 PD = Average daily sludge feed to digester (lb/day) 

Allocation of MAHLs to Nondomestic Sources. The portion of each pollutant 

MAHL allocable to nondomestic users, termed the maximum allowable industrial loading (MAIL), is equal to the total MAHL, less the loading contributed by 

domestic/background sources (LD/B), less an amount held in reserve as a safety 

factor (LSF): 

MAIL MAHL L L ( ) all unitsinlb day = − D R − SF

Domestic/Background Pollutant Loadings. The USEPA recommends that domestic/background pollutant concentrations be obtained through site-specific monitoring conducted at locations that receive wastewater solely from domestic 

sources. However, alternative approaches may be accepted. One approach, 

which takes advantage of data that may already exist, is to subtract known industrial loads from treatment plant influent loads. A second approach is to use 

the USEPA’s national survey results for domestic/background pollutant concentrations, which are summarized in Table 8. 

Safety Factors. The USEPA recommends allocating only a portion of the MAHL 

for each pollutant to the treatment plants current users. The remaining portion 

is recommended to be held in reserve as a safety factor to account for future industrial growth, potential slug loadings, and other uncertainties. A safety factor 

of 10 to 20 percent should be adequate in most cases, i.e., LSF = (0.1 to 0.2) 

MAHL. 
68 CERL TR 99/49 

Table 8. Residential/background pollutant 

concentrations from USEPA survey data. 

Pollutant 

Average Concentration 

(mg/L) 

Arsenic 0.007 

Cadmium 0.008 

Chromium 0.034 

Copper 0.109 

Cyanide 0.082 

Lead 0.116 

Mercury 0.002 

Nickel 0.047 

Silver 0.019 

Zinc 0.212 

Methylene Chloride 0.027 

Tetrochloroethene 0.014 

1,2 Dichloroethene 0.013 

Chloroform 0.009 

1,1 Dichloroethene 0.007 

1,1 Dichloroethane 0.007 

Source: Supplemental Manual on the Development 

and Implementation of Local Discharge Limitations 

Under the Pretreatment Program, USEPA Office of 

Water, May 1991. 

Calculation of Local Limits. Local limits are calculated by allocating MAHL values to domestic and nondomestic users. Three basic alternative allocation methods are accepted: 

a) Uniform concentration method 

(8.34) Local Limit = LNDU QNDU

Here, QNDU represents the total flow from all nondomestic users not included as 

part of the domestic/background class. This method results in the same local 

limits for all such nondomestic users, regardless of whether they discharge the 

pollutant in question. 

b) Contributory flow method 

(8.34) Local Limit = LNDU QNDUCONTRIB

Here, QNDUCONTRIB represents the total flow from only those nondomestic users who 

actually discharge the pollutant in question in concentrations above the background. All such users would have the same local limits, while other nondomestic users would be allowed to discharge up to the background concentration of 

the particular pollutant. 
CERL TR 99/49 69 

c) Wasteload allocation method 

(8.34) Local Limit = Lx Qx

Here, Local LimitX and QX represents the allocated pollutant load and corresponding flow of nondomestic user “X.” In this method, all significant nondomestic users have their own individual limits. 

3.5 Development of Discharge Limitations Based on Protection of the Collection System and Worker Health and Safety 

3.5.1 Prohibited Discharge Standards. These standards, applicable to all users, 

prohibit the discharge of any nondomestic wastes containing certain types or 

amounts of pollutants that would interfere with the operation of collection and 

treatment systems. Nationally prohibited discharges under 40 CFR 403.5 include the following: 

a) Pollutants that create a fire or explosion hazard, including but not limited to 

waste streams with a closed cup flash-point of less than 140 °F or 60 °C 

b) Pollutants that will cause corrosive structural damage, and in no case discharges with pH lower than 5.0 unless the treatment works is designed to accommodate such discharges 

c) Solid or viscous pollutants in amounts that will cause obstruction to the flow 

resulting in interference 

d) Any pollutant, including oxygen-demanding pollutants released in a discharge at a flow rate and/or pollutant concentration that will cause interference 

e) Heat in amounts that will inhibit biological activity in the treatment plant 

resulting in interference, but in no case heat in such quantities that the temperature at the treatment plant exceeds 40 °C unless alternate temperature limits are approved 

f) Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin 

in amounts that will cause interference or pass through 

g) Pollutants that result in the presence of toxic gases, vapors, or fumes within 

the collection or treatment system in a quantity that may cause acute worker 

health and safety problems 
70 CERL TR 99/49 

h) Any trucked or hauled pollutants, except at approved discharge points. 

3.5.2 Oil and Grease Limits. Although many municipal sewer use ordinances 

contain a numeric oil and grease limitation, these limits vary greatly because no 

technical basis presently exists for establishing such a limit (see Section 2). As 

preliminary guidance, the USEPA has suggested that a limit of 100 mg/L may be 

used for “petroleum oils, nonbiodegradable cutting oils, or products of mineral oil 

origin.” Likewise, a limit of 100 to 200 mg/L may be appropriate for polar oils 

and greases derived from animal and vegetable materials, which is approximately their background concentration in raw domestic wastewater. 

3.5.3 Protection Against Vapor Toxicity. Discharges to sewers of volatile pollutants with toxic vapors can create conditions hazardous to workers who must enter the sewer system. The national prohibited discharge standard given previously (par. 3.5.1g) is the minimum standard of protection for discharges of 

volatile pollutants. Some POTWs have also developed numeric limits based on 

worker health and safety criteria. 

3.5.3.1 Developing Local Limits Based on Vapor Toxicity. A simplified approach 

for calculating the aqueous concentration of a given VOC that results in an equilibrium atmospheric concentration harmful to workers is given in the USEPA 

guidance manual Guidance to Protect POTW Workers from Toxic and Reactive 

Gases and Vapors, EPA-812-B-92-001 (June 1992). The approach is based on 

Henry’s Law and maximum atmospheric concentrations established by the 

American Conference of Governmental Industrial Hygienists (ACGIH), which 

are based on continuous worker exposure during a 40-hour work week. These 

limiting concentrations are termed threshold limit values – time-weighted averages (TLV-TWA). These limits are conservative because equilibrium concentrations are not attained in a sewer system and because workers would likely not be 

exposed to fumes 40 hours/week. As a result, the USEPA recommends this approach for establishing screening levels (trigger for further action) and not enforceable limits. 

3.5.4 Protection Against Flammability/Explosivity. USEPA amendments to the 

General Pretreatment Regulations require municipalities to implement local limits that prevent flammable/explosive conditions from occurring in the sewer atmosphere (Federal Register, 55, 142, 1990). As noted previously, the specific requirement prohibits pollutants with a closed cup flashpoint of less than 140 °F 

(60 °C). While the flashpoint limitation is not in itself a sufficient local limit for 

all industrial users, it does provide a good supplement to other limitations by effectively prohibiting the discharge of undiluted volatiles such as gasoline, diesel, 

jet fuel, BTEX compounds, methyl ethyl ketone (MEK), and ethyl alcohol. 
CERL TR 99/49 71 

As an adjunct to the flashpoint limitation, the USEPA has also provided screening levels of the aqueous concentration of selected volatile chemicals that can be 

used to identify explosion hazards. Screening levels for the four BTEX compounds, which are based on 10 percent of their lower explosive limit (LEL), are 

given below: 

Compound Explosivity Screening Level (mg/L) 

Benzene 20 

Ethylbenzene 16 

Toluene 

Total Xylenes 

 17 

17 

Because these screening levels are higher than the local limits computed based 

on vapor toxicity, they do not control the establishment of local limits. They may 

be used as a screening tool where explosivity is the only consideration. 
72 CERL TR 99/49 

Appendix C: Example Pretreatment 

Program 

Significant portions of the following example were taken from the Aberdeen 

Proving Ground pretreatment regulation. This example is intended to serve 

both troop garrison and industrial installations. 

If this example is used to develop an Installation Pretreatment Program regulation, it must be edited to include information specific to the installation. This 

example has text bracketed and in bold where installation information must be 

included. Other text should be added to tailor this example to specific installation requirements. 

The following Example is a modified version of the Pretreatment Program developed during the Protocol alpha test exercise. Significant portions of this Example were taken from the Aberdeen Proving Ground pretreatment regulation and 

modified to comply with Protocol guidance. The tables in Appendix A of the Example were prepared using the MS Access based automated Protocol database. 

Some elements of the Example vary somewhat from the guidance in the Protocol, 

for the purpose of brevity or to make Example appear site specific. Process diagrams for the industrial processes generating wastewater are not included. 

There are only 15 Industrial Users and 4 Significant Industrial Users included 

in the Facility Inventory — normally a large Army installation would have 50 or 

more industrial wastewater sources. 

While the alpha test was at a TRADOC installation, this example is intended to 

serve both troop garrison and industrial installations. If text from this Example 

is used to create an Installation Pretreatment Program, it must be edited to 

include information and requirements specific to the installation. 
CERL TR 99/49 73 

 DEPARTMENT OF THE ARMY 

FORT CIVIL WAR GENERAL 

September 1998 

INSTALLATION PRETREATMENT PROGRAM 

Contents 

1 Purpose........................................................................................................................................ 74 

2 Scope............................................................................................................................................ 74 

3 Definitions.................................................................................................................................... 74 

4 Responsibilities .......................................................................................................................... 76 

a. Commanders, Directors and All Heads of Activities ....................................................76 

b. Pretreatment Program Manager...................................................................................77 

c. User/Activity Commanders or Managers......................................................................78 

d. Director of Public Works. ...............................................................................................78 

e. Wastewater Treatment Plant Manager .........................................................................79 

5 Program Criteria ......................................................................................................................... 79 

a. Policy. ...........................................................................................................................79 

b. Discharge Limits...........................................................................................................80 

c. Monitoring.....................................................................................................................85 

d. Non-Routine Discharges. .............................................................................................86 

e. Standard Conditions.....................................................................................................86 

Annex A — Current Facility Information and Reports................................................................ 89 

Facility Inventory ...............................................................................................................90 

Source Information............................................................................................................91 

Sources of Pollutants Detected.......................................................................................107 

Discharge Limits for Pollutants at Each Source..............................................................109 

Monitoring Report ...........................................................................................................112

Compliance Plan and SIU Compliance Report...............................................................114 

SIU Compliance Report ..................................................................................................115 

Recommended Pollution Prevention Measures ..............................................................117 

Annex B — Non-Routine Discharge Control Plan ..................................................................... 118 
74 CERL TR 99/49 

1 Purpose 

This Pretreatment Program document assigns responsibilities and establishes 

policies and procedures for the control of wastewater discharges from industrial 

processes to the Fort Civil War General Treatment Works. 

2 Scope 

This document applies to all the Commanders, Directors, and heads of all U.S. 

Army Garrison, Fort Civil War General, tenant and user activities that discharge 

industrial (non-domestic) wastewater to the Fort Civil War General Treatment 

Works. 

3 Definitions 

Act. The Federal Water Pollution Control Act later known as the Clean Water 

Act. 

Bi-annual. Twice each year. 

BOD5. Five day biochemical oxygen demand. 

COD. Chemical Oxygen Demand. 

Composite Sampling. Sample composed of two or more discrete samples. 

Domestic Sources. Wastewater contributed to the sanitary sewer from strictly 

residential areas. 

DPW. Directorate of Public Works. 
CERL TR 99/49 75 

Grab Sample. A sample which is taken on a one time basis without regard to 

flow or time. 

Industrial User. Any facility discharging wastewater which is not of comparable 

strength, origin and/or flow of typical domestic sources. A source of non-domestic 

wastewater. 

Installation. Fort Civil War General 

IPP. Installation Pretreatment Program 

Interference. A discharge which, alone or in conjunction with a discharge or 

discharges from other sources, 

(1) Inhibits or disrupts the wastewater treatment plant, its treatment processes 

or operations, or its sludge processes, use or disposal and 

(2) Therefore, is a cause of a violation of any requirement of the WWTP’s 

NPDES permit or prevention of sewage sludge use or disposal in compliance 

with Section 405 of the Act, Subtitles C and D of RCRA, the Clean Air Act or any 

State or 

Local regulations issued thereunder are available for review at the ECD, Bldg 

4603. 

NPDES. National Pollutant Discharge Elimination System. 

Pass-Through. A discharge of pollutant(s) which cannot be treated adequately by 

the WWTP and therefore exits into waters of the U.S. in quantities or 

concentrations which alone or in conjunction with other discharges from other 

sources, is a cause of a violation of any requirement of the WWTP’s NPDES 

permit. 

PPM. Pretreatment Program Manager 

RCRA. Resource Conservation and Recovery Act. 

Significant Industrial User. 1) Industrial Users which meet the criteria 

delineated in 40 CFR 403 and “Protocol for the Preparation of Installation 

Pretreatment Programs”. 2) Any Industrial User designated as such by the 

Pretreatment Program Manager. 
76 CERL TR 99/49 

State. State of location. 

Surety Agents. Any materials designated by the Department of the Army as 

chemical surety materials, to include blister agents, nerve agents and others 

identified by the Army. Simulated and experimental surety agents which 

produce the characteristic effect of surety materials on living tissue; i.e., 

blistering, acetylcholinesterase inhibition, etc., but which are not designated as 

surety agents by the Army, are included as surety agents. 

TSS. Total suspended solids. 

TTO. Total Toxic Organics. A single, quantifiable measurement which sums the 

concentration of all toxic organic compounds in a specified list. Limits for TTO 

are often established in categorical pretreatment standards. The list of 

compounds varies, dependent on the industrial source. 

Upset. An exceptional incident in which there is unintentional and temporary 

noncompliance with the discharge standards established by this program 

because of factors beyond the reasonable control of the industrial user. Also, an 

incident where a process (or processes) at a domestic treatment plant receiving 

industrial wastewater is rendered ineffective because of industrial pollutant 

loading, thus causing that treatment plant to be in non-compliance with its 

NPDES permit. 

Wastewater Treatment Plant. The treatment facility which receives both 

domestic and industrial wastewater from Fort Civil War General, and is subject 

to an NPDES permit. 

WWTP. Wastewater treatment plant. 

4 Responsibilities 

a. Commanders, Directors and All Heads of Activities 

Commanders, Directors and all Heads of Activities will: 
CERL TR 99/49 77 

(1) Authorize directives, issue orders, and assign responsibilities to ensure 

compliance with this program. 

(2) Ensure adequate funding (A106, OMA, etc.) is requested, authorized, and 

budgeted in order to carry out the requirements of this program. 

b. Pretreatment Program Manager 

Chief, Environmental Division, Directorate of Public Works, Fort Civil War 

General, will assume the title, duties, and responsibilities of Pretreatment 

Program Manager. The installation Pretreatment Program Manager, or his/her 

designee, will: 

(1) Investigate sources of non-domestic wastewater and prepare an inventory of 

industrial facilities. Update that inventory whenever changes to facility personnel or processes occurs. Include the inventory as Appendix A of this Program. 

(2) Determine pollutants of concern by conducting a background sampling 

survey of all potential pollutants entering the Fort Civil War General 

wastewater collection system. Establish new, and update existing, discharge 

standards (local limits) on pollutants of concern expected to occur in industrial 

wastewater discharging to the wastewater collection system from Significant 

Industrial Users. [Discharge limits are presented in Chapter 5 “Procedures,” b. 

Discharge Limits, (2) Specific Prohibitions.] 

(3) Determine which industrial activities shall be designated as Significant 

Industrial Users using criteria presented in the “Protocol for Preparation of 

Installation Pretreatment Programs,” including those subject to categorical 

pretreatment regulations as defined by part 403 through 473, title 40, Code of 

Federal Regulations (40 CFR 403 through 473). 

(4) Conduct sampling and analysis of discharges from Significant Industrial 

Users to demonstrate compliance with this program on an annual basis, and 

update the Monitoring report in Appendix A of this Program to record the results 

of that sample analysis. 

(5) Develop and execute plans to bring industrial discharges which are found to 

be not in compliance with this program, into compliance. These plans may 

include, but not be limited to: implementing pollution prevention measures, 

upgrading pretreatment structures, improving maintenance, upgrading the 
78 CERL TR 99/49 

wastewater treatment plant, and recommending closure or consolidation of 

industrial processes. 

(6) Augment existing, or establish new, training for industrial facility personnel 

focusing on pollution prevention and defining the capabilities and limitations of 

existing pretreatment systems. 

(7) Update the facility and compliance data included in the appendices of this 

Program. 

(8) Perform other duties as described in this document. 

c. User/Activity Commanders or Managers 

Each User/Activity Commander or Manager will: 

(1) Ensure that processes generating industrial wastewater are operated or 

performed properly. 

(2) Ensure that personnel involved in industrial processes have received 

pollution prevention and spill control training provided by the Installation. 

(3) Ensure that pollution prevention and spill control measures are enforced at 

the activity to prevent violation of pretreatment standards. 

(4) Provide all notifications as required by this program. 

d. Director of Public Works. 

The Director of Public Works, or his designee, will: 

(1) Maintain all pretreatment structures/equipment employed to meet the 

effluent requirements stated in Appendix A of this program. Maintenance shall 

include removal and disposal of all solid waste residues and/or sludges from 

pretreatment structures. 

(NOTE: If maintenance is provided by a contractor, then the Director of Public 

Works will ensure that a detailed description of maintenance service for all 

pretreatment structures and equipment shall be included in performance 

requirements of that contract.) 
CERL TR 99/49 79 

(2) Acquire necessary equipment to meet the requirements of this program when 

and if needed. 

e. Wastewater Treatment Plant Manager 

The Wastewater Treatment Plant Manager will: 

(NOTE: If this facility is operated under contract, these and other duties of the 

WWTP manager delineated in this document will be added to the performance 

requirements of that contract.) 

(1) Assist the Pretreatment Program Manager in establishing new and updating 

existing pretreatment standards. 

(2) Report upsets and pass-throughs at the wastewater treatment plant to the 

Pretreatment Program Manager. 

(3) Manage and control septage and other slug discharge points. 

(4) Report to the Pretreatment Program Manager the monthly volume of 

septage discharged. 

5 Program Criteria 

a. Policy. 

The Federal Water Pollution Control Act, enacted in 1972, and subsequent 

amendments, requires discharges to the Nation’s Waterways be of a nature and 

quality which will maintain the chemical, physical and biological integrity of 

said waters. In order to achieve the goals of the Act, operators of wastewater 

treatment plants are required to identify and control the discharges from 

industrial users of the wastewater treatment facility and conveyance system. 

Industrial users are classified as any facility which is discharging wastewater 

which is not of comparable strength, origin and/or flow of typical domestic 

sources. Wastewater treatment plants are subject to interference, upset and 

pass-through from discharges originating from industrial sources. It is the goal 
80 CERL TR 99/49 

of the Act to prevent such detrimental occurrences through the use of a 

pretreatment program. All industrial users on the Installation will control, 

modify or pretreat their waste streams to a degree that will ensure compliance 

with this program and protect the wastewater treatment plant. 

b. Discharge Limits. 

(1) General Prohibitions - The following prohibitions apply to all non-domestic 

users regardless of and in addition to any specific pretreatment standards. 

 (a) Pollutants may not be introduced into the sewer which will pass through 

the wastewater treatment plant or interfere with the operation and/or 

performance of the treatment facility. 

 (b) The following pollutants will not be introduced into the sanitary sewer 

system: 

 1. Pollutants which create a fire or explosion hazard in the treatment 

plant or its conveyance system. In no case will a waste stream have a flashpoint 

of less than 140F using test methods specified in section 21, part 261, title 40, 

Code of Federal Regulations (40 CFR 261.21). These pollutants include but are 

not limited to, gasoline, kerosene, naphtha, benzene, toluene, xylene, ethers, and 

pyrogenic and explosive materials. 

 2. Pollutants that will cause corrosive structural damage to the WWTP. 

In no case discharges with a pH lower than 5.5 or greater than 10.0 standard 

units. 

 3. Solid or viscous pollutants in amounts which will cause obstruction to 

the flow in the WWTP or its conveyance system resulting in interference, 

including but not limited to, ashes, cinders, mud, straw, shavings, metal, glass, 

rags, feathers, tar, plastics, wood, paunch or manure. 

 4. Any pollutant, including oxygen demanding pollutants (BOD, COD), 

released in a discharge and at a flow rate and/or pollutant concentration which 

will cause interference with the WWTP. 

 5. Heat in amounts which will inhibit biological activity in the WWTP 

resulting in interference, but in no case heat in such quantities that the 

temperature at the WWTP exceeds 40o

 C unless the Pretreatment Program 

Manager, in conjunction with the State, approves alternate temperature limits. 
CERL TR 99/49 81 

 6. Toxic pollutants which may interfere with any wastewater treatment 

process and which then pass-through the WWTP thereby constituting a hazard 

to humans or animals, pollute the waters of the State or contaminate the sludge 

so as to restrict the disposal option(s) selected by the WWTP. 

 7. Pollutants which result in the presence of toxic gases, vapors, or fumes 

within the WWTP in a quantity that may cause acute worker health and safety 

problems. 

 8. Any chemical surety materials. Chemical surety materials will be 

defined as all chemical warfare agents designated by the Department of the 

Army as chemical surety materials, to include blister agents, nerve agents and 

other identified by the Army. Simulated and experimental surety agents which 

produce the characteristic effects of surety materials on living tissue; i.e. 

blistering, acetylcholinesterase inhibition, etc., but have not been designated by 

the Army as surety materials, also are prohibited from being discharged to the 

sanitary sewer. 

 9. Any RCRA listed hazardous wastes, or mixtures that contain those 

wastes, that do not meet the requirements of section 3(a) (2) (iv), part 261, title 

40, Code of Federal Regulations (40 CFR 261.3(a) (2) (iv)), and that do not meet 

the local discharge limits established by this program. 

 10. Any waste containing or contaminated by mercury or its compounds. 

 11. Any wastewater containing radionuclide concentrations greater than 

natural background levels unless approved by the Pretreatment Program 

Manager. 

 12. Any substance which may cause a violation of the Army’s NPDES 

Permit or render as hazardous, the sludge produced by the wastewater 

treatment plant. 

 13. Pollutants incorporated in any State standard for the purpose of 

protecting the WWTP and as specified in the WWTP’s NPDES permit, will be 

enforceable as pretreatment standards. 

(2) Specific Prohibitions. 

 (a) All silver contaminated wastewater will be collected and disposed of 

through a silver recovery unit. The total combined effluent from the facility 

housing the recovery unit, will not have a silver concentration greater than 0.20 
82 CERL TR 99/49 

mg/L at the point the effluent enters the sanitary sewer and before dilution by 

other sources. 

 (b) Petroleum based products, nonbiodegradable cutting oil, or products of 

mineral oil origin will not be discharged to the sewer except the incidental 

amounts which are generated during washing operations of equipment and 

facilities. Discharge will then only be allowed after the effluent is pretreated 

through the use of an oil/water separator or some other device designed to 

remove oil from water. The oil and grease concentration in any discharge to the 

sanitary sewer will not exceed 100 mg/L. 

 (c) Any operation determined to be a categorical industrial operation, part 

403 through 473, title 40, Code of Federal Regulations (40 CFR 403 through 

473), and amendments thereto, are required to meet the pretreatment 

requirements for that particular categorical industry. 

 (d) Pollutant levels in all non-domestic discharges shall not exceed the 

concentrations listed in Table C1. These “local limits” are established to prevent 

pollutant concentrations from exceeding the maximum allowable pollutant 

concentrations in the wastewater treatment plant influent as stated in Table C2. 

The Pretreatment Program Manager and the Wastewater Treatment Plant 

Manager will modify these limits as is necessary to meet the goals of this 

Program. The list of organic compounds used measure Total Toxic Organics 

(TTO) is contained in 40 CFR Part 413 “Electroplating Point Source Category,”

paragraph 413.02, sub-paragraph (i). 

Table C1. Local limits for industrial discharges to sewer. 

Pollutant

Maximum Concentration 

at each source (mg/L)

1,3,5-Trimethyl benzene 2.00

Benzene 2.00

Cadmium 1.20

Copper 2.00

Chromium 2.00

Cyanide 5.00

Ethyl Benzene 2.00

Lead 5.00

n-Propyl Benzene 2.00

Naphthalene 2.00

Nickel 10.00

O & G 100.00

o-m Xylenes 1.40

p-Xylenes 0.60

Phenol 0.50
CERL TR 99/49 83 

Pollutant

Maximum Concentration 

at each source (mg/L)

Sec-Butyl Benzene 2.00

Silver 2.00

Sulfides 2.50

Tetrachloro Ethane 2.00

Toluene 2.00

Trichloro Ethane 2.00

Total Toxic Organics (TTO) 4.60

Table C2. WWTP influent limits. 

Pollutant Maximum Concentration (mg/L)

1,3,5-Trimethyl benzene 0.002

Benzene 0.010

Cadmium 0.030

Copper 0.030

Chromium 0.010

Cyanide 0.010

Ethyl Benzene 0.001

Lead 0.100

n-Propyl Benzene 0.010

Naphthalene 0.010

Nickel 0.500

O & G 50.000

o-m Xylenes 0.010

p-Xylenes 0.010

Phenol 0.010

Sec-Butyl Benzene 0.010

Silver 0.100

Sulfides 0.100

Tetrachloro Ethane 0.010

Toluene 0.010

Total Toxic Organics (TTO) 2.000

Trichloro Ethane 0.010

 (3) Discharge of Hazardous Waste. 

40 CFR 261.3(A) (2) (IV) Mixtures of sewage and RCRA listed hazardous wastes may be discharged to the sewer provided the mixture meets the following requirements: 

The following mixtures of solid wastes and hazardous wastes listed in Subpart D 

are not hazardous wastes (except by application of paragraph (a)(2) (i) or (ii) of 

this section) if the generator can demonstrate that the mixture consists of 
84 CERL TR 99/49 

wastewater the discharge of which is subject to regulation under either section 

402 or section 307(b) of the Clean Water Act (including wastewater at facilities 

which have eliminated the discharge of wastewater) and: 

 (a) One or more of the following spent solvents listed in 261.331 —

carbon tetrachloride, tetrachloroethylene, trichloroethylene — Providing, that 

the maximum total weekly usage of these solvents (other than the amounts that 

can be demonstrated not to be discharged to wastewater) divided by the average 

weekly flow of wastewater into the headworks of the facility’s wastewater 

treatment or pretreatment system does not exceed 1 part per million; or 

 (b) One or more of the following spent solvents listed in 261.31 —

methylene chloride, 1,1,1-trichloroethane, chlorobenzene, o-dichlorobenzene, 

cresols, cresylic acid, nitrobenzene, toluene, methyl ethyl ketone, carbon 

disulfide, isobutanol, pyridine, spent chlorofluorocarbon solvents — provided 

that the maximum total weekly usage of these solvents (other than the amounts 

that can be demonstrated not to be discharged to wastewater) divided by the 

average weekly flow of wastewater into the headworks of the facility’s 

wastewater treatment or pretreatment system does not exceed 25 parts per 

million; or 

 (c) One of the following wastes listed in 261.32 — heat exchanger bundle 

cleaning sludge from the petroleum refining industry (EPA Hazardous Waste No. 

K050); or 

 (d) A discarded commercial chemical product, or chemical intermediate 

listed in 261.33, arising from de minimis losses of these materials from 

manufacturing operations in which these materials are used as raw materials or 

are produced in the manufacturing process. For purposes of this subparagraph, 

“de minimis” losses include those from normal material handling operations (e.g. 

spills from the unloading or transfer of materials from bins or other containers, 

leaks from pipes, valves or other devices used to transfer materials); minor leaks 

of process equipment, storage tanks or containers; leaks from well-maintained 

pump packings and seals; sample purgings; relief device discharges; discharges 

from safety showers and rinsing and cleaning of personal safety equipment; and 

rinsate from empty containers or from containers that are rendered empty by 

that rinsing; or 

 (e) Wastewater resulting from laboratory operations containing toxic (T) 

wastes listed in Subpart D, provided that the annualized average flow of 

laboratory wastewater does not exceed one percent of total wastewater flow into 

the headworks of the facility’s wastewater treatment or pre-treatment system, or 
CERL TR 99/49 85 

provided the waste’s combined annualized average concentration does not exceed 

one part per million in the headworks of the facility’s wastewater treatment or 

pre-treatment facility. (Toxic (T) wastes used in laboratories that are demonstrated not to be discharged to wastewater are not to be included in this 

calculation.) Wastewaters in this case refers to waters which are normally part 

of the laboratory’s wastewater effluent and are generated from such operations 

as glassware and equipment cleaning, laboratory facilities cleaning, etc. 

Laboratory discharges must also comply with the restrictions under paragraph 

5b(2)(e) of this program. 

c. Monitoring. 

(1) The Pretreatment Program Manager will demonstrate compliance with the 

discharge limitations for Significant Industrial Users on an annual basis. The 

frequency may be increased as the PPM or WWTP Manager deems necessary to 

protect the treatment plant, if a user has a history of non-compliance or for any 

other reasons which the PPM feels are necessary. 

(2) Compliance demonstration will be achieved by one day of sampling representative of normal to peak flow and pollutant concentrations. Sampling and 

analysis will follow the “Guidelines Establishing Test Procedures for the Analysis 

of Pollutants,” part 136, title 40, Code of Federal Regulations (40 CFR 136). 

Frequency of sampling for Categorical discharges shall be according to the 

appropriate CFR. 

 (a) For measurement of pH, total petroleum hydrocarbons, volatile organics, 

sulfides, cyanide and total phenols, four grab samples are required spaced evenly 

through the duration of the day’s discharge. If the duration of the discharge is 

less than 30 minutes, two samples may be taken. 

 (b) Flow proportional composite sampling will be performed for all other 

regulated pollutants (time proportional will be allowed if flow proportional is not 

feasible). If the duration of the discharge is less than 30 minutes, a composite of 

two or more grab samples may be used. 

(3) Pollutants of Concern. The Monitoring report (Appendix A) will show the 

initial analysis of potential pollutants of concern, and subsequent annual 

analysis for those pollutants identified as Pollutants of Concern. 

(4) Right of Entry. The Pretreatment Program Manager, or his/her 

representative will have the right of entry upon or through any premises 
86 CERL TR 99/49 

discharging non-domestic wastewater for the purpose of ensuring compliance 

with this program or to gather information pertinent to the requirements of this 

program including document copying. All right of entry and document copying 

will be in compliance with Army regulations regarding protection of national 

security. 

(5) Safety Equipment. All safety equipment necessary to the specific user 

operations will be supplied by the user. All safety equipment which would be 

required during any compliance determination will be supplied by the 

Pretreatment Program Manager, or his designee. 

d. Non-Routine Discharges. 

The Pretreatment Program Manager will implement the Non-routine Discharge 

Control Plan presented in Appendix B. 

(1) Slug Control. The Pretreatment Program Manager will ensure that the 

Installation Pollution Prevention Plan, Installation Spill Contingency Plan, and 

Installation Spill Control and Countermeasure Plan contain measures to prevent 

spill and routine leaks of pollutants into the sanitary sewer system. 

(2) Septage. All septic waste haulers will be considered industrial users for the 

purpose of this program. A Septage Control Plan is incorporated into Appendix B 

of this document. Tenants or organizations discharging non-domestic wastes 

into septic tanks and septic holding tanks are required to meet the standards set 

forth in this program. Trucked wastes will only be discharged at the approved 

septage discharge points, coordinated through the Wastewater Treatment Plant 

Manager 

e. Standard Conditions. 

(1) Pretreatment System Operation and Maintenance. If pretreatment is 

necessary to meet the requirements of this program, such treatment systems will 

be operated and maintained in a manner which assures pollutant removal is in 

accordance with the designed operating parameters of the system. System 

maintenance should be scheduled during non-operational hours. If maintenance 

is required during operating times, the industrial user will cease or reduce 

wastewater discharges in an attempt to mitigate any adverse impacts on the 

wastewater treatment plant or conveyance system resulting from the discharge 

of untreated waters. If maintenance requires greater than 4 hours during which 
CERL TR 99/49 87 

time the discharge is not in compliance with the quality restrictions of this 

program, then discharges will cease until maintenance is complete. 

(2) Bypass of Pretreatment Facilities. Bypass is prohibited unless it is unavoidable to prevent loss of life, personal injury or severe property damage or no feasible alternative exists. Bypasses which do not exceed the discharge limits established by this program are permitted only if the bypass is necessary to 

perform maintenance on the system. All planned bypass events will be reported 

to the PPM and receiving Wastewater Treatment Plant Manager in writing at 

least 5 working days prior to the bypass. If an unanticipated bypass occurs, the 

PPM and wastewater treatment plant will immediately be verbally notified followed by written notification to both provided within 10 calendar days. Notification of bypass will include reasons for bypass, steps taken to mitigate, bypass 

duration, and if condition creating bypass has been corrected. 

(3) Dilution to Meet Standards. Increase of process water beyond what is normally required and for the sole purpose of meeting the discharge limits established by this program, is strictly prohibited. 

(4) Removed Substances. Solids, sludges, filter backwash and any other materials removed from the waste stream will be disposed of in accordance with Section 

405 of the Act and Subtitles C and D of RCRA. Hazardous sludge disposal will 

be coordinated through the Hazardous Waste Branch. 

(5) Hazardous Waste. 

 (a) All users will immediately notify the Pretreatment Program Manager and 

WWTP Manager verbally, and then in writing, of any discharge into the sewer 

which, if otherwise disposed of, would be a hazardous waste under part 261, title 

40, Code of Federal Regulations (40 CFR 261) and/or State hazardous waste 

regulations. The notification will contain: 

 1. Name of hazardous waste. 

 2. The EPA hazardous waste number. 

 3. Type of discharge (batch, continuous, etc.). 

 4. Identification of hazardous constituents. 

 5. Estimation of mass and concentration of constituents. 

 6. Estimation of future discharges for the next 12 month period. 

 (b) Notification is only required one time unless the waste characteristics or 

volumes change as in (6) below. 
88 CERL TR 99/49 

 (c) Notification is not required if the monthly discharge is below 15 kilograms of hazardous waste unless the discharged waste is an acute waste section 

33, part 261, title 40, Code of Federal Regulations (40 CFR 261.33 (e) and/or 

State hazardous waste regulations for which any volume must be reported. 

(6) Notification of Changed Discharge. All users will promptly notify the PPM in 

advance of any substantial change (increase or decrease) in the volume or character of pollutants in their discharge, including the listed or characteristic hazardous wastes for which each user has submitted notification of discharge under 

(5) above. 

(7) Discharge of Radionuclide Materials. All users desiring to discharge material 

with radionuclide concentrations greater than natural background levels must 

request approval in writing from the PPM prior to any discharge. Request must 

include the following: 

 (a) Radionuclide name and concentration. 

 (b) Quantity of the material. 

 (c) Description of the material (i.e., scintillation fluid). 

 (d) Type of discharge (batch, continuous, etc.). 

 (e) Location of desired discharge. 
CERL TR 99/49 89 

Annex A — Current Facility Information and Reports 

Facility Inventory 90 

Source Information 114 

Sources of Pollutants Detected 107 

Discharge Limits for Pollutants at Each Source 109 

Monitoring Report 112 

Compliance Plan and SIU Compliance Report 114 

Recommended Pollution Prevention Measures 117 
90 CERL TR 99/49 

Facility Inventory 

Bldg. No. Industrial User POC 

POC 

Phone No. 

Significant 

Industrial 

User? 

200 Garbage Dumpster Washrack Carl Stenger 555-0007 No

212 Used Oil/Diesel Fuel ASTs Carl Stenger 555-0007 No

350 Hospital -Silver Recovery Unit John Smith 555-0009 No

383 Auto Craft Shop Ed Cain 555-0002 Yes

440 Oily Sludge Drying Basin Kenny Worhal 555-0010 No

500 Harper Dental Clinic LT Alexander 555-0008 No

515 POV Car Wash Jim Smith 555-0011 No

872 5th Engineering Battalion BMO Palagar 555-0001 No

950 58th Transportation Battalion, Washrack Warren Brabant 555-0000 Yes

1100 TMP Automatic Car Wash Ray Long 555-0012 No

5138 ECS Washrack Paul Ritter 555-0005 No

5265 DOL Battery Shop Terry Tyler 555-0003 Yes

5265 DOL Plating Shop Al Carrasco 555-0014 Yes

5265 DOL Wheeled Vehicle Shop Dale Waters 555-0013 No

5265 DOL Paint Booth Al Carrasco 555-0004 No

6000 Fire Fighting Training Facility Jeff Scheer 555-0006 No 
CERL TR 99/49 91 

Friday, August 21, 1998 

Source Information 

Facility Name 58th Transportation Battalion, Washrack 

Building Number 950 

POC Warren Brabant 

POC phone number 555-0000 

Activity Description Washracks, Individual 

NAICS Code 811198 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 30720 

Average daily flow (gal/day) 20500 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User Yes 

Categorical Discharger No 

P2 Measures Central Vehicle Wash Facility 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

O & G 6 5/5/98 
92 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name 5th Engineering Battalion 

Building Number 872 

POC BMO Palagar 

POC phone number 555-0001 

Activity Description Washracks, Individual 

NAICS Code 811198 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 9600 

Average daily flow (gal/day) 5000 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures Central Vehicle Wash Facility 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

O & G 74 5/7/98 
CERL TR 99/49 93 

Friday, August 21, 1998 

Facility Name Auto Craft Shop 

Building Number 383 

POC Ed Cain 

POC phone number 555-0002 

Activity Description Automotive Craft Shops 

NAICS Code 811198 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 800 

Average daily flow (gal/day) 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User Yes 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Benzene 0.62 5/8/98 

Ethyl Benzene 0.33 5/8/98 

n-Propyl 0.013 5/8/98 

Benzene 

Naphthalene 0.038 5/8/98 

o-m Xylenes 0.85 5/8/98 

Toluene 1.76 5/8/98 

p-Xylenes 0.37 5/8/98 

Sec-Butyl 0.19 5/8/98 

Benzene 

O & G 22 5/8/98 

Phenol 0.09 5/8/98 

1,3,5-Trimethyl 0.056 5/8/98 

Benzene 
94 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name DOL Battery Shop 

Building Number 5265 

POC Terry Tyler 

POC phone number 555-0003 

Activity Description Battery Shops 

NAICS Code 811198 

Device Type pH Control 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 105 

Average daily flow (gal/day) 105 

Slug flow duration (minutes) 40 

Slug flow frequency (per month) 8 

Significant Industrial User Yes 

Categorical Discharger No 

P2 Measures Adjust Battery Neutralization to pH 7 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Lead 40 5/7/98 

Sulfides 0.024 5/7/98 

Nickel 3.2 5/7/98 

Cyanide 0.1 5/7/98 

Chromium 0.3 5/7/98 

Copper 6.7 5/7/98 

Cadmium 0.8 5/7/98 

Silver 0.16 5/7/98 
CERL TR 99/49 95 

Friday, August 21, 1998 

Facility Name DOL Paint Booth 

Building Number 5265 

POC Al Carrasco 

POC phone number 555-0004 

Activity Description Paint Booth - Water Curtain 

NAICS Code 811121 

Device Type None 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 1380 

Average daily flow (gal/day) 1380 

Slug flow duration (minutes) 20 

Slug flow frequency (per month) 1 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

O & G 17 5/7/98 

Phenol 0.009 5/7/98 

Cyanide 0.03 5/7/98 

Trichloro 0.012 5/7/98 

Ethane 

Toluene 0.019 5/7/98 
96 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name DOL Plating Shop 

Building Number 5265 

POC Al Carrasco 

POC phone number 555-0014 

Activity Description Plating (C) 

NAICS Code 332813 

Device Type Chromium Recovery Unit 

GPS Location unavailable 

Average rate of production 100 sq m/day 

Peak daily flow (gal/day) 2000 

Average daily flow (gal/day) 1000 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User Yes 

Categorical Discharger Yes 

P2 Measures Rinse water reuse 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Total Toxic 4.3 5/6/98 

Organics 

Lead 0.4 0.2 

4 day, 5/6/98 

Cyanide 3.6 2.9 

4 day, 5/6/98 

Cadmium 1 0.5 4 day, 5/6/98 
CERL TR 99/49 97 

Friday, August 21, 1998 

Facility Name DOL Wheeled Vehicle Shop 

Building Number 5265 

POC Dale Waters 

POC phone number 555-0013 

Activity Description Aqueous Parts Washers 

NAICS Code 811198 

Device Type None 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 340 

Average daily flow (gal/day) 340 

Slug flow duration (minutes) 15 

Slug flow frequency (per month) 1 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

O & G 2355 5/6/98 

Tetrachloro 0.014 5/6/98 

Ethene 

 

Phenol 0.004 5/6/98 
98 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name ECS Washrack 

Building Number 5138 

POC Paul Ritter 

POC phone number 555-0005 

Activity Description Washracks, Individual 

NAICS Code 811198 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 3000 

Average daily flow (gal/day) 2000 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures Central Vehicle Wash Facility 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

O & G 57 5/17/98 

Phenol 0.073 5/17/98 

Cyanide 0.02 5/17/98 
CERL TR 99/49 99 

Friday, August 21, 1998 

Facility Name Fire Fighting Training Facility 

Building Number 6000 

POC Jeff Scheer 

POC phone number 555-0006 

Activity Description Fire Training Pit 

NAICS Code unavailable 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 10000 

Average daily flow (gal/day) 10000 

Slug flow duration (minutes) 30 

Slug flow frequency (per month) 1 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Sulfides 0.09 5/10/98 

Cyanide 0.004 5/10/98 

O & G 52 5/10/98 

Phenol 0.017 5/10/98 
100 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name Garbage Dumpster Washrack 

Building Number 200 

POC Carl Stenger 

POC phone number 555-0007 

Activity Description Washracks, Individual 

NAICS Code 562111 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 120 

Average daily flow (gal/day) 50 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Cyanide 10 5/10/98 

O & G 2 5/10/98 

Phenol 0.76 5/10/98 

Sulfides 0.482 5/10/98 

Toluene 0.022 5/10/98 
CERL TR 99/49 101 

Friday, August 21, 1998 

Facility Name Harper Dental Clinic 

Building Number 500 

POC LT Alexander 

POC phone number 555-0008 

Activity Description Dental Office or Complex 

NAICS Code 621210 

Device Type Silver Recovery Unit 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 5 

Average daily flow (gal/day) 2 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Nickel 0.014 5/16/98 

Copper 0.103 5/16/98 

Chromium 0.002 5/16/98 

Cadmium 0.078 5/16/98 

Silver 0.13 5/16/98 

Lead 0.012 5/16/98 
102 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name Hospital -Silver Recovery Unit 

Building Number 350 

POC John Smith 

POC phone number 555-0009 

Activity Description Hospitals (C) 

NAICS Code 621111 

Device Type Silver Recovery Unit 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 10 

Average daily flow (gal/day) 7 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger Yes 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Silver 0.27 5/6/98
CERL TR 99/49 103 

Friday, August 21, 1998 

Facility Name Oily Sludge Drying Basin 

Building Number 440 

POC Kenny Worhal 

POC phone number 555-0010 

Activity Description Oily Sludge Dewatering 

NAICS Code unavailable 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 5760 

Average daily flow (gal/day) 1000 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Copper 1.3 5/19/98 

O & G 82 5/19/98 

Chromium 0.5 5/19/98 

Cadmium 0.07 5/19/98 

Lead 0.7 5/19/98 
104 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name POV Car Wash 

Building Number 515 

POC Jim Smith 

POC phone number 555-0011 

Activity Description POV Car Wash 

NAICS Code 811192 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 2880 

Average daily flow (gal/day) 2000 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Cyanide 0.1 5/4/98 

Sec-Butyl 0.011 5/4/98 

Benzene 

O & G 24 5/4/98 

Sulfides 0.007 5/4/98 

Phenol 0.102 5/4/98 
CERL TR 99/49 105 

Friday, August 21, 1998 

Facility Name TMP Automatic Car Wash 

Building Number 1100 

POC Ray Long 

POC phone number 555-0012 

Activity Description Washracks, Individual 

NAICS Code 811198 

Device Type None 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 15370 

Average daily flow (gal/day) 12000 

Slug flow duration (minutes) 0 

Slug flow frequency (per month) 0 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Cyanide 0.09 5/20/98 

Sulfides 0.018 5/20/98 

O & G 5 5/20/98 
106 CERL TR 99/49 

Friday, August 21, 1998 

Facility Name Used Oil/Diesel Fuel ASTs 

Building Number 212 

POC Carl Stenger 

POC phone number 555-0007 

Activity Description Fuel/Chemical Storage Areas 

NAICS Code unavailable 

Device Type Oil/Water Separation - Cast-in-place/precast concrete gravity 

separator 

GPS Location unavailable 

Average rate of production n/a 

Peak daily flow (gal/day) 150 

Average daily flow (gal/day) 150 

Slug flow duration (minutes) 35 

Slug flow frequency (per month) 2 

Significant Industrial User No 

Categorical Discharger No 

P2 Measures None 

Environmental permits None 

Pollutant 

Maximum 

Conc (mg/L) 

Average Conc (mg/L) 

(categorical dischargers only) Interval, Date 

Sec-Butyl 0.046 5/20/98 

Benzene 

 

Toluene 0.106 5/20/98 

O & G 15 5/20/98 

Benzene 0.22 5/20/98 

p-Xylenes 0.031 5/20/98 

o-m Xylenes 0.069 5/20/98 

Naphthalene 0.021 5/20/98 

Ethyl Benzene 0.017 5/20/98 

Sulfides 0.025 5/20/98 

Phenol 0.05 5/20/98 

Cyanide 0.6 5/20/98 
CERL TR 99/49 107 

Friday, August 21, 1998 

Sources of Pollutants Detected 

Pollutant Facility Name 

1,3,5-Trimethyl benzene Auto Craft Shop 

Benzene Used Oil/Diesel Fuel ASTs 

Auto Craft Shop 

Cadmium Harper Dental Clinic 

DOL Battery Shop 

Oily Sludge Drying Basin 

DOL Plating Shop 

Copper DOL Battery Shop 

Harper Dental Clinic 

Oily Sludge Drying Basin 

Chromium DOL Battery Shop 

Oily Sludge Drying Basin 

Harper Dental Clinic 

Cyanide DOL Plating Shop 

ECS Washrack 

TMP Automatic Car Wash 

POV Car Wash 

Fire Fighting Training Facility 

Garbage Dumpster Washrack 

DOL Paint Booth 

DOL Battery Shop 

Used Oil/Diesel Fuel ASTs 

Ethyl Benzene Auto Craft Shop 

Used Oil/Diesel Fuel ASTs 

Lead Harper Dental Clinic 

DOL Battery Shop 

Oily Sludge Drying Basin 

DOL Plating Shop 

n-Propyl benzene Auto Craft Shop 

Naphthalene Used Oil/Diesel Fuel ASTs 

Auto Craft Shop 

Nickel Harper Dental Clinic 

DOL Battery Shop 
108 CERL TR 99/49 

Friday, August 21, 1998 

Pollutant Facility Name 

O & G Fire Fighting Training Facility 

Garbage Dumpster Washrack 

POV Car Wash 

Auto Craft Shop 

58th Transportation Battalion, 

Washrack 

TMP Automatic Car Wash 

DOL Paint Booth 

DOL Wheeled Vehicle Shop 

Used Oil/Diesel Fuel ASTs 

ECS Washrack 

Oily Sludge Drying Basin 

5th Engineering Battalion 

o-m Xylenes Used Oil/Diesel Fuel ASTs 

Auto Craft Shop 

p-Xylenes Auto Craft Shop 

Used Oil/Diesel Fuel ASTs 

Phenol Auto Craft Shop 

Fire Fighting Training Facility 

POV Car Wash 

Garbage Dumpster Washrack 

Used Oil/Diesel Fuel ASTs 

DOL Wheeled Vehicle Shop 

ECS Washrack 

DOL Paint Booth 

Sec-Butyl Benzene POV Car Wash 

Auto Craft Shop 

Used Oil/Diesel Fuel ASTs 

Silver DOL Battery Shop 

Hospital -Silver Recovery Unit 

Harper Dental Clinic 

Sulfides POV Car Wash 

DOL Battery Shop 

Used Oil/Diesel Fuel ASTs 

Garbage Dumpster Washrack 

TMP Automatic Car Wash 

Fire Fighting Training Facility 

Tetrachloro Ethane DOL Wheeled Vehicle Shop 

Toluene Used Oil/Diesel Fuel ASTs 

DOL Paint Booth 

Auto Craft Shop 

Garbage Dumpster Washrack 

Total Toxic Organics (TTO) DOL Plating Shop 

Trichloro Ethane DOL Paint Booth 
Friday, August 21, 1998 

Discharge Limits for Pollutants at Each Source Facility Name Pollutant Max Conc Allowed (mg/L) Max Avg. Conc Allowed (

58th Transportation Battalion, Washrack O & G 100.00 5th Engineering Battalion O & G 100.00 Auto Craft Shop Benzene Ethyl Benzene n-Propyl benzene Naphthalene o-m Xylenes Toluene p-Xylenes Sec-Butyl Benzene O & G Phenol 1,3,5-Trimethyl benzene 2.00 2.00 2.00 2.00 1.40 2.00 0.60 2.00 100.00 0.50 2.00 DOL Battery Shop Lead Sulfides Nickel Cyanide Chromium Copper Cadmium Silver 5.00 2.50 10.00 5.00 2.00 2.00 1.20 2.00 DOL Paint Booth O & G Phenol Cyanide Trichloro Ethane Toluene 100.00 0.50 5.00 2.00 2.00 
Friday, August 21, 1998 

Facility Name Pollutant Max Conc Allowed (mg/L) Max Avg. Conc Allowed (DOL Plating Shop Total Toxic Organics (TTO) Lead Cyanide Cadmium 4.57 0.60 5.00 1.20 0.4 2.7 0.7 DOL Wheeled Vehicle Shop O & G Tetrachloro Ethane Phenol 100.00 2.00 0.50 ECS Washrack O & G Phenol Cyanide 100.00 0.50 5.00 Fire Fighting Training Facility Sulfides Cyanide O & G Phenol 2.50 5.00 100.00 0.50 Garbage Dumpster Washrack Cyanide O & G Phenol Sulfides Toluene 5.00 100.00 0.50 2.50 2.00 Harper Dental Clinic Nickel Copper Allowed (mg/L) Chromium Cadmium Silver Lead 10.00 2.00 2.00 1.20 2.00 5.00 Hospital -Silver Recovery Unit Silver 2.00 
Friday, August 21, 1998 

Facility Name Pollutant Max Conc Allowed (mg/L) Max Avg. Conc Allowed (Oily Sludge Drying Basin Copper O & G Chromium Cadmium Lead 2.00 100.00 2.00 1.20 5.00 POV Car Wash Cyanide Sec-Butyl Benzene O & G Sulfides Phenol 5.00 2.00 100.00 2.50 0.50 TMP Automatic Car Wash Cyanide Sulfides O & G 5.00 2.50 100.00 Used Oil/Diesel Fuel ASTs Sec-Butyl Benzene Toluene O & G Benzene p-Xylenes o-m Xylenes Naphthalene Ethyl Benzene Allowed (mg/L) Sulfides Phenol Cyanide 2.00 2.00 100.00 2.00 0.60 1.40 2.00 2.00 2.50 0.50 5.00 
Friday, August 21, 1998 

Monitoring Report S

Facility Name Date Flow (mg/L) Pollutant (mg/L) Time Max Conc Avg. Conc Interval Sample Procedure Taken by 

5/5/98 30720 O & G 15:30 6 Grab Bevelheimer 5/5/98 Phenol 15:30 0.058 Grab Bevelheimer 5/5/98 Sulfides 15:30 0.038 Grab Bevelheimer 

58th Transportation Battalion, Washrack 5/7/99 28500 O & G 9:00 12 Grab Carter 

5/7/98 800 1,3,5-Trimethyl- Benzene 16:00 0.056 Grab Hanson 5/7/98 Benzene 16:00 0.62 Grab Hanson 5/7/98 Ethyl Benzene 16:00 0.33 Grab Hanson 5/7/98 n-Propyl Benzene 16:00 0.013 Grab Hanson 5/7/98 Naphthalene 16:00 0.038 Grab Hanson 5/7/98 O & G 16:00 1.5 Grab Hanson 5/7/98 o-m Xylenes 16:00 0.85 Grab Hanson 5/7/98 p-Xylenes 16:00 0.37 Grab Hanson 5/7/98 Phenol 16:00 0.097 Grab Hanson 5/7/98 Sec-Butyl Benzene 16:00 0.19 Grab Hanson 5/7/98 Toluene 16:00 1.76 Grab Hanson 

5/13/99 750 Benzene 9:00 0.75 Grab Carter 5/13/99 Ethyl Benzene 9:00 0.41 Grab Carter 5/13/99 o-m Xylenes 9:00 0.68 Grab Carter 5/13/99 p-Xylenes 9:00 0.25 Grab Carter 

Auto Craft Shop 5/13/99 Toluene 9:00 1.69 Grab Carter 

5/7/98 105 Cadmium 10:15 0.8 Grab Cosper 5/7/98 Copper 10:15 6.7 Composite Cosper 5/7/98 Chromium 10:15 0.3 Composite Cosper 5/7/98 Cyanide 10:15 0.1 Composite Cosper 5/7/98 Lead 10:15 40 Composite Cosper 5/7/98 Nickel 10:15 3.2 Composite Cosper 5/7/98 Silver 10:15 0.16 Composite Cosper 

DOL Battery Shop 5/7/98 Sulfides 10:15 0.024 Composite Cosper 
Friday, August 21, 1998 

S

Facility Name Date Flow (mg/L) Pollutant (mg/L) Time Max Conc Avg. Conc Interval Sample Procedure Taken by 

5/13/99 Copper 8:30 5.3 Composite Carter 5/13/99 110 Lead 8:30 35 Composite Carter 

5/13/99 Nickel 8:30 2.8 Composite Carter 

5/20/98 2000 Cadmium 10:00 0.5 0.3 4 day Composite Carter 5/20/98 Cyanide 10:00 3.6 2.4 4 day Grab Carter 5/20/98 Lead 10:00 0.5 0.2 4 day Composite Carter 5/20/98 Total Toxic Organics (TTO) 10:00 4.3 Composite Carter 5/29/99 2000 Cadmium 9:00 0.6 0.3 4 day Composite Carter 5/29/99 Cyanide 9:00 3.2 2.2 4 day Grab Carter 5/29/99 Lead 9:00 0.5 0.3 4 day Composite Carter 

DOL Plating Shop 5/29/99 Total Toxic Organics (TTO) 9:00 4.2 5/6/98 340 O & G 10:00 2355 Grab Gerdes 

5/6/98 Phenol 10:00 0.004 Grab Gerdes 5/6/98 Tetrachloro Ethane 10:00 0.014 Grab Gerdes 

DOL Wheeled Vehicle Shop 5/10/99 340 O & G 10:00 1745 Grab Carter 
114 CERL TR 99/49 

Friday, August 21, 1998 

Compliance Plan and SIU Compliance Report 

COMPLIANCE PLAN Date: 15 June 1998 

1. The Pretreatment Program Manager will request funding for, and install, a 

metals recovery pretreatment process at the DOL Battery Shop. The earliest 

that funding can be expected is in FY 2000. Construction may begin 3rd Quarter 

FY 2000. 

2. The Pretreatment Program Manager will request funding for, and install, an 

oil/water separator at the DOL wheeled vehicle shop parts washer. The earliest 

that funding can be expected is in FY 2000. Construction could begin 3rd Quarter 

FY 2000. 

Date: 30 June 1998 

1. A106 funding requests have been submitted for both the DOL metals recovery 

process and oil/water separator. 

Date: 15 Sep 1999 

1. EPR funding is programmed for FY 2000 for both the metals recovery process 

and the oil/water separator. 
Friday, August 21, 1998 

SIU Compliance Report Facility Name Date Pollutant Max Conc Limit (mg/L) Measured Conc (mg/L) Over Limit? Avg. Conc Limit (mg/L) Avg. Conc (mg/L) 

58th Transportation Battalion, Washrack 5/5/98 O & G 100.00 6 5/7/99 O & G 100.00 12 5/7/98 1,3,5-Trimethyl benzene 2.00 0.056 5/7/98 Benzene 2.00 0.62 5/7/98 Ethyl Benzene 2.00 0.33 5/7/98 n-Propyl benzene 2.00 0.013 5/7/98 Naphthalene 2.00 0.038 5/7/98 O & G 100.00 1.5 5/7/98 o-m Xylenes 1.40 0.85 5/7/98 p-Xylenes 0.60 0.37 5/7/98 Phenol 0.50 0.097 5/7/98 Sec-Butyl Benzene 2.00 0.19 5/7/98 Toluene 2.00 1.76 5/13/99 Benzene 2.00 0.75 5/13/99 Ethyl Benzene 2.00 0.41 5/13/99 o-m Xylenes 1.40 0.68 5/13/99 p-Xylenes 0.60 0.25 Auto Craft Shop 5/13/99 Toluene 2.00 1.69 
Friday, August 21, 1998 

5/7/98 Cadmium 1.20 0.8 5/7/98 Copper 2.00 6.7 Over Limit 5/7/98 Chromium 2.00 0.3 5/7/98 Cyanide 5.00 0.1 5/7/98 Lead 5.00 40 Over Limit 5/7/98 Nickel 10.00 3.2 5/7/98 Silver 2.00 0.16 5/7/98 Sulfides 2.50 0.024 5/13/99 Copper 2.00 5.3 Over Limit 5/13/99 Lead 5.00 35 Over Limit DOL Battery Shop 5/13/99 Nickel 10.00 2.8 5/20/98 Cadmium 1.20 0.5 0.5 0.3 5/20/98 Cyanide 5.00 3.6 2.9 2.4 5/20/98 Lead 0.60 0.5 0.2 0.2 5/20/98 Total Toxic Organics (TTO) 4.57 4.3 5/29/99 Cadmium 1.20 0.6 0.5 0.3 5/29/99 Cyanide 5.00 3.2 2.9 2.2 5/29/99 Lead 0.60 0.5 0.2 0.3 DOL Plating Shop 5/29/99 Total Toxic Organics (TTO) 4.57 4.2 5/6/98 O & G 100.00 2355 Over Limit 5/6/98 Phenol 0.50 0.004 5/6/98 Tetrachloro Ethane 2.00 0.014 DOL Wheeled Vehicle Shop 5/10/99 O & G 100.00 1745 Over Limit 
CERL TR 99/49 117 

Friday, August 21, 1998 

Recommended Pollution Prevention Measures 

P2 Measures Facility Name Building Number 

Adjust Battery Neutralization to pH 7 DOL Battery Shop 5265 

ECS Washrack 5138 

58th Transportation Battalion, 950 

Washrack 

Central Vehicle Wash Facility 

5th Engineering Battalion 872 

Harper Dental Clinic 500 

Hospital -Silver Recovery Unit 350 

Auto Craft Shop 383 

Used Oil/Diesel Fuel ASTs 212 

Garbage Dumpster Washrack 200 

TMP Automatic Car Wash 1100 

DOL Paint Booth 5265 

POV Car Wash 515 

Oily Sludge Drying Basin 440 

Fire Fighting Training Facility 6000 

None 

DOL Wheeled Vehicle Shop 5265 

Rinse water reuse DOL Plating Shop 5265 
118 CERL TR 99/49 

Annex B — Non-Routine Discharge Control Plan 

1. PURPOSE. Implementation of this plan will ensure that septage and other 

slugs of wastewater discharged to the installation sanitary sewer will not 

adversely effect the Sewage Treatment Plant (STP) operations. 

2. SEPTAGE MANAGEMENT PLAN. 

a. Contents of septic tanks, holding tanks and port-a-johns throughout the 

installation are collected and discharged to the WWTP at a location designated 

by the WWTP manager. 

b. Limit on quantity. Not more than 20,000 gal of septage can be discharged to 

the sanitary sewer in any 24-hour period. Additionally, not more than 5,000 gal 

can be discharged within any 1-hour period. 

NOTE: The designated quantities were calculated, based on the maximum 

allowable concentration of BOD in septage received at the sewage treatment 

plant (400 mg/L), such that those quantities will add a maximum of 5 mg/L of 

BOD to the primary clarifiers, at a flow of 1.0 MGD. Based on an average BOD 

concentration in the influent of 150 mg/L, an additional 5 mg/L will still result in 

a BOD less than average strength for sanitary sewage, and should cause no 

problems for our trickling filters. Using a removal efficiency of 90 percent this 

will add 0.5 mg/L to our effluent and will not cause excursion of our 10 mg/L 

BOD discharge limit. Pumpage from port-a-johns is limited to not more than 

500 gal in any 24-hour period. 

c. Limit on quality. Septage with a biochemical oxygen demand BOD/COD of 

greater than 400/1300 mg/L is prohibited from being discharged to sanitary 

sewer. However, if a high strength septage is encountered at a pumping location, 

it can be mixed with a dilute septage location to arrive at a material that meets 

the less than 400/1300 BOD/COD criteria. However, pumpage from port-a-johns 

does not have to meet this criteria, provided the quantity criteria noted at a 

above is met. 
CERL TR 99/49 119 

Friday, August 21, 1998 

d. Quality control. If deemed necessary by the WWTP manager, a sufficient 

number of trucks will be sampled to fully characterize the septage entering the 

installation sewer system to ensure that high strength waste is not entering the 

sewer system. If these analysis show there is a potential problem, the PPM and 

WWTP manager will revise the septage control plan accordingly. Subsequently, 

random quality assurance samples will be taken quarterly by the WWTP. The 

sources of septage to be sampled will be rotated to ensure that all sources of 

septage are sampled. 

e. Controlled access to septage discharge port. The WWTP manager and his 

staff will control access to the septage discharge point, and maintain a record of 

septage discharged to the WWTP. 

3. NON-ROUTINE DISCHARGES 

a. Non-routine discharges (slugs) are defined as any quantify of industrial (nondomestic) wastewater that is discharged to the sanitary sewer on less than a 

daily frequency, and has the potential to cause interference with or pass-through 

the wastewater treatment plant. 

b. Non-routine discharges will be reported to the Sewage Treatment Plant 

Manager prior to discharge. The STP Manager must be notified of quantity and 

type of waste. A follow-up written notification will be sent to the STP Manager 

within 5 days for discharges greater than 500 gal. 

c. The Pretreatment Program Manager, on recommendation from the Sewage 

Treatment Plant Manager, may require: 

 i) metering the waste into the sewer at a specified flow rate, or 

 ii) additional pretreatment of the waste. 

d. Non-routine discharges will be monitored at the same frequency as other 

significant industrial user waste streams. 

e. Information on sources of non-routine discharges is included in Appendix A of 

this document (Facility and Pollutant Inventory). 

f. Examples of sources of non-routine discharges are recycling aqueous parts 

washers and fire fighting training pits. 
120 CERL TR 99/49 

CERL DISTRIBUTION

Chief of Engineers 

 ATTN: CEHEC-IM-LH (2) 

 ATTN: CEHEC-IM-LP (2) 

 ATTN: CECC-R 

 ATTN: CERD-L 

 ATTN: CERD-M 

U.S. Army Environmental Center (2) 

 ATTN: SFIM-AEC-ECC 21010-5401 

Defense Tech Info Center 22304 

 ATTN: DTIC-O (2) 

 11 

 7/99