October 1983 

EPA 

United States Office of 

Environmental Protection Water Enforcement 

Agency and Permits 

Procedures Manual 

for Reviewing a POTW 

Pretreatment Program 

Submission 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

WATER 

MEMORANDUM 

SUBJECT: Pretreatment Program Guidance 

TO: Users of the Procedures Manual for Reviewing a 

POTW Pretreatment Program Submission 

FROM: Rebecca W. Hanmer 

Acting Assistant Administrator for Water (WH-556) 

This manual presents the procedures for EPA Regions and 

approved States to review local POTW pretreatment program submissions. It facilitates the determination whether the submittal 

contains the data and information required by the General Pretreatment Regulations (40 CFR Part 403), and whether the program is 

approvable. It provides the reviewers with a suggested separate 

checklist for reviewing each program element. 

EPA Regional offices and States with approved programs must 

continue their efforts to review and approve local POTW pretreatment programs in their respective geographical areas. The approval 

of local POTW pretreatment programs is the cornerstone of the 

Agency's national pretreatment program. 

While this approval is critical to the success of the national 

pretreatment program, Approval Authorities must ensure that all 

substantive parts of the local pretreatment program are present 

when the program is approved. Prematurely approving incomplete 

programs may cause major problems in the future. In instances 

where a segment of the program is not fully developed when the 

program is approved, then the Approval Authority and the POTW 

should publicly document (preferably in writing) that a segment 

of the program is not fully established and that it will be 

developed after approval in accordance with an agreed upon time 

table. 
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Approval Authorities can use this manual to review and 

approve any local POTW pretreatment program. However, when using 

the manual and its checklists, these Authorities must understand 

that the manual is for guidance and its use must be tailored to 

the complexity and size of the program under review. A program 

developed by a small POTW with relatively few industrial users 

should not be reviewed in the same manner as a program developed 

by a large POTW with many industrial users. The level of detail 

and sophistication in the former program will naturally be less 

than in the latter program. Approval Authorities must bear this 

fact in mind when using this manual. 

I believe that Approval Authority personnel will find this 

manual to be a useful tool in reviewing local POTW pretreatment 

program submissions on a consistent basis. As this guidance may 

be revised periodically to reflect program experience or changes 

in program regulations, please feel free to write to the Office 

of Water Enforcement and Permits (EN-336) if you have suggestions 

on how the guidance may be improved or areas which should be 

addressed. Thank you. 
PROCEDURES MANUAL 

FOR 

REVIEWING A POTW 

PRETREATMENT PROGRAM SUBMISSION 

Rebecca Hanmer 

Acting Assistant Administrator, Office of Water 

Bruce R. Barrett, Jr. 

Director, Office of Water Enforcement and Permits 

Martha G. Prothro 

Director, Permits Division 

Dr. James D. Gallup 

National Pretreatment Coordinator 

October 1983 

Office of Water Enforcement and Permits 

Office of Water 

U.S. Environmental Protection Agency 

401 M Street, S.W. 

Washington, D.C. 20460 
ACKNOWLEDGEMENTS 

This document was prepared with guidance from EPA 

Headquarters, Office of Water Enforcement and Permits 

and EPA Regional Offices. The State of Maryland Water 

Resources Administration and New York State Department 

of Environmental Conservation participated as peer 

reviewers and provided valuable comments which have been 

incorporated into this document. This Procedures Manual 

was prepared by JRB Associates under EPA Contract No. 

68-01-6514. 
TABLE OF CONTENTS 

Page 

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 

1.1 PURPOSE OF THIS MANUAL. . . . . . . . . . . . . . . . . . . . 1-1 

1.2 HOW TO USE THIS MANUAL. . . . . . . . . . . . . . . . . . . . 1-2 

1.3 COMMENTING ON PROGRAM SUBMISSIONS . . . . . . . . . . . . . . 1-3 

2. LEGAL AUTHORITY. . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 

2.1 SUBMISSION COMPLETENESS .. . . . . . . . . . . . . . . . . . 2-2 

2.1.1 Relevant Regulations ................. 2-2 

2.1.2 Evaluation of Completeness .............. 2-2 

2.2 EVALUATION OF ATTORNEY'S STATEMENT. . . . . . . . . . . . . . 2-3 

2.2.1 Relevant Regulations ................. 2-3 

2.2.2 Evaluation of Statement. ............... 2-4 

2.3 LEGAL ADEQUACY. . . . . . . . . . . . . . . . . . . . . . . . 2-5 

2.3.1 Relevant Regulations ................. 2-5 

2.3.2 Evaluation of Adequacy ................ 2-5 

2.4 MULTIJURISDICTIONAL SUBMISSIONS . . . . . . . . . . . . . . . 2-13 

2.5 LEGAL AUTHORITY CHECKLIST . . . . . . . . . . . . . . . . . . 2-14 

3. TECHNICAL INFORMATION. . . . . . . . . . . . . . . . . . . . . . . 3-1 

3.1 INDUSTRIAL WASTE SURVEY . . . . . . . . . . . . . . . . . . . 3-1 

3.1.1 Adequacy of the Survey Master List .......... 3-2 

3.1.2 Thoroughness of Survey Questionnaire ......... 3-3 

3.1.3 Response to Survey .................. 3-5 

3.1.4 Completeness of Summary Information. ......... 3-5 

3.2 LOCAL EFFLUENT LIMITS . . . . . . . . . . . . . . . . . . . . 3-6 

3.2.1 Identification of Past POTW Operating Problems . . . . 3-7 

3.2.2 Sampling and Analysis to Determine Fate and Effect . . 3-8 

3.2.3 Development of Local Effluent Limits . . . . . . . . . 3-10 

TECHNICAL INFORMATION CHECKLIST . . . . . . . . . . . . . . . 3-12 

i 
TABLE OF CONTENTS (cont) 

Page 

4. PROGRAM IMPLEMENTATION PROCEDURES. . . . . . . . . . . . . . . . . 4-1 

4.1 UPDATE THE INDUSTRIAL WASTE SURVEY. . . . . . . . . . . . . . 4-1 

4.2 NOTIFY INDUSTRIAL USERS OF APPLICABLE STANDARDS 

AND REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . 4-2 

4.3 UNDERTAKE COMPLIANCE MONITORING PROCEDURES. . . . . . . . . . 4-3 

4.3.1 Receive and Analyze Self-Monitoring Reports 

and Other Notices. .................. 4-4 

4.3.2 Conduct Compliance Sampling and Analysis ....... 4-5 

4.3.3 Investigate Noncompliance. .............. 4-7 

4.4 PUBLIC PARTICIPATION. . . . . . . . . . . . . . . . . . . . . 4-9 

PROGRAM IMPLEMENTATION PROCEDURES CHECKLIST . . . . . . . . . 4-12 

5. ORGANIZATION, STAFFING, EQUIPMENT, AND FUNDING . . . . . . . . . . 5-1 

5.1 RELEVANT REGULATIONS. . . . . . . . . . . . . . . . . . . . . 5-1 

5.2 EVALUATION OF ORGANIZATION AND STAFFING . . . . . . . . . . . 5-2 

5.2.1 Clear and Appropriate Lines of Authority ....... 5-3 

5.2.2 Identification of Staff Responsibilities ....... 5-4 

5.2.3 Staff Qualifications ................. 5-5 

5.2.4 Staffing Levels. ................... 5-5 

5.2.5 Coordination with Other Departments. ......... 5-6 

5.3 EVALUATION OF EQUIPMENT . . . . . . . . . . . . . . . . . . . 5-6 

5.4 EVALUATION OF FUNDING . . . . . . . . . . . . . . . . . . . . 5-11 

5.4.1 Implementation Costs ................. 5-12 

5.4.2 Financing Sources and Cost Recovery Systems. ..... 5-15 

RESOURCES CHECKLIST . . . . . . . . . . . . . . . . . . . . . 5-18 

APPENDIX A BIBLIOGRAPHY OF PRETREATMENT REFERENCES. . . . . . . . . . A-1 

APPENDIX B DEVELOPMENT OF DISCHARGE LIMITATIONS TO CONTROL 

INCOMPATIBLE POLLUTANTS. . . . . . . . . . . . . . . . . . B-1 

APPENDIX C PRIORITY POLLUTANTS AND CATEGORICAL INDUSTRY INFORMATION . C-1 

ii 
LIST OF TABLES AND WORKSHEETS 

Page 

WORKSHEET 1 

WORKSHEET 2 

WORKSHEET 3 

WORKSHEET 4

TABLE 5-1 

TABLE 5-2 

TABLE 5-3 

TABLE 5-4 

TABLE 5-5 

TABLE 5-6 

TABLE 5-7 

LEGAL AUTHORITY CHECKLIST. . . . . . . . . . . . . . . 2-15 

TECHNICAL INFORMATION CHECKLIST. . . . . . . . . . . . 3-12 

PROGRAM IMPLEMENTATION PROCEDURES CHECKLIST. . . . . . 4-12 

RESOURCES CHECKLIST. . . . . . . . . . . . . . . . . . 5-18 

POTW PRETREATMENT PROGRAM PERSONNEL 

REQUIREMENT RANGES . . . . . . . . . . . . . . . . . . 5-7 

ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW 

PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES . . . . . 5-8 

ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW 

PRETREATMENT PROGRAM BY PROGRAM ACTIVITY . . . . . . . 5-9 

TYPICAL EQUIPMENT FOR A TWO-MAN FIELD SAMPLING CREW. . 5-13 

TYPICAL COMMERCIAL LABORATORY COSTS. . . . . . . . . . 5-14 

FACTORS AFFECTING POTW LEVELS OF EFFORT FOR 

PRETREATMENT PROGRAM OPERATING TASKS . . . . . . . . . 5-16 

HYPOTHETICAL POTW PRETREATMENT PROGRAM 

OPERATIONAL COSTS. . . . . . . . . . . . . . . . . . . 5-17 

iii 
1. INTRODUCTION 

1.1 PURPOSE OF THIS MANUAL 

This document has been prepared to assist States and EPA Regional Offices 

in reviewing local pretreatment program submissions. It is intended to provide a framework for the review of local programs as well as general criteria 

for evaluating these programs. The document can also serve as a starting 

point for States to develop individualized checklists for review of local programs under their jurisdiction, if such checklists have not yet been developed. 

A successful pretreatment program cannot be developed without adequate 

legal authority, technical information, implementation procedures, and resources. Each of these elements is essential in a successful program, and the 

pretreatment program submission must demonstrate that all are present if it is 

to be approved. A separate chapter in this manual is devoted to each element. 

Each chapter contains: 

• A summary of pertinent regulatory requirements 

• A discussion of key items that should be included in the submission 

• General guidelines and criteria for assessing the adequacy of the 

approaches proposed by the POTW 

• A checklist to aid the reviewer in evaluating completeness and 

adequacy. 

The focus of the review is to determine that the program not only meets 

regulatory requirements, but also that it will function well once it is 

implemented. 

A majority of the regulatory requirements associated with a local pretreatment program are addressed in the legal authority chapter. Other 

chapters identify activities, staff roles, and program items that are most 

likely to be included in a well-planned program. 

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1.2 HOW TO USE THIS MANUAL 

Each of the four checklists is intended to be photocopied and used in 

actual reviews. Agencies using these checklists may wish to separate the 

various sections and delegate portions of the review to individuals who have 

expertise in the appropriate areas. For example, a review of the technical 

information chapter may be assigned to an engineer. A lawyer may be assigned 

the task of reviewing the legal authority chapter, while someone with management or administrative experience might he responsible for reviewing the program implementation and resources sections of the submission. Each checklist 

allows the reviewer to indicate whether the section as a whole adequately 

satisfies Federal requirements, and to sign or initial this decision. 

Not every item on a checklist must necessarily be included in the submission to satisfy Federal requirements for an approvable program. Optional 

items are recommended on the checklists for a more comprehensive pretreatment 

program, but these items are not required. The review must be flexible, since 

the features necessary to operate a pretreatment program in a large community 

may not be necessary or appropriate for a smaller one with few industrial 

users. Where tables have been included in this manual to identify levels of 

staff and costs associated with operating a program, they are intended to be 

used as general guidance for the reviewer, not as rigid requirements for the 

program submission. Program approval must ultimately be based on the best 

professional judgement of the reviewer. 

To make this manual most useful, the reviewer should be familiar with its 

companion document, Guidance Manual for POTW Pretreatment Program Development. 

The Preparation Manual is intended to assist municipalities in developing 

their pretreatment programs and in preparing their program submissions. It is 

important for the reviewer to understand both the objectives that the local 

program is designed to achieve, and the process followed by a POTW in developing its program. 

1-2 
1.3 COMMENTING ON PROGRAM SUBMISSIONS 

A pretreatment program submission may be inadequate in some areas. 

Inadequacies can be expected because the level of guidance and expertise 

available to POTWs developing pretreatment programs varies across the country. 

The reviewer should look upon weaknesses in a submission not as a problem, but 

as an opportunity to give constructive guidance to the POTW authorities. 

Comments should be designed to assist a particular POTW in preparing an 

approvable submission, not simply make the submission package look good or 

enable the POTW to comply quickly with a deadline. 

The reviewer should point out specific weaknesses in the submission to 

the POTW and offer suggestions to correct these weaknesses. By providing 

clear and specific comments to the POTW, the reviewer can save the POTW time 

in revising its submission. Written comments should be provided to the POTW 

to ensure clarity, perhaps by sending a copy of the checklist with an explanatory cover letter that outlines the submission’s inadequacies. The EPA 

Regional Offices have a number of guidance documents, such as the Preparation 

Manual, that contain information useful to a POTW developing its pretreatment 

program. These documents (or relevant portions of them) could be attached to 

the cover letter and sent to the POTW as additional assistance in program 

development. Appendix A lists several guidance documents relevant to program 

development. 

The agency’s review of a program submission should be complete before it 

is transmitted to the POTW. All comments and questions should be sent to the 

POTW at one time. The POTW should have a reasonable time period within which 

to respond to the comments. If better documentation only is needed to complete the submission, a few weeks will probably be sufficient. However, if 

major areas were not addressed (such as sampling and analysis, or local pollutant limits), as is often the case in first submissions, many months may be 

needed to develop the required information. 

l-3 
2. LEGAL AUTHORITY 

The ability to develop and implement a successful pretreatment program 

depends upon the existence of adequate legal authority. Since program implementation and control rest with local government, it is important that legal 

authority be present at this level, The POTW must be able to respond to 

challenges by industrial users, to protect its investment in the treatment 

plant, to ensure the beneficial uses of its waters, and to protect the health 

and welfare of its citizens. 

The legal authorities needed to implement a pretreatment program are 

listed in 40 CFR 403.8(f)(l). In summary, a POTW must be able to: 

• Deny or condition new or increased contributions of pollutants, or 

changes in the nature of the pollutants discharged to the POTW 

• Require compliance with applicable pretreatment standards and requirements by industrial users 

• Control, through permit, contract, or other means, the contribution to 

the POTW by each industrial user 

• Require the development of a compliance schedule by each industrial 

user, and the submission of all notices and self-monitoring reports as 

necessary to assure compliance 

• Carry out all inspection, surveillance, and monitoring procedures to 

determine compliance, independent of information supplied by the 

industrial user 

• Obtain remedies for noncompliance, including the ability to seek 

injunctive relief, seek civil or criminal penalties, and/or collect 

liquidated damages 

• Comply with the confidentiality requirements and limitations on data 

restrictions specified in 40 CFR 403.14. 

To document these authorities, the materials submitted by the POTW must 

include a statement from the city solicitor or comparable official, and copies 

of all pertinent statutes, ordinances, and related material. 

2-1 
Determining the adequacy of a POTW’s legal authorities requires a twopart review. First, the submission must be reviewed to ensure that it is 

complete. Second, if the submission is complete, the individual items must be 

reviewed in more detail to determine that the legal authorities are adequate. 

The checklist for evaluating legal authority is divided into two parts to 

facilitate this review. The remaining sections of this chapter explain how to 

use the checklist, and how to evaluate each of the items on the checklist. 

2.1 SUBMISSION COMPLETENESS 

2.1.1 Relevant Regulations 

40 CFR 403.9(b) identifies the information that must be submitted to 

document legal authority, including: 

1. A statement from the city solicitor or a city official acting in a 

comparable capacity (or the attorney for those POTWs which have independent legal counsel) that the POTW has authority to carry out the 

program. 

2. A copy of any statute, ordinance, regulation, contract, agreement, or 

other authority that will be relied upon by the POTW to administer 

the program. 

3. A statement reflecting the endorsement or approval of local boards or 

bodies responsible for supervising and/or funding the program. 

2.1.2 Evaluation of Completeness 

Part I of the Legal Authority Checklist is designed to evaluate completeness. The final pretreatment program submission should be reviewed to ensure 

that all of the items listed above are included. If they are not, the reviewer should notify the POTW that the submission is incomplete, noting the 

specific deficiencies. 

To determine that statements of all local boards/bodies are present, the 

reviewer may first refer to the organizational portion of the submission to 

identify the local boards/bodies involved in the program. It is also a good 

idea to check the technical information portion of the submission because data 

2-2 
from the Industrial waste survey, service area description, or maps might 

indicate participation by other jurisdictions. In several cases, a check of 

the letterhead has also identified other boards/bodies. 

Finally, if any of the legal authorities cited are discretionary on the 

part of an official, the reviewer should look for a statement endorsing the 

program by that official. While such an endorsement is not mandatory, it is 

highly desirable. This endorsement is separate and distinct from the *‘funding 

endorsement .” 

Having completed this review, the next and more difficult step is to 

review the adequacy of the documentation Itself. While the documentation may 

be complete, even extensive, the requisite legal authority may not be present. 

Conversely, legal authority may be adequate, but poorly documented due to a 

lack of understanding. 

2.2 EVALUATION OF ATTORNEY’S STATEMENT 

2.2.1 Relevant Regulations 

40 CFR 403.9(b)(l) requires a statement from the POTW attorney, city 

solicitor, or another city official acting in a comparable capacity. The 

individual who signs this letter should be the person who is responsible for 

bringing an enforcement action in court. An acceptable statement must 

identify; 

1. The provision of the legal authority under section 403.8(f)(l), which 

provides a basis for each procedure under section 403.8(f)(2) 

2. The manner in which the POTW will implement the program requirements 

set forth in section 403.8, including the means by which pretreatment 

standards will be applied to individual industrial users (e.g., by 

order, permit, ordinance, contract, etc .> 

3. How the POTW intends to ensure compliance with pretreatment standards 

and requirements and to enforce them in the event of noncompliance by 

industrial users. 

2-3 
It is important to keep In mind the following: 

l The statement must cite the provision of the POTW’s legal authority 

that fulfills each 403.8(f)(l) requirement, be it In the sewer use 

ordinance, city code, or some other document 

0 If the legal authority for each 403.8(f)(2) procedural requirement is 

not clear, the statement should elaborate on where the requisite 

authority lies 

l Whatever legal authorities exist in the permit, contract, etc., should 

also be cited 

l The statement must specify the legal remedies that will be used to 

ensure compliance with pretreatment standards and to enforce against 

violators. 

2.2.2 Evaluation of Statement 

Part I of the Legal Authority Checklist is also used to evaluate the 

attorney’s letter. In evaluating an attorney’s statement, look for evidence 

that the attorney understands the scope of the POTW’s pretreatment program. 

Three basic questions should be answered in the evaluation: 

(1) Does the statement identify the provision of legal authority for 

each procedural requirement under 403.8(f)(2)? 

The attorney’s letter must specifically refer to the basic statutory 

authority for the entire program (usually a provision in State law authorizing 

the municipality to enact certain local ordinances or to enter into contracts), and cite particular ordinance (or contract or permit) provisions for 

each authority listed in 403.8( f)( 1). Where this has not been done or where 

the cited provisions are found to be inadequate, the reviewer should note the 

insufficiencies and a letter asking for clarification should be sent to the 

attorney. Copies of this letter should also be sent to the POTW, EPA, and/or 

the State. Any clarification received should be reviewed for completeness and 

inserted into the submission package. 

(2) Does the statement identify the manner in which pretreatment program 

requirements of 403.8 will be implemented? 

The attorney must state the control mechanism(s) to be employed in 

applying pretreatment standards to industrial users. These include permits, 

2-4 
contracts, ordinance provisions, and orders, among others. Most attorneys’ 

statements will not contain a detailed listing of 403.8 procedures, and this 

is not necessary. A general description of the procedures and relevant control mechanism(s) is sufficfent-- provided the submission contains detailed 

descriptions elsewhere. Often, the attorney’s statement will simply refer to 

the appropriate portions of the submission. This is acceptable If the submission Itself is found to be adequate. If it is not, the attorney, POTU, and 

other parties (e.g., EPA, State) should be notified of the problem with the 

submission. 

(3) Does the statement identify how the POTW intends to ensure compliance? 

A detailed explanation of compliance procedures does not necessarily have 

to appear in the attorney’s statement as long as these procedures are described elsewhere in the submission. If the attorney’s statement refers to 

such a description or generally describes enforcement procedures that will be 

followed, this portion of the statement should be judged adequate. However, 

if enforcement is the responsibility of more than one jurisdiction, the statement must explain how the POTW will ensure that the other jurisdictions carry 

out their responsibilities, typically through a joint powers agreement (see 

Section 2.4, Multijurisdictional Submissions, if more information is needed or 

desired to make a determination). The statement should specify remedies 

available in the event such an agreement is breached. A letter from the 

attorney for each jurisdiction is required. 

2.3 LEGAL ADEQUACY 

2.3.1 Relevant Regulations 

The legal authorities required for a local pretreatment program are 

listed in 40 CFR 403.8(f)(l) and summarized in the introduction to this 

chapter (page 2-l). Each is discussed in turn below. 

2.3.2 Evaluation of Adequacy 

The reviewer should look first for a reference to the State law authorizing a municipality to enact an ordinance controlling use of the public sewer 

2-5 
system and treatment plant. In some situations, several municipalities may 

join in an agreement forming a new entity to operate and control a POTW and 

its users. The terms of such an agreement must be examined to determine the 

new entity’s powers and to ensure that State law authorizes these powers. 

Part II of the Legal Authority Checklist is used to assess the adequacy 

of the authorities available for a POTW’s pretreatment program. The required 

legal authorities may be contained in a sewer use ordinance, joint powers 

agreement, series of contracts, local regulations, or a combination of these 

documents. Pretreatment programs that include many jurisdictions must contain 

legal documentation from each participating jurisdiction. 

The submission must show that the POTW has authority to: 

(1) Deny or condition new or increased contributions 

A POTW must have the power to regulate the discharge of pollutants which 

may cause pass-through, interference, or sludge contamination problems, or may 

exceed Federal categorical standards. Any ordinance or other written manifestation that provides authority to effectively control such discharges by industrial users will satisfy this requirement. The reviewer should look for a 

general prohibition of unauthorized (unpermitted) discharges and the authority 

to deny or place conditions on discharges that change in character or volume 

(e.g., a permit that can be modified upon notice of changed discharges). It 

is recommended that a POTW require an industrial user to provide timely notice 

of any substantial change in the quantity or quality of its industrial waste 

discharge. 

(2) Require compliance with applicable pretreatment standards 

The POTW must be able to prohibit the Introduction of pollutants into the 

system which pass through or interfere with the operation or performance of 

the treatment works. To accomplish this, the POTW must be able to enforce: 

6 General prohibitions against Interference and pass-through 

l The five specific prohibitions listed under 403.5(b) 

2-6 
l Any local limits developed to implement the general and specific 

prohibitions 

l National categorical pretreatment standards as they are promulgated. 

The POTW must be able to require compliance with national categorical 

pretreatment standards as they are promulgated. This prohibition should be 

spelled out in the ordinance. The ordinance should explicitly reference 

Federal pretreatment regulations and standards as an indication that these 

standards have been fully incorporated and made enforceable by the ordinance. 

Since not all of the national categorical standards have been promulgated, it 

Is unlikely that a complete list of the standards will be included in an 

ordinance . Authority is adequate if the ordinance states that national 

categorical standards will apply to industrial users once such standards are 

promulgated, or that such standards will be imposed as a permit or contract 

condition. 

When operational problems arise, POTW officials must have the legal 

authority to impose or revise local effluent limits to correct the problem. 

Any generic authority to establish specific effluent limits is adequate. 

Ordinance language indicating that local effluent limits may be made more 

stringent than prevailing Federal standards in order to meet the POTW’s NPDES 

permit limitations or State water quality standards is recommended, but not 

required. 

Another operational problem that must be considered is sludge contamination, which often limits disposal options. This concern stems from the 

Federal pretreatment regulations which define a POTW interference to encompass 

any discharge that prevents sludge use or disposal in accordance with Federal, 

State, and local laws. Accordingly, either the ordinance definition of interference or effluent limits set in the ordinance should effectively prohibit 

discharges which prevent proper sludge use or disposal. 

Usually prohibited discharge standards are spelled out in an ordinance. 

If they are not, authority may be adequate so long as the prohibitions can and 

will be imposed as permit or contract conditions. General language is 

2-7 
sufficient for prohibited discharge standards. Numerical limits are not 

mandatory, for example, in defining explosive discharges. Since similar 

questions often arise in reviewing programs, a few special cases are discussed 

here for guidance. Where an industrial user end-of-pipe heat limitation is 

set at a temperature higher than 104’F (as is often the case), the POTW should 

demonstrate, as part of its technical submission, that the higher end-of-pipe 

heat limitation will not cause the treatment plant influent temperature to 

exceed the prohibited discharge standard of 104’F. In addition, it is 

preferred that the dilution prohibition and the accompanying authority to 

impose mass effluent limits be explicit in the POTW ordinance, and that these 

authorities be extended to noncategorical industrial users. 

Sometimes ordinances allow POTWs to establish special agreements with 

industrial users to accept industrial waste discharges which otherwise do not 

conform to effluent limits contained in the ordinance. Such provisions must 

not allow the waiver of national pretreatment standards. Local standards may 

be waived, but national pretreatment standards may not, unless such a waiver 

is granted by mechanisms established under the General Pretreatment Regulations (such as removal credits, fundamentally different factors variances, or 

net/gross calculations). 

(3) Control through permit, contract to ensure compliance 

The POTW must be able to control the discharge of each industrial user. 

This individual control can be accomplished by a permit that allows discharges 

conforming to the standards set forth or by contract where the POTW provides 

its services subject to agreed upon terms and conditions (similar to permit 

provisions). An order to an industrial user is another acceptable technique. 

Each of these approaches establishes a legal framework that controls the 

volume and constitutents discharged, and establishes penalties for noncompliante . 

For larger systems, the establishment of a discharge permit system to 

administer and enforce pretreatment standards and requirements is strongly 

recommended. It should be noted that the regulations imply the use of a 

2-8 
discharge permit, not a connection permit. A connection permit merely allows 

individuals to hook up to the sewer system, and is similar to a building 

license or construction permit. A discharge or sewer use permit regulates 

continuing use of the sewer system and imposes conditions on discharges to the 

system. Once adopted, a permitting mechanism should contain the followlng 

components : 

0 Permit application - used to collect pertinent data; often appended to 

final industrial discharge permit 

l Limited duration - preferably no more than five years; allows periodic 

review of discharge conditions 

l Non-transferability - any transfer of a discharge permit must, at a 

minimum, be subject to POTW approval 

l Modification - allows incorporation of categorical standards and any 

specific effluent limits necessary to correct operational problems at 

the POTW; useful in dealing with noncompliance 

l Conditions - conditions for discharge should be clearly stated in the 

discharge permit 

l Revocation - excellent enforcement tool; permit system can be used 

effectively to enforce against detrimental activities besides illegal 

waste discharges (e .g . , falsification of self-monitoring reports, 

tampering with monitoring equipment and methods, refusal to allow 

timely access to industrial premises, etc.). 

A discharge permit system should allow adequate flexibility in altering 

discharge conditions to correct any operational problems at the POTW or to 

reflect changes in environmental regulations. An industrial discharge permit 

should never grant excessive legal right to pollute, as may occur, for examde, if permits are issued for indefinite duration or made freely transferable 

without the need for POTW approval. 

(4)(a) Require development of compliance schedules for installation of 

technology 

A POTW must have the authority to establish and enforce deadlines for the 

installation by an industrial user of any treatment facilities needed to meet 

applicable pretreatment standards. “Compliance schedules” should either be 

2-9 
specifically mentioned in the ordinance or be imposed under some broad authority (e.g., permits). The authority to require installation of pretreatment 

technology and impose in a permit any conditions necessary to ensure compliance with the ordinance is adequate. These conditions should include time 

limits that ensure progress is being made in discrete steps. 

(4)(b) Require submission of notices and self-monitoring reports 

The POTW must be able to require the five reports listed in 403.12 and 

any reports listed separately as part of a categorical standard, including: 

l Baseline monitoring reports 

l Compliance schedule progress reports 

l Compliance report on categorical standards deadlines 

0 Periodic reports on continued compliance 

l Notice of slug loading. 

The reviewer should look in the ordinance (or contract) for either a detailed 

description of the reports or a provision stating that reporting will be required at a particular official’s discretion or as a permit condition. If the 

ordinance actually details what the reports wtll contain, the reviewer must 

ensure that the reports required by the ordinance meet the specifications 

listed in 403.12. 

A POTW must also have the authority to require industrial users to provide prompt notification upon the discharge of any slug load or accidental 

discharge which may contribute to an interference at the treatment plant. In 

addition, it is recommended that a POTW establish penalties for any action 

taken by an industrial user which affects the integrity of monitoring proce 

dures, such as falsifying self-monitoring reports or tampering with monitoring 

equipment and methods. 

(5) Carry out inspection, surveillance, and monitoring procedures 

A POTW must have the authority to enter industrial premises for the purposes of inspecting, sampling and monitoring industrial waste discharges, and 

2-10 
reviewing any records required to be kept onsite. POTW officials must be 

allowed to enter the premises at any reasonable time, not just during normal 

working hours. This additional flexibility may be necessary for handling 

emergency situations, suspected illegal nonwork hour discharges, and cases of 

suspected tampering with monitoring equipment. No language in a POTW ordinance shall require the POTW to afford prior notice of inspection, sampling, 

and monitoring activities. Although prior notice may be given to ensure 

cooperation, it is not always a good idea because it may enable the user to 

alter conditions being investigated. 

The checklist identifies several items that might be included in the 

right to inspect. It is not important for the ordinance to specifically list 

these things so long as they are permissible interpretations of a given 

authority. The reviewer should beware of any language limiting the right of 

an inspector to enter any premises where effluent sources, treatment systems, 

or records are located (e.g., process investigation restrictions or limitations on access to records). A POTW must also have the authority to require 

industrial users to install, use, and maintain monitoring equlpnent that enables effective self-monitoring by the industrial user and compliance monitoring by the POTW. 

(6)(a) Obtain remedies for noncompliance 

Two remedies for noncompliance must be available: injunctive relief, and 

civil or criminal penalties. An injunction may be necessary to prevent irreparable harm to the treatment plant, to the health and safety of plant workers 

and other individuals, or to the envlronment-- those situations where damages 

at law would not be an adequate remedy. Injunctive relief might not be specifically mentioned in the sewer use ordinance. It might still be available, 

however, as a matter of common law. In such a circumstance, the attorney 

should explain precisely how the POTW can seek injunctive relief. 

Where a POTW has police powers, it must establish the authority to 

enforce civil or criminal penalties against industrial users that violate 

pretreatment standards or requirements. An ordinance provision granting a 

2-11 
POTW the authority to impose a penalty or fine of at least $300/violation/day 

constitutes an adequate civil or criminal penalty for the purposes of this 

requirement. EPA regulations specify that, where State law does not permit a 

municipality to impose civil or criminal penalties, the municipality must 

enter into contracts that provide for liquidated damages for a violation of 

pretreatment standards and requtrements. This type of contract should be 

avoided if at all possible for two reasons. First, courts generally do not 

enforce penalty clauses in contracts. A liquidated damages clause is likely 

to be perceived as a penalty substitute and therefore held unenforceable. 

Second, even if the clause is held enforceable, most POTWs would not want to 

be limited in the amount recoverable for actual plant damages caused by an 

illegal discharge. The establishment of an administrative/adjudicative 

mechanism (e.g., show-cause hearing) to resolve conflicts between industrial 

users and the POTW Is also recommended. 

(6)(b) Authority to immediately and effectively halt or prevent any 

discharge 

A POTW must be able to halt immediately any actual or threatened discharge which may present an imminent or substantial endangerment to the health 

and welfare of persons or the environment, or cause interference with the 

treatment plant’s operation. An ordinance can provide this authority by 

allowing the POTW to suspend wastewater treatment service and/or discharge 

permits in such situations, and by requiring the discharger to immediately 

stop or eliminate the contribution upon notification of the suspension. The 

ordinance should further provide that if the discharger fails to comply voluntarily with a suspension order, the POTW may take any steps necessary, including severance of the sewer connection, to prevent further discharge. If 

the ordinance does not provide such authority, it may still be available as a 

valid exercise of police powers. The POTW attorney should explain emergency 

procedures in his statement. 

(7) Comply with confidentiality requirements 

While a POTW may establish procedures to protect confidential data, It 

must be able to release effluent data to the public. Effluent data as defined 

2-12 
in 40 CFR 2.302 must be available to the public without restriction. Effluent 

data include : 

l Information necessary to determine the identity, amount, frequency, 

concentration, temperature, or other characteristics of any pollutant 

discharged 

l A description of the manner or rate of operation of any source to the 

extent necessary to determine what was discharged under an applicable 

standard or limitation 

l A general description of the location and nature of the source to the 

extent necessary to distinguish it from others. 

Data or information on research, products, processes, and methods can be protected to a large extent and need only be released if necessary to disclose 

that a source is in or out of compliance or to allow a determination of feasibility/attainability of a standard or limitation. Information that is proprietary, a trade secret, or business confidential can be withheld provided it is 

not “effluent data” as defined above. 

2.4 MULTIJURISDICTIONAL SUBMISSIONS 

POTWs often serve more than one politlcal jurisdiction. In these 

instances, the agency or entity holding the NPDES permit for the discharge of 

municipal wastewater has primary responsibility to enforce pretreatment standards throughout the entire geographical area served by its conveyance and 

treatment system. A sufficient ordinance/resolution or regulation and 

pretreatment program must be in place for each industrial user within the 

treatment plant’s service area. 

This requirement may or may not present a problem, depending upon how the 

POTW is structured. If a special sewer district encompassing the entire 

service area has been created, and the sewer district has rulemaking authority 

sufficient to implement a centralized pretreatment program, there is no 

problem. The typical case, however, involves municipal POTWs which service 

industries lying beyond the municipal boundaries and thus beyond the reach of 

municipal ordinances. A mechanism to control the discharges of these 

industries should be established. In order to control the discharges of such 

2-13 
industries, there must be either: (1) an agreement between the POTW and the 

outlying jurisdiction where the industry is located (this agreement should 

specify that the outlying jurisdiction will enforce the POTW’s requirements or 

else allow the POTW itself to undertake enforcement); or (2) a contract 

between each industry and the POTW which conditions the industry’s receipt of 

sewer service upon compliance with the POTW’s requirements. 

It is recommended that the POTW and each outlying jurisdiction with a 

categorical or significant industrial user enter into an interjurisdtctional 

pretreatment agreement. This agreement should address the following: 

l Ordinance or regulation 

l Local discharge limit mechanism 

l Pretreatment program administration 

l Records transference 

l Inspection and sampling authority 

0 Enforcement. 

In its final pretreatment submission, the POTW should include: 

l The ordinance/resolution or regulation for each jurisdiction involved 

l The POTW’s pretreatment agreements with the contributing jurisdfctions. 

Each ordinance should be evaluated individually for the required legal authorities discussed in Section 2.3. It will be necessary for the reviewer to 

complete a Legal Authority Checklist for each jurisdiction served. 

2.5 LEGAL AUTHORITY CHECKLIST 

The Legal Authority Checklist (Worksheet 1) is divided into two parts. 

Part I is designed to cover submission completeness, while Part II covers 

legal adequacy. Roth parts reference the applicable sections of the Federal 

pretreatment regulations. 

2-14 
Worksheet 1 

Legal Authority Checklist 

Name of POTW 

Date 

Sect ion 

of POTW’ s 

Yes No Submission 

- - 

PART I. Submission Completeness Checklist (Legal Aspects) 

A. 40 CFR 403.9(b) requirements for submission: 

(1) Does the submission contain a statement from 

the city solicitor, POTW attorney, or other 

official? 

(2) Does the submission contain a copy of every 

legal authority source cited in the attorney’s 

statement or necessary for program implementation? (e.g., ordinances, contracts, statutes, 

joint agreements, permits, regulations, etc.) 

(3) Does the submission contain endorsements from 

all local boards/bodies responsible for supervising/funding the pretreatment program? 

*(4) If any of the legal authorities cited are vested 

in a particular official’s discretion, is there 

a statement of endorsement from such official? 

B. 40 CFR 403.9(b)(l) requirements for attorney’s 

statement: 

(1) Does the statement identify the provision of 

legal authority for each requirement under 

403.8(f)(2)? 

(2) Does the statement identify the manner in which 

403.8 program requirements will be implemented? 

(3) Does the statement identify how the POTW intends 

to ensure compl lance? 

c. If the POTW service area includes more than one 

agency, jurisdiction, government, or body, does the 

submission include all ordinances, resolutions, 

regulations, service agreements and other legal 

documents relevant to the analysis of multijurisdictional issues? (Use separate Part II forms 

for each jurisdiction.) 

PART II. Legal Adequacy [403.8(f)(l)] 

Does the POTW have the authority to: 

A. Deny or condition new or increased contributions of 

pollutants? [403.8(f)(l)(i)l 

B. Require compliance with applicable pretreatment 

standards? [403.8(f)(l)(ii)l 

(1) General prohibitions: pass-through, interference [403.5(a)] 

2-15 
Worksheet 1 

Legal Authority Checklist (Continued) 

Name of POTW 

Date 

Yes 

(2) Specific prohibitions [403.5(b)]: 

0 Fire/explosive hazard? 

l pH/corrosion? 

l Solid or viscous - obstruction/interference? 

0 Flow rate or concentration to cause interference? 

l Heat - treatment plant influent 40°C (104”F)? 

(3) Locally developed limits? [403.5(c) and (d)] 1 

(4) National categorical standards? 

[403.8(f)(l)(ii)l 

C. Control through permit, contract, etc., to ensure 

compl lance? [403.8(f)(l)(iii)] 

D. Require development of compliance schedules and 

submission of reports? ]403=8(f)(l)(iv)l 

(1) Development of compliance schedules for 

installation of technology? 

(2) Submission of notices and self-monitoring 

reports including 403.12 requirements (baseline 

report, compliance schedule progress report, 

report on final compliance with categorical 

pretreatment standards, periodic reports on 

continued compliance, notice of slug loading)? 

E. Carry out inspection, surveillance, and monitoring 

procedures: [403.8(f)(l)(v)] 

(1) Right to enter premises at any reasonable time? 

(2) Right t 0 inspect generally for compliance? 

(3) Right to sample? 

(4) Right to require installation of monitoring 

equipment? 

(5) Right to inspect and copy records [403.12(n)]? __ 

F. Remedies for non-compliance by industrial users? 

]403.8(f)(l)(vi)l 

(1) Obtain remedies for noncompliance: 

0 Injunctive relief? 

l Are the civil or criminal penalties sufficient - 

to bring about compliance, or act as a 

deterrent? 

(2) Halt Immediately and effectively any actual or 

threatened discharge? 

G. Comply with confidentiality requirements (protection 

of public access to effluent data)? [403.8(f)(l)(vii)] 

1403.14) 

Section 

of POTW’s 

No Submission - 

2-16 
Worksheet 1 Name of POTW 

Legal Authority Checklist (Continued) Date 

Sect ion 

of POTW’ s 

Yes No Submission 

- - 

H. Form special agreements (waivers) : 

(1) Does the ordinance contain a special agreement 

clause? - - 

(2) If yes, does this special agreement clause 

specifically exclude the waiver of Federal 

categorical pretreatment standards? - - 

I. Control extra-jurisdictional agencies, and industries 

which contribute industrial wastewaters to the POTW? - - 

*Indicates item is recommended, but not mandatory. 

I have reviewed this submission in detail and have determined the legal authority 

to be: 

( ) Adequate ( > Inadequate 

Date : Reviewed by: 

(Name) 

2-17 
3. TECHNICAL INFORMATION 

Sound technical information is necessary to develop and implement a successful pretreatment program. Although the information available to a POTW 

will increase and improve in accuracy once the pretreatment program is underway, the submission should contain sufficient, valid technical data to demonstrate that: 

• All industries discharging pollutants which may adversely impact the 

collection system or treatment works have been identified 

• The pretreatment program (particularly procedures) is designed to 

control the number and type of Industrial users discharging to the 

system 

• Local effluent limits are adequate to protect the POTW and enable 

compliance with its NPDES permit. 

Without this information, the ability to achieve the objectives of a pretreatment program may be questioned. 

This chapter focuses on evaluating the completeness and adequacy of the 

technical information upon which the local program is based. Two major elements will be assessed: (1) the industrial waste survey (IWS), the method by 

which a POTW gathers relevant data on its industrial users, and (2) the local 

effluent limits developed to prevent industrial discharges that might interfere with POTW operations or cause permit violations. A checklist is provided 

to assist the reviewer in determining the completeness and adequacy of the 

documentation provided in the submission. 

3.1 INDUSTRIAL WASTE SURVEY 

40 CFR 403.8(f)(2) requires a POTW to identify and locate all possible 

industrial users that might be subject to the pretreatment program and to 

identify the volume and character of pollutants discharged to the treatment 

plant. The objective of these requirements is to ensure that the pretreatment 

program includes those industries which can potentially cause pass-through, 

interference, or sludge contamination problems. The program submission must 

3-1 
demonstrate that these requirements have been met. A suggested method to 

gather this required information involves the following steps: 

• Develop a list of potential industrial users 

• Eliminate industrial users that are not problems 

• Survey remaining industrial users to gather pertinent data 

• Follow up as necessary to ensure adequate response 

• Compile and evaluate information collected. 

While variations from this generic approach are acceptable, most approvable 

submissions will Include these elements. 

3.1.1 Adequacy of the Survey Master List 

The pretreatment program submission should Include a master list of all 

industrial users discharging to the treatment plant. The sources used to 

develop this list should be documented, such as: 

• 

• 

• 

• 

• 

• 

• 

• 

Water use and billing records 

Sewer connection permits 

Business license records 

Chamber of Commerce rosters 

Local telephone directory 

Utility company records 

Property tax records 

Other standard listings of industrial firms. 

Lists based on current water use, sewer permits, and license records are 

usually very complete. If these are not available, several different sources 

may be needed to develop a comprehensive master list. In determining the 

adequacy of the sources, the reviewer should examine critically the type and 

number of sources used. A small POTW with few industrial users will often 

know its users well. In such a case, the sources used to develop the master 

list are not critical. However, for a large POTW, this would not necessarily 

be the case, and sources should be carefully reviewed. 

3-2 
Since the sources above may include insignificant industries, the POTW 

will often establish criteria for eliminating industries from the list. These 

critetia should be valid and should be documented in the pretreatment program 

submission. For example, valid criteria for exclusion could include: 

l A manufacturing operation which does not generate wastewater (dry 

manufacturing process) 

l A direct discharger 

l A discharger of sanitary wastewater only. 

In reviewing the exclusion rationale, it is important to determine which 

industries rere eliminated from the list and why they were eliminated. The 

reviewer should determine (based upon experience with similar operations) 

whether any of the eliminated industries might potentially affect the treatment plant. If this is the case, the POTW should he notified of the concern. 

3.1.2 Thoroughness of Survey Questionnaire 

The POTW should gather discharge information from all industries on its 

master list. The submission should identify the procedure used to gather 

information. This procedure might include : 

l Questionnaires mailed to industries 

l Telephone calls 

l Visits to industries 

0 Information already on file at POTW. 

The submission should also provide the date of the industrial waste survey. 

Survey information should be as current as possible, and preferably no more 

than three years old. 

St is satisfactory for a small POTW with few industries to use telephone 

calls or site visits to survey its industries. This is usually not feasible 

for a larger system with many industrial users. Most large POTWs use questionnaires to collect survey information. It is helpful for the submission to 

3-3 
include a copy of the questionnaire, although this is not required. If ineluded, the questionnaire should be reviewed to determine whether it requests 

sufficient information to establish a basis for local limits development and 

the compliance monitoring program. The questionnaire should be easy to read 

and understand. It should require the signature of an official authorized to 

sign for the company, as well as the name of a company representative who can 

be contacted by the POTW to arrange site visits for inspection and monitoring. 

Information requested from industrial users, whether by questionnaire, 

phone call, or visit, should be described. At a minimum, the following information must be requested: 

l Name of industry 

l Address of facility 

l SIC code(s) or expected classification 

l Wastewater flow (or water consumption rate if flow is not known) 

l Quantities and concentrations of pollutants discharged 

l Major products manufactured or services supplied 

l Description of onsite pretreatment facilities and practices. 

Although not required, it is recommended that the following information also 

be requested: 

0 Location6 of discharge points 

l Raw materials used or stored at the site 

l Flow diagram or sewer map for the indu6try 

l Description of current wastewater treatment practices 

l Number of employees 

l Operation and production schedules. 

A POTW which already has an existing pretreatment program may possess files 

containing information normally gathered by a survey. If the information is 

current and Includes both industrial classifications and pollutant concentration/quantitie6, an additional survey may not be needed. 

3-4 
3. I .3 Response to Survey 

The submission should describe the survey’s comprehensiveness by including the number and percentage of industrial users responding to the survey. 

It should also include a detailed description of follow-up procedures used to 

obtain information from industries which either failed to respond or returned 

Incomplete surveys. Follow-up measures would most likely include letters of 

reminder, telephone calls, and/or site visits. A response rate of less than 

80 percent will most likely hinder the establishment of an effective program. 

At lower rates, there would be less confidence in extrapolating survey results, since major classes of dischargers will probably be omitted or inappropriately represented. 

3.1.4 Completeness of Summary Information 

Unless the State or EPA specifically requests the inclusion of all 

responses to the industrial waste survey, it is not necessary that they be 

included in the submittal. It is usually more valuable to have the results of 

the survey summarized. Results should be tabulated in a format that includes 

the number of industries in specific SIC categories and the quantities of 

specific pollutants entering the POTW system. This format will enable the 

POTW to more easily identify industries which will be subject to categorical 

standards and industries discharging pollutants controlled by local standards. 

Appendix C provides the reviewer with information concerning the 25 categorical industries. Table C-l fndtcates which pollutants are commonly discharged from each category of industrtes. Table C-2 lists those categories or 

subcategories which have been excluded from regulation and Table C-3 contains 

a listing of SIC codes for industrtes affected by the categorical standards. 

The summary data should be reviewed to determine whether the POTW has 

full knowledge of the nature and extent of pollutant discharges affecting the 

plant. This summary should demonstrate that sufficient information is available to provide a sound foundation for all subsequent program development 

activities. 

3-5 
3.2 LOCAL EFFLUENT LIMITS 

40 CFR 403,5(c) requires the POTW to develop and enforce local effluent 

limits to ensure that: 

l Pollutants discharged by industrial users do not pass through or 

interfere with the operation and performance of the treatment plant 

l Prohibited discharges (i.e., heat, explosive/fire hazards, corrosive 

agents, etc.) are avoided. 

Local effluent limits must not be developed and enforced without providing 

individual notice and an opportunity to respond to any affected party requesting such notification. 

In order to demonstrate the adequacy of local limits, the program submission should include the technical information on which these limits are based. 

This information includes operation and maintenance data, a description of 

current sludge disposal practices, and the nature and extent of sampling 

activities. It is not adequate to adopt, without any rationale, literature 

values or values from other POTW ordinances as local limits. Unique characteristlcs at each POTW should preclude the uniform application of literature 

values. 

Furthermore, it is not acceptable to have a pretreatment submission without any numerical limits. A pretreatment program is not in force in the 

absence of limits, since limits supply the benchmark against which all noncompliance enforcement activities will be measured. Without specific limits, 

monitoring will have very little meaning since the POTW will have no way of 

knowtng whether a violation exists. If a violation does develop, there would 

be no basis for enforcement. As a result, limits on industrial pollutants, 

including those limtts that can be currently met by industry without any 

treatment or in-plant control, are a minimum requirement. 

The major steps toward establishing local effluent limits include: 

3-6 
l Identifying industrial pollutants entering the treatment system 

0 Identifying past POTW operating problems 

0 Sampling and analyzing to determine fate and effect 

l Developing numerical limits. 

The first step was discussed in Section 3.1. The remaining steps will be 

discussed in the following sections. The intent is to provide the reviewer 

with guidelines to ascertain the adequacy of the informatlon presented. 

3.2.1 Identification of Past POTW Operating Problems 

It Is important for the reviewer to determine whether the POTW has taken 

adequate steps to identify operating problems known or suspected to have been 

caused by industrial discharges. At a minimum, these steps would include a 

review of operating records to identify the frequency of treatment plant 

upsets and NPDES violations. The submittal should indicate the number and 

frequency of upsets, problems, or violations during a recent period (usually 

the past 18 months) and the probable cause of such Incidents. 

The submission should describe each known or suspected case of operating 

problems caused by an industrial discharge, such as: 

0 Reductions in removal efficiency 

l Degradation of the collection system facilities 

l Emergencies such as sewer plugging, excessive corrosion, unusual 

odors, explosion hazards, explosions or fires 

l Violation of NPDES permit conditions 

l Water quality degradation and fish kills at the POTW’s effluent discharge point 

l Sludge contamination. 

These descriptions should be sufficiently detailed to determine the cause of 

the problem (e.g., industrial discharge, equipment failure, or improper operation and maintenance), duration of the incident, magnitude of the damage done, 

3-7 
and corrective actions taken. In the case of permit violations, the specific 

parameter(s) violated should also be identified. 

Although prevention of sludge contamination is a major objective of the 

Federal regulations, this issue is often overLooked in preparing a local 

pretreatment program. The submission should include a description of the 

volume and characteristics of sludges produced at the treatment facility and 

discuss current methods of disposal. The impact Industrial contrlbutnrs have 

on current sludge disposal methods should be discussed, and any future disposal methods should be evaluated. The most stringent applicable standards, 

whether Federal, State, or local sludge pollutant limits (other than for 

conventionals), should be provided. 

If the program is for a new treatment plant, information on past performance will not be available. In this case, it is important to ensure that the 

POTW used the pollutant informatton obtained from its industrial waste survey 

to assess: (1) the treatment system’s tolerance for pollutants; (2) the 

effects of pollutants on proposed NPDES permit limits and/or on recetving 

water quality; and (3) the effect of these pollutants on the POTW’s sludge 

disposal options. 

3.2.2 Sampling and Analysis to Determine Fate and Effect 

The nature and extent of the POTW sampling program should be documented 

in the program submission. Often, POTWs sample and analyze inflllent and 

effluent quality for parameters such as BOD, TSS, pH, fecal coliform, temperature, flow, chlorine demand or residual chlorine, and dissolved oxygen. 

Sometimes, parameters such as COD, ammonia, total nitrogen, and total phosphorus are also measured. Based on a review of both industries discharging to 

the POTW and past operational problems, additional sampl Ing and analysis may 

be needed to quantify the extent of pollutant pass-through and sludge contamination, and to provide a basis for establishing local 1imlts. 

3-8 
Such a sampling program should be designed to obtain quantitative infotmation regarding the concentration, loads, and fluctuations of specific pollutants identified from the industrial waste survey. The program may include: 

l Sampling of significant industries to quantify industrial pollutant 

loading 

l Sampling of nonindustrial interceptors within the collection system to 

determine the background concentration and loading from nonindustrial 

sources 

l Scan of the POTW influent, effluent, and sludge for the 126 priority 

pollutants 

l Sampling within the treatment plant itself to determine, via mass 

balance calculation, the fate of the specific pollutants within the 

treatment plant, and to determine the areas within the system which 

are most heavily affected by the pollutants in question 

l Sampling and analysis of POTW sludge for priority pollutants when the 

POTW uses land spreading or ocean dumping for sludge disposal 

l Sampling and analysis of POTW sludge leachate when the POTW uses a 

sanitary landfill 

l Sampling and analysis of ash resulting from incineration of POTW 

sludge. 

In evaluating a pretreatment sampling program, the reviewer needs to 

determine if: 

l The appropriate pollutants were sampled 

l The appropriate sampling locations were chosen 

l The appropriate type of sampling was performed (composite or grab) 

l Sufficient samples were taken to acquire the necessary information to 

establish limits 

l The data are adequate to support the limit-setting process 

l The sampling and analysis procedures were adequate. 

3-9 
3.2.3 Development of Local Effluent Limits 

Local effluent limits must be established in the following cases: 

l If an industry is discharging pollutants which are harmful to the 

treatment system 

0 If categorical standards have not yet been promulgated for that 

industry 

0 If categorical standards are not sufficient to protect the treatment 

plant 

0 If significant industries are not covered by categorical standards. 

The program submission should explain the basis for deciding what local limits 

are required. The reviewer should determine if the need for local limits has 

been correctly assessed based upon information in the IWS, past operational 

problems, and any sampling results presented. 

The program submission should document the procedures used, or proposed 

to be used, to establish specific local limits. The procedures should have a 

strong scientific basis, and all industrial pollutants of concern should be 

covered. The reviewer should evaluate appropriateness, adequacy, and consistency with applicable national and State pretreatment standards. In no case 

can local limits be less stringent than existing national and State pretreatment standards for a given industry. 

The reviewer should also ascertain whether local limits are applied 

equitably among the industries discharging the regulated pollutants. Ideally, 

the limits should be technically and economically achievable. The criteria 

for “economic” and “technical” feasibility, if used, must be stated and be 

consistent with applicable Federal, State, and local laws. As a general rule, 

limits on specific pollutants should not be lower than the detection limits of 

currently available standard laboratory analytical techniques. Finally, the 

reviewer should check to see that the procedures used to develop limits, the 

data supporting the limits, and the rationale for the limits have been made 

3-10 
available to industrial users and other interested parties. These parties 

must also have been given the opportunity to review and comment on the limits. 

A general methodology for establishing local limits is presented in 

Appendix B. If the reviewer is unfamiliar with the establishment of such 

limitations, this Appendix may be useful in evaluating the methods and limits 

contained in the POTW’s submission. 

3-11 
Worksheet 2 

Technfcal Information Checklist 

Name of POTW 

Date 

PART I. Industrial Waste Survey [403.8(f)(2)(1) and (ii)] 

A. Were the sources used sufficient to assure that all 

major industrial users were identified and located? 

B. Were the criteria used to eliminate industries 

from the inventory appropriate? 

C. Survey Questionnaire 

(I) Did the POTW obtain the following information 

(either through the survey or other means): 

l Name? 

0 Address? 

0 SIC code(s) or expected classification? 

0 Wastewater flow rate or water consumption 

rate? 

l Loads and/or concentrations of pollutants 

in discharge? 

0 Major products manufactured or services 

suppl fed? 

** Residuals generated by IU’s disposal methods? 

*e Locations of discharge points? 

l Description of existing pretreatment 

facilities and practices? 

(2) Is the information current within the last 

3 years? 

*(3) Does the questionnaire require the signature 

of an authorized company representative? 

D. Fol Low-Up Procedures 

(1) Did the POTW follow up the questionnaire (with 

additional written requests, telephone calls 

or site visits) to obtain a complete and 

accurate response? 

E. Summary Informat ion 

(1) Were the users classified by industrial category 

and/or SIC code? 

(2) Has the POTW correctly characterized the waste 

discharged from each industrial user or 

industrial type? 

(3) Does the information obtained demonstrate 

sufficient characterization of the IU’s waste 

Yes 

Section 

of POTW’ s 

No Submission - 

discharges to the POTW? 

3-12 
Worksheet 2 

Technical Information Checklist (Continued) 

Name of POTW 

Date 

PART II. Methodology for Establishing Discharge Limitations 

A. POTW Operating Problems and Plant History 

(1) Did the POTW adequately document instances of: 

l Inhibition/upset? 

l Pass-through? 

l Sludge contamination? 

B. Developmental Sampling Program 

(1) Has the POTW recently sampled and analyzed: 

l Treatment plant influent? 

l Treatment plant unit operations? 

0 Plant effluent? 

l Sludge? 

*a Industrial effluents? 

(2) Did this analysis include pollutants of 

concern identified in the survey? 

(3) Were appropriate sampling locations chosen? 

0 In the treatment system? 

0 In the collection system? 

l At the industries? 

(4) Was the appropriate type of sampling performed 

for each pollutant type (composite or grab)? 

*(5> Was the sampling frequency sufficient to 

give an accurate characterization? 

c. Need for Locally Developed Discharge Limitations 

Sect ion 

of POTW’s 

Yes No Submission - - 

[403.5(c)] 

(1) Did the POTW assess whether or not pollutants are 

present in the influent in amounts that inhibit 

treatment processes used by the POTW? 

(2) Did the POTW assess whether or not toxic pollutants are present in the POTW effluent in 

amounts known to exceed water quality criteria? 

(3) Are sludge disposal methods acceptable in view - 

of pollutant load? 

D. Methodology for Setting Local Discharge Limits 

(refer to Appendix B) 

(1) Is the methodology appropriate? 

(2) Were relevant numbers used for: 

l Inhibition/upset concentrations? 

l Background concentrations? 

l Removal efficiencies? 

l Water quality criteria/standards? 

l Land application criteria? 

- e 

- - 

3-13 
Worksheet 2 Name of POTW 

Technical Information Checklist (Continued) Date 

Section 

of POTW’s 

Yes No Submission - - 

l Non-secured landfill disposal (including ash 

disposal)? - - 

E. Appropriateness of Locally Developed 

Discharge Limitations 

(1) Are local limitations at least as stringent as 

national pretreatment standards for the 

appropriate categories? 

(2) Do local limitations enable the POTW to meet 

NPDES permit limits? 

(3) Will State water quality standards be met once 

local discharge limits are complied with? 

(4) Will State sludge disposal guidelines/ 

regulations be complied with? 

F. Hultijurisdictional Submissions 

Were data from IUs and treatment plants in all 

jurisdictions considered in developing this 

technical information? - - 

*Indicates item is recommended, but not mandatory. 

I have reviewed this submission in detail and have determined the technical 

information to be: 

( ) Adequate ( ) Inadequate 

Date : Reviewed by: 

(N-e) 

3-14 
4. PROGRAM IMPLEMENTATION PROCEDURES 

Thorough and complete program implementation procedures are necessary 

components of a pretreatment program. The minimum procedures which must be 

documented in the pretreatment program submission are detailed in 40 CFR 

403.8(f)(2). A POTW must be able to: 

• Identify and locate all industrial users possibly subject to the pretreatment program 

• Identify the character and volume of pollutants discharged to the 

treatment works by these users 

• Notify industrial users of applicable standards and requirements 

• Receive and analyze self-monitoring reports and other notices from 

industrial users 

• Randomly sample and analyze industrial effluents 

• Investigate instances of noncompliance 

• Comply with public participation requirements. 

The procedures adopted by a POTW should be well thought out and easy to understand. They should be clear enough to be followed by all users, the public, 

and POTW staff members. Finally, the procedures should be flexible enough to 

allow reaction to day-to-day operating situations. In evaluating these procedures, the reviewer needs to determine whether they are complete and responsive to the Federal requirements outlined above, and whether they can be 

effectively implemented. 

The first two requirements have already been covered in Section 3.1, 

Industrial Waste Survey. Accordingly, this chapter will focus only on updating the IWS and on the remaining five procedures. As in earlier chapters, a 

checklist is provided at the chapter’s end. 

4.1 UPDATE THE INDUSTRIAL WASTE SURVEY 

To adequately implement the pretreatment program, information on industrial users should be updated on a regular basis. Up-to-date information is 

4-1 
essential not only for determining the nature and quantity of the waste 

entering the system, but also for scheduling pretreatment activities and 

allocating resources to meet changing program needs. The submission should 

include procedures for identifying and gathering information on new industries 

moving Into the POTW service area and for updating its existing user information base. There are various mechanisms through which new industrial users 

can be identified, including: 

• A requirement that new industries fill out applications for sewer use 

when they apply for business licenses 

• Communication with other city departments (water, utilities, health, 

and building departments) concerning new industries in the POTW service area 

• Continual review of business license records and/or other standard 

listings of industrial firms, such as Chamber of Commerce rosters or 

the telephone directory. 

In addition, the IWS should be updated on a continual basis. Several 

updating procedures are available, such as: 

• A permit system which requires notification of changes in industrial 

processes, wastewater discharges, or industry ownership 

• Ongoing POTW inspection and monitoring activities 

• Periodic expiration of permits and subsequent reapplication by permit 

holders 

• Periodic mailing of an IWS questionnaire to the industry accompanied 

by a request to update the information. 

4.2 NOTIFY INDUSTRIAL USERS OF APPLICABLE STANDARDS AND REQUIREMENTS 

The POTW is responsible for being up-to-date on all Federal pretreatment 

standards and applicable requirements under the Clean Water Act and Resource 

Conservation and Recovery Act. Such standards and requirements include: 

• Federal categorical standards 

• State standards 

4-2 
0 Local limits 

l Other pertinent requirements (e.g., user charges). 

A number of techniques are acceptable for obtaining current information 

on the status of national categorical standards. A POTW may assign a staff 

member to review the Federal Register or it may rely upon an attorney to perform this function. In some instances, the POTW may obtain the information 

from the State pretreatment coordinator, if the State provides such a service. 

Periodic requests or phone calls to State or EPA officials may also be sufficient. 

The POTW is also responsible for notifying any industrial user that may 

be affected by existing or newly promulgated standards and requirements. 

Ongoing procedures to do this should be identified in the program submission. 

Suitable procedures include: 

0 General mailing list 

0 Individual letters to industries 

l Permit/contract conditions 

l Permit/contract modifications 

l Published notices in newspapers, circulars, etc. 

If notification by mail is proposed, it is usually a good idea to require a 

signed acknowledgement of receipt to ensure that the notice has actually been 

received by the industry. Newspaper notices may be adequate if the notices 

appear in the same section of the paper on a fixed schedule (e.g., once a 

week), and if industrial users are informed of the location and time of 

publication. Permit and contract amendments are probably the best method of 

notification since acknowledgement is ensured when a company official signs 

the permit/contract. 

4.3 UNDERTAKE COMPLIANCE MONITORING PROCEDURES 

Self-monitoring, compl lance sampl ing , and noncompliance investigations 

are closely related. The first two activities determine an industrial user’s 

4-3 
compliance with pretreatment standards, limits, and other requirements. The 

third activity constitutes the POTW’s response to potential instances of 

noncompliance. All three involve sampling and analysis of industrial effluents and data analyses. Under self-monitoring, the sampling and analysis are 

performed by the industrial user’s staff or representative. Under compliance 

sampling and investigations, the work is carried out by the POTW’s staff or 

authorized representative. Investigatory sampling and analysis must be performed with sufficient care to produce evidence that is admissible in court, 

and thus, It is normally more rigorous than compliance sampling and analysis. 

4.3.1 Receive and Analyze Self-Monitoring Reports and Other Notices 

The program submisston must describe the POTW’s procedures for receiving, 

analyzing, and storing self-monitoring reports, compliance schedule reports, 

and other reports/notices submitted by industrial users. A systematic 

approach to managing the data collected from these sources should be evident. 

The system may be manual or computerized depending upon the POlW’s size and 

number of industrial users. The system should ensure that reports are 

received on time, reviewed by a technical specialist, and ultimately filed in 

a retrievable manner. The system should facilitate a comparison between 

discharge values reported by industrial self-monitoring or POTW compliance 

monitoring, and discharge limits specified in the industry’s permit or contract or in the municipal ordinance. 

Basic features of a workable system include: 

l A master list or log of expected reports during a specified time frame 

(monthly is sufftcient) 

l A procedure to enter date of receipt of each report (usually on the 

master list or log) 

0 A procedure to screen and compare reported values and compliance 

information with discharge standards and compliance schedules 

0 A procedure (if the screening is done by a non-technical person) to 

refer problem submissions to a technical specialist for more thorough 

evaluation 

4-4 
l A filing system to ensure that the data are retrievable and maintained 

for an appropriate period of time (three years or longer) 

l The ability to cross reference to permit, contract, and POTW monitoring files, if applicable. 

It Is also Important to ensure that the expected volume of reports can be 

handled by the proposed procedures. In addition, the submission should identify by title the individual responsible for evaluating self-monitoring and 

compliance schedule reports. 

4.3.2 Conduct Compliance Sampling and Analysis 

The submission must document and describe the POTW’s procedures for sampling and analyzing industrial effluents. Three basic types of compliance 

sampling and analysis are commonly used: 

0 Scheduled monitoring (sampling and analysis on a fixed schedule) 

l Random monitoring (sampling and analysis--scheduled or unscheduled-- 

that Is unannounced or performed with short notfce) 

l Demand monitoring (sampling and analysis triggered by an event such as 

a public complaint or an observed POTW operating problem). 

The reviewer should note that monitoring for billing purposes (e.g., surcharge 

for BOD or SS) Is not compliance monitoring. Compliance monitoring involves a 

comparison of actual discharge amounts to permitted discharge amounts. 

Although sometimes the two types of monitoring may be combined and conducted 

at the same time, monitoring for billing purposes alone is not sufficient to 

assess compliance. 

The regulations specifically call for program procedures to randomly 

sample and analyze industrial discharges to the treatment works. Random 

sampling is intended to ensure that collected samples are representative of 

actual operations. It is particularly useful when industries can easily and 

quickly alter their processes or operations to obtain more favorable results. 

The requirement for random sampling does not mean that the events cannot be 

scheduled. A POTW may schedule its random monitoring activities on a 

4-5 
quarterly, semi-annual, or even annual basis, provided It does not inform the 

industrial user of the specific time or day the sampling will take place far 

enough in advance to enable the user to alter its discharge. A limited amount 

of advance notice, such as providing indefinite information about the day or 

time of arrival, or telephoning the company representative just before arrival, is acceptable, and is often necessary to ensure access to the sampling 

point. 

Besides identifying the types of monitoring that the POTW will conduct, 

the submission should also include: 

l The minimum sampling frequency at each major industrial user (at least 

annually is necessary) 

l A list of industries, both categorical and noncategorical, that will 

be included in the random sampling program (major or significant users 

should be noted) 

0 The acttvities or events that will trigger the demand sampling program 

(e.g., upsets, inhibitions, public complaints). 

The reviewer should determine whether the sampling frequency assures reasonable coverage each year of all categorical and significant users. 

The frequency and type of sampling (grab, composite, or flow proportional) will vary depending on the type of industry, pollutants of concern, and 

resources available (e.g., manpower and equipment). Each submission should 

identify the sampling approach, frequency, and technique as well as the pollutants to be monitored for each group of industrial users. The program’s adequacy can be determined by comparing it with the results of the industrial 

waste survey. The reviewer should check that each industrial user that is or 

will be subject to national categorical standards will have its effluent monitored by the POTW at appropriate intervals. In addition, when an industrial 

user is known to discharge a priority pollutant in its wastewater, the POTW 

should sample and analyze for that pollutant. A list of priority pollutants 

usually present in the wastewaters of various industrial groups is included in 

Appendix C. POTWs will probably also monitor flow rates and measure 

4-6 
conventional pollutant parameters such as BOD, COD, TSS, pH, and others. 

Whether the samples obtained are grab samples, a grab sample series, or composite samples should also be identtfled. 

As part of this section’s review, the reviewer should evaluate the appropriateness of sampling procedures. Sampling procedures should conform with 

those described in the EPA NPDES Compliance Sampling Inspection Manual. 

Chain-of-custody procedures should be identified in the submission. 

The analysis of samples, as well as the sampling itself, may be performed 

in-house or under contract by a commercial laboratory, The submission should 

describe the analytical methods to be employed and the quality assurance program that will be followed. When samples from categorical industries are 

analyzed , the methods used must conform to those prescribed in the applicable 

categorical standard. Test procedures for other pollutants should conform to 

one of the standard analytical methods cited in Table I of 40 CFR 136, “Guidelines Establishing Test Procedure8 for the Analysis of Pollutants.” Other 

methods may be used only where they have been approved by the EPA Regional 

Administrator. Laboratory quality assurance procedures should conform to 

specifications contained In EPA’s Handbook for Analytical Quality Control in 

Water and Wastewater. Table C.4 in Appendix C lists the detection levels and 

approved EPA methodologies for analysis of the priority pollutants. If commercial laboratory services are to be used, the POTW should provide the name 

of the laboratory or a description of its criteria for selecting a laboratory. 

Official certification of the laboratory is normally a good thing for the POTW 

to require because the certification ensures that correct procedures and 

equipment are used and that the appropriately trained staff are employed. 

4.3.3 Investigate Noncompliance 

The pretreatment program submission must describe how the POTW will 

investigate instances of noncompliance. These methods should be capable of 

handling three types of situations: 

4-7 
l An emergency situation when the POTW must move immediately to halt an 

industrial discharge that “reasonably appears to present imminent 

endangerment to health or welfare of persons.” 

l A nonemergency situation when the POTW desires to halt or prevent a 

discharge which “presents or may present an endangerment to the environment or threatens to interfere with the POTW’s operation.” 

l A situation when an industrial user fails to comply with other pretreatment requirements, such as timely submission of reports, achlevement of compliance schedule milestone(s) , maintenance of sampling and 

pretreatment facilities, and maintenance of records. 

The information gathered should be admissible as evidence in enforcement proceedings or judicial actions. Thus, sampling and analysis, and other data 

collection activities should be conducted with a greater degree of care than 

would otherwise be required. 

Noncompliance investigation procedures may be detailed in the legal or 

procedural section of the program submission. If these procedures are discussed in the legal section (e.g., in the sewer use ordinance), the procedural 

section of the submission should cite the appropriate legal document. The 

procedures that will be used to investigate instances of noncompliance should 

include the following: 

l Establish criteria for classifying situations as emergencies 

l Notify industrial users of noncompliance incidents 

l Provide for Industry response to notification 

l Take actions to correct identified problems 

l Verify that violation has been corrected 

l Resort to legal recourse to obtain industrial compliance and/or allow 

industry to challenge POTW violation determination 

l Perform quick response sampling, analysis, and inspection in the event 

of emergency conditions such as fire, explosion, corrosive actlon, 

acute upset, or imminent danger to health and safety 

l Gather data so that it is admissible in court proceedings or other 

enforcement actions. 

4-8 
Informal notice of industrial user noncompliance usually involves 

letters, telegrams, telephone calls, meetings, and visits. It is always a 

good idea for the industrial user to acknowledge receipt of the notice. 

Formal notification methods tnclude cease and desist orders, injunctions, 

citations, and subpoenas. Industrial users can respond through letters, 

telephone calls, meetings, and show-cause hearings. 

To abate and control the problem discharge, the user may take corrective 

procedures, such as process change, installation of new treatment technology, 

improved operating practices, repair of faulty equipment, and termination of 

discharge. The time frame for correcting the violation which the POTW establishes should be flexible enough to cover both emergency and less severe 

situations. Under emergency cond t t ions, the POTW may need to terminate the 

discharge until other corrective measures are in place. The POTW should have 

this authority and provisions for using it. A nonemergency violation may be 

handled by modifying the permit, contract, or other provision. The POTW can 

verify corrective actions through certification by the industrial user that 

the violations has been corrected, increased self-monitoring requirements, and 

follow-up monitoring inspection by the POTW. While certification is acceptable for less serious violations, the POTW should verify corrective actions 

first-hand in serious cases. 

Because it is fmpossible to predict which actions will require legal 

proceedings, and because the integrity of data must be proved tf the case 

ultimately goes to trial, it should be assumed that any data collected during 

an investigation will end up in court. Thus, chain-of-custody and quality 

assurance provisions become important aspects of a POTW’s noncompliance investigation. The program submission should indicate that the POTW will follow 

proper chain-of-custody procedures. 

4.4 PUBLIC PARTICIPATION 

The pretreatment program submission must describe the procedures used by 

the POTW to ensure public participation in the program. Specific requirements 

include : 

4-9 
l Informing the public on the compliance status of industrial users 

0 Individual notice and comment on proposed local effluent limits 

l Public access to nonconfidential data and records. 

Although usually not required by Federal regulation, it is a good idea 

for the POTW to hold public meetings as it develops the local program. In 

situations where grant assistance is being provided, full-scale public participation (citizen advisory committees, public meetings, or public hearings) may 

be required. If meetings were held, the results of these meetings and the 

resolution of any issues should be documented in the submission in the form of 

summaries, verbatim transcripts, or by attaching meeting notes. A description 

of the attendees (i.e., number, groups represented) should be included. 

The POTU must publish, at least annually, a list of significant industrial violations in the largest local daily newspaper. A significant violation is one that: 

l Results in the exercise of emergency authority 

l Remains uncorrected 45 days after notice of noncompliance is given to 

the industrial user 

0 Involves failure to accurately report. 

The name of the newspaper should be specified and the frequency of publication 

stated. Information other than the name of the discharger may be included in 

the notice, although this is not required. 

The requirement for individual notice of local limits was mentioned 

earlier in Section 4.2. Since groups and individuals other than industrial 

users may request notice, it is important that the submission described procedures for accomplishing this notice. 

It is recommended that public access to nonconfidential information 

contained in the documents and records developed in the course of the program 

be provided. In this case, the submission should identify the steps taken by 

4-10 
the POIW to provide such public access. The location or office where interested people can go to read or copy docmcnts, permits (if a permit system is 

used) , and monitoring records should be specified. The local library, city/ 

town hall, public works office, or POTU are acceptable locations. The hours 

of operation should include convenient times for the public at large. These 

provisions should also allow the POTW to restrict access to confidential 

information about industrial mere. 

4-11 
Worksheet 3 Name of POTW 

Program Implementation Procedures Checklist Date 

Yes 

PART I. Updating the Industrial Waste Survey [403.8(f)(2)(1) 

and (ii)] 

A. Are procedures identified for updating (periodically) 

the waste survey information for existing users? 

B. Do procedures require new industries to supply 

discharge information or otherwise ensure that it 

will be collected? 

PART II. Notification of Appropriate Federal, State, and/or Local 

Standards or Limitations [403.8( f)(2)( iii)] 

A. Are there procedures for keeping abreast of existing 

and newly promulgated standards and requirements? 

B. Is there a mechanism to identify and notify 

industrial users of standards, limitations, or 

other requtrements? 

PART III. Receipt and Analysis of Self-Monitoring Reports and 

Other Notices [403.8(f)(2)(iv)] 

A. Are there procedures for determining what selfmonitortng and other reports are due? 

B. Are values reported by industries compared to 

discharge standards or compliance schedules? 

C. Are problems referred to appropriate authorities 

for technical evaluatton and follow-up? 

PART IV. POTW Compliance Sampling and Analysis [403.8(f)(2)(v)] 

A. Does the description of the monitoring program 

include procedures for periodic random sampling 

of significant tndustrial dischargers? 

B. Are sampling and monitoring parameters identified 

for each firm or group of industries? 

C. Is the POTW sampling for the significant pollutants 

identified by the Industrial Waste Survey or by the 

priority pollutant/industry matrix? (Appendix C) 

D. Do the sampling and monitoring procedures conform to 

EPA requirements? (40 CFR 136 ,“Standard Methods”) 

E. Is the frequency adequate to determine compliance 

independent of information supplied by IUs 

(at least annually)? 

No 

- 

Section 

of POTW’ E 

%hlliEEiOIl 

4-12 
Worksheet 3 Name of POTW 

Program Implementation Procedures Checklist (Continued) Date 

Section 

of POTW’E 

Yes No Submission 

- - 

PART V. Noncompliance Investigations and Enforcement 

[403.8(f)(2)(vi)l 

A. Are follorup activities described that include 

provision5 to: 

(1) Cover emergency situations? 

(2) Notify industrial users of violations? 

(3) Allow for response by industrial users? 

(4) Abate and control problem discharges? 

(5) Verify that corrective actions have worked? 

(6) Obtain compliance through legal means if 

necessary? 

(7) Assess penalties for noncompliance? 

B. Are procedures for quick response sampling and 

analysis included (demand sampling)? 

C. Are chain-of-custody and quality control provisions 

specified? 

PART VI. Public Participation 

A. Do procedures include at Least annual notice of 

violations published in local newspapers? 

[403.8(f)(2)(vii)] 

B. Is notice and opportunity to respond provided, both 

to the industrial users and the general public, on 

the process of developing local industrial 

effluent limitattons? [403.5(c)(3)] 

*c. Are program records available to the public? 

PART VII. Multijurisdictional Submissions 

A. Are there procedures to coordinate monitoring, 

enforcement, and implementation activities 

between the jurisdictions involved? 

B. Has the NPDES permit holder assumed lead 

responsibility in program implementation? 

*Indicates item is recommended, but not mandatory. 

I have reviewed this submission in detail and have determined the implementation 

procedures to be: 

L- > Adequate ( ) Inadequate 

Date : Reviewed by: 

(Name) 

4-13 
5. ORGANIZATION, STAFFING, EQUIPMENT, AND FUNDING 

The ability to develop and implement a successful pretreatment program 

depends upon a number of factors. The importance of legal authority, sound 

technical information, and proper procedures has already been discussed. This 

chapter focuses on needed resources and an organization to apply them efficiently and effectively. An acceptable submission will demonstrate that the 

POTW has: 

• A workable organization to integrate elements of the program 

• A staff of appropriate size and training to carry out program 

requirements 

• The necessary equipment to fulfill monitoring and other program needs 

• Adequate funds to support the proposed program. 

The above elements are closely interrelated, and all should be present in a 

successful program. 

While the level, type, and kind of resources will vary from program to 

program, it is possible to establish guidelines for use in evaluating the submission’s adequacy. This is the approach taken in this chapter. Rather than 

attempting to cover all possible solutions to the resources problem, each element is discussed generically. Key factors are identified, “rules of thumb” 

are provided for evaluating staffing and funding levels, and a framework for 

review is established. A checklist is provided to assist the reviewer. 

5.1 RELEVANT REGULATIONS 

40 CFR 403.8(f)(3) requires that the POTW have “sufficient” resources and 

qualified personnel to implement the authorities and procedures called for in 

the program. Although the regulations do not specify what is “sufficient,” 

they do require that the POTW submit certain items: 

• A brief description (including organization charts) of the POTW organization which will administer the program 

5-1 
• A description of funding levels and full- and part-time manpower 

available to implement the program. 

If more than one agency is responsible for administering the program, each 

agency must be identified. The responsibilities of each participating agency 

must also be delineated and procedures for coordination described in the submission. 

In some instances, a submission may indicate that certain equipment, 

staff, and/or funds are not yet available to carry out the program. Such a 

program can be approved conditionally pending the acquisition of complete 

funding, manpower, and/or equipment, provided that: 

• The inadequately supported aspect(s) of the program does not need to 

be implemented immediately 

• Adequate legal authority and procedures exist for the complete program, including the aspect(s) not being implemented immediately 

• The necessary resources will be available when such aspect(s) is 

implemented. 

This provision for conditional approval [40 CFR 403.9(c)] is designed to avoid 

the unnecessary costs that can result from acquiring and maintaining resources 

(particularly staff and equipment) before they are needed. 

5.2 EVALUATION OF ORGANIZATION AND STAFFING 

Organization and staffing requirements will vary according to the complexity and comprehensiveness of the local program. Whether the staff is 

large or small, it must be organized in a way that facilitates the successful 

completion of program responsibilities. The adequacy of the program’s organization and staffing is based not only on whether essential functions are 

covered, but also on whether the number and type of staff are appropriate to 

implement program requirements. The following elements should be evident in 

the submission: 

• Clear and appropriate lines of authority 

• Identification of staff responsibilities 

5-2 
l Qualifications of staff 

a Staffing levels related to required work effort 

l Coordination with other departments 

l Contract management (if required). 

5.2.1 Clear and Appropriate Lines of Authority 

A description of the POTW organization is needed, including the functional departments which will carry out the program. This description may 

include the titles and numbers of employees within each functional department, 

and the employees (or department) within the POTW that will coordinate with 

each service district in interjurisdictional programs. It is recommended that 

the functional departments identify services such as administration, engineering, sampling/inspection, laboratory analysis, legal work, accounting, and 

billing. 

A POTW must submit either an organization chart for the entire wastewater 

treatment program or a chart specifically structured for the pretreatment 

program. If the entire POTW organization is shown, notations on the chart or 

an accompanying text should indicate where pretreatment responsibility rests. 

In particular, responsibility for procedural functions such as notifying 

industrial users of applicable standards, receiving and reviewing selfmonitoring reports, conducting sampling and analysis of industrial effluents, 

and initiating enforcement actions should be clearly identified. If the 

pretreatment organization is provided, its relationship to the overall POTW 

organization is provided, its relationship to the overall POTW organization 

should be described. 

A variety of different organizational systems and structures are approvable. The key is to determine whether the proposed structure is workable. 

In evaluating the program’ s organization, the reviewer may ask the following 

queEtionE: 

l Are aUthOritie8 and responsibilities clearly designated? 

l Do supervisors have direct responsibility for the appropriate number 

of employees (usually no more than six or eight staff members)? 

5-3 
0 Is the program effectively integrated with the rest of the POTW’s 

activities? 

5.2.2 Identification of Staff Responsibilities 

Text accompanying the organization chart should identify the responsibilities and duties of each staff member or department involved in the program, including: 

l Technical assistance. A staff member or department should have the 

responsibility of evaluating data that industrial users supply on 

their IWS forms, self-monitoring reports, and compliance schedule 

reports. This person or department also should have responsibility 

for reviewlng results of POTW monitoring and sample analyses and for 

industrial inspections. 

0 Industrial monitoring. The submission should designate a staff member 

or department with responsibility for staffing and supervising fteld 

monitoring personnel. It should also specify the number and qualiftcations of personnel who will be assigned to the field monitoring 

crewt s) . 

l Laboratory analysis. As indicated earlier, a POTW may either perform 

its own sample analyses or contract with a commercial laboratory for 

analytical services. If the work is done in-house, laboratory support 

staff must be identified. 

0 Legal assistance. The person(s) providing legal assistance to the 

municipality will interpret regulations and other legal documents that 

affect pretreatment program operations and prepare contracts or other 

agreements. This person also will initiate formal legal actions 

against violators, including injuncttve relief when necessary. 

l Administration. The program administrator and administrative staff 

should have responsibility for data management, communicatton with 

IUs, program finances and accounting, personnel, and the public 

parttcipation program. 

A small POTW may have the same person performing the duties associated 

with one or more of these five general work areas, while a large POTW may have 

several people assigned to each functtonal group. In addition, a large POTW 

may wish to separate functions that are grouped together under administration. 

Responsibility for some of the work areas may be assigned to contractors or 

other local agencies, but all areas of work and corresponding staff should be 

identified in the submission. 

5-4 
5.2.3 Staff Qualifications 

The submission should Include the qualifications for all key staff positions. The qualifications of existing and proposed staff should be reviewed 

to ensure that they are appropriate for the position. While there are no 

rigid guidelines that apply, there are several factors that can be used to 

evaluate the adequacy of staff qualifications. The education and experience 

should match the functions to be performed. Sampling and analysis functions, 

for example, would normally be performed by a chemist experienced in effluent 

monitoring (preferably industrial). Tradeoffs between education and experience are acceptable, and certif.lcation in an appropriate discipline (e.g., 

professional engineer) is desirable, but not required. Key disciplines that 

one would expect to see are engineering (environmental, civil, sanitary, 

chemical), chemistry (organic, inorganic, physical, analytical), public 

administration, business administration, and law. 

5.2.4 Staffing Levels 

The level of staff needed to implement a program depends on the size of 

the treatment plant and the number of Industrial users regulated under the 

pretreatment program. Small POTWs with few industrial users may be able to 

implement a pretreatment program satisfactorily using only one or two personyears of effort. Large POTWs with many industrial users may need a pretreatment program staff with as many as 30 to 50 people, depending on the number of 

samples and measurements to be obtained, the frequency of monitoring, and the 

number and complexity of analyses to be performed. POTW staff requirements 

will also vary significantly if work is performed by outside personnel (e.g., 

contract support). These outside resources should be included when assessing 

the adequacy of staffing levels. 

A quantitative estimate of the level-of-effort, including outside 

support, should be provided in the submission for each staff position or 

function. Such estimates may be in the form of labor hours per year, personyears, or percent involvement of a person in pretreatment program activities. 

The amount of work required to perform necessary sampling and analysis, 

technical reviews, and administrative tasks should be compared to the proposed 

5-5 
staffing levels. Generalized estimates of personnel requirements as a function of POTW size and number of industrial users are shown in Table 5-l. More 

refined and detailed personnel estimates for a POTW having a flow of 5 mgd and 

10 industrial users are shown in Tables 5-2 and 5-3. These figures can be 

used to gauge the adequacy of staffing levels for individual functions, 

although they should not be treated as rtgid requirements. 

5.2.5 Coordination with Other Departments 

Interaction between groups within the pretreatment program and other POTW 

departments in order to facilitate the program’s smooth operation should be 

clear in the submission. A flow chart for routine program operations may be 

included. For example, the chart would show who receives and reviews selfmonitoring reports, what happens when the reports are acceptable, and what 

happens when they indicate violations. 

5.3 EVALUATION OF EQUIPMENT 

The major items of equipment necessary to implement a successful pretreatment program may include sampling gear, analytical instruments, vehicles, 

office furniture and accessories, and data processing devices. The type and 

amount of equipment needed will vary as a function of program size, complexity, and structure (i.e., contract or other outside services). The pretreatment program submission should list the major equipment to be used in the 

program, including any commercial services or outside capabilitles. This list 

should be reviewed for completeness and adequacy. At a minimum, the POTW 

should show that it has the capability to sample and analyze industrfal wastewaters for all pollutants of concern identified in the technical information 

section of the submission (e.g., metals, priority pollutants, or special 

pesticides). 

Some of the specific capabilities that the program submission should 

demonstrate include grab and flow composite sampling, gas and liquid chromatography , atomic absorption, and mass spectroscopy. The equipment needed may 

be available in-house or from external sources. It is a good idea for all 

analytical work to be performed by a certified laboratory to ensure the 

5-6 
TABLE 5-l 

POTW PRETREATMENT PROGRAM 

PERSONNEL REQUIREMENT RANGES 

Ranges presented in this table are estimates based on anticipated 

averages for typical programs. Individual program personnel requirements may 

vary significantly from the ranges shown here. 

POTW 

Flow Range 

(MGD) 

Relative Number of 

Indirect Dischargers 

5 small l-3 

large 2-5 

5-25 small 2-4 

large 4-8 

25-50 small 

large 

50 small 

large 

100 large 

Range of Personnel 

Requirements for 

Pretreatment Program 

4-6 

S-10 

6-8 

10-15 

15-50* 

*Special cases, such as large metropolitan systems, require more in-depth 

review. 

Source : Local Pretreatment Program Requirements and Guidance. 

Environmental Technology Consultants, Inc.: September 1979. 

5-7 
TABLE 5-2 

ESTIMATED POTU PERSONNEL REQUIREMENTS FOR A POTU 

PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES 

PO'lW AVERAGE DESIGN FLOW: 5 HCD 

NUMBER OF INDUSTRIAL USERS IN PROGRAM: 10 

PERSONNEL 

NUMBER 

REQUIRED 

I. Supervisor - For delegating the responslbllitlce 1 

and running the program 

2. Engineer - To review reports and assist the 1 

Supervisor 

3. Field Crew - To take samples and do all field 2 

investigations 

4. Laboratory - For analyzing samples part-time 

Technician 

5. Lawyer - For all legal action and proceedings part-time 

TOTAL FULL-TIME PERSONNEL REQUIRED 

-----e-e5.0 

5-8 
TABLE 5-3 

ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW 

PRETREATMENT PROGRAM BY PROGRAM ACTIVITY 

Estimates presented in this table are based on anticipated averages for typical programs. Individual program personnel requirements may vary significantly from the estimates shown here. 

POTW AVERAGE DESIGN FLOW: 5 MGD 

NUMBER OF INDUSTRIAL USERS IN PROGRAM: 10 

Program Activity 

1. 

2. 

3. 

4. 

1. 

2. 

3. 

4. 

5. 

Program Development 

Develop Pretreatment 

Program 

Conduct Industrial 

Waste Survey 

Determine POTW 

Removal Allowance 

Frequency of Workdays 

Activity per Number of per 

POTW or IU Activities Activity 

once 1 

once 1 1 

once2 1 

Review IU Pretreatment once 10 

Facility Proposal 

15-25 

15-25 

10-20 

0.5-2 

Total 

Workdays 

25 

25 

20 

20 

------------------------------------------------ 

TOTAL WORKDAYS - 93 

90 ; 220 WORKDAYS/PERSON/YEAR - .41 Person-years 

Program Operation 

Review IU Compliance 3lyear 30 0.5-l 30 

Schedule Reports 

Review IU Final Compli- once 10 0.5-2 20 

ante Schedule Report 

Review IU SelfMonitoring Report 

2lyear 20 0.1-0.5 10 

Sample IU 

(spot-check) 

l/year 10 2-4 40 

Investigate IU 

Non-compliance 

---- 5 l-5 25 

5-9 
TABLE 5-3 (Continued) 

ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW 

PRETREATMENT PROGRAM BY PROGRAM ACTIVITY 

Program Activity 

6. Administrative 

Enforcement Action 

7. Legal Enforcement 

Actions 

8. Comply with Public 

Notice Requirements 

9. Sample POTW Inf luent , 

Effluent, and Sludge 

Frequency of 

Activity per 

POTW or IU 

---- 

e--- 

l/year 

l/year 

10. Prepare Self-Monitoring 2/year 

Report for Approval 

Authority 

11. Laboratory Analysis l/year 

of Required Sampling 

Number of 

Activities 

3 

1 

1 

1 

2 

13 

Workdays 

per 

Activity 

3-10 

15-20 

l-3 

5-10 

5-10 

l-2 

Total 

Workdays 

30 

20 

3 

10 

20 

26 

-------------------------------------------------- 

TOTAL WORKDAYS = 234 

234 4 220 WORKDAYS/PERSON/YEAR = 1.06 Person-years 

I IWS is periodically updated during program impLementation procedures. 

2 Annual monitoring and reporting by the POTW is required during program 

implementation to maintain any removal credit allowance. 

Source: Local Pretreatment Program Requirements and Guidance. Environmental 

Technology Consultants, Inc.: September 1979. 

5-10 
quality of results. Other equipment that may or may not be necessary depending upon the size and complexity of the program includes vehicles for sampling 

and inspection, computer terminals, software and hardware for data reduction 

and analysis as well as for program administration, and office accessories, 

such as word processing, duplication, and productton devices. 

5.4 EVALUATION OF FUNDING 

An itemized estimate of pretreatment program costs must be included. The 

submission must contain either projected costs for the ftrst year of program 

operation or the actual costs for the most recent operating year if the pretreatment program was fully implemented in that year. These costs should be 

itemized in the following areas: 

l Labor (salaries, benefits) 

l Annualized capital costs 

l Operatfon and maintenance costs (travel, supplies, etc.) 

l Overhead (rent, phones, etc.) 

l Debt service 

l Other applicable costs. 

The submission should also provide an account of the revenue sources to 

be used to cover the annual costs of the pretreatment program. This account 

may be descriptive, or may be an itemization of each revenue source and 

amount. In addttion, a system for continuous revenue generation (e.g., user 

charges) should be discussed. It is helpful if the POTW submits its most 

recent annual financial statement showfng actual expenditures and revenues so 

that the reviewer can assess the POTW’s financial base. However, submitting 

the financial statement is not a Federal requirement. 

In reviewing the funding section of the submittal, it will be necessary 

to evaluate whether cost estimates are appropriate, and to determine whether 

costs will be adequately met by the proposed sources of revenue. Where shortfalls exist, the program may still be approvable if the inadequately funded 

5-11 
program element need not be implemented immediately and future funding will be 

available when needed. 

5.4.1 Implementation Costs 

A POTW program submission should provide an estimate of the annual cost 

of implementing its pretreatment program. The two types of costs Involved are 

capital costs and operating costs. The capital cost of purchasing equipment 

represents a single cash outlay, while labor, O&M, and the other items represent operating expenses that must be recovered yearly. Equipment may be 

purchased directly out of the POTW’s budget if sufficient reserve cash is 

available; its may also be financed or leased and then repaid annually as an 

ongoing cost in the operating budget. 

Capital Costs 

A major financial decision for a POTW implementing a program involves the 

procurement of samplfng and analysis equipment. A POTW has the choice of 

purchasing equipment, leasing equipment, contracting services, or any combination of these. Depending on the level of monitoring required for the program, 

a POTW should determine which of these options is the most cost-effective. It 

may be most feasible for small or medium-sized plants to buy equipment for 

sampling and conventional pollutant analyses, while using a commercial 

laboratory for metals and organics analyses. Larger POTWs, conducting more 

toxics analyses, may choose to buy equipment for full in-house capability. 

Since sampling/analysis equipment can be expensive to purchase and maintain, 

the POTW should determine what the impact of these costs would be on sewer and 

monitoring charges to industries and whether purchase is warranted. Typical 

costs for sampling and analysis equipment for nonconventional pollutants are 

shown in Table 5-4. Typical analytical costs of a commercial laboratory are 

shown in Table 5-5. 

Operating Costs 

Annual operating costs will generally be based on the level of effort 

estimated to conduct various tasks within the program. While the majority of 

operating costs may be attrlbuted to labor, other significant costs may result 

5-12 
EQUIPMENT PURCHASE PRICE 

TABLE 5-4 

TYPICAL EQUIPMENT FOR A TWO-MAN FIELD SAMPLING CREW 

- Van with two-way radio $12,000 

- Gas Detector 450 

- 2 self-contained breathing units 1,500 

- 4 portable samplers with bottles 8,200 

- 1 portable pH meter 800 

- 2 flow meters 3,000 

- Flumes and weirs 1,600 

- Velocity meter 600 

- Safety equipment 400 

- Miscellaneous tools and equipment 200 

TOTAL $28,750 

ADDITIONAL LABORATORY EQUIPMENT FOR SAMPLE ANALYSIS 

EQUIPMENT 

- Atomic absorption 

spectrometer (basic) 

- Supplies for AA 

- Gas chromatograph 

mass spectrometer (GC/MS) 

- Accessories and glassware 

for GC/HS (including a yearly 

service contract) 

ESTIMATED 

PURCHASE PRICE 

$ 25,000 

3,000 

120,000 

15,000 

- Reagents and other chemicals 15,000 

TOTAL $178,000 

Source: Odeal, Erwin J. "Economics of Local Pretreatment Program Administration." Proceedings: National Pretreatment Symposium. Duluth, 

Minnesota: August 22-24, 1979. Cost Information updated, 1983. 

5-13 
Parameter 

TABLE 5-5 

TYPICAL COMMERCIAL LABORATORY COSTS' 

Conventional Analysis 

Acidity/alkalinity $9 

BOD 

COD5 

20 

20 

Chloride 15 

Nitrogen (total) 20 

Oil 6 grease 20 

Suspended solids 8 

Toxics Analysis 

Metals (typical) 

Organics by GC 

Price per Analysis 

$10 - 18/metaL 

60/compound 

NPDES Analysis (scans) 

Base neutrals $350 

Acid extracts 200 

Pesticide/PCBs 225 

13 metals 300 

Total 126 Compounds 800-12002 

1 Based on 1983 estimated costs from commercial laboratories 

2 Includes $300 for asbestos 

5-14 
from equipment O&M, overhead, and debt repayment. For simplicity, some POTWs 

estimate labor hours for each program task and then convert these to total 

cost by multiplying by a gross factor that represents overhead and other 

costs. Table 5-6 lists program tasks and various factors affecting the level 

of effort for each. By combining labor costs with other direct and indirect 

costs ( the total annual budget for the program can be calculated. See Table 

5-7 for estimated operational costs of a POTW pretreatment program. 

5.4.2 Financing Sources and Cost Recovery Systems 

The means for recovering program costs should be presented in the 

submission. Major capital expenditures, such as equipment purchase, may be 

financed by municipal bonds or with surplus capital improvement revenues, if 

available. As mentioned earlier, leasing and contract services are viable 

options that avoid Large cash outlays. 

Continuous revenue sources from fees, charges, or interest are necessary 

to recover annual operating costs, which include debt service payments if 

loans are outstanding. Ideally, revenues should be generated from the industries serviced by the program in proportion to their relative use. However, 

any means of generating continuous revenues adequate to recover costs is 

acceptable. 

A cost allocation scheme should be used to recover pretreatment costs 

from various groups or classes of users according to some basis, such as monitoring. There are many types of charges or fees that may be used to generate 

revenues from users. The most appropriate types for a pretreatment program 

include a service or monitoring charge, an industry surcharge, and a pollutant 

strength surcharge. The POTW should choose a justifiable and equitable 

allocation basis when applying pretreatment charges to industrial users. 

5-15 
TABLE 5-6 

FACTORS AFFECTING POTU LEVELS OF EFFORT FOR 

PRETREATMENT PROGRAM OPERATING TASKS 

Activities Factors 

Sampling and Inspection -Total number of IUs 

-Frequency of sampling 

Laboratory Analysis -Number of samples 

-Type of analysis 

-Pollutants analyzed (i.e., toxics, 

conventionale, metals, etc.) 

Technical Assistance 

(including permitting 

process and report 

review) 

Legal Aeeietance 

Financial/ 

Administrative 

-Treatment plant capabilities 

-POTW lnfluent and effluent characteristics 

-Total number of IUs 

-Nmnber of IUs with pretreatment 

-Number and seriousness of violations 

-Availability of in-house counsel 

-Burden of proof created by ordinance 

-Total number of IUs 

-Frequency of monitoring 

-Size of service area 

5-16 
TABLE 5-7 

HYPOTHETICAL POTW PRETREATMENT PROGRAM OPERATIONAL COSTS’ 

Size of POTW 

Cost Component Small Medium Large 

(1) Sampling 6 Industrial Review 

Labor 

Non-Labor 

(2) Laboratory Analysis 

Labor 

Non-Labor 

(3) Technical Assistance 

Labor 

Non-Labor 

(4) Legal Assistance 

Labor 

Non-Labor 

(5) Program Administration 

TOTAL 

$13,500 

11,003 

2,500 

$28,000 

--- 

28,000 

0-a 

--- 

S 7,320 

--- 

--- 

$25,000 

$76,820 

S 26,000 

--- 

--- 

$ 51,000 

20,000 

31,000 

S 27,000 

0-e 

--- 

s 13,300 

--- 

0-e 

$ 28,000 

$142,300 

$ 47,000 

--- 

--- 

$105,000 

84,000 

21,000 

s 54,000 

--- 

e-e 

$ 36,000 

-mm 

mes 31,000 

$273,000 

------------------------------------------------------------------------------ 

1 Assumptions 

(1) Size is defined in terms of “significant” industrial users. Small is 

assumed to include 40, medium 130, and Large 300 industrial users. 

(2) Major metropolitan areas are excluded from this analysis. They are 

considered special cases and should be evaluated on an individual basis. 

(3) A 33% overhead rate is assumed for municipal employees. 

(4) Sampling &i Industrial Review. Small POTW: 1 person half-time, medium 

POTW: 2 persons half-time, large POTW: 2 persons full-time. 

(5) Laboratory Analysis. Small POTWs contract out all lab analysis. Medium 

size POTWs possess AA capabilities. Large POTWs possess both AA and 

GC-MS capabilities. 

(6) Technical Assistance. For small POTWs , this service is performed by the 

program manager who is accounted for in program administration. Assume 

senior and junior engineers part-time for medium-sized POTWs and fulltime for large POTWs. 

(7) Legal Assistance. Small POTWs obtain part-time assistance from municipal 

lawyer. Medium-sized POTWs use one-third time of in-house legal counsel. 

Large POTWs have one person full-time. 

(8) Program Administration. Includes program management and coordination as 

well as clerical support. 

Source : Odeal, Erwin J. "Assessing Administrative and Financial Needs of a 

Local POTW Pretreatment Program.” Proceedings : National Pretreatment Symposium. Duluth, Minnesota: August 22-24, 1979. 

5-17 
Worksheet 4 

Resources Checklist 

Name of POTW 

Date 

PART I. Organization and Staffing [403.8(f)(3) and 403.9(b)(3)] 

A. Is the description of the POTW organization clear 

and appropriate? 

B. Are mechanisms identified for delegating pretreatment 

tasks to other Local government agencies? 

C. Are personnel or positions identified that are 

responsible for: 

( 1) Technical review? 

(2) Monitoring? 

(3) Laboratory analysis? 

(4) Legal asststance and enforcement? 

(5) Administration? 

D. Have appropriate staffing levels been determined 

based on the program description? 

PART II. Equipment 

A. Does the POTW have adequate sampling equipment or 

other provisions to conduct necessary sampling? 

B. Does the POTW have adequate analytical capabiLities 

to perform analyses for: 

(1) Nutrlents and other nonconventlonals? 

(2) Metals? 

(3) Toxic organics? 

C. If not, are other arrangements made to do so 

(e.g., contract with private Laboratory, 

other agency)? 

PART III. Funding Estimates and Sources 

A. Does the POTW present an itemized estimate of pretreatment implementation costs? 

B. Is there an account of revenue sources that will 

cover the annual costs of the pretreatment program? 

Yes 

Section 

of POTW’s 

No Submission 

- 

5-18 
Worksheet 4 Name of POTW 

Resources Checklist (Continued) Date 

Section 

of POTW’s 

Yes No Submission 

- - 

PART IV. Multijurisdictional Submissions 

A. Does each jurisdiction participate in funding the 

pretreatment program? 

B. Are the relationships between the staff (personnel) 

of the participating jurisdictions adequately 

described and documented? - - 

I have reviewed this submission In detail and have determined the 

resources to be: 

( ) Adequate ( > Inadequate 

Date : Reviewed by : 

5-19 
APPENDICES 
APPENDIX A 

BIBLIOGRAPHY OF PRETREATMENT REFERENCES 
APPENDIX A 

BIBLIOGRAPHY OF PRETREATMENT REFERENCES 

Association of Metropolitan Sewerage Agencies, Pretreatment Resource Reader. 

Washington, DC: Association of Metropolitan Sewerage Agencies, 1982. (NTIS 

Order No. PB82-181629). 

Dyer, J., Feiler, H., and Bernick, A., Handbook of Industrial Waste 

Pretreatment (Water Management Series). New York: Garland Publishing, 

Inc., 1981. 

U.S. Environmental Protection Agency, Fate of Priority Pollutants in Publicly 

Owned Treatment Works, Volumes I and II (EPA Publication No. 440/1-82-303). 

Washington, DC: U.S. Environmental Protection Agency, September 1982. 

(NTIS Order NO. PB83-122788). 

U.S. Environmental Protection Agency, Guidance Manual for POTW Pretreatment 

Program Development. Washington, DC: U.S. Environmental Protection Agency, 

October 1983. 

U.S. Environmental Protection Agency, Handbook For Sampling and Sample 

Preservation of Water and Wastewater. (EPA Publication No. 600/4-82-029). 

Washington, DC: U.S. Environmental Protection Agency, September 1982, 

(NTIS Order NO. PB83-124503). 

U.S. Environmental Protection Agency, Industrial Residuals Manual, Volumes I, 

II, and III. Washington, DC: U.S. Environmental Protection Agency, 

November 1981. (Available from EPA Office of Water Enforcement and 

Permits). 

U.S. Environmental Protection Agency, Methods for Chemical Analysis of Water 

and Wastes. (EPA Publication No. 600/4-79-020). Washington, DC: U.S. 

Environmental Protection Agency, March 1979. (NTIS Order No. PB-297686). 

U.S. Environmental Protection Agency, Treatability Manual, Volumes I, II, III, 

IV, and V. (EPA Publication No. 600/8-80-042c). Washington, DC: U.S. 

Environmental Protection Agency, July 1980. (NTIS Order Nos. PB80-223050, 

PB80-223068, PB80-223076, PB80-223084, and PB80-223092). 

Water Pollution Control Federation, Industrial Wastewater Control Program for 

Municipal Agencies. Washington, DC: WPCF, 1982. (WPCF Order No. MOP 

OM-4). 

Water Pollution Control Federation, Joint Treatment of Industrial and 

Municipal Wastewaters. Washington, DC: WPCF, 1976. (WPCF Order No. 

M0021). 

Water Pollution Control Federation, Pretreatment of Industrial Wastes. 

Washington, DC: WPCF, 1981. (WPCF Order No. MOP FD-3). 

A-1 
Sources listed with an NTIS Order Number are available from: 

National Technical Information Service 

U.S. Department of Commerce 

5285 Port Royal Road 

Springfield, VA 22161 

Sources listed with a WPCF Order Number are available from: 

Water Pollution Control Federation 

2626 Pennsylvania Avenue, N.W. 

Washington, DC 20037 

A-2 
APPENDIX B 

DEVELOPMENT OF DISCHARGE LIMITATIONS 

TO CONTROL INCOMPATIBLE POLLUTANTS 
APPENDIX B 

DEVELOPMENT OF DISCHARGE LIMITATIONS 

TO CONTROL INCOMPATIBLE POLLUTANTS 

1.0 INTRODUCTION 

A critical part of a municipality’s task in developing a local pretreatment program is the development of defensible numerical effluent limitations 

for the discharge of incompatible pollutants. These limitations are often 

incorporated directly into a municipal ordinance or are applied through individual permits issued to nondomestic users of the sewerage system. Such limits are needed to enforce the prohibited discharge standards of the General 

Pretreatment Regulations and to implement the three fundamental objectives of 

the National Pretreatment Program: 

• To prevent the introduction of pollutants into the POTW which could 

interfere with its operation 

• To prevent the pass-through of untreated pollutants which could violate a POTW’s NPDES permit limitations and applicable water quality 

standards 

• To prevent the contamination of a POTW’s sludge which would limit 

selected sludge uses or disposal practices. 

Locally developed limits are also necessary in cases where categorical standards have not yet been promulgated for an industry, the industry is not 

covered by categorical standards, or categorical standards are not adequate to 

protect the municipal treatment plant, receiving stream, or sludge. 

This Appendix is intended to assist POTWs in calculating limits to implement these three objectives. The first section of the Appendix outlines the 

general methodology for determining allowable pollutant loadings, choosing the 

appropriate level of protection, and allocating these loadings to dischargers. 

Sections 2, 3, and 4 present equations and guideline data that can be used to 

calculate the limiting pollutant concentrations at the influent of the municipal treatment plant which will protect the wastewater treatment processes, the 

receiving water, and sludge disposal options. Section 5 discusses 

B-1 
considerations for allocation of pollutant loadings to individual industrial 

users. Section 6 demonstrates the calculation of a discharge limit for one 

pollutant, copper, using a hypothetical example. 

The methodology described here for determining allowable influent concentrations and setting industrial effluent limits is widely known and accepted. 

The basis for some of the material that appears in this Appendix is a document 

originally prepared by the State of Indiana and the EPA Region V Office. The 

original document has been reorganized and expanded to facilitate a better 

understanding of the material. 

1.1 GENERAL METHODOLOGY 

An incompatible pollutant’s effect on a POTW must be evaluated simultaneously from three perspectives -- impact on the treatment plant, impact on 

the receiving water, and impact on sludge described above. The limit for that 

pollutant can then be set to ensure that all pretreatment program objectives 

are met. It should be pointed out that the limiting factor which meets the 

most restrictive of the three objectives may vary from pollutant to pollutant. 

For example, at a particular POTW, constraints on the land application of 

sludge may limit the allowable influent concentration of cadmium, while the 

effects on the receiving water may limit the influent concentration of copper. 

The hypothetical example provided at the end of this document will demonstrate 

the effect of these limiting factors on the influent pollutant limit for 

copper. 

As a general procedure, influent concentration limits should be calculated for a particular pollutant based on each of the three factors (i.e., 

treatment processes, water quality, and sludge). The most stringent of the 

three will determine the influent limit to be used for that pollutant. The 

POTW will then have to translate that influent limit into discharge limits for 

its industrial users that discharge the pollutant into its sewage system. 

Although this document provides some specific data on only cyanide and 

nine metallic pollutants, a POTW may receive other industrial pollutants with 

B-2 
toxic characteristics. Industrial waste surveys and/or POTW sampling, if done 

properly, should identify the existence of such pollutants. Calculation of 

limits for such pollutants would follow the same general methodology discussed 

in this Appendix, although inhibition and removal data would have to be developed from other sources. It should be noted that this methodology does not 

account for any cumulative, synergistic, or antagonistic effects that may 

occur when several toxic pollutants are present simultaneously. Figure 1 

shows an overview of the steps used in developing pollutant discharge limitations. Table 1 presents the two basic formulae used to determine local diacharge limitations. The back calculation formula is used to calculate allowable POTW influent concentrations based on threshold concentrations from 

various in-plant criteria. The mass conversion formula allows for the determination of a mass loading (in lbs/day) if the flow and concentration of the 

wastewater are known. 

B-3 
FIGURE 1 

Activated 

Sludge 

1. Determine 

Inhibitory 

Concentration 

Value 

2. Calculate 

Inf luent 

Concentration 

that Is not 

Inhibitory 

to this Process 

BASIC STEPS IN DEVELOPING 

POLLUTANT DISCHARGE LIMITATIONS 

Influent to POTW 

NPDES 

Anaerobic Limitations or 

Dige8tiOn Water Quality Standards 

1. Determine 

Inhibitory 

Concentration 

Value 

2. Calculate 

Influent 

Concentration 

that is not 

Inhibitory 

to this Process 

1. Calculate 

Influent 

Concentration 

which will 

allow POTW to 

comply with 

its NPDES 

permit and/or 

protect water 

quality 

v Select Most 

Stringent Value 

v 

Calculate Load 

Available for Industrial 

Disch?rgers 

Sludge 

Disposal 

1. Determine 

Sludge Disposal 

Method 

2. Calculate 

Influent 

Concentration that 

will allow Disposal 

Option 

Allocate'Load to 

Industries By 

Permit or Order 

B-4 
TABLE 1 

BACK CALCULATION FORMULA 

Ll Lp- - 1-Ep 

Where: Lp - Allowable POTW influent concentration (in mg/l> 

Li - Threshold concentration for the appropriate unit operation or 

appropriate permit limitation (in mg/l) 

RP = Reduction in upstream unit processes (expressed as a decimal) 

MASS CONVERSION FORMULA 

L- Q x C x 8.34 

Where: L - Mass loading (in lbs/day) 

Q = Wastewater flow (in MCD) 

c = Concentration (in s&l) 

8.34 - Conversion factor ($$%D)) 

B-5 
2.0 PREVENTION OF INHIBITION OF TREATMENT PROCESSES 

One of the primary objectives of the National Pretreatment Program is to 

prevent the discharge to a POTW of incompatible pollutants that would interfere with or inhibit the POTW’s operation. In the case of cyanides, “heavy” 

metals, and other toxic pollutants, treatment plant upsets could result If the 

pollutant’s toxicity is great enough to inhibit the microbial activity of the 

biological treatment system and cause a decrease in the pollution removal 

efficiency of the municipal treatment facility. Pollutant discharge limits 

should be set to maintain the concentration of each toxic pollutant below the 

inhibition threshold of the treatment unit. 

2.1 ACTIVATED SLUDCE PROCESS 

To calculate a discharge limit that will prevent inhibition of an activated sludge process, it is necessary to determine if an inhibition or upset 

condition exists. This determination can be made by examining POTW operating 

records for disruptions or changes (e.g., settling characteristics of secondary sludge, bacterial species populations in the mixed liquor of the aeration 

basin, etc.). If, after examining various operating parameters, no inhibition 

or upset conditions can be found, but a POTW protection criteria is desired, 

current levels of pollutants of concern should be used as threshold concentrations to determine maximum allowable influent loadings based on prevention of 

activated sludge inhibition. If, however, inhibition or upset conditions are 

found, the POTW must first determine the concentration of each pollutant of 

concern entering the activated sludge process. Care should be taken to 

include all recycle and return lines which may be sources of these pollutants, 

e.g., return activated sludge (RAS). 

After this concentration has been determined, it should be compared with 

various inhibitory concentration values that can be found in the technical 

literature. Table 2 lists threshold concentrations for inhibitory effects of 

several metallic pollutants and cyanide on activated sludge processes, nitrification processes, and anaerobic sludge digestion. These inhibitory values 

are taken from technical literature and the experience of States and municipalities. 

B-6 
TABLE 2 

THRESHOLD CONCENTRATIONS* OF TOXIC POLLUTANTS 

THAT COULD INHIBIT BIOLOGICAL TREATMENT PROCESSES 

Toxic 

Pollutant 

Arsenic 

Cadmium 

Chromium (total) 

Chromium (hex) 

Copper 

Cyanide 

Lead 

Mercury 

Nickel 

Zinc 

Threshold of 

Inhibitory Effect 

on Activated Sludge 

0.05 mg/l 

1.0 mg/l 

10.0 mg/l 

1.0 mg/l 

1.0 mg/l 

0.1 mg/l 

0.1 mg/l 

0.1 mg/l 

1.0 mg/l 

1.0 mg/l 

Threshold of 

Inhibitory Effect 

on Nitrification 

--- 

-em 

-- 

--- 

0.1 mg/l 

0.5 mg/l 

0.5 mg/l 

--- 

0.5 mg/l 

0.1 mg/l 

Threshold of 

Inhibitory Effect 

on Anaerobic 

Sludge Digestion 

1.5 mg/l 

0.02 mg/l 

100.0 mg/l 

50.0 mg/l 

10.0 mg/l 

4.0 mg/l 

--- 

--- 

10.0 mg/l 

20.0 mg/l 

*Concentrations are specified at influent of the unit process in dissolved 

form. 

References: (l), (3), and (5) 

B-7 
Some qualificattons to the data in Table 2 should be noted. The concentrations reported in Table 2 are for the dissolved form of each metal and 

should be used only for comparison purposes and preliminary calculations if 

the actual proportion of dissolved to total metal is unknown. In addition, 

concentrations reported in this table reflect the minimum concentration which 

showed an inhibitory effect for all bench-scale and full-scale studies regardless of test conditions. The result is that many of the values are contradictory, with the same concentratton having no inhibitory effects, some 

inhibitory effects, or total upset effects. Thus, in using the data in Table 

2, it should be noted that these inhibitory concentrations are not absolute 

and all other possibilities should be examined prior to adopting a value from 

this table as a threshold concentration. 

Using an established threshold concentration, a maximum allowable influent concentration to the POTW (Lp) is calculated for each pollutant of concern 

using the back calculation formula from Table 1, as follows: 

Where: Lp = Maximum allowable influent concentration to the POTW (in 

mg/l) 

Li = Established threshold concentration for the pollutant of 

concern (in mg/l) 

RP = Reduction of the pollutant of concern through the primary 

treatment processes (expressed as a decimal) 

Table 3 presents typical removal rates through primary and secondary 

treatment processes for several metals, but should only be used for comparison 

purposes and preliminary calculations. Plant-specific data are more valid and 

should always be used by the POTW for final calculations. 

If, after maximum allowable influent concentrations have been calculated 

for all possible in-plant criteria, the activated sludge is selected as a 

controlling in-plant criteria (i.e., having the lowest maximum allowable 

influent concentration), the maximum allowable influent concentration for 

B-8 
TABLE 3 

Toxic 

Pollutant 

Cadmium 

Chromic 

Copper 

Cyanide 

Lead 

Mercury 

Nickel 

Zinc 

TYPICAL POTU REMOVAL RATES 

FOR INCOMPATIBLE POLLUTANTS 

Percent Removal Percent Removal Through 

Through Primary Treatment Primary and Secondary Units 

Median Value' 

7 

16 

18 

20 

22 

6 

26 

Median Value' 

50 

71 

82 

56 

57 

51 

32 

76 

1 Reference: (1) 

2 Reference: (2) 

B-9 
sludge is converted to a mass loading (L) prior to the allocation procedure 

(see Section 5.01, using the mass conversion formula from Table 1 as follows: 

L= Q x C x 8.34 

Where : L = Maximum allowable mass loading to the POTW (In lbs/day) 

Q = Design flow (in MGD) of the POTW 

C = Maximum allowable influent concentration (in mg/l) 

8.34 = Conversion factor 

2.2 ANAEROBIC DLGESTION 

To calculate a discharge limit that will prevent inhibition of anaerobic 

sludge digestion, the same basic procedure utilized for the activated sludge 

process is followed. First, it must be determined if an inhibition or upset 

condition exists by examining POTW operation records for disruption or changes 

in such operating parameters as digester supernatant volume and methane gas 

production. If no Inhibition or upset conditions are found, a POTW can adopt 

current concentration levels of pollutants of concern entering the digestor as 

threshold concentrations, if a POTW protection criteria is desired. If an 

inhibition condltlon does exist, the POTW must determine the concentration of 

the pollutant of concern entering the digester, and only then compare the 

actual value to the data contained in Table 2, being sure to take Into account 

all limitations of these literature data. 

After establishing a threshold concentration, the POTW must determine the 

maximum allowable mass loading to the digester, using the mass conversion 

formula , as follows: 

L=QxC x x 8.34 

Where : L = Maximum mass loading to the digestor (in lbs/day) 

Q = Sludge flow to the digester (in MGD) 

cX - Established threshold concentration for the anaerobic 

digestion process (in mg/l> 

8.34 = Conversion factor 

B-10 
After a maximum allowable loading to the digester is determined, the maximum allowable influent concentration to the POTW (C) is calculated, using 

another form of the mass conversion formula, as follows: 

C= L 

Q x 8.34 

Where: C = Maximum allowable influent concentration (in mg/l) 

L = Maximum allowable mass loading to digester (in lbs/day) 

Q = Design wastewater flow of the POTW (in MGD) 

8.34 = Conversion factor 

However, the amount of a pollutant of concern in the sludge is llmited by 

the amount of pollutant removed from the wastewater. In the case of metals, 

all metals removed from the wastewater are generally deposited in the sludge. 

Therefore, the maximum allowable influent concentration for metals must be 

adjusted for the amount of metals which remain in the final effluent as 

follows: 

Where: c* = Adjusted maximum allowable influent concentration (in mg/l) 

C = Unadjusted maximum allowable influent concentration (in 

w/l) 

Ep = Reduction of pollutant of concern through the entire POTW 

(expressed as a decimal) 

The fi.nal result is that the POTW maximum allowable influent concentration is allowed to increase by a factor of (1-Ep) to account for the pollutant 

of concern (metal) in the final effluent. For other types of pollutants, 

other removal mechanisms such as air stripping of volatile pollutants (which 

would reduce the amount of pollutant in the sludge) must be similarly considered. Assuming that anaerobic digestion is selected as the controlling 

In-plant criteria, the adjusted maximum allowable influent concentration to 

the POTW is converted to a mass loading prior to the allocation procedure. 

B-11 
This is performed using the mass conversion formula found in Table 1 as 

follows: 

L=Q x c* X 8.34 

Where: L = Maximum allowable influent mass loading (in lbs/day) 

Q = Design wastewater flow of POTW (in MGD) 

CI = Adjusted maximum allowable influent concentration (in mg/l) 

8.34 = Conversion factor 

B-12 
3.0 PREVENTION OF POLLUTANT PASS-THROUGH 

The second objective of the National Pretreatment Program is to prevent 

the pass-through of incompatible pollutants, which could violate a POTW’s 

NPDES permit requirements and applicable water quality standards. Two procedures are presented below. The first assists the POTW in developing pollutant 

discharge limits to ensure that NPDES permit limitations or any applicable 

State or local discharge limits are not violated. The second provides the 

POTW with a methodology for developing pollutant discharge limits to protect 

water quality criteria if desired, in the absence of specific national, State, 

or local discharge limitations. 

3.1 COMPLIANCE WITH THE POTW NPDES PERMIT 

There is only a single step involved in determining the maximum allor 

able influent concentration to the POTW required for that POTW to comply with 

its NPDES permit requirement for a particular pollutant of concern. Using the 

back calculation formula, the maximum allowable influent concentration is 

determined as follows: 

Li Lp - - 1-Ep 

Where: Lp = Maximum allowable influent concentration (in mg/l) 

Li = NPDES permit limitation for the pollutant of concern 

(in mg/l) 

EP = Reduction of pollutant of concern through the entire 

POTW (expressed as a decimal) 

If the NPDES compliance in-plant criteria controls, the maximum allowable 

influent concentration is converted to a mass loading prior to the allocation 

procedure, as shown in previous sections. 

3.2 PROTECTION OF RECEIVING STREAM’S WATER QUALITY 

EPA and State publications contain information on the effects of toxic 

pollutants on receiving water quality. The main problems caused by toxic 

pollutants are the restriction of domestic and industrial uses of surface 

B-13 
water, toxicity to aquatic organisms, and the accumulation of toxics in the 

food chain. Also, there has been recent concern about trace organics that are 

carcinogenic to humans. For these reasons, a POTW can, in the absence of specific toxic pollutant effluent discharge limitations, develop specific local 

discharge limitations to protect the receiving stream’s quality by using 

established national water quality criteria. However, it should be noted that 

the establishment of water quality standards for a particular receiving stream 

is the responsibility of the NPDES authority and the POTW is under no obligation to develop these standards. In addition, any effluent discharge limitations based on water quality criteria that are developed by a POTW would still 

be subject to revision by the NPDES authority and would require corresponding 

revisions to a POTW’s local discharge limitations. 

Exhibit A summarizes water qualtty criterta for 21 priority pollutants 

contained in EPA’s Ambient Water Quality Criteria, Series (l), as published in 

the November 28, 1980, Federal Register. These new criteria have replaced 

those formerly established in the 1976 edition of Quality Crtteria for Water 

(the “Red Book”). The criteria were derived by using “guidelines,” which, 

theoretically, would ensure protection of aquatic health and human health. 

Offictally, the criteria are only recommended values; they are not enforceable 

as water quality standards. However, they do provide useful documentation in 

the interpretatton of State water quality standards. 

To calculate the maximum allowable pollutant loading to the POTW’s treatment plants that will protect the receiving water quality from degradation, 

the POTW has to determine the in-stream water quality standard (Cwq) for the 

pollutant of tnterest. This may be available from the State water qualtty 

agency. Otherwise, data from Exhibit A may need to he used even though they 

are not speciftc and may be too strtngent. The maximum allowable pollutant 

concentration in the POTW’s effluent (Ceff) can then he calculated, taking 

tnto account the dilution factor of the receiving stream, as follows: 

C eff p (Cwq)(Dilution factor) 

Where: Ceff = Maximum allowable pollutant concentration (in mg/l) at the 

POTW effluent to protect receiving stream’s water quality 

C 

w q 

= In-stream water quality standard (in mg/l) 

B-14 
Q 

Dilution Factor - 

str + Qeff 

Q eff 

Where : QBtr - Critical low flow of receiving stream (in mgd) 

Q eff - POTW actual effluent flow (in mgd) 

Calculation of the dilution factor involves determining the total volume 

of effluent discharged by the POTW into the receiving stream, either by actual 

flow measurement or by estimation, using the actual POTW influent flow and 

subtracting other sources of wastewater leaving the POTW, such as sludge flow. 

Once the maximum allowable pollutant effluent concentration (Ceff) is determined, the maximum allowable influent concentration to the POTW based on 

protection of water quality is calculated using another version of the back 

calculation formula, as follows: 

C eff Lp - - 1-Ep 

Where: Lp = Maximum allowable influent concentration to the POTW (in 

41) 

C eff = Maximum allowable pollutant concentration at the POTW 

effluent (in rag/l) 

EP = Reduction of pollutant of concern through the entire POTW 

(expressed as a decimal) 

If water quality is selected as a controlling in-plant criteria, the maximum 

allowable fnfluent concentration is converted to a mass loading prior to the 

allocation procedure, as shown in previous sections. 

B-15 
4.0 PROTECTION OF SLUDGE QUALITY 

The last major objective of the National Pretreatment Program is the generation of sludge that ie compatible with the overall sludge management program and consistent with the selected disposal option of the POTW. Pollutant 

discharge limits should be calculated so that the POTW sludge remains compatible with the selected disposal option. There are three basic methods which 

POTWs utilize for sludge disposal at the present time: 

0 Incineration 

l Landf illing 

l Land application. 

Each of these methods has different costs and benefits associated with its 

use. For this reason, the required sludge quality and degree of pretreatment 

needed will also vary. 

4.1 INCINERATION 

Incineration of sludges with high concentrations of priority pollutants 

can volatilize organics and metals. Little information exists on the release 

of these pollutants into the air during incineration. What is known about 

incineration is that it is very expensive to operate and requires an air pollution control permit. If incineration is the disposal option used, the POTW 

should sample and analyze the resulting ash to determine if the ash quality is 

compatible with its disposal method. 

4.2 LANDFILL DISPOSAL 

The determining factor for landfill disposal is whether the sludge is 

c1assified as a hazardous waste. To ensure that a particular sludge is not a 

hazardous waste, the EP (extraction procedure) toxicity test must be performed. When landfill disposal is used by the POTW, the sludge leachate 

should be sampled and analyzed when there is a possibility that the leachate 

may contaminate or degrade groundwater or surface water resources. 

B-16 
4.3 LAND APPLICATION 

To predict the sludge quality needed for land application, plant operational data should be analyzed, and land quality and quantity should be determined. The POTW should know the general soil type and Cation Exchange 

Capacity (CEC) of the land application site. Table 4 provides Federal guidelines on loading linltatlons for land application of metal-bearing sludges. 

In addition, each State may have Its own land application limitations. Both 

Federal and State rules should be evaluated to determine necessary sludge 

quality and allowable pollutant loads to the municipal treatment plant. These 

llaltatlonB should be utilized by the POTW to find the maximum cumulative pollutant loading (L) for a specific contaminant. Two procedures are described 

below. The first procedure ie designed to aseiat the POTW in assessing sludge 

disposal Impacts while the BeCOnd will help in establishing local discharge 

llmltatlons which will allow the POTW to dispose of its sludge properly and 

economically. 

4.3.1 Procedure to AsBesS Sludge Dieposal Impacts 

In order to evaluate the Impacts of poselble sludge contamination, a POTW 

must first analyze it8 final sludge product for each pollutant of concern. 

Units of this analysis are generally in terms of milligrams of pollutant per 

kilogram of sludge on a dry weight basis. (If data are provided on a wet 

weight ba618, be sure to convert to dry weight using the sludge percent 

solids.) After converting from m&kg dry to lbsldry ton (by multlplying by 

0.002), a maximum cumulative loading (L) for the appropriate pollutant of concern IB chosen based on the particular characteristics of the soil (Table 4 or 

applicable State or local loading limitations). Using these two values, the 

maximum amount of sludge which can be applied per acre is determined, as 

follows : 

L AR-- C 

Where : AR = Maximum allowable amount of sludge applied per acre (in dry 

tons/acre> 

B-17 
TABLE 4 

REQUIReMENTS FOR SLUDGE APPLICATION TO AGRICULTURAL LAND 

PRIMARY RBQUIRMENT - NITROGEN 

1. Sludge application rates should provide total plant available nitrogen fertilizer requirement of the crop growth, and the requirement to 

prevent nitrate pollution of groundwater. 

ADDITIONAL REQUIREMENTS - TRACE METAL ELEMENTS 

1. Maximum annual Cd loading: 

l Jan. 1, 1981 to Dec. 31, 1985 1.25 kg/ha 

l Beginning Jan. 1, 1986 0.50 kg/ha 

2. Soil/sludge pH control 

0 pH of sludge amended soil should be maintained at 6.5 or greater 

3. Total cumulative metal loadings (kg/ha) 

Cation Exchange Capacity (meq/lOO gm) 

Element o-5 5-15 >15 

Pb 500 1000 2000 

Zn 250 500 1000 

cu 125 250 500 

Ni 50 100 200 

cd 5 10 20 

4. Cd/Zn ratio of sludge applied should be less than 0.015 in naturally 

acidic 5011s. 

Derived from Reference (7). 

B-18 
L = Maximum cumulative loading (in lbs/acre) 

c- Pollutant concentration In sludge (in lbsldry ton) 

Using the maximum amount of sludge which can be applied per acre and the 

available acreage for sludge application, the total amount of sludge that can 

be applied is calculated a5 follows: 

TA = AR x A 

Where: TA = Total amount of sludge allowable for disposal on available 

acreage (in dry tons) 

AR = Maximum allowable amount of sludge applied per acre (in dry 

tons/acre) 

A = Available acreage for sludge disposal (in acres) 

This total amount of sludge allowable for disposal on available acreage 

IB next divided by the POTW’B current sludge generation rate to determine the 

lifetime of the available acreage based on the amount of pollutant in the 

sludge, as follows: 

Where: ‘J? = Adjusted site lifetime (in years) 

TA - Total amount of sludge allowable for disposal on available 

acreage (in dry tons) 

SG - POTW’s current sludge generation rate (in dry tons/yr) 

This adjusted site lifetime can then be compared to the original lifetime 

of the available acreage. If the site lifetime is not reduced significantly, 

the POTW may decide to set a threshold concentration at current pollutant 

level5 a8 a POTW protection criteria. However, if the site lifetime is reduced significantly, the POTW must establish a local discharge limitation 

which will allow an acceptable disposal site lifetime. 

B-19 
4.3.2 Procedure to Establish Local Discharge Limitations to Protect POTW 

Sludge Disposal Options 

The maximum cumulative pollutant loading per acre (L, previously determined using the soil characteristics of the sludge disposal site), the amount 

of available site acreage (A), and the original site lifetime (T) are used to 

calculate the maximum allowable pollutant mass loading in the sludge to comply 

with the maximum cumulattve pollutant loading per acre and sttll maintain the 

original site lifetime, as follows: 

ML- LxA 

T x 365 

Where: ML = Maximum allowable pollutant mass loading (in lbs/day) 

L = Maximum cumulative pollutant loading per acre (in lbs/acre) 

A = Available acreage (in acres) 

T = Original site lifetime (in years) 

365 = Conversion factor (in days per year) 

Next, the maximum allowable pollutant mass loading (ML*) to the influent 

of the treatment plant, to ensure appropriate sludge quality for land application, can be calculated by adjusttng ML for removal through the entire plant, 

as follows: 

Where: ML* = Adjusted maximum allowable pollutant mass loading (in 

lbs/day) 

ML = Unadjusted maximum allowable pollutant mass loading (in 

lbslday) 

Ep = Pollutant reductton through the entire POTW treatment system 

The maximum allowable pollutant concentration at the influent of the 

plant (C) can be found by converting the adjusted maximum allowable influent 

pollutant mass loading using the mass conversion formula, as follows: 

B-20 
C- ML* 

Q x 8.34 

Where : L = Maximum allowable pollutant concentration (in n&l) 

ML* - Adjusted maximum allowable influent mass loading (In 

lbB/day) 

Q - POTW design flow (in MGD) 

8.34 - Conversion factor 

This concentration is used as the sludge disposal in-plant Criteria in 

determining which In-plant criteria controls. If the sludge dispoeal criteria 

controls, the adjusted maximum allowable lnfluent maBB loading (ML*) Is used 

to begin the allocation procedure. 

B-21 
5.0 ALLOCATION OF THE POLLUTANT LOAD TO INDUSTRY 

The final step in the process of setting effluent limitations is to 

allocate the maximum pollutant loading to the treatment plant to the individual industrial dischargers. This may be accomplished In several ways, as diecussed below. 

5.1 ALTERNATIVE METHODS 

0 Single concentration or mass limit: A single concentration or mass 

limitation can be established, which no industrial user (IU) can 

exceed, and, when domestic contribution is taken into account, will 

not exceed the allowable influent loading. This method corresponds to 

the example calculation shown in Section 6 of the Appendix. A single 

limit for all users may be easier to regulate and enforce. 

0 Proportionate: Allocation can be accomplished proportionately, using 

various IU characteristics such as mass loading or flow rate to divide 

up the allowable pollutant discharge. The preferred method of allocation is the one based on mass loadings. However, if concentration 

data is not available for each IU, the mass loading ratio may not be 

used, and proportionality will have to be based on another characteristic such as IU flow. However, if the flow is based on water usage, 

this method penalizes the industrial user that recycles or reuses some 

portion of its wastewater. This method may be desirable when there 

are only a few dischargers of a given pollutant in the entire industrial community. 

l Technology-based: Technology-based limitations are developed by considering wastewater treatment systems for each particular industrial 

user that are best suited to that IU's wastewater. Information on 

state-of-the-art treatment system performance can be obtained from EPA 

Development Documents supporting effluent limitattons guidelines and 

standards. 

5.2 OTHER CONSIDERATIONS 

a Growth: Expansion should also be considered in the POTW service area 

when allocating pollutant loading. Expansion can include domestic 

contributions where future population growth can cause overloads of 

compatible pollutants, as well as future industrial contribution. If 

land has been zoned for industrial parks or other developments, POTWs 

must allocate a certain portion of the allowable influent loading to 

this planned expansion. 

l Design: Proposed or planned design changes in the munictpal treatment 

plant should be taken into account when developing and settlng industrial effluent limitations. For example, nitrificatton is a more 

B-22 
sensitive process than activated sludge for some pollutants. A POTW 

planning to upgrade would need to develop protection criteria for this 

process if it is the limiting factor for some pollutants. Industrial 

discharge limits might then have to be made more stringent to protect 

the new design. Industrial users should be kept informed of such 

plans and developments so that pretreatment technologies are appre 

priate over time. 

5.3 PROCEDURE FOR ALLOCATION OF POLLUTANT LOADINGS TO INDUSTRY 

After determining the controlling in-plant criteria and converting the 

maximum allowable influent concentration to mass (lbs/day), the uncontrollable 

fraction of the maximum allowable influent loading should be subtracted prior 

to allocation. For most POTWs, the uncontrollable fraction will be the pollutants contributed by domestic wastewaters, and is determined by sampling a 

typical domestic sewer interceptor where no industry exists. Table 5 presents 

data on typical background concentrations of various pollutants found in raw 

sewage and other nonindustrial sources, but should only be used for comparison 

purposes and preliminary calculations. 

Once the uncontrollable fraction of a pollutant is subtracted from the 

maximum allowable influent loading, the controllable or allocatable fraction 

remains. After considerations such as expansion have been considered, allocation of the controllable fraction is performed using one of the three 

methods specified. Procedures for single concentration and proportionate 

allocation method follow. 

Single concentration allocation is performed by adding together the flows 

of all current and future ILJ5 contributing a specified pollutant of concern 

and then applying the mass conversion formula, as follows: 

Single Concentration 

Limitation C (w/l) = 

Allocatable Fraction (lbs/day) 

(Q 1 + Q, +Q,.. .> X 8.34 

Where: (Q, + Q, + Q,) = Sum of all IUs’ flows which discharge the 

specific pollutant of concern 

B-23 
TABLE 5 

TYPICAL BACKGROUND CONCENTRATIONS OF 

TOXIC POLLUTANTS IN NONINDUSTRIAL SEWAGE 

(INCLUDES DOMSTIC MD COMMERCIAL SEWAGE)* 

Toxic Pollutant 

Arsenic 

Cadmium 

Chromium (total) 

Wper 

Cyanide 

Lead 

Nickel 

Zinc 

“Background” Concentration 

0.003 mg/l 

0.003 mg/l 

0.05 mg/l 

0.061 mg/l 

0.041 mg/l 

0.050 mg/l 

0.021 mg/l 

0.175 mg/l 

*Concentrationa are total pollutants except where otherwise Indicated. 

References: (9) 

B-24 
Proportionate allocation is based on a particular characteristic of each 

industrial user. For example, using each IU’s mass loading or wastewater flow 

to establish the appropriate proportion, the allocation is performed as 

follows: 

Proportionate Allocation Method 1 (Mass): 

Proportionate Concentration CL11 

Limitation For IU #l = Allocatable Fraction (lbs/day) X (~7 

t 

Ql x 8.34 

Where : L1 = Current mass loading from IU #l for a 

specific pollutant (lbs/day) 

Lt = Total mass loading from all industrial 

users for a specific pollutant (Lbs/day) 

Ql = Wastewater flow of IU Rl (MCD) 

8.34 = Conversion factor 

This is the preferred method of proportionate allocation, if industrial user’s 

pollutant concentrations are known. If they are not, the next method may be 

used. 

Proportionate Allocation Method 2 (Flow) : 

Proportionate Concentration (Q,) 

Limitation For IU #I = Allocatable Fraction (lbs/day) X - (Q,) 

Ql x 8.34 

Where : Ql = Wastewater flow of IU #l (KD) 

Qt = Sum of wastewater flows for all IUs which discharge 

a specific pollutant of concern 

8.34 = Conversion factor 

The above procedures would be repeated for all industrial users discharging 

that particular pollutant of concern. 

B-25 
6.0 A HYPOTHETtCAL POTW EXAMPLE 

For reasons of brevity and simplicity, this example calculation of allowable influent loading to a POTW addresses only one pollutant, copper. The 

methodology presented here, however, will be equally applicable for calculating limits for other pollutants discharged by electroplaters or other industries. Our hypothetical POTW utilizes an activated sludge unit for secondary 

treatment and anaerobic digestion of sludge. POTW sludge is applied on nearby 

farmland. 

The treatment plant has a design flow of 10.0 MGD (9.9 MGD average). The 

POTW is required to develop a pretreatment program because it has an electroplating facility manufacturing printed circuit boards contributing copper to 

its system. The POTW pumps 0.2 MGD of raw sludge, thickens it from 1 percent 

to 5 percent solids, and then pumps to anaerobic digesters. 

For the purpose of this example calculation, we will assume that the 

electroplating facility discharges only copper. The POTW has determined, 

through its sampling program, that the average removal of copper through the 

acttvated sludge portion of the treatment system is 83 percent with primary 

treatment achieving an average of 25 percent removal. The POTW has an NPDES 

effluent 1Cmitation for copper of 1.0 mg/l. 

The POTW has documented upset and inhibition conditions at its treatment 

plant caused by high copper concentrations. The threshold copper concentrations at the influent to each appropriate unit operation for this example are 

as follow: 

Activated sludge - 1.0 mg/l 

Anaerobic digestion - 10.0 mg/l 

B-26 
6.1 CALCULATING MAXIMUM ALLOWABLE POLLUTANT LOAD TO THE POTW FOR COPPER 

6.1.1 Preventing Inhibition of Treatment Plant Processes 

To determine the influent concentration of copper that will not inhibit 

treatment plant process, the POTW must calculate in-plant criteria for both 

the activated sludge process and the anaerobic digestion process to find the 

controlling in-plant criteria concentration. 

(1) Activated Sludge 

Using the back caluclation formula presented in Table 1, the inplant criteria for the activated sludge process can be determined, 

as shown below: 

LP = 

1.0 mgll 

l-O.25 - 1.3 mg/l 

Where : Activated sludge copper threshold concentration = 1.0 mgll 

POTW X removal through primary treatment - 25% (or 0.25) 

(2) Anaerobic Digestion 

Determining the allowable influent copper concentration for proper 

anaerobic digestion is slightly more complicated. The al lowable 

amount of copper, in lbs/day, In the anaerobic digester is determined by first calculating the flow of sludge to the anaerobic 

digester, and then applying the mass conversion formula shown in 

Table 1, using the anaerobic digestion copper threshhold concentration and the calculated flow rate, as follows: 

0.2 MGD 

5 = 0.04 MGD (concentrated by extracting water from 1% to 5%) 

Allowable Cu mass loading to digester - (0.04 MGD)(lO mg/1)(8.34) 

= 3.34 lbsfday 

B-27 
Using the allowable amount of copper to the digester, an allowable 

influent concentration can be calculated, using another form of the 

mass conversion formula and the POTW design flow, as follows: 

Allowable influent Cu concentration = 

3.34 lbslday 

(10 MGD)(8.34) = Ogo4 mg’l 

However, only 83 percent removal of copper is achieved through the 

entire treatment system and, therefore, only this portion of the 

influent copper reaches the digester. Consequently, the allowable 

lnfluent concentration is adjusted using another form of the back 

calculation formula as follows: 

Allowable influent Cu concentration = 

0.04 mg/l 

0.83 = 0.048 mg/l 

6.1.2 NPDES Permit Compliance 

Using the back calculation formula presented in Table 1, the in-plant 

criteria to meet the POTW NPDES permit requirement is calculated as follows: 

LP = 

1.0 mg/l 

1-O .83 - 5.88 mg/l 

Where : NPDES permit limitation = 1.0 mg/l 

Reduction of copper through the entire POTW = 83% (or 0.83) 

6.1.3 Determination of Possible Sludge Disposal Impacts 

In addition to the possible impacts mentioned above, sludge disposal 

options may be limited for this hypothetical POTW because of the amount of 

copper in its digested sludge, which it intends to apply to surrounding farmland. In order to evaluate this possibility, the POTW has analyzed its 

digested sludge and found it to contain 525 mg/kg (dry weight) of copper. 

Converting to pounds per ton: 

Copper content of - 525 mg/kg (dry weight) x 0.002 = 1.05 lbs/dry ton 

digested sludge 

B-28 
Using the most stringent total 

Table 4 (125 kg/ha), and converting 

cumulative metal loading option from 

to lbs/acre : 

Total cumulative metal loading 111 lbs/acre 

Copper content of digested sludge = 105 lbs/ton = 106 dry tons/acre 

yields the maximum amount of sludge which can be applied in dry tons/acre. 

The hypothetical POTW applies approximately 45 dry tons/month of dewatered digester sludge to about 410 acres of surrounding pasture and farmland. Using the maximum amount of sludge which can be applied per acre and 

the land available for application, the total amount of sludge which can be 

applied for the lifetime of the sites can be calculated: 

Total sludge allowable a 106 dry tons x 410 acres 

for disposal on available acre 

= 43,460 dry tons 

acreage 

Using this total site lifetime application and the current sludge disposal rate (45 dry tons/month), the lifetime of the sites available for appllcation is calculated: 

Lifetime of available 43,460 dry tons 

acreage for sludge = 45 dry tons/months 

disposal 

= 966 months or 80 years 

Therefore, unless the orlglnal lifetime expectancy of the sludge disposal 

sites is well over 80 years, this POTW’s sludge disposal options will not be 

affected by the current amount of copper in its sludge. In addition, any 

reduction of the POTW plant influent copper concentration due to other local 

limitations will further lower the amount of copper in the sludge and extend 

the useable lifetime of the sludge disposal sites. 

B-29 
6.1.4 Determination of Controlling In-Plant Criteria 

Reviewing the in-plant criteria for each condition: 

Activated sludge - 1.3 mg/l 

Permit conditions - 5.88 mgll 

Anaerobic digestion - 0.048 mg/l 

It can be seen that anaerobic digestion is the controlling in-plant criteria. 

Therefore, it is possible that a POTW can be substantially below its permit 

condition for a toxic pollutant and still experience inhibition and interference severe enough to prevent proper plant operation from that same pollutant. 

6.2 ALLOCATION OF LOCAL LIMITS FOR COPPER 

After calculating an allowable influent concentration of 0.048 mg/l of 

copper as an in-plant crtteria for proper anaerobic digestion, the POTW must 

allocate the required reduction to attain this concentration among its industrial users. The POTW has identified an electroplating facility as the only 

major industrial user discharging copper to its system. This facility has a 

flow of 0.050 MGD and currently averages 7.0 mg/l copper in Its effluent. 

Using the allowable influent concentration, the allowable pollutant mass 

loading is calculated: 

Allowable lbs/day = (10.0 MGDJ(0.048 mgllJ(8.34) = 4.0 lbs/day 

After sampling at a number of domestlc interceptors, the POTW has determined 

the copper concentration in domestic wastewater to be 0.025 mg/l. Calculating 

the current domestic copper mass loading: 

Domestic lbs/day = (9.85 MGDJ(0.025 mg/1)(8.34) = 2.1 lbs/day 

The allowable copper which can be allocated to industry is then calculated by subtracting the domestic background loading: 

B-30 
Allowable lbs/day = 4.0 lbs/day - 2.1 Ibslday = 1.9 Ibslday 

The current electroplating mass discharge is: 

Electroplating Ibs/day = (0.050 MGDJ(7.0 mg'lJ(8.34) = 2.92 lbslday 

This particular electroplating factlity is subject to a categorical standard of 4.8 mg/l for copper. When compliance with this categorical standard 

is achieved, the electroplating mass discharge will be: 

Electroplating lbslday = (0.050 MGD)(4.8 mg/1)(8.34) = 2.00 lbslday 

The POTW has two future contributions to its system planned. One is a 

housing project which will house approximately 500 people. At an estimate of 

150 gallons per person daily, the total wastewater flow increase is 0.075 MGD. 

However, because of the high cost of copper, builders are planning to use PVC 

pipe instead of copper pipe, which the POTW believes is the major source of 

domestic copper contribution. Therefore, the POTW is assuming a negligible 

amount of copper in this additional flow. The second future addition is a 

brass plating operation, which will be a major discharger of copper. This 

facility will have a design flow of 0.025 MGD and is also subject to a categorical standard for copper of 4.8 mg/l. Knowing that the existing facility 

already exceeds the allocatable loading using the categorical standard, a more 

stringent single concentration local limitation is established: 

Allowable electroplating 1.90 lbs/day 

concentration = (0.050 + 0.025 MGDj(8.34) = 3.o mg'l 

Therefore, a single concentration local limitation of 3.0 mg/l for both the 

existing and future electroplating facilities will allow the POTW to meet Its 

allowable influent concentration and will not violate the controlling in-plant 

criteria. 

B-31 
REFERENCES 

1. U.S. Environmental Protection Agency. Federal Guidelines - State and 

Local Pretreatment Programs. Vols. I, II, and III. EPA-430/9-76-017a, b, 

and c. January 1977. 

2. U.S. Environmental Protection Agency. Fate of Priority Pollutants in 

Publicly Owned Treatment Works. EPA-440/l-82-303. September 1982. 

3. Anthony, Richard M., and Breimhurst, Lawrence H. “Determining Maximum 

Influent Concentrations of Priority Pollutants for Treatment Plants.” 

Journal of the Water Pollution Control Federation, Vol. 53. October 1981. 

4. Dyer, Jon; Feller, Howard; and Bernick, Arnold. Handbook of Industrial 

Waste Pretreatment, Water Management Series. New York: Garland 

Pub1 ishing Inc. 1981. 

5. Eick, Richard W. “History of Priority Pollutants at the District and 

Determination of Prohibitive Discharge Limits (PDL).” 2nd Edition. 

Sanitary District of Rockford, Illinois. March 1982. 

6. U.S. Environmental Protection Agency. Ambient Water Quality Criteria. 

EPA-440’5-80. October 1980. 

7. U.S. Environmental Protection Agency. “Municipal Sludge ManagementEnvironmental Factors.” Federal Register, 41, No. 108, pp. 22531, 22543. 

June 1976. 

8. JRB Associates. “How to Set Local Limits.” Handout prepared for 

Pretreatment Seminars, sponsored by U.S. Environmental Protection Agency 

under Contract No. 68-01-5052. May 1982. 

9. JRB Associates. “Assessment of the Impacts of Industrial Discharges on 

Publically Owned Treatment Works.” Prepared for U.S. Environmental Protection Agency under Contract No. 68-01-5052. November 1981. 

B-32 
EXHIBIT A 

This Exhibit presents a summary of national water quality criteria that 

have been generated by EPA. These numbers do not have any regulatory status; 

they are intended to serve as general guidelines for the preservation of the 

intended uses of water. The criteria numbers on this table are organized 

under two major headings: aquatic life and human health. The first heading 

is further subdivided into acute and chronic criteria. These two numbers 

represent pollutant concentrations which, if not exceeded, should protect 

most, but not necessarily all, aquatic life and its uses. The aquatic life 

criteria specify both acute (maximum) and chronic (24 hour average) concentrations. The combination of the two numbers is designed to provide adequate 

protection of aquatic life and its uses from acute and chronic toxicity and 

bioconcentration while being more flexible than a one number criterion. 

The human health criteria are divided into two categories. The first 

group of numbers under water and organisms was generated assuming consumption 

of both drinking water and aquatic organisms (i.e., fish) by humans. The 

second group of criteria was derived assuming the consumption of aquatic organisms only. The criteria for human health are based on the carcinogenic, 

toxic or organoleptfc (taste and odor) properties of the pollutants. The 

meanings and practical uses of these criteria values vary accordingly. 

For carcinogenic substances, no scientific basis exists for estimating 

“safe” levels. Therefore, the criteria are expressed as ranges of values 

corresponding to incremental cancer risks of 10 -7 to 10 -5 (one additional case 

of cancer in a population ranging from ten million to 100,000, respectively). 

A detailed discusston of.these criteria, how they were developed and 

qualifications regarding their use can be found in Reference 6. 

B-33 
PARAMETER 

?RESHUATER AQUATIC LIIL TOXICITY AlMAN NEALTH 

ACUTE (Maximu) CHRONIC (24. Nr. Ave.) UATlsX 6 ORCAnI~ ORGAN1 SHS 

Accnapthcnc 

Acroleln 

Acrylonltrilc 

Aldrinf 

Mcldrin 

Ant irony 

Arsenic 

Asbeetos 

1,700 ugfl 520 tag/l 

60 w/l 21 ug/l 

7,550 y/l 2,600 rg/l 

(3 a/l) -- 

(2.5 us/l) (.0019 ug/l) 

9.000 ug/l I.600 ug/l 

(440 ug/l) 

fkntene 5,300 ug/l 

BrntIdlnc 2.500 ug/l 

Berylltu 130 ug/l 

Cadmiu (e(l.05(ln(hnrdExhibit A 

(Ref. 6) 

oce@))-3.73))w,l) 

Carbon Tetrachloride 35,200 ug/l 

5.3 ug/l 

-- 

Chlordane (2.4 l&l) c.0043 ue/l) 

Chlortnatcd 250 ug/l 

Bentcner 

Hexachlorobenrene 

1.2.4.5- 

Tetrachlcr 

robenrene 

Pentachlorobenzene 

Trichlorobenzene 

Honoclorb 

benzene 

10 

-5 

10 

-6 

10 

-7 

10 

-5 

10 

-6 

(20 ug/l objectionable taete L odor) 

.58 *a/l 

.7b ngfl 

.7I n&l 

22 q/l 

J(Jo*oo(J 

f iberm/ 

6.6 ug/l 

1.2 rig/l 

68 rig/l 

10 Is/l 

.05g tag/l 

.07b ngfl 

.071 ngll 

lb6 u(l/l 

2.2 rig/l 

30.000 

fibers/l 

.66 ugfl 

.12 rig/l 

6.8 ngfl 

4 ug/l .b w/l 

b.6 ngfl .46 rig/l 

7.2 ngfl .72 ngfl 

.30 ugfl 

320 ugfl 

.0058 ugfl 

.007b rig/l 

.0071 q/l 

.22 rig/l 

3,ooo 

fiber41 

.066 ug/l 

.OI2 rig/l 

.68 ngll 

780 ug/l 

6.5 w/l .65 u&l 

.79 ngll .079 ngfl 

.76 q/l .076 rig/l 

45,000 w/l 

175 rig/l 17.5 rig/l 

400 ue/l 40 ugfl b w/l 

5.3 ngfl .53 ngll .053 rig/l 

1170 rig/l I17 rig/l 11.7 rig/l 

.Oh tag/l 69.4 ug/l 6.9b q/l .694 ug/l 

.046 rig/l 4.0 q/l .60 rig/l .04g ngf 1 

,072 ngfl 7.) rig/l .74 rig/l 

40 ugll 

71 ugfl 05 ug/l 

-- 

(20 ug/l obJectionable taste 6 odor) 

10 

-7 

.065 tag/l 

.0079 rig/l 

.0076 ngll 

1.75 ngfl 

.07b rig/l 

B-34 
Exhibtt A 

(Ref. 6) (Continued) 

PARAMETER 

FRESHWATER AQUATIC LIFE TOXICITY HWN HEALTH 

ACUTE (MaxImu) CHRONIC (24. Hr. Ave.) WATER 6 ORGANISMS ORGANISM? 

ICI -5 lo-b lo-7 IO-5 10-6 lo-7 

Chlortnated 

EC hams 

1 ,Z-Dichlo- llR.OO0 ug/l 

roethane 

20,000 “R/l 9.4 “R/l .94 “R/l .094 “g/l 2430 “g/l 243 ugfl 24.3 q/l 

-Trichloroethane lE.000 ugfl 9,400 ugfl 

I,],2 Trlchloroethane 

1.1.1 Trichloroethane 

-Tet rachlorol thnne 

l,l,2,2-Trtrschlororthanr 

Pentnchlorethane 

Hexachloroethanr 

Chlorinated 

Napthalenes 

Chlorinated 

Phenols 

b-Chloro-3- 

tfethylphrnol 

2.4.6-Trichlorophrnol 

3-Monochlorophenol 

4-kmochlorw 

phenol 

2.3-Dichlorcr 

phenol 

2.5-Dlchlorophenol 

2,h-Dichloropheno 1 

3,4-Dichlorophenol 

2.3,4,6-Tetrarhlorophcnol 

2,4,5-Trlchlorophenol 

2,4,6-Trlrhlorophrnol 

9.320 “g/l 

7.240 “g/l 

980 “R/I 

1,600 “g/l 

30 “R/l 

2.400 “g/l 

l.lOn ug/l 

540 ug/l 

6 q/l .b “g/l .Ob “g/l 418 ugfl 41.8 ugfl 4.IR “R/I 

IR.4 mgll 1.030 mg/l 

1.7 “g/l .I7 “g/l .Ol7 ugfl 107 “R/l 10.7 “R/l 1.07 uRf1 

19 “R/l 1.9 “g/l .I9 ugfl 07.4 “R/l a.74 “g/l .074 “g/l 

970 “Rf 1 

12 “g/l 

(.I “g/l objectlonablr taste and odor) 

(.I “g/l ohjectlonable taste and odor) 

(-4 “g/l oh)ectionable trnte and odor) 

c.5 “g/l objectionable tante and odor) 

(.2 “g/l oh)ecttonahlr taqtr and odor) 

(.3 ugll obJectionable tante and odor) 

(I.0 “R/l obJectIonable taste and odor) 

(1.0 “g/l oh)ecttonahlr taRte and odor)12 “g/l 

1.2 “R/I .I2 “R/l 3b “g/l 3.6 “g/l .36 “g/I 

(2.0 “g/l objrrtlonnblr taste and odor) 
Exhibtt A 

(Ref. 6) IGmtlnurd) 

PARAMETER 

C‘RESHYATCR MpATIC LIPE TOXICITY yMN HIWLTH 

ACU~xlnum~ CHRONIC (24. Hr.-&r.) 

- 

WATER 6 ORGANISMS ORCANI SMS 

.-__ ---___--~ --- 

1O-5 lo+ IO -I In-% ln-6 

2-Methyl-hchlorophenol 

3-Methyl-4- 

Chlorophrnol 

3-Methyl-bChlorophrnol 

(I.ROO o~/l oh]rctlonable tantr and odor) 

(3,000 nR/l oh)ertlonablr tantt= and odor) 

(20 uR/I obJrctloneble taste and odor) 

Chloroalhyl 

Et hers 238.000 UR/ I 

his-(chloromethyl)-ether 

his-(2-chloroethyl) ether 

his-(2-chloroisopropyl )- 

ether 

Chloroform 28.900 u&l 1,240 q/l 

2-chlorophenol 4,3AO UR/l 

c%romlu 

Hexavalcnt (21 q/l) c.29 w/l) 

Chralu 

Trivalent (e(l.OfI(ln(hard- 44 UR/l 

Chraiu ness))+3.48)w,,) 

cow-r (e(.94(ln(hard- (5.6 q/l) 

ncss))-1.23) us/l) 

Cyanide (52 w/l) (3.5 w/l) 

Prre Cyanide 

( HCIHCN , as CN) 

DM snd (I.1 UR.1) c.001 W/l) 

Ilctabo11ter 

TDC .6 y/l 

DDE I.050 u&l 

Dichlorobantaas 1.120 &g/l ?b3 q/l 

10 -I 

.038 i’,R/I .OO38 q/l .on03A q/l 18.4 q/l 1.86 llR/l . IRb lIRl 

.3 URll .03 ugll .OO3 UK/l 13.6 uR/l I. 36 q/l .I36 uR/ 

34.7 w/I 6.36 q/l 

1.9 q/l .I9 ug/l .019ug/I I57 u&l 15.7 ug/l 1.57 ugll 

(.I UK/I obJectionable taste and odor) 

50 ug/l -- 

170 mg/l 3.433 q/l 

(1 qq/l objecttonable taste 6 ardor) 

200 ug/l 

.24 n&l .02b rag/l .0024 ngll -24 q/l .024 q/l .002b ngll 

boo */I 2.6 q/l 

B-36 
Rxhlbit A 

(Ilcf. 6) (Continutd) 

PARAnETRR 

PRESWATER AQUATIC LIFE TOXICITY HlRuN HEALTH 

ACUTE (Mnrimu) CHRONIC (24. Hr. Ave.) WATER & ORGANISMS ORGAN1 SMS 

1O-5 lo+ 10 

-7 

1o-s 1o-b 10-l 

Dichlor* 

btnzidintt . 103 ug/l .0103 ug/l .00103 ug/l 0.204 tag/l .0204 ugfl Do2Ob ugfl 

Mchlorotchylcncr 

l,l-Dichloro- 11.600 w/l .33 ugfl .033 ug/l .Do33 ug/l 18.5 ug/l 1.85 ug/l .185 og/l 

tthylcnt 

2-b-Dichlore 

phenol 

Dlchloroproptntr 

Dichloroprczpent* 

2-&Dimtthylphenol 

2-4-Dinitrotoluent 

1,2-Diphtnylhydratine 

Endoeul fsn 

Endrin 

gt hyl benzene 

Pluroanthtne 

Halotthern 

Halomethanes 

Heptachlor 

Hexachlorobucadltne 

2,020 ug/l 365 og/l (3.09 a/l for protection of public hcnlth) 

23.000 og/l 5.700 us/l 

6.060 og/l 244 ugfl 81 ug/l 14.1 8g/l 

2,120 ug/l (400 ug/l objtctlontblt ttrtt L ardor) 

330 ug/l 230 ug/l 1.1 ug/l .lI ug/l 

270 ug/I 

f.22 w/l) t.056 ug/l) 

t.18 ug/l) f.0023 us/l) 

32.000 ug/l 

3.980 u(l/l 

360 ug/l 122 uu/l 

11.000 ug/l 

(.52 ug/l) f.0038 ug/l) 

90 ug/l 9.3 ug/l 

422 n.g/l 42 rig/l 

74 ugfl 

1 us/l 

l.b q/l 

42 uefl 

1.9 ug/l .I9 ug/l .019 ug/l 157 ugfl 15.7 ug/l 1.57 ug/l 

2.78 rig/l .278 rig/l .0278 rig/l 2.85 rig/l .285 rig/l .0285 ngfl 

4.47 uR/l .447 ug/l .045 ug/l 500 ugll 50 ug/l 5 ug/l 

.Oll ug/l 91 ug/l 9.1 ug/l .91 ug/l 

4 rig/l 5.6 ug/l .56 ug/l .056 ug/l 

159 ug/l 

3.28 q/l 

54 ug/l 

R-37 
Exhibit A 

(Ref. 6) (Continued) 

PARAffElER 

FRESHWATER AQUATIC LIFE TOXICITY HIHAN HRALTH 

ACUTE (Msximu) CHRONIC (26. Hr. Ave.) YATRR L ORGANISMS ORGAHISMS 

1O-5 10 -6 lo-’ 10 -5 1o-b 

Hexachlore 

cyclohexane 

Llndane 

BHC 

alpht-BHC 

bet t-BHC 

t ech-BHC 

gat-BHC 

(2 ugfl) (.08 ugfl) 

100 ugfl 

Hexchloro- 7 ugfl 5.2 ugfl 

cyclopentadlene 

Itophoront 117,DoD ugfl 

Letd (t(l.22(ln(htrd- (e(2.35(ln(htrdner8)b.17)ug,l) nem)-9.48) ugfl) 

(4.1 ugfl) t.2 &g/l) 

23.000 ug/l 620 ugfl 

(e(.7b(ln(htrd- (Cc .76( ln( htrdne88))+4.02) 

u(lfl) 

ntrr))+l.Ob) 

ugfl) 

Mercury 

Napthnltne 

Nickel 

Nitrobentcnt 

Nlcrophenolt 

27,000 ugfl 

230 ugfl 

h,b-Dinitro-ocre801 

2,4-Dinitrophtnol 

Ni trommlnts 5,850 t&l 

n-N1 t rowsdlrethyltmlne 

n-Ni tro8- 

odiethyltmlne 

n-Nttroeodi-nbutyluint 

n-Nltromdiphenyltmint 

n-Ni troropyrrolldine 

lo-’ 

92 rig/l 

163 ngfl 

123 ngfl 

186 ngfl 

9.2 ngfl .92 ngfl 310 ngfl 31 ngfl 3.1 ngll 

lb.3 ngfl 1.63 ngfl 547 ngfl 54.7 ngfl 5.4 ngll 

12.3 ngfl 1.23 ngfl 414 ngfl 41.4 ngll 6.14 ngfl 

18.6 ngfl 1.86 ngfl 625 ngfl 62.5 ngfl 6.25 ngfl 

(206 ugfl for protection of public health) 

5.2 a/l 520 q/l 

50 ugfl 

114 ngll 116 ngfl 

13.4 ugfl loo ugfl 

(19.8 q/l for protection of public httlch) 

13.4 &g/l 

70 ug/l 

765 ug/l 

lb.3 u/l 

16 ngfl 1.4 ngll .14 rig/l 160.000 n(l/l 16.000 ngfl 1600 ngfl 

8 ngll .8 ng/l.OB rig/l 12.400 ngfl 1,240 ngfl 124 ngfl 

64 ngfl 6.4 rig/l .bbng/l 5.868 ngfl 586.8 rig/l 58.68 ngfl 

69,ODO ngll 4,900 ngll 490 ngll 161,000 ngfl 16.100 rig/l 1,610 ngfl 

160 ngll 16 ngfl 1.6 ngfl 919.000 ngfl 91,OOD ngfl 9190 ngfl 

~-38 
PMWUTBR 

Penttchlor* 

phenol 

Phenol 

Phthalatt 

Dimethylphthalete 

Methylphrhalato 

Di-n-but ylphthalate 

Die-2-tthylhtxylphthelttt 

Polychlorimuttd 

Bipheaylr 

Polynuclotr 

Arautic 

Rydroc8rbow 

Saleniu 

Silver 

Trichloroethylene 

Tttrtchlor* 

ethylene 

Thtlliu 

Tolwnt 

Toxtphtnt 

vinyl Chloride 

Zinc 

Kxhlblt A 

(Ref. 6) (Conrlnwd) 

MSIWATER @ATIC LIPE TOXICITY BwtAn NxALTn 

ACUTE (Haximw) CHRDllIC (24. Ilr. Ave.) WATER 6 ORUNI!DlS ORGAllIsus 

55 ug/l 3.2 w/l 

10.200 *I1 2.560 ~11 

940 ugfl 3 q/l 

t.014 us/l) 

(260 og/l) (35 w/l) 

45,DOD us/l 

5,280 rgfl 840 ugll 

1.400 ugfl 40 lag/I 

17.500 us/l 

(1.6 -II/l) t.013 call) 

lo-5 

.79 ngfl 

28 Qgll 

2’ w/l 

8 W/l 

7.1 ngfl 

20 ugfl 

1o-6 lo-’ 1o-5 10-6 

(1.01 a/l for proctction of public health) 

(3.5 -11 for protection of public htelth) 

313 -11 

350 1/l 

34 all 

15 q/l 

.079 ~/1.0079 o#/l 

2.7 8&l 

.B ugfl 

13 rgll 

14.3 q/l 

.?l n&l 

2 ulJ/l 

.28 a(/1 

0.27 w/l 

.08 uafl 

.O?l ngfl 

.? u#/l 

0.79 Q&/l 

311 rig/l 

DO? ~11 

08.5 ugfl 

7.3 ngfl 

5246 y/l 

2.9 1/l 

1.8 g/l 

154 a/l 

,079 ag/l 

31.1 rig/l 

80.7 l&l 

8.05 ugfl 

48 Y/l 

b2b q/l 

.73 ngfl 

524.6 ugfl 

10-2 

.0079 ryfl 

3.11 aq/l 

8.07 ~(11 

.805 y/l 

.0?3 lag/l 

52.b6 ug/l 

nttt))+1.95)Wfl~ (47 -11) (5 q/l objectionable teete tnd odor) 

B-39 
APPENDIX C 

PRIORITY POLLUTANTS 

AND 

CATEGORICAL INDUSTRY 

INFORMATION 
TABLE C.1 

MATRIX OF PRIORITY POLLUTANTS POTENTIALLY 

DISCHARGED FROM INDUSTRIAL CATEGORIES 

Table C.1 lists the 25 categorical industries and the potential 

priority pollutants that can occur in significant amounts in the 

wastewater discharged from each group. This does not mean that every 

facility within a specific group discharges that pollutant; it does 

mean that there is a high probability that it will be discharged, 

based on a national survey of the industries conducted by USEPA. In 

addition, it does not mean that other priority pollutants will not be 

found in significant quantities, but that, in general, the manufacturing 

process and raw materials involved do not lead to the discharge of these 

pollutants. 

NOTE: The information in the table was developed from Industry 

Summaries prepared by the USEPA, dated March 1979, from the published 

development documents for effluent limitations from Industrial point 

source categories. This information is subject to change, and, as 

shown in Tables C.l and C.2, some industry groups may not be regulated. 

C-l 
TABLE C.l 

PKIUKITY POLLUTANTS 

dl 

: 3. :-<hluruphenoL 

.‘. I,:-dishlorobrnzeoe 

25. :. 3-dichlorobrnzenc 

:+z, 1 ,I-dl<hlorJbenreoc 

WI. . ).)-dlchlorobentldloe 

:8. !.l-ve 

.‘Y. :.:-trJns-dlchloroeth,~ 

IO. J.L-dlchloroDheno1 

II I.‘-dichlaroprc~.inc 

1:. 1 .‘-dIchlaro>raDylen. (1.Gdlchlow 

11. :.i-dimethvl~henol 

I-. ‘..-dlnltrLltQ;ucne 

15. :.6-dcn~crotolucne 

16. ;.‘-dlphenylhvdrarinr 

x*chvlbenrrne 

18. :!wrathonr 

19. A-chlorophenvl phcnyl ether 

.ao. .-bromuphcn?l phenvl ether 

“1. bis(:-ihlJr~l~~~proay1 ether Y *-. bLsC?-chloroethoxv) methane 

-3. methylcne chloride (dlchloromerhanc) 

.-. arthv\ ch’.oridc (chloroathrnel 

.i. merhvl bramlde (bromomethane) 

-6. brnmform (rrlbrouawtheoc) 

-, - dAchlorobromoawthaoe 

. chlor g 

” , 

30. h-e 

31. lnpohorone 

52. n.aDhchalcnc 

33. nltrobcnrene 

Ii. :-a55. :-nltroDhcnol 

ib. ? .C-dlnitroDheno1 

31. L.6-dlnlrro-o-crebol 

58. N-nitrosodrmcchylamlne 

59. S-nltrosodlphcn~lamlne 

60. S-nitrorodl-n-propvlamlnr 

hl. pentrchlorophenol 

62 . phenol 

63. bls(2-ethylheryl) phthslatc 

bU . bury1 bcozvl Dhthalatc 

C-2 
T 

1 

r 

1 

1 

2 

1 

1 

1 

T 

A 

A 

A 

1 

1 

1 

1 

-r 

T 

c 

1 

1. 

b 

* 

TABLE C.l (Continued) E 

MATRIX OF PRIORITY POLLUTANTS WY 

POTENTIALLY DISCHARGED FROM 

INDUSTRIAL CATEGORIES 

POLLUTANT FOUND IN 

SIGNIFICANT QUANTITY 
G cn 

z u 

TABLE C.l (Continued) 2 

iii ii r 

MATRIX OF PRIORITY POLLUTANTS g 

z Y 

w it% b. POTENTIALLY DISCHARGED FROM - v) ;; - 2 

INDUSTRIAL CATEGORIES ,: mm 

POLLUTANT FOUND IN 

SIGNIFICANT QUANTITY 
CATEGORICAL INDUSTRY 

IRON & STEEL 

LEATHER TANNING 6 FINISHING 

METAL FINISHING 

NON-FERROUS METALS 

ORE MINING b DRESSING 

ORGANIC CHEMICALS, PLASTICS 

AND SYNTHETICS 

PESTICIDES 

PETROLEUM REFINING 

PHARMACEUTTCALS 

PLASTICS PROCESSING 
TABLE C.l (Continued) 

POTENTIALLY DISCHARGED FROM 

INDUSTRIAL CATEGORIES 

POLLUTANT FOUND IN 

STGI4IFICAST QUANTITY 

PRIORITY POLLUTANTS 
TABLE C.l (Continued) 

POTENTIALLY DISCHARGED FROX 

INDUSTRIAL CATEGORIES 

POLLUTANT FOUND IN 

SIGNIFICANT QUANTITY 
TABLE C.2 

556 

hb7 

444 

461 

650 

534 

bb5 

560 

569 

513 

457 

5b5 

4% 

647 

415 

420 

025 

r13 

621 

471 

bL0 

514 

146 

553 

055 

619 

139 

459 

416 

AC3 

466 

640 

i)O 

020 

b70 

hi7 

423 

510 

429 

Adhcslvc and Sealants 

Alulnkm Forming 

AUCO and Ocher Lmmdrl~r 

Ebctery WE. 

Carbon Black 

Coal ?(lnln,g 

Coil Coatln# 

Copper Pomlnp 

El~ctrlcal and El8ctronlc Products 

2 El~crroplatlnE 

Explor1vc* Yfg. 

foundry 

Cam and Uood Chemicals 

Ink ?ormulat ion 

Inorganic Chemlcalm 

Iron and Steel Mfg. 

Leather Tmnlnp and Plnlrhing 

2?iechanlcal Producrm 

2 hral ?lnlrhlng 

tdonf*rroua lletalm !Unuf~cturln~ 

Nonferrous !letals Cormiru 

Ore Mining and Dremlng 

I tiEUliC ch.=iCalS 

Paint Porml~tlon 

Pwln~ and Roofing ttacarlalr 

Pertlcldes 

Perrohru Reflnlna 

Pharmaceutical Mfg. 

Phoro&raphlc Equlpwnt and Suppll9r 

‘Plmrica and Synthetics 

Plastlcr Moldlnp and Formln# 

Porcwlaln Enameling 

Prlntlng and Publlshln# 

pdp. Paper. and Paperboard 

Rubber Mfg. 

Shlpbulldln# 

So.p and Decerganc nrr. 

Scar Electric Powerplant* 

Text 118 

Timber 

STATUS REPORT OF CATEGORIES TOTALLY OR PARTIALLY 

EXCLUDED FROM PRETREATMENT REGULATION 

CAHCORY/SUBCATECORY APPLCTCD 

PARAGRAPH 8 EXCLUSION PitO.JLCT Dl!?CUZD 

Total Part la1 Total Parrl*l 

-- P 

X 

X 

X 

X 

X 

X 

X 

X 

II 

X 

X 

X 

x 

X 

X 

X 

X 

x 

x 

X 

x 

L 

x 

X 

X 

2 The El~crropl~rl~ and the l4~hanlcal Producta Cacmgorlea have been ccnblned for MT 

rulematlng under the Metal tlnlrhlng Category. 

Source: This table 1s an update of the July 1981 Swary of Paragraph 8 Exclurlonm prepared by the Offlee of Quality 

the Efflumt Culdcllncs Dlvlslon. Offlcc of Yacer ilegulattonr and Stmdardm. Office of Water. WA. It “.. .I 

scmormdm frm Jeffrey Denlc. dated August 14. 1981. This lnfomatlo~ la subfact to change. 

C-R 
TABLE C.3 

REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES 

Industry Category SIC Code -~__~ _--.--I_ 

Adhesives and Sealants 2891 

Aluminum Forming 

l Rolling with Emulsions 

l Rolling with Neat Oils 

l Extrusion 

l Drawing with Neat Oils 

l Forging 

l Drawing with Emulsions or Soaps 

3353, 3355 

3353, 3355 

3354 

3353, 3355 

3463 

3353, 3355 

Coal Mining 

0 Coal Preparation 1111, 1112, 1211, 1213 

l AcidlFerrugenous !line Drainage 1111, 1112, 1211, 1213 

l Alkaline Yine Drainage 1111, 1112, 1211, 1213 

l Areas under Reclamation 1111, 1112, 1211, 1213 

0 Western Coal Mines 1211, 1213 

Coil Coating 

l Steel Basis Material Coating 

l Galvanized Basis ?laterial Coating 

l Aluminum Basis Xateria? Coating 

3479 

3479 

3479 

Copper Forming 

l Hot Rolling 3351 

l Cold Rolling 3351 

l Extrusion 3351 

l Drawing 3351 

l Pickling 3351 

l Alkaline Cleaning 3351 

l Forging 3351 

l Copper Foil Production 3497, 3351 

Electroplating (Yetal Finishing) 

l Electroplating of Common Yetals 

l Electroplating of Precious ?letals 

3471 & 3479 

not be subject to regulations) 

(Some industries within 

these subcategories may 

l Electroplating of Speciality ?Ietals 

l Anodizing 

0 Coatings 

l Chemical Etching & Xilling 

l Electroless Plating 

l Printed Circuit Board 

l Chemical Yatching 

0 Immersion Plating 

l Pickling 

l Bright Dipping 

l Alkaline Cleanin?, 

Source: Summarized from (1) "Summary of Paragraph 8 Exclusions," EGD, OWRS, 

EPA, .July, 1981; (2) Standard Tndustrial Classification Xanual, 

Executive Office of the President, Office of ?lnnngement and Budget, 

1972. 

C-9 
TABLE c. 3 (Cnnt inucd) 

RFC,I’I,ATED 1NI)l’STRIAl. SL:RCATEGORTES WTTH ASSOCTATEI~ SIC COI)ES 

Tndust ry Cateqorv SIC Code --_-- -A_ __ _--- ~-~-. -. - -------- ~.--. -~-.~- 

0 Iron and Steel 

0 copper 

0 Al umi num 

0 Zinc 

0 I.cad 

3322, 332k, 3325 

3362 

3361 

3369 

3369 

3369 

0 (:hlorint~ h, Sn or K Hydroxide 2812 

l Hydrof 1 uor iv :\c id Product ion 2819 

l XL1 :)ichrom;~tc b Sulfate Production ,819 

0 Titanium Diclxidt, 2816 

l Aluminum l‘luoride Product ion 2819 

0 Cl) rornc I’ i grnt’n t 281h 

l Copptar Sul fatta Product ion 2819 

l Hydrog:1,n (Ivan idta Product ion 2819 

l Si~.ktal Sul fatt, I’roduc-t ion 2819 

. %dium Bisulf itta Product ion 2819 

l Sodium Sil i(~ofluoridt~ Production 2819 

l (‘ckt~makin$ 

0 Sinttnring 

l Irc~nnnking 

l Stt~rlmaking 

0 \‘acuum Dc~ass ing 

0 Cent inuous Casting 

l Hot lTormino. 

l S(.a 1 cx Kernova 1 

l AC, i d Pi c k 1 in E 

l Cclld I-‘orming 

l Al knl ine (~le~~nin~ 

. Hot (:oa t i ng 

3312 

3313 

3312 

3312 

3312 

3312 

3312, 3315, 3317’ 

3312, 3315, 3317! 

3312, 3315, .3317] 

3316 

3312, 3315, 331h, 3317 

3312, 3315, 3317’ 

0 H;\i r Pulp L’nhairing with Chrome 

Tann in$ and Finishing 

0 Hii i r Snvc I‘n\l;l i r i rig w i t h Cliromt~ 

Tanning or Finishing 

0 I.nh;\irinq with ‘,‘c~gc~t;lble or 

Al urn. ‘l’;~nning nnd Finishing 

l Finishing of ‘l‘;lnnt~d Hides 

. \‘~~gt~tablc or Chrc~mc~ Tanning of 

I’nha it-cad Hides 

l ~‘n\lairing with Chrome Tanning and 

So Finishing 

0 Shcclr ing 

3111 

3111 

3111 

3111 

3111 

3111 

3111 

c-10 
TABLE C.3 (Continued) 

RECULATED INDUSTRIES SUBCATEGORIES WITH ASSOCI:1TED SIC CODES 

Industry Category SIC Code 

_-_-.__--.__ --.--___-- -.. --.~~_ -.. - ---- 

_--.---_----_ Yetal Finishin&lechanical Products -- ___._ --_-_____- 

Sonferrous -- _~_ - -~- ?letals ?ianufacturin& --.-- - 

l Bauxite Refining 

0 Primary Aluminum Smelting 

l Secondary Aluminum Smelting 

0 Primary Copper Smelting 

l Primary Copper Refining 

l Secondary Copper 

l Primary Lead 

0 Primary Zinc 

l ?letallurgical Acid Plants 

l Primary Columbium Tantalum 

l Secondary Silver - Photographic 

l Secondary Silver - Xonphotographic 

l Primary Tungsten 

l Secondary Lead 

Ore ?!ini3 and Dressing -___ -- 

l Base and Precious Yetals 

(Cu, Pb, Zn, AR, Au, Pt, No) 

l Ferroailoy Ores 

l Uranium, Radium, \!anadium Ores 

l Tungsten Ore 

l Nickel Ores 

l Vanadium Ore (non-radioactive) 

0 Ant imony Ore 

Organic Chemicals, Plastics and ___----- ___-.___- 

Synthetic Materials 

l Processes with Process Water, 

Contact as Steam Diluent 

Quench or Vent Cns Absorbent 

Pesticides ~-- Chemicals ---- 

l Organic Pesticide Yfg. 

l Metallo-Organic Pesticides 

l Pesticide Chemicals Formulating 

Petroleum Ref ina _---- ------ 

l Topping 

l Cracking 

0 Petrochemicals 

0 Lube 

l Integrated 

Lnrgc number of subcateRor it’s i nc 1 ud i IIR : 3411-29; 

3432-66; 3483-3599; 3613- 

23; 3629-39 

2819 

3334 

3341 

3331 

3331 

3341 

3332 

3333 

3331, 3332, 3333 

3339 

3341 

3341 

3339 

3341 

1021, 1031, 1041, 1044, 

1061 

1061 

1094 

1061 

1061 

109: 

1099 

2865, 2869 

2869, ,879. 

2869, 2879 

2869, ‘879 

2911 

2911 

2911 

2911 

2911 

C-11 
TABLE C. 3 (Continued) 

KF(;I’I.A’!‘EI) 1ST)I’STKI ES SIIRCATECORI ES WITH ASSOCIATED SIC CODES 

Industrv Category ---- -- 

Pharmactut ical ?lanufactur& 

l Fermclntntion Products 

0 Extract ions 

l Cht~mical Syntllcsis Products 

l ?Iisin~/(:c,npo~lnding - Formulation 

l Rt>stlarch 

SIC Code -- --- ___- 

2833, 2831 

2831, 2833 

2833 

2834 

2831, 2833, 2834 

2821 

2821 

282 1 

2821 

2821 

2821 

2823 

2821 

2821 

2821 

2823 

2821 

282 1 

2821 

282 3 

l ;Ilk\ds 6 I’nsnturnted Polyester Resins 2821 

2821 

2821 

2821 

2821 

I’last its and Svnthetics (Organic 

Cht>micnls, Plastics, Synthetic 

?!,I t t’ r i 3 1 s > 

l I’olyvinvl (Ihloridc 

0 f‘olvvinvl Ac‘tbtate 

0 1’0 1 vs t vrene 

0 P~lypr~~pvlene 

0 I’olvt~thylt’nc 

0 (:t’ 1 1 ophanc 

l K;~von 

l :\HS and SAN Kes in - Copolvmc~rs 

0 P~~lvt~ster 

0 S~1011 6 

0 Gel lulc,st Acctattt 

0 ;\(.rvl its 

0 ltt hv 1 c’ne - ITiny Acetate 

0 1’~~1~~tt~trnfluorncthylene 

0 1’~) 1 vpropylcnc t-‘iber 

0 (It’1 1~1lose Sitrate 

l P~lvamide (Nvlc)n 6/12) 

l Polyester Kesins (Thermoplnst its) 

0 Si 1 iconcs 

P:rcelain Enamel in& 

0 s t e tJ 1 

0 Cast Iron 

0 Aluminum 

0 Copper 

Pgl~.,- P>~P~r_-a-nnd~ _I’aperboard 

l l’nbl cached Kraf t 

l Sodium Based neutral Sulfite 

Semi -Chemi cn 1 s 

l Ammonia Based Seutral Sulfite 

Semi-Chemical 

l I’nt~lc;tcht~d Krnft-Seutral Sulfite 

Semi-Chemical 

0 Paperboard from \?astepaper 

0 Dissolving Krnft 

c-12 

3631, 3632, 3633, 3639, 

3469, 3479, 3431 

?lainly 3631, 3431 

Yninly 3469, 3479, 3631 

?tainly 3479, Limited use 

in 3469 and 3631 

2611 

2611 

2611 

2611 

2631 

2611 
TABLE C. 3 (Cent inued) 

RECIII,ATED INDI’STRIAL SCBCATECORIES WITH ASSOCIATED SIC CODES 

Industll Categorv SIC Code -_-----_--__-__ A_ -____-- - ---~_--- _-- 

Ku-LP Paper and Payerboard (Cent inued) -?_-- ---_---_. --- 

o ?larket Bleached Kraft 

0 OCI‘ Blr~ached Kraft 

l Fine Bleached Kraft 

l Pnpcsrgradc Sul f it e 

0 Dissolving Sul f itc Pulp 

l Croundwood - Therm0 - ?lechnnical 

l Croundwood - C?IN Papers 

l (;roundwood - Fi nc Papers 

l Sod;1 

l l’nblcachr~d Krnft & Semi-Chemical 

0 Semi -Chem i (‘a 1 

0 Wnstcpnptlr - ?lolded Products 

0 Nonintr~grated - l.ightweight Paper 

0 Nonintegrated - Filter and Nonwoven 

Papers 

l Non intcigrat ed - Paperboard 

0 I)(, i ~ik 

l 5011 intcKr;it ed Fine Paper 

l Nonintegrated Tissue Papers 

0 Ti ssut’ from Was t cpnper 

l I’apcrgr:id~~ Sul f i tt (Drum Wash) 

Steam Electric f’owcr Ceneratini 

0 (;cncrnt ing I’ni t 

0 Sma 1 1 I.11 i t 

0 Old 1’11 i t 

Text i lc Indust r-L _~_ _~_ - - - - a 

l Wool Scouring 

l Wool Finishing 

0 Woven Fabric Finishing 

l Knit Fabric Finishing 

0 Carpet !lills 

l Stock and Yarn Dyeing & Finishing 

0 Sonwoven ?lanuf nc t ur ing 

l Fcltcd I-abric Processing 

Timber f’roducts 

l Wood Preserving - Bnultonizing 

l Wood f’urning and Fixtures (with 

and !<i thout Water Wash Spray 

Booths or Iaundry Facilities) 

2611 

2611 

2611 

2611, 2621 

2611 

2611, 2621 

2611, 2621 

2611, 2621 

2611, 2621 

2611 

2611 

2646 

2621 

2621 

2631 

2611, 2621 

2621 

2631 

2647 

2611, 2621 

4911, 4931 

4911, 4931 

4911, 4931 

4911, 4931 

2299 

2231 

2261, 2262, 2269 

2251-59 

2271, 2272, 2279 

2269 

2297 

2291 

2491 

2511, 25 

2531, 

12, 2517, 252 1 

2541 

‘?lainly Zero Dischargers 

‘Low Flow or Zero Discharge 

C-l 3 
1. 

3 -. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

Il. 

12. 

13. 

14. 

15. 

16. 

17. 

18. 

19. 

20. 

21. 

22. 

23. 

24. 

25. 

26. 

27. 

28. 

29. 

30 . 

31. 

32. 

33. 

34. 

35. 

36. 

37. 

38. 

39. 

40. 

acenaphthene 

acrolein 

acrylonitrile 

benzene 

benzid ine 

carbon tetrachloride 

chlorobenzene 

1 ,2,4-trichlorobenzene 

hexachlorobenzene 

1,2-dichloroethane 

1 ,l ,l-trichloroethane 

hexachloroethane 

1 ,1-dichloroethane 

1 ,l ,2-trichloroethane 

1,1,2,2-tetrachloroethane 

chloroethane 

his (2-chloroethyl) ether 

2-chloroethyl vinyl ether (mixed) 

2-chloronaphthalene 

2,4,6-trichlorophenol 

parachlorometa cresol 

chloroform (trichloromethane) 

2-chlorophenol 

1 ,2-dichlorobenzene 

1 ,3-dichlorobenzene 

1 ,4-dichlorobenzene 

3,3-dichlorobenzidine 

1 ,l-dichloroethylene 

1,2-trans-dichloroethylene 

2,4-dichlorophenol 

1 ,2-dichloropropane 

1,2-dichloropropylene (trans 

2,4-dimethylphenol 

2,4-dinitrotoluene 

2,6-dinitrotoluene 

1,2-diphenylhydrazine 

ethylbenzene 

f luoranthene 

4-chlorophenyl phenyl ether 

4-bromophenyl phenyl ether 

1.8 

0.6 

0.5 

0.2 

0.08 

0.12 

0.25 

0.05 

0.05 

0.03 

0.03 

1.6 

0.07 

0.02 

0.03 

0.52 

0.3 

0.13 

1.9 

0.64 

0.36 

0.05 

0.31 

0.15 

0.32 

0.24 

0.13 

0.13 

0.1 

0.39 

0.04 

1 ,3-dichloropropene ) 0.34 

0.32 

0.02 

0.01 

b 

0.2 

0.21 

3.9 

2.3 

TABLE C.4 

DETECTION LEVELS FOR PRIORITY POLLUTANTS 

PRIOKITY POLLUTANTa 

Detection EPA 

Level (ug/L) Met hod 

610 

603 

603 

602 

605 

601 

601 

612 

612 

601 

601 

625 

601 

601 

601 

601 

611 

601 

625 

604 

604 

601 

604 

601 

601 

601 

605 

601 

601 

604 

601 

601 

604 

609 

609 

b 

602 

610 

611 

611 

c-14 
DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued) 

PRIORITY POLLUTANTa 

Detection EPA 

Level (ug/L) Met hod 

41. bis (2-chlorisopropyl) ether 0.8 

42. bis (2-chloroethoxy) methane 0.5 

43. methylene chloride (dichloromethane) 0.25 

44. methyl chloride (chloromethane) 9.08 

45. methyl bromide (bromomethane) 1.18 

46. bromoform (tribromomethane) 0.2 

47. dichlorobromomethane 0.1 

48. chlorodibromomethane b 

49. hexachlorobutad iene 0.34 

50. hexachlorocyclopentadiene 

51. isophorone 5.7 

52. naphthalene 1.8 

53. nitrobenzene 3.6 

54. ni trophenol 0.45 

55. 4-nitrophenol 2 .R 

56. 2,4-dinitrophenol 13.0 

57. 4,6-dinitro-o-cresol 16.0 

58. N-nitrosodimethylamine 0.15 

59. N-nitrosodiphenylamine 0.81 

60. N-nitrosodi-n-propylamine 9.46 

61. pentachlorophenol 7.4 

62. phenol 0.14 

63. bis (2-ethylhexyl) phthalate 2 .o 

64. butyl benzyl phthalate (3.34 

65. di-n-butyl phthalate 0.36 

66. di-n-octyl phthal ate 3.0 

67. diethyl phthalate 0.49 

68. dimethyl phthalate 9.29 

69. benzo (a) anthracene (1,2-benzanthracene) 0.013 

70. benzo (a) pyrene (3,4-benzopyrene) 0.023 

71. 3,4-benzofluoranthene 0.018 

72. benzo (k) fluoranthane (11, 12-benzofluoranthene) 0.017 

73. chrysene 0.15 

74. acenaphthylene 2.3 

75. anthracene 0.66 

76. benzo (ghi) perylene ( 1 , 12-benzoperylene) 0.076 

77. f luorene 0.21 

78. phenanthrene 0.64 

79. dibenzo (a,h) anthracene ( 1 ,2,5,6-dibenzanthracene) 0.03 

80. indeno ( 1 ,2,3-cd) pyrene (2,3-o-phenylenepyrenr) 0.043 

81. pyrene 0.27 

82. tetrachloroethylene 0.03 

___----__- 

611 

611 

601 

60 1 

601 

611 1 

601 

601 

hl2 

609 FIDC 

610 

609 FID 

604 

604 

604 

604 

bf) 7 

697 

607 

604 

604 

606 

606 

606 

60h 

60h 

606 

610 HPLCd 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

610 HPLC 

60 1 

c-15 
DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued) 

83. toluene 0.2 

84. trichloroethylene 0.12 

85. vinyl chloride (chloroethylene) 0.18 

86. aldrin 0.004 

87. dieldrin 0.002 

88. chlordane (technical mixture 6 metabolites) 0.014 

89. 4, 4’-DDT 0.012 

90. 4, 4’-DDE (p, p’-DDX) 0.004 

91. 4, 4’-DDD (p, p’-TDE) 0.011 

92. Al pha-endosul fan 0.014 

93. Beta-endosulfan 0.004 

94. endosul fan sulfate 0.066 

95. endrin 0.006 

96. endrin aldehyde 0.023 

97. heptachlor 0.003 

98. heptachlor epoxide 0.083 

99. Alpha-BHC 0.003 

100. Beta-BHC 0.006 

101. Gamma-BHC (lindane) 0.004 

102. Delta-BHC 0.009 

103. PCB-1242 (Arochlor 1242) 0.065 

104. PCB-1254 (Arochlor 1254) b 

105. PCB-1221 (Arochlor 1221) b 

106. PCB-1232 (Arochlor 1232) b 

107. PCB-1248 ( Arochlor 124R) b 

108. PCB-1260 (Arochlor 1260) b 

109. PCB-1016 (Arochlor 1016) b 

110. toxaphene 0.24 

111. antimony (total) 10 

112. arsenic (total) 10 

113. asbestos (fibrous) b 

114. beryllium (total) 1 

115. cadmium (total) 1 

116. chromium (total) 5 

117. copper (total) 1 

118. cyanide (total) 20 

119. lead (total) 10 

120. mercury (total) 0.2 

121. nickel (total) 10 

122. selenium (total) 5 

123. silver (total) 1 

PRIORITY POLLUTANTa 

Detection EPA 

Level (ug/L) Method 

602 

601 

601 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

608 

FURe 

FUR 

FLAMEf 

FUR 

FUR 

FUR 

DIS+ 

Fgb 

FUR 

FUR 

FUR 

C-16 
DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued) 

PRIORITY POLLUTANT’ 

Detection EPA 

Level (ug/L) Method 

124. thallium (total) 10 FUR 

125. zinc (total) 1 FUR 

126. 2,3,7,8-tetrachlorodibenzepdioxin (TCDD) 0.003 

a This numbering does not correspond with numbers on EPA’s list of priority pollutants. 

b No detection limit determined. 

C Flame ionization detection (FID). 

d High pressure liquid chromatography (HPLC) . 

e Furnace ( FUR). 

f Flame (FLAME). 

I3 Distlllatlon (DIsT). 

h Cold vapor (CV). 

Source: “Methods for Organic Chemical Analysis of Municipal and,Industrlal 

Wastewater ,” Environmental Monitoring and Support Laboratory, 

Cincinnati, OH 45268. EPA-600/4-82-057. July 1982. 

Table C.4 lists the analytical methods and appropriate detection 

limits for the EPA priority pollutants. The information contained in 

“Methods for Organic Chemical Analysis of Municipal and Industrial 

Wastewater” represents an effort to provide procedures that are as 

uniform and cost effective as practical for a wide cross-section of 

chemical compound classes. Due to the variable chemical and physical 

properties of the parameters, some compromises had to be made. 

Therefore, in some of the methods, the extraction procedures, cleanup 

procedures and determinative steps are not optimum for all parameters. 

c-17