Pretreatment Review of TPDES Permit Applications & How to Identify Industrial Users Bianca Cooper & David James May 17, 2017 Water Quality Division Texas Commission on Environmental Quality

Introduction All publicly owned treatment works (POTWs) that discharge to a waterbody of Texas, must apply for a Texas Pollutant Discharge Elimination System (TPDES) permit. The application to discharge wastewater goes through a series of administrative and technical reviews before a permit is written and issued.

TPDES Permitting Process Application Received by TCEQ Administrative Review Technical Review Standards and Assessment Review Draft Permit Sent for Comments Pretreatment Review Simple permitting process diagram

Pretreatment Review – Domestic Worksheet 6.0 All POTWs must complete Worksheet 6.0 as part of their TPDES permit application Include SIUs, CIUs, and other IUs discharging to the WWTP Based on total number, average process flow, and other information Worksheet 6.0 – Industrial Waste Contribution. This worksheet requests information on the numbers and types of industrial users that contribute wastestreams to the POTW as well as any instances of interference or pass through that the WWTP has experienced in the past three years. When the TCEQ pretreatment staff review Worksheet 6.0 of the permit application and find that the POTW is not receiving discharges from SIUs or CIUs, or other information to be considered, the staff will develop language for the contributing industries and pretreatment requirements section of the TPDES permit that we call Option 1.

Pretreatment Review – Worksheet 6.0 Section 1.A: Use results from water billing records or surveys CIUs, SIUs, or Other IUs: Enter “0” or “None” if none are discharging. Do not enter “N/A” Any issues in the sanitary sewer system or WWTP? Include dates, duration, description of issue, sources Copy of the actual Domestic worksheet 6.0 – Industrial Waste Contribution Application Form, page 1. Domestic Technical Report was updated Sept. 1, 2016 and can be found on TCEQ website

Pretreatment Review – Worksheet 6.0 Section 3: Include required information for all SIUs and CIUs B. Process Information: Provide as much detail as possible Copy of the actual Domestic worksheet 6.0 – Industrial Waste Contribution Application Form. Note that other IU’s are not included in No. 3.

Pretreatment Review – Worksheet 6.0 Section 3, Items C-E: Describe the product, provide flows, and applicable rules Section 3: Industrial Interruptions Describe any problems caused by IUs, i.e. interference or pass through Copy of the actual Domestic worksheet 6.0 – Industrial Waste Contribution Application Form, page.

TPDES Permit - Pretreatment Options 1 and 2

POTWs not required to have an approved pretreatment program TPDES Pretreatment Permit Language “CONTRIBUTING INDUSTRIES AND PRETREATMENT REQUIREMENTS” Option 1 POTWs not required to have an approved pretreatment program Option 2 POTWs are required to conduct an industrial waste survey (IWS) and may be required to develop a pretreatment program

TPDES Pretreatment Permit Conditions Option 1 No approved pretreatment program No development of a pretreatment program No formal Industrial User survey Permit Language Requirements General and Specific Prohibitions 40 CFR §403.5 POTW notification requirements New introduction of pollutants Substantial changes in volume or character of pollutants Require any indirect discharger to: Comply with the reporting requirements of Sections 204(b), 307, and 308 of the Clean Water Act The Contributing Industries and Pretreatment Requirements section of the TPDES permit will have pretreatment language based on the information in Worksheet 6.0. Option 1 has the general and specific prohibitions. The majority of POTW’s are in this category. As discussed earlier, the general and specific prohibitions are included in the Opt. 1 language. In addition, the POTW must notify the TCEQ when there is a substantial change in the Industrial contribution to the POTW or anything that may impact the WWTP.

TPDES Pretreatment Permit Language Option 2 Activity No. 1 Submit an industrial user survey Due within 60 days of issued permit Based on results, TCEQ will determine if program development is required or not POTWs that are (or may) be required to develop a pretreatment program When Option 2 is assigned to a TPDES permit, it will include a table to complete for the IU survey.

Industrial Users Identification and Survey

Problems and Discharges to Consider Collection System: Stoppages or overflows? Corrosion of lines? Wastewater Treatment Plant: Exceeding permit discharge limits? Biomonitoring or WET failures? Exceeding sludge criteria for its disposal method? Unusual or noxious odors? Industrial Users (IUs) Excessive amounts of pollutants or hydraulic loads? Excessive fats, oils, or grease (FOG)? Wastewater with high or low pH? POTWs need to identify and to evaluate potential problems at the WWTP. These problems include collection system stoppages and overflows, effluent violations, and sludge contamination. Once you identify the problem (e.g., high pollutant loadings, high flows, oil & grease, or pH extremes), the next step is to identify possible industrial sources. The picture denotes a sewer overflow from a manhole.

How to Identify Industrial Users Water billing records Applications for sewer service Building permits Property tax records POTW collection system personnel POTW treatment plant operators As mentioned earlier, to identify IU’s, one may begin by looking at water billing records, applications for sewer service, building permits, property tax records, POTW staff, as well as consulting with the City personnel. Wastewater collection system and wastewater treatment plant personnel frequently know of problem dischargers.

How to Identify Industrial Users (cont.) Business and telephone directories Texas Manufacturer’s Directory Chamber of Commerce records Economic Development organizations Direct observation (drive-by) Internet searches Toxic Release Inventory (TRI) www.epa.gov/TRI/ EPA Envirofacts www.epa.gov/enviro/ Hazardous Waste Generators Examples of other resources you can use to identify industrial users include business directories such as the Texas Manufacturer’s Directory, telephone, chamber of commerce records, Economic Development organizations, drive-bys and the internet, such as the TRI and Envirofacts that can help identify industries that may discharge toxic or hazardous substances. Trade Associations (e.g. metal finishers, etc.) Ask your currently permitted industries of any known competitors in the area, etc. Contributions to the POTW may be from connections outside the service area or City limits. Once you have exhausted these resources, you will have made a master list of industrial users located in the POTW’s service area

Facility Types – Commonly Missed Small metal plating facilities Metal Finishing (40 CFR Part 433) Truck washing facilities Transportation & Equipment Cleaning (40 CFR Part 442) Grease & Grit Processing facilities Centralized Waste Treatment (40 CFR Part 437) Facilities with no categorical pretreatment standards Hospitals (40 CFR Part 460) Meat and Poultry Products (40 CFR Part 432) Plastic Molding and Forming (40 CFR Part 463) And several others Some of the common types of facilities that are overlooked are listed here. For example small metal plating facilities, or facilities that do not have categorical standards and facilities that might impact the collection system as well as the WWTP. For example, meat and poultry facilities do not have categorical standards. However, due to their high strength waste they may impact the POTW. Some truck washing facilities may be subject to the TEC depending on what they hauled and the volume of wash water used. Grease and grit trap processing facilities may be subject to CWT categorical pretreatment standards due to grit processing. Hospitals have cafeterias and may possibly discharge metals or certain hazardous wastes. Possibly industrial laundry facilities could give you problems due to the volume, temperature, metals, oily wastes, or high-strength waste.

Industrial User or Waste Survey Compile master list of potential IUs in service area – consider… IUs with high water usage IUs that might impact the POTW Standard Industrial Classification (SIC) code North America Industrial Classification System (NAICS) code Compare to categories: 40 CFR Parts 405-471 The industrial user survey includes commercial users that are sources of any pollutants of concern, such as photo processers, dentists, and restaurants. In order to determine if these facilities use and discharge process wastewater and obtain additional information about them, you will want to send out a questionnaire or survey form requesting this information. The TCEQ is happy to share the form with you that developing pretreatment programs must use.

Industrial User Survey (cont.) Survey each IU to collect information Conduct follow-up inspections Conduct follow-up telephone calls Summarize data Maintain and update IU list

TPDES Permit - Pretreatment Options 3 and 4

TPDES Pretreatment Permit Language “CONTRIBUTING INDUSTRIES AND PRETREATMENT REQUIREMENTS” Option 3 POTWs within an approved pretreatment program Has SIUs discharging to the specific WWTP Option 4 No SIUs discharging to the specific WWTP

TPDES Pretreatment Permit Language Option 3 WWTPs: Have an approved TPDES pretreatment program 40 CFR Part 403 requirements Reassessment certification of existing TBLLS Notification to redevelop existing TBLLs Either due 60 days after permit issuance Technically based local limits (TBLLs) This slide outlines TPDES Pretreatment Option 3 and requirements. Written certification of TBLLs reassessment is Form No. 20221

TPDES Pretreatment Permit Language Option 3 WWTPs: Due on specified month WWTP influent/effluent monitoring List of SIUs in significant noncompliance (SNC) and newspaper publication Annual Report New introduction of pollutants Substantial changes in volume or character of pollutants Notification Requirements

TPDES Pretreatment Permit Language Option 4 WWTPs: Covered under approved TPDES pretreatment program No SIUs in the service area of the plant Notification requirements still apply Influent/effluent sampling not required TBLLS may applicable through the pretreatment ordinance, based on allocation method used. Since the permit does not have influent/effluent sampling, the notification requirements are really important because industries may begin discharging during the permit term, and the notification usually comes through the annual report, for example.

Stormwater & Pretreatment Team (512) 239-4671