This blog installment describing a Pretreatment Program discusses the Pretreatment Program and its important elements.
Once the determination has been made that a POTW requires a pretreatment program, NPDES permit will be modified to include the requirement to develop and submit the program to the State for review and approval.
Pretreatment Program must contain the following elements:
1) Legal Authority – POTW must operate pursuant to legal authority enforceable in federal, State or local courts, which authorizes or enables the POTW to enforce its pretreatment rules and regulations developed pursuant to the CWA and implementing regulations.
2) Procedures – the appropriate procedures must be followed to ensure compliance with pretreatment requirements.
3) Funding – the municipality must have appropriate funding to carry out the authorities and procedures specified in its approved pretreatment program.
4) Local Limits – The governmental entity must develop the limits or demonstrate why these limits are not necessary.
5) Enforcement Response Plan (ERP) – The program must have an ERP containing detailed procedures, including how the POTW will investigate and respond to instances of IU compliance.
6) List of SIUs – the city must prepare a list of Significant Industrial Users (SIUs), update it and submit it to the State and also indicate the applicable type of Industrial Users (IUs).
7) Statement of Authority – A statement from the City solicitor or equivalent declaring that the POTW has adequate authority to carry out program requirements.
8) Statutes, regulations, ordinances – Copies of statutes, regulations, ordinances that the POTW relies upon to administer the pretreatment program – including a statement reflecting the endorsement or approval of the bodies responsible for supervising or funding the program – is required for cities.
9) Organizational chart – A brief description and organizational chart of the organization administering the program.
Pretreatment program submissions that are complete proceed to the public notice process. Upon approval, State is responsible for modifying the Permit to require implementation of the approved pretreatment program. Once approved, State will oversee program implementation by receiving annual POTW reports and conducting periodic inspections.
In my next blog I will be talking about different Pretreatment Standards.
If you have any questions, please contact me at shrivani@smithmanage.com
Source: U.S. EPA Introduction to the National Pretreatment Program, 2011.