An essential component of the National Pollutant Discharge Elimination System (NPDES) and water reclamation is the Industrial Pretreatment Program. The national pretreatment program is designed to protect the public wastewater collection systems and treatment facilities. According to the U. S. Environmental Protection Agency (EPA), the national pretreatment program is responsible for a 50% decrease in pollutants transferred to public wastewater treatment facilities since 1987.
The public collection system and treatment facilities are designed to treat domestic wastewater and because wastewater from industries is dramatically different than domestic, it must be monitored and regulated through an industrial pretreatment program. Each establishment that discharges any non-domestic wastewater is subject to the industrial pretreatment program and may be required to have a permit to discharge. The type of processes performed at the facility, the pollutants that may be discharged, and the quantity of water sent to the collection system by the facility will all be considered when determining whether or not a permit will be required.
There are certain substances and quantities of specific pollutants which cannot be discharged to the collection system. The City of Little Rock Pretreatment Ordinance gives further details on what these prohibitions are:
Ordinance
Local Limits
Categorical Dischargers
The initial step to determine if a facility will need a permit is for pretreatment staff to assess the information provided on an industrial user survey form. More information may be required through a phone call, on-site visit, or reviewing SDSs of materials that are used at the facility.
Industrial User Survey Form
Permit Application
Toxic Pollutant Scan
One of the first steps in the industrial user permitting process is for the facility to complete an Industrial User Survey form. Here, Cornelius Jones, Pretreatment/Sampling Coordinator, answers questions about the form and how to complete it.
There are fees for new permits, permit modifications or transfers, annual permits, permit renewals, noncompliance inspections and monitoring, late reporting, and special discharge inspections and monitoring. These fees are found in the Consolidated Fee Schedule.
Additionally, there are surcharges which are associated with extra strength wastewater: TSS, COD, and Oil & Grease (O&G). The surcharge rates can be found in the City of Little Rock Sewer Rate Ordinance.
Some wastewater may be hauled in and discharged at Adams Field Water Reclamation Facility. Depending on the source and composition of the wastewater, the discharger may be required to have an Industrial Pretreatment Permit.
EPA has promulgated pretreatment standards to reduce discharges of mercury from dental offices into publicly owned treatment works. Amalgam separators are a practical, affordable and readily available technology for capturing mercury and other metal before they are discharged into sewers. Dental Office Category requirements are summarized as follows:
1. Ensure the removal of dental amalgam solids from all amalgam process wastewater via amalgam separator(s) or equivalent device(s) that meet the standard of the final rule. See §441.30(a) (1-2) for an existing source and §441.40 for a new source.
2. Implementation of two best management practices. See § 441.30(b) for an existing source and §441.40 for a new source.
3. Comply with reporting requirements. See §441.50(a).
4. Maintain and make available for inspection certain records documenting compliance. See §441.50(b).
For questions regarding LRWRA's Pretreatment program or to submit reports, please email pretreatment@lrwra.com or call (501) 688-1530 or call (501) 688-1532.
Sources:
EPA Pretreatment Program Website
EPA Dental Amalgam Website