Wastewater Treatment Division

Industrial Pretreatment Program

Water is a finite resource; we have all that we will ever get. It is used over and over again, and its cleanliness must be protected.

Introduction

In the late 1960's, a spark from a train traveling over the Cuyahoga River in Cleveland, Ohio set the polluted river on fire. The Potomac River was such a threat to public health that residents needed tetanus shots if they came in contact with the water. It wasn't only the environmental community that sounded an alarm. The pollution of our waterways and its consequences caught the attention of our nation.

Wastewater treatment of some kind has been practiced by civilized society for over 100 years. However, it wasn't until 1972 that strict standards for clean water were established by the United States Congress.

In 1972, the United States Congress passed the "Water Pollution Control Act" with the purpose to "restore and maintain" the quality of our nation's water. The "Water Pollution Control Act" was amended in 1977 and re-titled the "Clean Water Act." As amended, the "Clean Water Act" includes requirements limiting the level of pollutants that industries are allowed to discharge into sanitary sewer systems. Within the Clean Water Act, the United States Congress established the Environmental Protection Agency (EPA).

In 1978, the Environmental Protection Agency (EPA) established the "General Pretreatment Program Regulations." These regulations and the subsequent amendments required the City of Broomfield and over 2,000 other Publicly Owned Treatment Works (POTW's) nationwide to operate EPA-approved Pretreatment Programs.

What is "Pretreatment"?

The term "Pretreatment" refers to the treatment an industrial discharger often must provide to its wastewater before it reaches the municipal wastewater treatment plant.

The pretreatment program is designed to prevent industrial wastewater discharges from adversely affecting the local municipal wastewater treatment plant's operations and/or its workers. The City and County of Broomfield has both legal and moral obligations to assure that its wastewater is properly treated and that the resulting bio-solids and effluent are safe for disposal or reuse. The health and economic welfare of the community are of the utmost importance to us. For this reason, Broomfield's Industrial Pretreatment Program is committed to protecting your water resources.

City Regulations

On December 8, 1981, Broomfield Mayor Walter P. Spader signed into effect Ordinance Number 463, which instituted the City's Industrial Pretreatment Program.

Federal Regulations

The "General Pretreatment Regulations" define the National Pretreatment Program. These regulations are published in Volume 40, Part 403 of the "Code of Federal Regulations" (40 CFR 403). This document is available in many libraries and government offices.

The federal Resource Conservation and Recovery Act (RCRA) regulates specific waste types as hazardous waste. The RCRA regulations are published in volume 40, Part 260 of the Code of Federal Regulations. Organizations that generate, store, or transport hazardous waste are required to notify the EPA of their activity and obtain an identification number.

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Why does Broomfield need a pretreatment program?

Broomfield has both legal and moral obligations to assure that its wastewater is properly treated and that the resulting bio-solids and effluent are safe for disposal or reuse. Broomfield's Wastewater Treatment Facility is not designed to treat toxic and hazardous wastes.

The treatment plant uses both physical and biological removal treatment processes. Certain caustic and/or acidic substances can cause extensive and costly damages to piping, pumps, and motors. However, the most common damage is that caused by toxic wastes that destroy the delicately-balanced biological treatment systems. Such damage can lead to virtually untreated wastes being discharged into Big Dry Creek and causing health hazards to the entire area. Under these conditions, the Colorado Department of Public Health and Environment and/or EPA is authorized to fine the City and County of Broomfield up to $25,000 per day, per violation.

Effectiveness of Program

Since the program has been instituted, the majority of metal contamination from industrial users has been reduced 84 to 98 percent. Another means of measuring the effectiveness of our Industrial Pretreatment Program is the actual performance of the POTW. In 1995 and 1996, no incidences of passing through, interference, or NPDES violations were related to industrial discharges.

A more contemporary measurement of an Industrial Pretreatment Program's effectiveness is the bio-monitoring procedure. This is the 48-hour static replacement median lethal concentration (LC50) procedure. The bio-monitoring tests provide an effective method for analyzing the toxicity of effluents, which may contain a broad range of contaminants that cannot be obtained solely from chemical analyses. This test determines the survival of aquatic species in various dilutions of the wastewater effluent. Broomfield's effluent is tested on a regular basis using ceriodaphnia and flathead minnows. There has been insufficient mortality to calculate an LC50 in any case.

Who must be in the pretreatment program?

Due to the wastewater reclamation facility's high susceptibility to interference and upsets from a variety of sources and pollutants, all industrial users in Broomfield, including those which also may be subject to national requirements, are required to submit a permit application. Since not all industries present an immediate hazard to the POTW, only those considered significant industrial users are required to obtain an Industrial Wastewater Discharge Permit and to share the costs of administration and enforcement.

What industries are significant industrial users?

Significant industrial user criteria is based on 40 CFR 403.3(t) and includes the following:

a. An industry subject to categorical pretreatment standards, or
b. An industrial user that:

1. discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, non-contact cooling, and boiler blowdown wastewater),

2. contributes a process waste stream that makes up five percent of more of the average dry weather hydraulic or organic capacity of the POTW treatment plant, or

3. is designated by the director on the basis that the industry has a reasonable potential for adversely affecting the POTW's operation or for violating any pretreatment standard or requirement.

All significant industrial users must meet all applicable Wastewater Discharge Permit limits in addition to the following local limits:

1. The director is authorized to establish local limits pursuant to 40 C.F.R.§ 403.5(c).

2. The following pollutant limits are established to protect against pass-through and interference and to implement provisions of this chapter. No significant industrial user shall discharge wastewater that exceeds the following limits at any time for any length of time:

Pollutant¹

Arsenic

Cadmium

Chromium

Chromium VI

Lead

Mercury

Molybdenum

Nickel

Oil and grease

Silver

Zinc

Benzene

BTEX²

¹All pollutants are to be analyzed as total.
²This is the sum of measured concentrations for Benzene, Toluene, Ethylbenzene, and Xylene.

3. The following pollutant limits are established to protect against pass through and interference and to implement provisions of this chapter. The following local limits represent the total mass that the city may receive from all permitted significant industrial users. The city shall determine the allocation of each pollutant for each user.  The total mass of pollutants allocated to these users or discharged by these users shall not exceed the following limits at any time for any length of time:

Pollutant¹

Copper

Selenium

¹All pollutants are to be analyzed as total.

Are there further requirements?

Significant industrial users are required to monitor and submit periodic reports on their discharges; develop pretreatment systems to assure no discharge in excess of the legal amount; and to provide adequate facilities for Broomfield to monitor their discharges.

All industries are required to report to the Industrial Pretreatment Program any changes in their processes that could result in a change in their discharge. Periodic inspections must be allowed, if requested, in order to confirm compliance.

Commitment

Finally, the health and economic welfare of the community are of the utmost importance to us. For this reason, the City and County of Broomfield's Industrial Pretreatment Program is committed to protecting your water resources.

For further information, please contact:
Dennis R. Rodriguez
Industrial Pretreatment/Stormwater Administrator
2985 West 124^th Avenue
Broomfield, Colorado 80020
Telephone: 303.464.5648
Fax: 303.464.5652

e-mail: Dennis Rodriguez

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