Broomfield Wastewater Reclamation Facility

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 which 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 was tested in January, April, July, and November using ceriodaphnia and flathead minnows. There was 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 critical are required to obtain an Industrial Wastewater Discharge Permit and to share the costs of administration and enforcement.

What criteria are used to classify?

A critical industry or business is one that either discharges or stores potentially hazardous wastes. Critical dischargers are required to submit an application for an Industrial Wastewater Discharge Permit. After a review of the application and an inspection of the applicant's facility, the discharger will be classified either as a significant contributor or a potential contributor. Significant and potential contributors are placed in one of four sub-classifications, according to the type of pollutants present.

Permit Classification

Class 1A - Any discharger subject to categorical pretreatment standards that discharges federally regulated wastewater to the POTW.

Class 1B - Any non-categorical industry that contributes a process waste stream.

Class 2A - Any industry that may be subject to reporting discharges in order to comply with the Code of Federal Regulations, title 40, section 403.12, or any categorical industry that has a fully contained system and does not have open floor drains or sink drains connected to the wastewater collection system in any area where the federally regulated process wastewaters are present. This includes, but is not limited to, industries that discharge hazardous waste in any amount in excess of 15 kilograms per month or acutely hazardous waste in any amount.

Class 2B - Any industry that discharges process wastewater containing priority pollutants not regulated by categorical pretreatment standards directly to the wastewater collection system and under normal and proper operation does not contribute those pollutants in excess of the limitations set by Chapter 13.28 or has the potential to adversely affect the POTW.

Chapter 13.28 "Wastewater" Discharge Limitations

SCHEDULE 13-28-A
LIMITATIONS ON DISCHARGES
SPECIFIC POLLUTANT LIMITATIONS

Table A. All users, except where mass limits have been established, shall not discharge any wastewater with pollutant concentrations exceeding the following limits:

Maximum Concentrations in mg/l*

*All concentrations are totals for the listed pollutant or pollutant property, except where otherwise indicated.

Table B. The total mass of pollutants allocated to Significant Industrial users through 13.28 Schedule A and 13.28.070 (B)(2) shall not exceed the following Maximum Allowable Headworks Load (MAHL):

• All pollutants shall be measured and reported as total concentrations. **These pollutant/pollutant properties shall be grab samples, all others listed shall be composite samples.

Table C. Total BTEX (benzene, toluene, ethyl benzene and xylene) and Benzene