A Guide For Assessing Industrial Discharge

By Peter Chawaga

Wastewater treatment plants are staffed by hardworking operators and equipped with top-of-the-line equipment to handle the influent that comes their way and get it treated and up to code. But it’s the governing bodies and regulators that determine what that code will be and how to keep it from being breached, ultimately setting the standards for public and environmental health.

To help ensure that those standards are upheld, the U.S. EPA has released a new best practices guide aimed at addressing hazardous chemical discharges to wastewater treatment plants.

“The target audiences for the guide are National Pollutant Discharge Elimination System [NPDES] permit writers for POTWs [publicly-owned treatment works] and pretreatment coordinators for their state, region, or POTWs,” an EPA spokesperson said.

Per the Clean Water Act, the NPDES was established to address pollution into surface water. Any industrial or municipal facility that discharges waste into surface waters must obtain an NPDES permit to do so, provided by a state- or federally-employed permit writer. Wastewater treatment plants with approved pretreatment programs will also have pretreatment coordinators who can provide information about requirements and coordinate with the EPA over pertinent regulations.

The guide parses the EPA’s three main regulations for addressing toxic and hazardous pollutants: the Emergency Planning and Community Right-to-Know Act (EPCRA) for limiting toxic release inventory (TRI) chemicals, the Resource Conservation and Recovery Act (RCRA) for hazardous waste, and the Clean Water Act (CWA) for other pollutants. It also describes online tools that permit writers and pretreatment coordinators can use to gather more information about pollutants.

It was developed by the EPA’s pretreatment program, a cooperative effort between federal and local regulators to protect water quality from wastewater discharges, at the behest of the agency’s Office of Inspector General (OIG).

“The OIG recommended better linkages and coordination between EPA programs that deal with hazardous chemicals discharged to POTWs,” an EPA spokesperson said. “The OIG also recommended that information on whole effluent toxicity (WET) be more widely available [and that] better tools be available for NPDES permit writers and pretreatment coordinators to analyze TRI and WET information and apply it to the permit through the pretreatment program.”

As the EPA sees it, permit writers and wastewater treatment plants are not necessarily prepared to deal with a particularly challenging type of waste: discharge from industrial operations.

“Most wastewater treatment plants are designed to treat primarily domestic sewage,” the spokesperson said. “POTWs and permit writers for POTWs receiving industrial wastewater that is potentially hazardous or toxic must evaluate whether this influent has a reasonable potential to cause pass-through or interference and result in an NPDES permit violation.”

By describing the EPA’s regulations on statutes that address toxic and hazardous chemicals of the types found in industrial wastewater, the guide was compiled as a way to help them with that challenge and to assess whether or not they are prepared.

“Understanding whether a POTW’s industrial users are discharging toxic and hazardous chemicals is important in establishing whether a pretreatment program needs to revise or enforce new local limits, or whether a POTW without a pretreatment program needs to develop one,” said the spokesperson. “The best practices guide includes resources for permit writers and pretreatment coordinators to identify potential sources of hazardous pollutants to conduct a reasonable potential analysis.”

The guide provides tools to permit writers and coordinators which will hopefully have a trickle-down effect that aids the work of wastewater treatment plants. In turn, that should help protect us all.