Setting Local Limits for Industrial Discharge: A Case Study
Dianna S. Kocurek - Tischler/Kocurek, Gayle Woodside - IBM (SSA Journal Volume 9 Number 3/4 - Fall 1995 pp. 13 - 17 )

The federal pretreatment regulations at 40 CFR 403 require publicly-owned treatment works (POTWs) to control the discharge of non-domestic wastewaters. POTWs are typically wastewater treatment plants operated by a city, town, or other municipality. Non-domestic wastewaters, although not strictly defined in the regulations, are wastewaters that are not normally though of as domestic, that is, originating from residential dwellings. Typically, non-domestic waste waters are discharge from industrial sources. POTWs control non-domestic discharges through highly structured pretreatment programs required by the federal regulations. POTWs that must develop pretreatment programs are those with a total flow (domestic and non-domestic) greater than five million gallons per day (MGD). If multiple POTWs are controlled by the same authority, and their combined flow is greater than 5 MGD, then they too must develop pretreatment programs. Additionally, the non-domestic wastewater must contain discharges that are either subject to federal pretreatment standards or contain pollutants that will cause problems for the POTW. In reality, almost any city with a wastewater flow greater than 5 MGD will be large enough to have some industrial development that will require the city to establish a pretreatment program. This article discusses the requirements of a pretreatment program, with emphasis on the requirement for a local limits program. The article describes the process by which local limits are set and presents the City of Austin's recent experience in obtaining approval for their local limits program by EPA as a case study. The participants invited to help set the local limits, the role of the EPA and the Austin City Council, and the methods approved for calculating the local limits are described. Further, flexibility within the process that achieves environmental protection for the receiving waters while allowing for industrial process flexibility and growth is discussed.