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For more information, contact David Eppstein by email at
deppstein@masco.harvard.edu, or by calling 617-632-2860.

 
2.0 BACKGROUND INFORMATION ON PRETREATMENT

In areas served by municipal sewers, pretreatment of industrial wastewater discharges is often required to limit the discharge of toxic, corrosive, or other pollutants into the sewer system and associated sewage treatment facilities. Sewage treatment facilities that are owned by states and municipalities are known as Publicly Owned Treatment Works (POTW). For purposes of this Manual, pretreatment means the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to or in lieu of discharging or otherwise introducing such pollutants into a POTW. The reduction or alteration may be obtained by physical, chemical, or biological processes, process changes or by other means, except not by dilution.

In most districts, both general and specific discharge limits are applied to all industrial users of the POTW system. In general, industrial wastewater sewer discharges must be controlled to prevent:

  • Harm or interference with the sewer system or any POTW treatment process, including sludge use, management, or disposal.

  • Passage (pass-through) of untreated pollutants through the POTW that could cause a violation of any federal or state law or permit.

  • Any violation of water quality criteria from the POTW effluent or adverse effects on the receiving waters.

  • Threat of endangerment of the life, health, or welfare of any person or persons (including sewer and POTW workers) or of the public health, safety, or welfare, or the environment, or public property (including fire or explosion hazards in sewers or the POTW).

As part of the EPA National Pollution Discharge Elimination System (NPDES) permit system, the operator of a POTW is periodically required to evaluate the specific discharge limits it sets for industrial wastewater relative to existing federal and state environmental quality criteria. These specific industrial discharge limits are called Local Limits. To conform with federal and state guidelines, an evaluation of Local Limits must be based upon a substantial body of analytical data including the quantity and quality of industrial sewer discharges, non-industrial sewer discharges, treatment plant pollutant removal rates, and residual biosolids (sludge).

In the Boston Metropolitan Sewerage Service Area, the MWRA found in its Local Limits evaluations that specific industrial discharge limits were required for several heavy metals and organic compounds and, furthermore, that prohibitions were required for industrial discharges of pesticides, polychorinated biphenyls, phenanthrene, and mercury. The applicable Local Limits and discharge prohibitions are included in the MWRA Sewer Use Regulations (360 CMR 10.000) and appear as requirements in all MWRA sewer use permits issued to industrial dischargers.

For mercury, the MWRA developed an enforcement limit for the prohibition that requires that samples of an industrial discharge show a maximum mercury concentration of 1.0 micrograms per liter (µg/L)1. The basis for this enforcement limit is a statistical evaluation that determined that mercury would be present if detected in a wastewater sample at a concentration greater than 1.0 µg/L (i.e., five times the typical analytical laboratory detection limit of 0.2 µg/L). Thus, adoption of the enforcement limit eliminates the possibility of a false positive analytical result for which the MWRA would take a noncompliance enforcement action.

To comply with the MWRA Local Limits, each permitted industrial facility should study its proposed or existing wastewater discharges to find the most economical and practical approaches to meet the Limits. For some facilities, compliance with all Local Limits may be achieved by implementation of a source reduction program. For other facilities, source reduction combined with pretreatment, or pretreatment alone, may be required. Often, the lowest capital and operating costs for a new pretreatment system are achieved when the system at each discharge point is integrated with source reduction, source segregation, and other aspects of facilities management.

        1The concentration unit of (µg/L) is often referred to as "parts per billion" (ppb).

 

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08/16/2006

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