Industrial Pretreatment Program

Q: How do I apply for an Industrial Pretreatment Program permit?

To apply for a pretreatment permit (new or renewal), fill out a Wastewater Discharge Permit Application and mail it to the address indicated on the form. For new industrial users who are unsure if they are subject to the Industrial Pretreatment Program, the Wastewater Survey for Non-Residential Establishments should be filled out and returned to the Industrial Pretreatment Program Administrator. Based on the information provided, the City will determine if the discharge is subject to the Industrial Pretreatment Program, and then a permit application must be completed.

Q: What are regulated industries required to do?

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 the City 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. View the City’s Municipal Code. https://www.ecode360.com/27648005

Q: What industries are significant industrial users and required to be permitted?

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: 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), contributes a process waste stream that makes up five percent of more of the average dry weather hydraulic or organic capacity of the City’s treatment plant, or is designated by the City on the basis that the industry has a reasonable potential for adversely affecting the City’s operation or for violating any pretreatment standard or requirement.

Q: What is the Industrial Pretreatment Program?

The Industrial Pretreatment Program permits, monitors and regulates a variety of industries in order to protect the City’s treatment plant and the Mississippi River from the discharge of harmful contaminants. Typical industries that are regulated are: Electroplaters, metal finishers Chemical Manufacturers Casting Facilities Food Manufacturers Dental Offices Other businesses that put chemicals into the City’s sewer system. The Industrial Pretreatment Program conducts audits and compliance monitoring inspections. The purpose of the inspections are to collect and confirm information concerning an industrial user and its regulated processes and to evaluate the industry’s compliance with the applicable pretreatment standards and regulations. The Industrial Pretreatment Program is primarily concerned with identifying the wastewater pollutant pathways through the industrial user, evaluating the effectiveness of pretreatment and/or monitoring systems and verify that residue associated with the removal of wastewater pollutants is disposed properly.

Q: Why is the Industrial Pretreatment Program necessary?

Discharging certain substances into the sewer system can: interfere with the operation of the wastewater treatment plant by upsetting the biological process and killing the microorganisms needed for proper treatment Jeopardize the health and safety of sewer workers. Clog sewer lines Be extremely dangerous if dumped in high concentrations. Mix with other chemicals to form toxic gases. Harm the environment (Mississippi River) The City’s treatment plant is not designed to remove heavy metals, cyanide or other toxic chemicals. Approximately 40 to 60 percent of these substances can settle out of the wastewater and into the sludge, contaminating it and preventing its reuse, while the remainder empties into the receiving waters like the Mississippi River. Other chemical can flow through the treatment plant and not get removed. Once this happens, marine life is exposed to toxic substances, which may enter the food chain and can eventually affect people. In addition, these toxins can prevent the City from meeting its effluent limits that are established by EPA and Missouri Department of Natural Resources. To control toxic discharges at the source, the EPA and Missouri Department of Natural Resources require that the City implement an Industrial Pretreatment Program.

The City’s Industrial Pretreatment Program is a collaboration of citizens, the business community, and City staff working together to protect the environment and O’Fallon’s wastewater treatment systems while meeting local, state and federal environmental regulations.

The Industrial Pretreatment Program’s primary goal is to protect the integrity of the sewer collection system, ensure proper operation of the City’s Wastewater Treatment Plant, and prevent the introduction of harmful pollutants into the treatment system. The Program is mandated by the U.S. Environmental Protection Agency and the Missouri Department of Natural Resources in their efforts to protect our State’s natural environment.

The Program accomplishes this by maintaining an up-to-date list of industrial users within the service area and by conducting compliance inspections of on-site pre-treatment systems who receive sewer service from the City of O’Fallon.

The Program also includes issuing and enforcing Industrial Wastewater Discharge Permits to Significant Industrial Users in order to limit the volume and strength of discharged wastewater and requires the implementation of on-site pollution prevention protocols and regular maintenance of wastewater pretreatment facilities. Significant Industrial Users must conduct routine self-monitoring of their wastewater discharges and report compliance status to the City. Additionally, City staff monitor reports and conduct routine inspections of Significant Industrial Users to ensure permit compliance.

The City of O’Fallon is legally and morally obligated to assure that 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, O’Fallon’s Industrial Pretreatment Program is committed to protecting your water resources.

Background:

National Pretreatment Program

The national pretreatment program is a component of the federal Clean Water Act. It is a cooperative effort of federal, state, and local environmental regulatory agencies established to protect water quality. The EPA and Missouri Department of Natural Resource authorizes and requires local municipalities to perform permitting, administrative, and enforcement tasks for discharges into the municipalities’ publicly owned treatment plants. The program is designed to:

protect publicly owned treatment plants
reduce conventional and toxic pollutant levels discharged by industries and other nondomestic wastewater sources into municipal sewer systems and into the environment.

The national pretreatment program requires nondomestic dischargers to comply with pretreatment standards to ensure the goals of the federal Clean Water Act are attained.

The objectives of the program are to:

prevent the introduction of pollutants into the City’s treatment plant that will interfere with its operation, including interference with its use or disposal of municipal sludge,
prevent the introduction of pollutants into the City’s treatment plant that will pass through the treatment works or otherwise be incompatible with it, and
improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.

The national pretreatment program identifies specific discharge standards and requirements that apply to sources of nondomestic wastewater discharged to the City’s treatment plant. By reducing or eliminating waste at the industries (“source reduction”), fewer toxic pollutants are discharged to and treated by the City’s treatment plant, providing benefits to both the City’s treatment plant and the environment.

NEW — EPA Rule for Dental Offices:

On June 14, 2017 the U.S. EPA published Dental Effluent Guidelines to reduce discharges of mercury from dental offices to municipal wastewater systems. Dental facilities subject to the rule must achieve the following:

Remove dental amalgam solids from process wastewater using an ISO 11143 separator or equivalent.
Implement Best Management Practices including not discharging waste amalgam and not using cleaners with pH lower than 6 or greater than 8.

Additional Information:

For further information and/or permit applications, please call 636-379-2212.

Frequently Asked Questions:

How do I apply for an Industrial Pretreatment Program permit?

What are regulated industries required to do?

What industries are significant industrial users and required to be permitted?

What is the Industrial Pretreatment Program?

Why is the Industrial Pretreatment Program necessary?

Quick Links:

Introduction to the National Pretreatment Program (EPA, 2011) - https://www.epa.gov/sites/production/files/2015-10/documents/pretreatment_program_intro_2011.pdf
Clean Water Act – https://www.epa.gov/environmental-topics/water-topics#what-you-can-do
Federal EPA Regulations (40 CFR 403) – https://www.ecfr.gov/cgi-bin/text-idx?SID=058d52179bb45249a56ffa20e0f9ccee&mc=true&node=pt40.31.403&rgn=div5
Categorical Pretreatment Standards: https://www.ecfr.gov/cgi-bin/text-idx?gp=&SID=058d52179bb45249a56ffa20e0f9ccee&mc=true&tpl=/ecfrbrowse/Title40/40CIsubchapN.tpl
Missouri State Pretreatment Regulations (refer to 10 CSR 20-6.100): https://www.sos.mo.gov/cmsimages/adrules/csr/current/10csr/10c20-6.pdf
EPA IPP Regulations – https://www.epa.gov/npdes/national-pretreatment-program
EPA Dental Fact Sheet – https://www.epa.gov/sites/production/files/2016-12/documents/dental-elg_final_fact-sheet_12-2016.pdf
Dental Effluent Guidelines – https://www.epa.gov/eg/dental-effluent-guidelines
O’Fallon Municipal Code – https://www.ecode360.com/27648005

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