Pretreatment & Pollution Prevention

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Industrial Pretreatment

The National Pretreatment Program is a cooperative effort of federal, state and local regulatory environmental agencies established to protect our water quality.

The program is designed to reduce the level of potentially toxic pollutants discharged by industry and other non-domestic wastewater sources into the municipal sewer system, and thereby, reduce the amount of pollutants released into the environment from these sources. Learn more about the success of the pretreatment program on the EPA site.

The National Pretreatment Program was established by Congress under authority of the Federal Water Pollution Control Act of 1972 (P.L. 92-500) as amended by the Clean Water Act of 1977 (P.L. 95-217). Implementation requirements of the pretreatment portion of these laws were first codified into 40 Code of Federal Regulations (CFR) Part 403 in 1978.

The National Pretreatment Program is unique in that the General Pretreatment Regulations require all large Publicly Owned Treatment Works (POTWs) (i.e., those designed to treat flows of more than 5 million gallons per day (MGD) and smaller POTWs with significant industrial discharges to establish local pretreatment programs. These local programs must enforce all national pretreatment standards and requirements in addition to any more stringent local requirements necessary to protect site-specific conditions at the POTW. More than 1,500 POTWs have developed and are implementing local pretreatment programs designed to control discharges from approximately 30,000 significant industrial users.

The Arizona Department of Environmental Quality (ADEQ) received authorization from the Environmental Protection Agency (EPA) to operate the National Pollutant Discharge Elimination System (NPDES) Permit Program (Section 402 of the Clean Water Act) on the state level in December of 2002.

 Under the Arizona Pollutant Discharge Elimination System (AZPDES) Permit Program, all facilities that discharge pollutants from any point source into water of the United States are required to obtain or seek coverage under an AZPDES permit. Pollutants can enter waters of the United States from a variety of pathways, including agricultural, domestic and industrial sources. For regulatory purposes these sources are generally categorized as either point source or nonpoint sources.

ADEQ developed rules for the AZPDES program in 2001 and revised them in 2002 and 2004. The most recent revision was published in the Arizona Administrative Code on Dec. 26, 2003. View the final version of the AZPDES rules at 18 A.A.C. 9, Art 9 effective on Feb. 2, 2004 (page 82).

Objectives of the Pretreatment program:

  1. Protect publicly owned treatment works (POTW) from pollutants that may cause interference with sewage treatment plant operations.
  2. Prevent introducing pollutants into a POTW that could cause pass through of untreated pollutants to receiving waters.
  3. Manage pollutant discharges into a POTW to improve opportunities for reuse of POTW wastewater and residuals (sewage sludge).
  4. Prevent introducing pollutants into a POTW that could cause worker health or safety concerns, or that could pose a potential endangerment to the public or to the environment.

The term "pretreatment" refers to the requirement that non-domestic sources discharging wastewater to POTWs control their discharges, and meet limits established by EPA, the State of Arizona or the local municipality (Control Authority) on the amount of pollutants allowed to be discharged. The control of the pollutants may necessitate treatment prior to discharge to the POTW (therefore the term "pretreatment"). Limits may often be met by the non-domestic source through pollution prevention techniques (product substitution, recycle and reuse of materials, more efficient production practices, improved environmental management systems, etc.), pretreatment of wastewater, or implementation of best management practices.

Approved pretreatment programs in Arizona are managed by local governments including sewerage collection and treatment agencies as defined by Arizona Administrative Code Chapter 18-09. Tempe’s pretreatment program was approved May 28, 1983 (see EPA Pretreatment program approval letter). These programs protect the environment by limiting the amount of potentially toxic pollutants entering the waters of the US and biosolids applied on the land. They also protect the health and safety of workers and sewage treatment plants from upsets by regulating industrial users that discharge treated wastes into the sewer system. Regulatory oversight of industrial sources by approved programs includes formal permitting, compliance monitoring (routine compliance inspections and sampling), and enforcement. Many pretreatment programs work effectively with industrial users to reduce contaminants in the waste stream through voluntary pollution prevention efforts.

City Regulations
To administer the program, the pretreatment section issues permits for wastewater discharges, samples and inspects industries, and manages compliance issues with regard to federal, state and local regulations.

To view the City of Tempe's legal authority to implement and enforce this program please refer to: City Code, Chapter 27, which became effective in 1983.

Other useful pretreatment documents can be found under Pretreatment Documents & Information

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).  

EPA Pretreatment Program Overview

EPA Categorical Limits and Standards

EPA Pretreatment Sector Compliance Notebooks











Pollution Prevention (P2)

What is P2?
Pollution Prevention (P2) is reducing or eliminating waste at the source by modifying production processes, promoting the use of non-toxic or less-toxic substances, implementing conservation techniques, and re-using materials rather than putting them into the waste stream. P2 is about efficiency. As non-product outputs are minimized then materials and resources are used more efficiently and profits are maximized. Since Pollution Prevention is a key policy in national environmental protection activities, a number of Partnership Programs and other EPA initiatives utilize this approach in their work.

In the 1970s, the acute and visible pollution problems of our air and water and the burgeoning problems of hazardous waste disposal pointed us toward controlling and managing the wastes that we could see. EPA developed standards, promulgated regulations and enforced the law with an emphasis on end-of-pipe solutions. These actions had a measurable and positive effect on environmental quality.

In the 1980s, more diffuse and subtle sources of pollution and better methods of detection increased awareness of how ubiquitous and long-lived our waste problems are. Difficult-to-control sources of pollution and recognition of the global nature of environmental issues brought the concept of pollution prevention as a compelling response to the prospect of further contamination. Pollution prevention was a basic reorientation of the nation's approach to pollution that would prevent problems before they occurred. The following is from the text of Pollution Prevention Act of 1990.

"The United States of America annually produces millions of tons of pollution and spends tens of billions of dollars per year controlling this pollution.

"There are significant opportunities for industry to reduce or prevent pollution at the source through cost-effective changes in production, operation, and raw materials use. Such changes offer industry substantial savings in reduced raw material, pollution control, and liability costs as well as help protect the environment and reduce risks to worker health and safety.

"The opportunities for source reduction are often not realized because existing regulations, and the industrial resources they require for compliance, focus upon treatment and disposal, rather than source reduction; existing regulations do not emphasize multi-media management of pollution; and businesses need information and technical assistance to overcome institutional barriers to the adoption of source reduction practices.

"Source reduction is fundamentally different and more desirable than waste management and pollution control. The Environmental Protection Agency seeks to address the historical lack of attention to source reduction.

"As a first step in preventing pollution through source reduction, the Environmental Protection Agency has established a source reduction program which collects and disseminates information, provides financial assistance to States, and implements the other activities provided for in the Pollution Prevention Act of 1990.

"Congress declared it to be the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner."

Why is the City of Tempe interested in P2?
Through P2 programs, businesses get into and stay in compliance with environmental laws, improve profits, productivity and become more environmentally friendly. This also helps the City reduce its costs for treatment, reduces interference with the operation of treatment facilities and risk of pass-through of toxic pollutants, prevents violation of water quality standards, prevents POTW sludge contamination, protects the health and safety of the worker, and maintains treatment capacity at the wastewater plants. This in turn saves tax dollars.

For Further information about Pollution Prevention:

Visit the EPA P2 website

Other EPA Resources 

Region 9 Information

Arizona Department of Environmental Quality (ADEQ) P2