City of Dayton Industrial Pretreatment Program GUIDE FOR BUSINESSES

The City of Dayton recognizes that businesses that discharge non-residential wastewater to the sewer system may face a complex and often confusing array of regulations. For this reason, the City's Industrial Pretreatment Program developed this guide as an introduction to the rules and regulations contained in the City of Dayton Sewer Use Ordinance. This ordinance applies to all new and existing businesses which discharge wastewater within the City of Dayton's sewer service area. We hope this guide will be useful in answering questions you may have concerning site inspections, monitoring of wastewater discharges, obtaining applicable permits, and complying with wastewater discharge regulations. We encourage you to keep a copy of this guide available as a reference. If you have any questions regarding the Pretreatment Program, please contact a Division of Wastewater Pretreatment Coordinator at 937-333-1501.

THE NEED FOR WASTEWATER PRETREATMENT

Wastewater treatment plants are very effective at treating domestic (household) sewage through a combination of biological, physical and chemical processes. Domestic sewage is characterized by its lack of toxic or potentially harmful substances in significant concentrations, and does not require pretreatment before discharge to the sewer system.

However, businesses often use concentrated quantities of solvents, acids, chemicals, heavy metals, or other materials, and have the potential to discharge concentrated amounts of such materials into the sewer system. By themselves, or in combination with other substances, these concentrated materials can destroy sewer lines, produce hazardous gases, or create flammable or explosive conditions. These same materials can also interfere with the operation of the wastewater treatment plant or pass through untreated, resulting in a lower quality of effluent entering the Great Miami River. Controlling these discharges at their source - by pollution prevention methods, pretreatment of wastewater before discharge, and by prohibiting the discharge of specific hazardous substances to the sewer system - eliminates many of the problems associated with non-residential wastewater discharges.

In addition, the City of Dayton has an established a reuse and recycling program for the biosolids (treated solids) which are produced as a result of the wastewater treatment processes. The biosolids are utilized on farmland as a fertilizer and soil amendment. In order for the City to maintain the biosolids recycling program, pollutants that may pass through the wastewater treatment process and contaminate the biosolids must be kept from entering the sewer system. The Pretreatment Program and the Sewer Use Ordinance are the City's primary means for assuring that the biosolids meet the EPA's rigorous quality standards for land application.

REGULATORY AUTHORITY

The wastewater treatment field is regulated on every facet of the environment: air (emissions from the treatment plant and power generating systems), land (recycling of biosolids) and water (discharge of treated effluent into the river). The Federal Clean Water Act is the primary law controlling water pollution. The Act provides for the establishment of industrial pretreatment programs and industrial wastewater discharge regulations. Authority to administer pretreatment programs was delegated from the U. S. Environmental Protection Agency to the Ohio Environmental Protection Agency. When the City developed its pretreatment program and its Sewer Use Ordinance, the Ohio EPA delegated the City of Dayton authority to administer the program in the City's sewer service area.

The primary objectives of the Pretreatment Program are to:

• Protect the environment, and public health and safety;
• Provide safe working conditions for sewer utility workers;
• Protect the sewers and wastewater treatment plant from damage due to an accidental or deliberate discharge of pollutants;
• Prevent the introduction of substances that would block or obstruct the sewer system;
• Prevent the introduction of pollutants into the sewer system which would interfere with the wastewater treatment process, or pass through the plant and into the Great Miami River;
• Improve the opportunity to reclaim and recycle municipal wastewater and biosolids.

The City of Dayton's Industrial Waste Pretreatment Program provides the authority, through Sewer Use Ordinance No.29641-98, for the Pretreatment Program staff to:

• Identify and define prohibited wastes;
• Develop local limits on specific pollutants;
• Obtain access to facilities for inspections and sampling;
• Require non-residential dischargers to provide an adequate sampling location;
• Require treatment of non-domestic wastes to meet discharge standards;
• Require the implementation of pollution prevention methods
• Require non-residential dischargers to submit applications and obtain discharge permits;
• Require non-residential dischargers to monitor their discharge and submit reports;
• Take enforcement action for non-compliance with the program regulations.

PRETREATMENT AND PROHIBITED WASTES

Your facility will be required to pretreat your wastewater (remove toxic and other restricted substances) and/or apply pollution prevention methods before discharging into the City's sewer system if your wastestream contains:

• Prohibited wastes such as:
  • Flammable or explosive substances
  • Highly toxic and poisonous substances
  • Solid or viscous substances which may obstruct flow
  • Wastewater having a pH less than 6.0 or greater than 12.0
• Pollutants in excess of federal, state and local limits
• Wastes which may damage or clog sewer transmission facilities and pipelines

The Pretreatment Program also restricts the total quantity of the materials entering the sewer system. Some of the materials that may be restricted /include:

• Acids and/ or bases
• Wastes with high temperatures
• High B.O.D. (high organic loading)
• High suspended solids
• Heavy metals
• Fats, oils and greases (FOG) in excess of 100 mg/L

BUILDING PERMIT APPLICATIONS

Non-residential customers applying for a building permit may be asked to provide specific information as to the nature of the wastewater to be discharged from their facility, and how the wastewater will be generated. Information concerning chemicals, fuels, solvents, maintenance chemicals, etc. that will be brought or stored on site and which could have the potential to enter the sanitary or storm sewers will need to be provided as well. The applicant may also need to provide information on floor drains, sumps, or other connections to sewers, and submit required plans or drawings. If your business uses restricted materials, a pretreatment process or pollution prevention may be required prior to discharging to the sewer system.

INDUSTRIAL WASTEWATER DISCHARGE PERMITS

You will be asked to complete an Industrial Wastewater Discharge Permit Application if your business appears to be a Significant Industrial User or a Categorical Industrial User.

A Significant Industrial User is a facility that discharges 25,000 gallons per day of process wastewater, contributes 5% of the flow or loading to the treatment plant, has the potential to violate pretreatment standards, or which may have a potentially significant impact on the wastewater treatment plant. Process wastewater does not /include sanitary (restrooms, showers, kitchens, etc.) or non-contact heating or cooling wastewater.

A Categorical Industrial User generates wastewater classified under any of the industrial categories identified in the Code of Federal Regulations, Title 40 (40 CFR), Parts 401, 403 and 405 through 471. A specific list of categorical industries is in 40 CFR, Part 403, Appendix C & D. There are specific state and federal regulations that apply to categorical industries.

Proposed new significant or categorical users must submit the Industrial Wastewater Discharge Permit Application at least 90 days prior to sewer connection. If, after the City's review of the completed permit application, it can be verified that you have no categorical industrial waste discharge, no significant process wastewater flow to the sewer system, and no potentially significant impact on the wastewater treatment plant, you will not need to obtain an Industrial Wastewater Discharge Permit. You may, however, be issued one of several types of minor control documents that impose specific requirements or limitations for your wastewater discharge.

Note: If your facility does require an Industrial Wastewater Discharge Permit, you should take into consideration the time frames involved in the issuance of the permit. Once the completed application form is received, it can take 30 to 60 days to write a draft permit. Your business will then have an opportunity to review and comment on the draft permit.

An Industrial Wastewater Discharge permit must be issued prior to the discharge of any significant or categorical process wastewater. Other wastewater not requiring a permit may be discharged prior to issuance of the Industrial Wastewater Discharge Permit as long as any necessary spill prevention procedures or facilities are in place. This means a facility can be occupied and discharge sanitary flows only while an Industrial Wastewater Discharger Permit is being obtained, provided all other applicable requirements for sewer use, building permits, fire codes, etc. are met.

Careful attention on the part of the permittee is required to assure that all Industrial Wastewater Discharge Permit conditions are met. All permits require that the business report any change of location or ownership of the business, changes in the facility's wastewater strength or flow, or any other changes in the production processes. Permits are generally issued for a 5-year time period. A permit renewal application must be submitted at least 90 days prior to the permit expiration.

Any pretreatment facilities required to treat industrial wastewater prior to discharge to the sewer must also meet the requirements of the Ohio EPA for submittal of an application for a Permit To Install (PTI), including submittal of information such as an engineering report, plans, and technical specifications. A PTI should be issued by the Ohio EPA prior to the discharge from the pretreatment facility.

SPILL PREVENTION

You may also be required to develop a Spill Prevention Plan if your facility: 1) has floor drains, catch basins, sumps or any other outlet to the sewer system other than restrooms, 2) uses, mixes and/or stores chemicals, paints, oils, solvents, detergents and/or fuels onsite. Any accidental discharges of prohibited or controlled materials must be reported immediately to the City of Dayton, Division of Wastewater Treatment.

MONITORING REQUIREMENTS

Your business may be required to monitor and test its wastewater discharge and submit regular reports as required by your Industrial Wastewater Discharge Permit. The permit will specify the sampling locations, the type and frequency of samples to be collected, the parameters the samples must be tested for, the discharge limits for each parameter tested, record keeping requirements, and the due dates for submittal of the facility's discharge monitoring reports (Periodic Reports on Continued Compliance) and any other report or documentation as required. Self-monitoring reports require a signature by an authorized person declaring that the information contained in the report is true, accurate and complete.

SITE INSPECTIONS

Pretreatment Program staff may conduct inspections at any businesses that discharge into the City's sewer service area. These site visits allow the pretreatment staff to become familiar with the types of businesses within the service area, determine if the discharges from the businesses may impact the sewer system, locate any spill pathways from process or chemical storage areas to the sewer, and educate the businesses about the Pretreatment Program and any applicable discharge regulations.

During the inspection, business personnel will be interviewed and a tour will be conducted to familiarize the pretreatment staff with your operation. You will be asked questions regarding waste generating processes, wastewater composition, pretreatment equipment, water consumption, volume of wastewater discharged, chemical storage, location of floor drains and any other pathway to the sewer system, and procedures for the clean-up of any spills. You may also be asked to show the pretreatment staff your waste hauling manifests or receipts for waste hauling and disposal, and your accidental spill prevention and clean-up plan.

During inspections, operations that will contribute wastes to the sewer will be inspected, and sampling locations will be identified. These sampling locations will be used, according to the Pretreatment Program's monitoring requirements, to obtain representative samples of your facility's discharge. Analysis of the samples will show if your discharge is meeting applicable limits and regulations. Note: Your business is required by Sewer Use Ordinance 29641-98 to provide an accessible location for representative sampling of your facility's wastewater discharge.

Pretreatment staff may periodically monitor your facility's wastewater discharge. Monitoring methods may /include collecting 24-hour composite samples, collecting grab samples, taking flow readings, as well as conducting visual inspections of pretreatment equipment.

LOCAL LIMITS

The City's Sewer Use Ordinance gives the Director of Water the authority to set local limits for specific substances that may interfere with or pass through the wastewater treatment plant. The current Local Limits for discharges to the City's sewer are listed in the Regulations section of this web site.

CATEGORICAL STANDARDS

The U.S. EPA has issued federal industrial wastewater categorical standards (CFR Title 40, Parts 401, 403, and 405 through 471) for certain industries. Categorical standards may be more stringent than the local limits listed above. For all these industries, the EPA's standards would become part of the Industrial Wastewater Discharge Permit issued by the City to the industry. The State may also have more stringent standards that would also be applied in the permit.

ENFORCEMENT ACTIONS

The City of Dayton's Pretreatment Program regulations and local limits are enforceable within all cities, townships, counties and/or agencies served by the City of Dayton wastewater facilities, in accordance with state law. Sewer Use Ordinance 29641-98 specifies penalties for violations, which /include:

• Administrative Fees of up to $1000 per day per violation
• Civil Penalties of up to $1000 per day per violation
• Criminal penalties
• Termination of wastewater service
• Cost recovery for any expense, loss or damage caused by a wastewater discharge
• Penalties equal to the economic benefit obtained by a user as a result of its violations

The Regulations section of this web site contains the City's Enforcement Response Plan that describes how violations are generally addressed.

ASSISTANCE

We at the City acknowledge that the Industrial Pretreatment Program regulations are very technical, and without prior experience, may be difficult to understand.

Please do not hesitate to contact a Pretreatment Program Coordinator for an explanation of terms, help with completing forms, interpretations of regulations, or an explanation of what implications the Pretreatment Program will have on your business.

The Pretreatment Program Coordinators are Beau Dodge and Sharon Vaughn. They may be reached at 937-333-1501, and their offices are located at the City of Dayton Wastewater Treatment Plant, 2800 Guthrie Rd, Dayton, OH 45418.