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A City of Cooperation

Pretreatment

The City of Oregon has an EPA approved Industrial Pretreatment Program.  Oregon’s Pretreatment Program administers local, state and federal regulations affecting area businesses and the quality of the wastewater discharged into the City of Oregon’s wastewater treatment system.  These regulations were implemented to:

·       Prevent the introduction of pollutants into the municipal wastewater system, which will interfere with the operation of the system or contaminate the resulting sludge

·       Prevent the introduction of pollutants into the municipal wastewater system, which will pass through the wastewater system, inadequately treated, into Maumee Bay/Lake Erie or otherwise be incompatible with the wastewater treatment system

·       Protect both municipal personnel who may be affected by sewage, sludge, and effluent in the course of their employment as well as protecting the general public

·       Allow for the beneficial re-use of biosolids

Area businesses are required to install, operate and adequately maintain pretreatment systems to remove those pollutants that could otherwise damage or obstruct the wastewater collection system; or interfere with or pass through the wastewater treatment process. Examples of such pollutants include heavy metals, cyanide, oil & grease, toxic organics, and acidic or caustic wastes from industrial operations.

Some major elements of the city’s Pretreatment Program include: Locates industrial users and identifies the pollutants they discharge; Notifies industrial users of applicable standards and requirements related to pretreatment; Issues wastewater discharge permits; Performs sample collection and site inspections; Reviews monitoring & permittee self-monitoring reports; Investigates instances of noncompliance with pretreatment standards and requirements; Provides annual public notification of industrial users which have significantly violated applicable pretreatment standards and requirements; Develops and enforces local limits to control the discharge of pollutants by its industrial users into its treatment plant; Initiates enforcement activities when appropriate.

Industrial Waste Surveys

Industrial Waste Surveys summarize an industry’s processing activities and help define the wastewater characteristics of that industry. The information derived from the Survey helps to determine whether or not the industry will need to be issued a Wastewater Discharge Permit or related discharge authorization. Industries meeting the following criteria should complete an Industrial Waste Survey.

1)    Industries new to the Oregon Sanitary Sewer Collection system or sanitary sewer that connects to the Oregon Sanitary Sewer Collection system.

2)    Existing industries that have significantly modified their wastewater characteristics and/or meet a categorical standard.

Wastewater Discharge Permit

Permission is required for any discharge of industrial wastewater into the City of Oregon’s wastewater collection system.  Several different permits are issued based on the nature of the business and the volume and characteristics of wastewater to be discharged. Our program is also involved in the approval of discharges of hauled wastewater at the City’s approved receiving station. The process for obtaining a discharge permit varies for different classes of users. These different classes are:

·                     Wastewater Discharge (Industrial User) Permit

·                     Wastewater Hauler Discharge Permit

·                     Special Wastewater Discharge Permit

The following criteria, as defined in the EPA’s General Pretreatment Regulations (US CFR 403) and the Oregon Municipal Code Section 927.10, are used to determine if an industry is a significant industrial user as follows:

·       Conducts operations that are subject to the EPA’s categorical standards, or

·       Discharges an average of 25,000 gallons per day of process wastewater, or

·       Contributes a process wastestream which makes up 5% or more of the average dry weather hydraulic or organic capacity of the wastewater treatment plant, or

·       Has a reasonable potential for adversely affecting the City’s wastewater treatment plant operations or for violating any pretreatment standard or requirement.

Discharge permits follow a standard format designed to provide permittees with complete information as to their discharge limits, sampling and reporting obligations, general conditions and any special requirements. Wastewater Discharge Permits are issued for no more than 3 years, while Wastewater Hauler Discharge Permits are issued yearly. Permits may be modified and/or reissued more frequently depending on user changes or new wastestream information

Monitoring Requirements

The Pretreatment Program staff conducts inspections, surveillance and monitoring of industrial wastewater sources discharging to the City’s wastewater collection system. The monitoring and inspections are performed in order to verify compliance with all applicable pretreatment standards.

Unannounced monitoring of SIU’s are usually conducted monthly. Other monitoring and inspection activities are conducted on an as needed basis. Often these activities are related to problems or unusual conditions noted either at the Wastewater Treatment Plant or within the wastewater collection system. They may also be a part of an investigation initiated subsequent to an anonymous report of suspicious activity or illegal dumping. If you have any question about a suspicious discharge to the sanitary sewer system, please contact the Oregon Wastewater Treatment Plant at 419-698-7042. Your assistance would be appreciated and your confidentiality respected.

Spill Prevention
You may also be required to develop a Slug Control 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 Oregon Wastewater Treatment Plant at 419-698-7042.

Local Discharge Limits

The Oregon Municipal Code, Section 927.05, gives the Director of Public Service the authority and responsibility 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 of Oregon sanitary sewer system are listed in the Standards and Limits 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 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 Management

The City of Oregon's Pretreatment Program regulations and local limits are enforceable within all cities, townships, counties and/or agencies served by the City of Oregon Wastewater Treatment Plant, in accordance with state law.  The ultimate goal of the Enforcement Management Plan is to ensure compliance with all applicable local, state and federal rules and regulations as they relate to pretreatment standards and requirements.

The enforcement response for any given violation will vary according to several factors. The violation’s magnitude and duration; any effect on the wastewater treatment works or the receiving stream; any injury to personnel or the public, the compliance history of the business; and any good faith demonstrated by the offender are all accounted for when determining the most appropriate enforcement response for a violation.

1.   Investigation of Noncompliance

The Oregon Wastewater Treatment Plant assesses user compliance with permits or the Federal, State and City rules/regulations:

a.      On-site inspections of the user to include scheduled and unscheduled visits;

b.      Scheduled and/or unscheduled sampling of the industrial wastewater discharge;

c.      Review of self-monitoring data.

The compliance status of Significant Industrial Users will be evaluated at a minimum once every 6 months.

2.   Types of Violations

The following is a list of different types of violations, by category. This list serves as a general list of anticipated types of noncompliance. The users permit, City, State and Federal regulations serve as additional references for pretreatment requirements.

Unpermitted Discharges. Users are responsible for obtaining and renewing permits, if required.

Permit Limits. Users are responsible for maintaining compliance with all wastewater discharge limits. The City will evaluate the extent of the limit violation(s). In determining the extent of violation(s), Significant Noncompliance (SNC) as defined by State and EPA regulations will be determined.

Self-Monitoring Violations. A user who fails to adequately conduct all the monitoring required in the permit, including monitoring frequencies and sampling methods specified, is in violation. This includes a user who does not resample per its permit when a limit violation occurs.

Reporting Violations. A user who fails to provide information (e.g. self-monitoring reports, violation explanation) required in its permit or the Oregon Municipal Code in the required time frame is in violation. Late or incomplete reports will also be considered violations.

Permit Conditions. Failure to apply or reapply for a permit is considered a violation. Users who violate the general or other conditions (e.g. slug loading, dilution prohibition) outlined in the permit or the Oregon Municipal Code shall be considered to be in violation.

Enforcement Orders. Failure to meet the requirements of an order (e.g. interim limits, milestone dates), whether the order was entered into voluntarily or mandated by the Director, shall be considered a violation.

3.   Enforcement Responses.

Responses to violations affecting the operation of the WWTP, resulting in WWTP NPDES violations, or resulting in environmental harm or endangerment to human health will be taken immediately or as soon as possible following discovery.

A user will be sent a written Notice of Violation (NOV) for each individual violation. Escalated or continuing enforcement action will be taken against users who do not return to compliance in a timely manner.

Show cause hearings may be held at the Director's discretion prior to taking enforcement actions.

The city’s Sewer Use Ordinance 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

 

Cases of falsifying reports, tampering with monitoring or sampling equipment or otherwise preventing the collection of representative data may be referred to the City Prosecuter for possible criminal investigation.

Annual Reports

Significant Noncompliance Publication  - Federal regulations and Section 927.22 of the Oregon Municipal Code require the City to annually publish a listing of permitted industrial sewer users who have been in significant noncompliance with their discharge permit during the previous year. The City uses the NPDES permit-defined pretreatment year (September 1 through August 31) as the basis for this publication list. Section 927.22 of the Oregon Municipal Code defines the criteria for making the determination of significant noncompliance.

Annual Reporting - The City annually submits a Pretreatment Program Report for submission to the Ohio EPA. For reporting purposes, the pretreatment program year runs from September 1 through August 31. The report includes a narrative summary of the past year’s pretreatment program actions and activity.

Assistance

We understand that the Industrial Pretreatment Program regulations are very technical, and may be difficult to understand. Please feel free to contact the City of Oregon Wastewater Treatment Plant Superintendent or Chief Chemist 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 Wastewater Treatment Superintendent and Chief Chemist may be reached at (419) 698-7042.

 

 

 
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