Pretreatment Program Requirements

Discharge Limitations
All sewer users are subject to the City of Defiance local discharge limits, as specified in Section 925.05 of the Sewer Use Code and discussed in the Pretreatment Standards and Limits section of this site. Certain industrial users are also subject to federal categorical discharge limits Section 925.05(b)(1), also administered by the City of Defiance.

Reporting Requirements
a. New Industries or Businesses – Any new industry or business wishing to discharge into the City’s sewer system must first apply to the Defiance Water Pollution Control Division for permission to discharge wastewater. Our requirements for a potential user depend on the projected and potential wastewater quantities and characteristics of that facility.

The following classification categories of business/industries must complete and submit a Baseline Monitoring Report (BMR).

Industrial Survey - Classification Category Description

1. Manufacturing facilities discharging process wastewater.
2. Non-manufacturing facilities discharging non-domestic wastewater.
3. Manufacturing facilities discharging only domestic wastewater.

The BMR includes, but is not limited to, such information as:

• number of employees
• major activities at the facility
• description of manufacturing activity or service
• specific activity/activities conducted at the facility
• chemicals used or handled
• water usage rates and an explanation of purposes
• wastewater characteristics including expected discharge rates
• description of any wastewater pretreatment facilities
• information on any hazardous waste or materials

b. Existing Industries and Businesses – Any existing industry/business wanting to make modifications resulting in significant changes in the quantity and/or quality of their wastewater discharge must first apply to the Water Pollution Control Division for permission to do so. Pertinent information and/or an updated BMR would need to be submitted to us. Existing users may also be required to submit one or more of the following reports to the Defiance Water Pollution Control Division on a regular basis:

1. Semi-Annual Compliance Report
2. Annual Pretreatment System Operating Report
3. Spill Prevention Control and Countermeasures Plan
4. Slug Control Plan
5. Toxic Organic Management Plan

Monitoring Requirements
Initial Monitoring – Sample Manhole
Depending on the potential and projected characteristics of the facility’s wastewater, the City may require the installation of a sample manhole and an initial collection and analysis of a representative wastewater sample to determine compliance with all applicable regulations.

Continued Monitoring – Sample Manhole – Based on an evaluation of the BMR and the initial monitoring results, the City may determine the need for, and establish the frequency of, additional monitoring.

Sewer Surcharges – In an effort to have users discharging wastewater having an unusually high amount of solids and/or organic materials pay for the treatment costs of such waste the City has developed specific charges for these types of wastewater treatment. These charges are determined from routine periodic monitoring of wastewater discharges in excess of 250 mg/l of Suspended Solids (SS) and/or 500 mg/l of Chemical Oxygen Demand (COD).A unit cost is charged for each pound of SS or COD discharged in excess of these limits. We would be more than happy to discuss and review these surcharges in detail upon request.

Specific Requirements – Some of the requirements determined on a case-by-case basis include the following:

1. Need for an Industrial Discharge Permit
   a. Users discharging more than 25,000 gallons/day
   b. Users discharging more that 5% of WPC plant capacity
   c. Users with potential to interfere with the treatment process or pass through the WPC wastewater treatment plant
2. Need for a sample manhole installation
   a. Users subject to permitted local or categorical limits
   b. New structures with the potential to accommodate such users
   c. Users discharging high solids or high organic strength wastewater
3. Self-monitoring requirement for Federal Categorical Discharge Standards
4. Pretreatment system requirements
5. Need for a Spill Prevention Plan or Slug Control Plan. Section 925.08(a)(4) of the City Code contains the details of the requirements for such plans.
6. Need for flow equalization or other control of discharge rates

Ohio EPA Approval – Ohio Environmental Protection Agency approval is required for certain projects and regulatory requirements. This approval is normally obtained through the “Permit to Install” (PTI) process. Specific information regarding this process will be provided for those projects requiring a PTI.

The Defiance Water Pollution Control Division has established an excellent and cooperative working relationship with our industrial/commercial users. In order to continue to assist our sewer users and to fulfill our mandated regulatory duties, it is imperative that the Water Pollution Control Division review and approve potential new sewer users and existing users planning a significant change in their wastewater characteristics.

This review and approval will also insure that our wastewater system (sewers, pumping stations, etc.) and wastewater treatment plant has adequate capacity to accept and treat additional discharges. Additionally it will help insure that we are able to maintain compliance with certain other regulatory requirements such as effluent limits, and sludge handling and disposal regulations.

As stated earlier, the comprehensive BMR Questionnaire report is available and is required in certain instances. However, as an alternative to this lengthy report, a “Commercial/ Industrial Wastewater Discharge Request” short form has been developed. The information requested on this form will allow for an initial evaluation of potential new sewer users and those expanding or planning a significant change in wastewater characteristics. This information will help to determine which users may be required to submit the more detailed BMR form.