Pretreatment Program

We are required, as are all other municipalities in the nation, to comply with comprehensive federal and state regulations governing how we must control the sources of our wastewater. The federal pretreatment regulations are contained in the Code of Federal Regulations (CFR) in section 403 US CFR 403. Section 925 of the Defiance Municipal Code of Ordinances (Sewer Use Code) incorporates much of these federal and state regulations and it can be referred to by industries and businesses for requirements regarding their wastewater discharges. As you browse this site, it may be helpful to review Section 925.02 Definitions of the Code. This section provides the definitions for many of the technical terms and phrases applying to the pretreatment program.

We have implemented a comprehensive program of industrial wastewater control (Pretreatment Program) that was required, reviewed, and approved by the Ohio Environmental Protection Agency (OEPA). The program regulates all industrial users within the City of Defiance and also applies to outlying rural areas to the north and south of the city through the provisions of intergovernmental agreements. Our Service Area Map provides an overview of the areas served by the Defiance wastewater treatment plant.

The City of Defiance 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 Defiance Section 925 Sewer Ordinance . This ordinance applies to all new and existing businesses which discharge wastewater within the City of Defiance'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 the City of Defiance Water Pollution Control Division at (419) 782-0841.

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 Maumee 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 Defiance 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.

epa logoREGULATORY AUTHORITY
The wastewater treatment field is regulated on every facet of the environment on both 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 USEPA to the Ohio Environmental Protection Agency OEPA. When the City developed its pretreatment program and its Sewer Use Ordinance, the Ohio EPA delegated the City of Defiance authority and responsibility 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;
  • Protect the sewers and wastewater treatment plant from damage due to an accidental or deliberate discharge of pollutants;
  • Provide safe working conditions for sewer utility workers;
  • 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 Maumee River;
  • Improve the opportunity to reclaim and recycle municipal wastewater and biosolids.

The City of Defiance's Industrial Waste Pretreatment Program provides the authority, through Sewer Use Ordinance 925, 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 (Standards and Limitations)
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:

  • Flammable or explosive substances o Highly toxic and poisonous substances
  • Solid or viscous substances which may obstruct flow
  • Wastewater having a pH less than 5.5 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

NEW & EXISTING SEWER USERS
Non-residential customers and existing sewer users who are expanding or changing the nature of their sewer discharge 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. This information is gathered using Non-Domestic User Questionnaires . 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.

permitsINDUSTRIAL WASTEWATER DISCHARGE PERMITS
You will be asked to complete a Baseline Monitoring Report (BMR) 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 BMR 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.

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 any 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 Defiance, Division of Water Pollution Control.

MONITORING REQUIREMENTS
Your business’ wastewater discharge may be monitored and tested and you may have to 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 semi-annual compliance reports and any other report or documentation as required. All industry reports require a signature by an authorized person declaring that the information contained in the report is true, accurate and complete.

Sampling locations for sewer users with discharge permits 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. Your business is required 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. Costs associated with contract laboratory analysis of wastewater samples are the responsibility of the sewer user.

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.

LOCAL LIMITS
The City's Sewer Use Ordinance gives the Superintendent of the Water Pollution Control Division 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's sewer are listed in the Pretreatment 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 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 Defiance's Pretreatment Program regulations and local limits are enforceable within all cities, townships, counties and/or agencies served by the City of Defiance wastewater facilities, in accordance with state law. 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

The Enforcement Policy 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. The various sections of this website will provide more detailed information on various aspects and areas of the Defiance Pretreatment Program. Please feel free to contact the City of Defiance 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 City of Defiance Pretreatment Program Coordinator may be reached at (419) 782-0841, with the office located at the City of Defiance Wastewater Treatment Plant, 26273 State Route 281, OH 43512.

This pretreatment program overview section has, in part, been adapted and is used by the City of Defiance, Ohio with the permission of the City of Dayton, Ohio.

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