Establishing an Effective Pretreatment Program

Have you ever heard the phrase, "Just pour it down the drain?"

By James Fischer

Have you ever heard the phrase, “Just pour it down the drain?” Unfortunately, this is the mentality that many wastewater customers have. Items that are poured down the drain include grease, oil, pesticides, herbicides, paint, and pharmaceuticals. Treatment plants are typically not designed to remove many of these pollutants. The materials can interfere with plant operations or they can pass through the treatment processes into the receiving stream.

There are many different types of industries that can potentially discharge harmful materials to the collection system. Because of this potential, regulations were established by the U.S. Environmental Protection Agency (EPA) in the late 1970s to address discharges from industries to a publically owned treatment works (POTW).

The EPA developed the National Pretreatment Regulations to help protect POTWs from potentially hazardous and toxic discharges. The regulations require the local entity to develop and implement a pretreatment program and enforce its provisions on their industrial users (IU).

A pretreatment program is designed to prevent the following four problems:

• POTW operation interference
• Effluent pollutants
• Sludge contamination
• Chemical exposure to workers

The requirements for establishing a pretreatment program are included within the discharge permit that is issued to the POTW by the regulatory agency, either the EPA or the state. Facilities that have a permitted discharge of more than five million gallons per day are usually required to establish a program. Smaller facilities may have to develop a program if they have a discharger that disrupts their operations or if they have a discharger that is considered to be a categorical industrial user (CIU).

A categorical industrial user is one that has specific discharge limitations placed on them by the EPA which in turn are enforced by the local entity once a pretreatment program is established.

A pretreatment program is established by the local entity with specific local discharge limitations that are developed to protect their facilities. These local limits are then placed upon dischargers through an ordinance and permit system. This may require the discharger to implement some form of treatment to comply with the limits in the local ordinance and other provisions that may be included in a permit. This is where the term “pretreatment” comes from: a discharger doing something to their water prior to it being discharged to the collection system.

When a local entity is required to develop a pretreatment program, there are many requirements it must fulfill to get the program approved. Once approved, there again are many provisions the entity must develop, implement, and enforce upon its customers. A good relationship with your public information staff will be important to program success.

To learn more about establishing an industrial pretreatment program, visit The Texas Engineering Extension Service has developed a one-hour training course in cooperation with WaterWorldCE. The document provides detailed information on this important topic.


About the Author: James Fischer is an Associate Training Specialist with the Texas Engineering Extension Service’s Water and Environmental Training Program. For more information on TEEX, visit

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