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Archived: P2Rx no longer updates this information, but it may be useful as a reference or resource.

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Publicly Owned Treatment Works: Reasons for Change
Table of Contents
Background and Overview
P2 Opportunities
Reasons for Change
Complete List of Links

Essential Links:

EPA-POTW Resources
General information for POTWs.

EPA-RCRA Information on Hazardous Wastes for Publicly Owned Treatment Works
RCRA information for POTWs.

There are three major reasons POTWs should consider when planning P2 programs:

1. Sustainability
2. Regulatory incentives (including Storm Water Regulations)
3. Human health and environmental reasons

POTWs are overwhelmingly organized as agencies of local government (often as a department within a city or municipality, but in some cases as independent agencies or authorities). Their operations are funded out of usage fees and tax revenues. Capital funding for major construction projects can be raised through bond issues, typically requiring voter approval. A federal program, the Clean Water State Revolving Fund (CWSRF), established to help local systems comply with the Clean Water Act, has provided nearly $30 billion in low interest loans for projects throughout the country.
Pollution prevention programs can enable POTWs to survive the increasing demands of urbanization and population growth. This occurs because of:
        •Reduction in toxics in the waste stream leads to cost savings;
        • Reduction in material usage and waste generation leads to cost savings;
        • Cleaner facilities result in fewer lost time incidents and other worker-related injuries;
        • Regulatory flexibility leads to reduced environmental compliance costs and overall operating expenses

Regulatory Incentives
        • Clean Water Act (CWA)
        • 40 CFR Part 403
        • National Pretreatment Program
        • Other Federal and State Regulations

Water pollution standards have become increasingly stringent since adoption of two major Federal environmental statutes: the Clean Water Act of 1972, which implemented a national system of regulation on the discharge of pollutants; and the Safe Drinking Water Act of 1974, which established standards for drinking water. Industrial facilities sending their wastes to municipal treatment plants must meet certain minimum standards to ensure that the wastes have been adequately pretreated and will not damage municipal treatment facilities. Municipal water treatment plants also must meet stringent drinking water standards. The list of contaminants regulated by these statutes has grown over time. For example, the 1996 Safe Drinking Water Act Amendments include standards for the monitoring of cryptosporidium and giardia, two biological organisms that cause health problems.

Clean Water Act (CWA)
The primary goal of the CWA is to protect, restore, and maintain the chemical, physical and biological integrity of the waters of the United States. One interim goal of the act is to return the nation's water to conditions deemed "fishable and swimmable." All discharges into the waters of the United States, publicly owned treatment works, storm water discharges, and storm sewers are covered under this act. Direct discharge to any surface water requires a National Pollutant Discharge Elimination System (NPDES) permit.

Discharge to a publicly owned treatment work (POTW) does not require a NPDES permit, but will require an industrial user permit which is issued by the local water treatment operator. The general pretreatment requirements prohibit the following:

1) pollutants that create a fire hazard in the POTW;
2) pollutants that will cause corrosive damage to the POTW;
3) pollutants (solid or viscous) in amounts that will obstruct flow in the POTW;
4) any pollutant released at a flow rate or concentration that interferes with the POTW operations (this includes oxygen-demanding pollutants);
5) effluents at a temperature that will inhibit biological activity in the POTW;
6) petroleum oils, non-biodegradable cutting fluid, or mineral oil products which will pass through the POTW or interfere with performance of chemicals in the POTW;
7) pollutants that result in toxic fumes within the POTW; and
8) any trucked or hauled pollutants.

Facilities are also required to notify the POTW within 24 hours if any violations of the pretreatment requirements occur. Often state or local governments have additional reporting requirements, which should be addressed prior to discharge.

Often, an NPDES permit is required even if no wastewater is produced onsite. A permit will be necessary if any storm water comes into contact with industrial activity or construction activity. This contact includes any handling equipment or activities, raw materials, intermediate products, final products, or industrial machinery exposed to storm water that drains to a storm sewer system or directly to receiving waters. Note that a storm water permit is not required for municipal systems that have combined wastewater and storm water systems, but the POTW should be informed that industrial storm water will be entering the sewers.

General PT Regulations (40 CFR Part 403)
• Objectives: prevent pass through and interference (including preventing interference with sludge use and disposal); promote beneficial re-use of effluents and sludge. (See 403.2)
• National prohibited discharge standards: temperature, pH, explosive, etc. (See 403.5)
• Application of national categorical pretreatment standards (See 403.6)
• Requirements for State and local Publicly Owned Treatment Works (POTW) programs (See 403.8(f) and 403.10)
• Reporting requirements for POTWs and Industrial Users (IU) (See 403.12)
• Other requirements (e.g., FDF variances, net/gross adjustments) (See 403.13 -403.17)
• Categorical Pretreatment Standards (40 CFR Parts 405 - 471)

National Pretreatment Program
Q: What is the National Pretreatment Program?
The National Pretreatment Program is designed to reduce the amount of pollutants discharged by industry and other non-domestic wastewater sources into municipal sewer systems, and thereby, reduce the amount of pollutants released into the environment from publicly owned wastewater treatment plants. The program is a cooperative effort of federal, state, and local regulatory environmental agencies established to protect water quality. The objectives of the program are to protect the Publicly Owned Treatment Works (POTW) or municipal wastewater treatment facility from pollutants that may interfere with plant operation or pass through the plant untreated and to improve opportunities for the POTW to reuse treated wastewater and sludge (biosolids) that are generated. The term "pretreatment" refers to pollutant control requirements for nondomestic sources discharging wastewater to sewer systems that are connected to POTWs. Limits on the amount of pollutants allowed to be discharged are established by EPA, the State, or the local authority. Pretreatment limits may be met by the industry through pollution prevention (e.g., production substitution, recycling and reuse of materials) or treatment of the wastewater.

Q: Under what Statutory Authority is the Pretreatment Program Administered?
The National Pretreatment Program's authority comes from section 307 of the Federal Water Pollution Control Act (more commonly referred to as the Clean Water Act). The federal government's role in pretreatment began with the passage of the Clean Water Act in 1972. The Act called for EPA to develop national pretreatment standards to control industrial discharges into sewerage systems.

Q: Are there any prescribed National Standards for Pretreatment?
There are two sets of standards: "categorical Pretreatment Standards" and "Prohibited Discharge Standards." These are uniform national requirements which restrict the level of pollutants that may be discharged by nondomestic sources to sanitary sewer systems. All POTWs that are required to implement a Pretreatment Program must enforce the federal standards.

Q: What are Categorical Pretreatment Standards?
These are technology-based limitations on pollutant discharges to POTWs promulgated by EPA in accordance with Section 307 of the Clean water Act that apply to specified process wastewaters of particular industrial categories [see 40 CFR 403.6 and 40 CFR Parts 405- 471]

Q: What are Prohibited Discharge Standards?
These are standards that prohibit the discharge of wastes that pass through or interfere with POTW operations (including sludge management). These are the general prohibitions. There are also specific prohibitions that forbid the discharge from all nondomestic sources certain types of wastes that
1) create a fire or explosion hazard in the collection system or treatment plant,
2) are corrosive , including any discharge with a pH less than 5.0, unless the POTW is specifically designed to handle such wastes,
3) are solid or viscous pollutants in amounts that will obstruct the flow in the collection system and treatment plant, resulting in interference with operations,
4) any pollutant discharged in quantities sufficient to interfere with POTW operations, and
5) any discharge with temperatures above 140 F (40 C) when they reach the treatment plant, or hot enough to interfere with biological processes.

Other Federal and State Regulations
Community Right-to-Know

If you calculated 10,000 pounds or more annual usage of any of the TRI-listed chemicals or other hazardous substances you may have a responsibility to report those chemicals. This report is required by July 1 of each year for the chemical(s) used in the previous calendar year.
Emergency Planning and Community Right-to-Know Act (EPCRA) requires industry to provide information to the public concerning the presence and release of toxic and hazardous chemicals. EPCRA is a reporting requirement, not a P2 law, but it does drive P2 because of the publicity it generates relative to an industry's environmental policies

Occupational Safety and Health Administration Act
Under OSHA, employers (regardless of size) are required to meet several standards which will maintain a safe and healthful workplace. The "general duty clause" of OSHA states that "a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm" must be provided to the employee. Section 1910.1200 of OSHA is the hazard communication standard and requires employers to inventory, classify, and label all chemical substances onsite that are considered to be "hazardous" to health or have physical properties which are hazardous.

All employers must have a written program available to employees which includes inspection, inventory, labeling, availability of material safety data sheets, employee training, agency reporting, and record keeping systems. Employers of fewer than 10 people may be exempt from the record-keeping systems only. Several states have their own OSHA regulations. It will therefore be necessary for facilities to contact their state agency to find their requirements.

Superfund (Comprehensive Environmental Response, Compensation, and Liability Act) (CERCLA) & Superfund Amendments and Reauthorization Act (SARA)
Under the original Superfund, the EPA was authorized to undertake any measures necessary to address any hazard to human health and the environment triggered by burning, leaking, or explosion of hazardous substances, contamination of food chains, or drinking water contamination.

Toxic Substances Control Act (TSCA)
Under TSCA, the EPA is given the authority to limit or prohibit the manufacture, processing, distribution of disposal of a chemical substance which they have determined poses a risk to human health or the environment. EPA will also gather information on all risks associated with toxicity to all new and existing chemicals.

Section 4 is the authorization for the EPA to require testing of chemical substances or mixtures they determine could be a risk to human health or the environment. Section 5 grants the EPA the right to test all new chemical substances to determine their toxicity and subsequent risk 90 days before manufacturing, processing or importing said chemical. Section 6 is the official notification that the EPA may regulate the manufacture, processing, distribution in commerce, and the use and disposal of any chemical substance determined to be toxic. Section 8 is the requirement for all users and manufacturers to keep records and submit reports to the EPA.

Hazardous waste minimization was first endorsed in 1984 RCRA (Resource Conservation and Recovery Act) reauthorization (HSWA) which
• Introduced P2 by stipulating that generators must have a P2 plan, and
• Stated that reduction or elimination of hazardous wastes should take priority over waste management after generation

Pollution Prevention Act of 1990 is the chief legislation concerning P2, however, it

• Does not mandate P2, but does require industry to establish a P2 plan,
• Establishes source reduction as the preferred means of environmental management, and
• Requires industry to annually report their P2 and recycling practices

Link here for more detail regarding:
Storm Water Regulations
State Storm Water Regulations Versus Federal Storm Water Regulations

Human Health and Environmental Reasons
The health and environmental impacts of pollutants in water systems is well-documented. Examples include Mercury and Fecal Coliform Bacteria.

Mercury is a pervasive problem in many of the Nation’s rivers, estuaries, and lakes, and is a prime example of the type of transformation a substance can undergo when it enters an aquatic environment. According to EPA's Ambient Water Quality Criteria for Mercury, certain microorganisms convert inorganic and organic forms of mercury into highly toxic methylmercury or dimethylmercury forms, and therefore "any form of mercury is highly hazardous to the environment." Research has shown that predatory fish in acidified bodies of water have elevated levels of methylmercury in their tissues, indicating that while biological processes within an aquatic system affect rates of methylation, the system's chemical conditions affect methylation as well. Since seemingly innocuous forms of mercury can be readily converted to methylated forms, mercury poses a serious threat. (Lewis).

Methylmercury is highly persistent, accumulates in fat tissues, and is passed through the food chain such that it often reaches the highest concentrations in top-level predators. In other words, methyl-mercury is readily passed from small fish and shellfish to predatory fish, birds, and other animals, including man. This process was responsible for 1,800 cases of mercury poisoning in Kyushu, Japan, the result of the discharge of methylmercury from chemical factories into Minamata Bay. Human symptoms of "Minamata disease" included hearing loss, speech disturbances, constricted vision, and other neurological disorders such as disruptions in the physical and mental development of babies whose mothers regularly consumed contaminated fish. In laboratory studies, cats and rats fed shellfish from the Bay behaved much as they and other animals did in nature when methylmercury accumulated beyond the given species' threshold points, they became intoxicated. They behaved erratically and died. (Lewis)
Fallen leaves, animal wastes, run-off waters from croplands, parking lots, or forest floors all these things are potential pollutants when they enter a stream. Many of these natural substances, and many which occur less naturally such as pesticides, household chemicals, and industrial wastes can be utilized by one or more organisms, metabolized or broken down by fungi and bacteria, and often, converted into simpler forms. On the other hand, these same foreign substances could cause a change in the pH or chemical composition of a given water system and create a harmful situation, or they could be transformed by biological or chemical processes, becoming more or less soluble, or being converted into forms which are more toxic to organisms in the river or stream. Simply stated, what is easily accommodated by a stream with one set of natural characteristics may be harmful to a stream with a different make-up. (Lewis)

To complicate matters, different organisms vary in their susceptibilities to various chemical concentrations at different stages of their life cycles: What is considered a toxic dose to an infant may be harmless to an adult. (Lewis)

Fecal Coliform Bacteria presents a serious health challenge for POTWs. In many communities, water-based recreation is impaired by high levels of bacteria. This results from increases in raw sewage discharges into waterways. Albert Slap of the University of Cincinnati College of Law reports approximately 40,000 overflows of raw sewage per year. There are an estimated 400,000 occurrences of backups of raw sewage into residential homes and between 1.8 and 3.5 million Americans become sick every year from swimming in polluted waters. The Center for Disease Control estimates that as many as 900 people die each year from waterborne infections from inadequately treated sewage.

Additional information can be found at:


Pollution Prevention Handbook: Sewage and Wastewater Treatment Plants


Lewis, Barry. Pollution in Our Surface Waters: Where Does it Come From? What Does it Mean? Academy of Natural Sciences. December, 1995.

Pacific Northwest Pollution Prevention Resource Center.

Slap, Albert J. Adjunct Professor at Law. University of Cincinnati College of Law. “Wet Weather Public Sewer Issues Under Federal Clean Water Act.”


The Topic Hub™ is a product of the Pollution Prevention Resource Exchange (P2Rx)

The Publicly Owned Treatment Works Topic Hub™ was developed by:

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Hub Last Updated: 5/22/2007

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