What is the Industrial Pretreatment Program?

The Industrial Pretreatment Program is mandated under the Clean Water Act, specifically under the General Pretreatment Regulations (40 CFR 403).  These regulations established the various responsibilities of federal, state and local governments, industry and the public towards controlling the pollutants in wastewater that pass-through or interfere with the treatment process at the treatment plant.

The City of Carrollton complies with the pretreatment regulations through the Carrollton Industrial Pretreatment Program (IPP).  This program continuously evaluates the wastewater of new and existing facilities, issues wastewater discharge permits, and monitors permitted industries through regular wastewater sampling and comprehensive facility inspections.

What is Pretreatment?

Pretreatment is any physical, chemical, or biological process or any industry process change that will remove, reduce or eliminate pollutants in wastewater prior to discharging into the publicly owned treatment plant, or the receiving water.  (Receiving water is a stream, lake, river, ocean or other surface or groundwater into which treated or untreated wastewater is discharged.)

What are the objectives of wastewater pretreatment?

If the wastewater has excessive amounts of suspended solids, oil, or grease, this would result in clogging of sewer lines, sewer back ups in the streets, drainage back ups into facilities, offices and homes.  If flammable or explosive organics find their way into the wastewater, these could cause sewer lines and treatment plants to blow up, along with it streets, homes and injury to the people.  If high concentrations or heavy metals, cyanide or arsenic are in wastewater stream, this could be too much for the treatment plant to handle and thus could get released into the receiving water, harming its aquatic life.  And considering that most of the receiving waters are sources for treated potable water, this could become quite personal and find its way into one's very own glass of water.

The main objectives of the pretreatment program are the control of wastewater pollutants which could pass through treatment or interfere with treatment of the publicly owned treatment works (POTW) and the improvement of the recycling and reclaiming of municipal and industrial wastewater and sludge.  Pretreatment also helps keep sewer lines unclogged, protects the wastewater treatment plant from possible damage and the health and safety of the plant personnel and the public in general.

Which POTW treats Carrollton's wastewater?

The Trinity River Authority - Central Regional Wastewater System is the POTW that receives the wastewater from Carrollton.  The wastewater undergoes primary, secondary, and advanced treatment, thereby producing a very high effluent that is discharged into the receiving body, the Trinity River.

Does every business in the City have to be regulated by the IPP?

No.  Only Significant Industrial Users (SIUs) are regulated under the IPP.  Significant Industrial Users are those non-domestic sources of wastewater pollutants, which either: a) by definition in the federal regulations are categorical industries; b) discharges a process waste stream averaging 25,000 gallons or more; c) contributes a process waste stream which makes up 5% or  more of the average dry weather hydraulic or organic capacity of the POTW; or , d) designated by the POTW as a significant industrial user.

However, every industry in the City, new or existing, is required to fill up the Industrial Waste Survey Form at least once in three years.

What is an Industrial Waste Survey?  What is its purpose?

The Industrial Waste Survey (IWS) is the backbone of a local pretreatment program.  this is required under the federal Pretreatment Regulations to enable the City to determine which industries are required to be regulated by the IPP.  The survey is basically a four step process consisting of user identification, data collection, data verification and evaluation.

If an industry is required to be regulated under the program, what does the industry have to do?

If an industry is evaluated to be a Significant Industrial User (SIU), then they must apply for a permit to discharge their wastewater into the City sewer system, using the Permit to Discharge Application form, along with the Application Instruction Guide.  The application is to be filed at the Environmental Services Department located in City Hall at 1945 E. Jackson Road.  The annual fee for the permit is $400.00.

Inspections and evaluation of the permit application along with the results of the baseline monitoring of the SIU's wastewater are then done.  Once approved, a permit to discharge for a period not to exceed three years is then granted.  This permit will state the monitoring, reporting and compliance requirements that the SIU would be required to observe.

What happens if a permitted industry does not comply with the City's Industrial Pretreatment Program or its Permit?

The IPP makes every effort to maintain working partnerships with the City's regulated industries, valuing information and compliance over enforcement as the best way to achieve mutually beneficial economic and environmental goals.  However, if an industry remains non-compliant with the IPP, that industry becomes liable for criminal and civil penalties and fines.  Furthermore, because protecting public water is a federal mandate, the City of Carrollton is required to enforce the IPP.

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