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Business Objective

A city overseeing a small pre-treatment program asked ALG to assist with a complete program update, including revisions to the sewer use ordinance (SUO), enforcement response plan (ERP), multi-jurisdictional agreements (MJAs), local limits, and general improvements to program implementation. The City initiated this program update to correct deficiencies noted in several pre-treatment compliance inspections and audits by both U.S. Environmental Protection Agency and the Regional Water Quality Control Board.

/practice-area/water-quality

Technical Approach

ALG staff coordinated a complete and comprehensive overhaul of the City’s pre-treatment program, concurrently updating multiple program foundation documents and implementation practices to improve compliance with federal and state pre-treatment program requirements. The federal pre-treatment program (40 CFR Part 403) requires that the control authority’s legal authorities (i.e., SUO, local limits, and MJAs) contain specific provisions. Using program guidance documents, including the Environmental Protection Agency’s (EPA’s) Model Pre-treatment Ordinance, Pre-treatment Program Legal Authority Reviews Checklist, Multi-jurisdictional Pre-treatment Programs Guidance Manual, and Local Limits Development Guidance, along with direct references to the regulations, ALG staff worked with the City to incorporate required elements and City concerns across the various authorities. These authorities were tailored to include City-specific issues such as salts management, water softener controls, and fats, oils, and grease (FOG) controls. ALG staff served as the subject matter experts for the diverse group collaborating on these program changes, including pre-treatment program staff, the City Attorney’s office, the Utilities’ Directors office, and City General Manager’s office.

Drawing on more than a decade of experience as pretreatment program auditors and referencing guidance documents such as the Industrial User Permitting Guidance Manual and Guidance for Developing Control Authority Enforcement Response Plans, ALG also drafted new and improved program tools, standard operating procedures, and implementation policies to guide program activities. These included updated permit application materials, a new industrial user permit template, an updated ERP, a new control mechanism for wineries, enforcement notice templates, and development of a surcharge program for high-strength dischargers.

Results

Following the update of these program authorities, the City will be implementing a pretreatment program that is in compliance with state and federal program requirements, as well as resolving all program deficiencies noted by EPA and the Regional Water Control Board. Using the new and updated permit template allows program staff to streamline oversight activities as the program regulates new groups of industrial users. Using new tools for the revised enforcement and new surcharge programs have clarified incentives for industrial user compliance, as well as timely and accurate user reporting. ALG continues to assist our client with upcoming program improvements, including program reporting and the development of a full FOG control program.

City Pre-treatment Program Update and Implementation Assistance