47    THE EFFECTS OF THE PRETREATMENT
PROGRAM ON HAULED WASTE IN WISCONSIN
Ken Denow and Vanessa Thompson
Wisconsin Department of Natural Resources
Milwaukee, Wisconsin 53212
ABSTRACT
In 1983, the Wisconsin Department of Natural Resources (WDNR) began delegating the pretreatment program* to Publicly Owned Treatment Works (POTWs) with design flows of greater
than or equal to (>) 5 million gallons per day (MGD). The delegation required these POTWs to
establish procedures to identify and characterize hauled waste. POTWs permitted haulers, analyzed the waste, verified compliance, and enforced their sewer use ordinance (SUO).
POTWs without pretreatment programs are not required to establish the same procedures
and/or compliance measures. This is causing an inequity in the control of hauled wastes between
POTWs with pretreatment delegation and those without. The result is a shift in the disposal of
hauled waste to POTWs without pretreatment programs. There is evidence that smaller POTWs
were accepting noncompliant categorical wastes, some POTWs were experiencing negative plant
impacts, and some POTWs with pretreatment programs were no longer accepting industrial
hauled waste.
These trends caused us to study hauled waste programs at POTWs. Our research involved collecting information from POTWs through surveys, on-site inspections, personal contacts, informational reporting forms, and background literature review.
Information was obtained on the volume and types of waste being discharged, facility size and
treatment capability, how the waste was being identified and characterized, frequency of negative plant impacts, and guidance and training needed by POTW operators.
The results confirmed:
• The volume of waste hauled in Wisconsin has increased dramatically since 1985.
• POTWs <5 MGD are accepting considerably more waste since the inception of the
pretreatment program.
• POTWs <5 MGD are experiencing negative plant impacts due to hauled waste.
• POTW operators want and need additional information on hauled waste.
The results support the premise that the pretreatment program affects where and how hauled
wastes are disposed. How hauled waste is managed needs to be recognized and understood by
the regulatory, environmental engineering, and operations community in meeting the needs of
POTWs and the environment.
The United States Environmental Protection Agency (U.S. EPA) and states need to spend more
effort on educational and informational programs to provide the needed tools to all POTWs. The
U.S. EPA needs to evaluate existing rules and regulations to learn if they are causing inequity between the acceptance and regulation of hauled waste at POTWs.
'The pretreatment program is delegated to those POTWs with design flow >5 million gallons per day and is a permit
requirement. The term POTW >5 will represent those POWTs with pretreatment programs, while POTW <s will represent those without.
52nd Purdue Industrial Waste Conference Proceedings. 1997. Ann Arbor Press, Chelsea. Michigan 48118. Printed in
U.S.A.
467