THE NATIONAL STRATEGY FOR PRETREATMENT OF TOXIC
INDUSTRIAL EFFLUENTS: ISSUES AND IMPLICATIONS
Alexandra P. Wright, Associate and Group Manager
Jack D. Homkow, Senior Environmental Manager
Dawn D. Roderique, Environmental Analyst
Water and Wastes Group
Fred C. Hart Associates, Inc.
New York, New York 10022
INTRODUCTION
Overview
This year the United States Environmental Protection Agency (EPA) will promulgate
a revised general pretreatment regulation (40 CFR 403). The preamble to these general
pretreatment regulations will serve as a public statement of the Agency's overall pretreatment strategy. The pretreatment requirements set forth in these regulations will
have far-reaching effects to approximately 55,000 industrial dischargers who currently
introduce toxic and hazardous wastes into publicly-owned treatment works (POTWs).
EPA has expended considerable effort and resources in developing a national strategy
that adequately responds to basic pretreatment policy issues. Included among these key
issues are: (a) scope of regulations-i.e., extent of industry and pollutant coverage; (b)
establishment of a sludge policy; (c) determination of an effective enforcement strategy;
and (d) overall program costs to industries and municipalities.
Before outlining the basic issues confronting EPA in its present pretreatment review
effort, it would be appropriate to discuss: (a) the significance of industrial discharges to
POTWs, (b) EPA's proposed pretreatment regulations, and (c) public particpation in the
rule-making process.
Significance of Industrial Discharges to POTWs
Industrial discharges to POTWs are routinely identified as the source of significant
environmental problems. These discharges contain varying quantities of toxic and hazardous wastes. Many of these industrial pollutants are incompatible with the typical
POTW's treatment capabilities and can cause three types of problems which can result
in violation of the POTW's National Pollutant Discharge Elimination System (NPDES)
permit requirements and nonattainment of water quality standards.
First, slug discharges and high concentrations of certain pollutants can inhibit or interfere with the proper operation of a POTW. Interference and inhibition problems
generally result in inadequate treatment of normal domestic waste and industrial wastes
the POTW was originally designed to treat.
Second, even when the inhibition/interference problems mentioned above have been
dealt with, there still are numerous pollutants that often receive inadequate treatment
in the typical POTW. These pollutants-either in whole or in part-exhibit the tendency
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