2    IMPLEMENTATION AND ENFORCEMENT OF AN
INDUSTRIAL WASTE PRETREATMENT PROGRAM IN
ORLANDO, FLORIDA
Elizabeth T. Skene, Environmental Compliance Manager
City of Orlando
Orlando, Florida 32805
Erik L. Melear, Associate Environmental Engineer
Boyle Engineering Corporation
Orlando, Florida 32801
BACKGROUND
An industrial waste pretreatment (IWP) program was developed for the City of Orlando, Florida
through the combined efforts of the City and Boyle Engineering Corporation. The driving force
behind the City of Orlando's IWP program is the limited available options for effluent and sludge
disposal, and the stringent requirements for their use. As the City's treatment plants receive wastewater from more than 325 industrial users, it is imperative to have an active IWP program.
After the Florida Department of Environmental Regulation (FDER) mandated the cessation of
effluent discharges into surface waters, the City chose to reuse the highly treated effluent for: 1)
irrigating 10,000 acres of citrus; 2) recharging the surficial aquifers; and 3) mitigating losses of
wetlands. Stringent standards have been established for these methods of effluent reuse. The prohibitive cost and limited availability of landfills emphasized the need for sludge reuse as a conditioner for
nutrient poor soils.
A mass balance was performed to calculate the local pollutant discharge limits for 18 metals, boron,
and cyanide. A limit for total toxic organics and metals was imposed. A field investigation, including
site visits, was conducted to develop data for the mass balance analysis. Wastewater discharges were
monitored for 26 parameters. Threshold inhibition concentrations were determined from operating
data and performance profiles for the three treatment plants. A primary element of concern is boron
which is highly poisonous to citrus. A new precipitating agent for the treatment of copper from
printed circuit board manufacturing wastewaters contains high levels of boron which is not removed
by secondary biological treatment. Impacts on users has not been severe with the exception of a few
electroplaters and printed circuit board manufacturers. The photographic and printing industries will
be affected due to solvents and silver in their waste stream.
The IWP program was implemented in a variety of ways: public information meetings, legal
notices, permits, fees, contractual agreements and research programs. Legal authority was established
by revising the sewer use ordinance. Users are divided into four classifications for purposes of
permitting. Permits are issued only to users in Classification 1 and users in Classification 2 are only
required to have a Spill Containment Plan. A $50.00 permit and renewal fee is collected. In the more
difficult cases, the City contracts directly with a discharger and exerts more control over the industrial
discharge.
There are several methods available for enforcement: code violation notices, fines, compliance
schedules, public notice, and termination of service. The City's Environmental Compliance Section
conducts routine compliance monitoring of users with emphasis on the categorical industries. Domestic wastewaters are monitored for boron and other pollutants of primary concern. Foreclosure on the
property can occur if the fines are not paid or a settlement is not negotiated. Case histories of an
electroplater and printed circuit board manufacturer will be presented to describe this process. Each
user has full liability for the discharge of their wastewaters, and could be required to compensate the
City and others for damages.
Implementations and enforcement of the industrial waste pretreatment program for the City of
Orlando has dramatically improved sludge quality. Reuse by land application, land reclamation,
vermiculture, and composting is now possible. Cadmium in the sludge was reduced as much as 90%,