The Wisconsin DNR’s Pretreatment Program is a requirement of the federal Clean Water Act law outlined in the Code of Federal Regulations (CFR) 40, in various sections and subsections. The term “pretreatment discharger” refers to the situation where the facility does not discharge their wastewater directly to the waters of the state. Instead, the discharge flows into a municipal sewage treatment plant (also called a POTW or publicly owned treatment works) and mixes with other sewage for treatment before it is discharged to the waters of the state. The US EPA has designated the State of Wisconsin DNR to administer this federal code within the state. In response to this designation, the State has adopted several State Administrative Codes that describe the requirements for pretreatment discharges. These are contained in Wis. Admin. Codes NR 211, and NR 220-297.
Pretreatment dischargers are issued permits if regulated by publicly owned treatment works (POTWs) delegated to implement the program, or they are issued control documents if regulated by the Department. Control documents can be issued directly to the facility by the DNR, or the DNR can pass this permitting authority on to the local POTW if the POTW is designated as a “control authority” for this function. Permits issued by control authorities have an expiration date; control documents issued by the DNR do not have expiration dates. A control authority can develop its own discharge requirements under its municipal ordinances, but they cannot be less restrictive than the federal regulations. The discharge limitations are grouped by categories of industrial and commercial dischargers and subgrouped by the federal standard industrial coding or SIC code that applies to that facility.
Facilities that discharge in the pretreatment program are required to send periodic compliance reports (PCRs) to the DNR or the control authority for review of their compliance with pretreatment discharge limitations. These PCRs are reviewed and the data entered into a computer system for compliance tracking. The actual data entry and compliance tracking is decentralized across the state. For facilities that have DNR control documents, the compliance tracking is done by the Regional Office of the DNR. For facilities that are indirectly regulated by the control authorities, each Regional Office has designated a person or persons to track compliance and do compliance inspections and enforcement.
The Fond du Lac Regional Wastewater Treatment Resource & Recover Facility administers an industrial pretreatment program that regulates certain industrial users. These users are monitored in order to control the introduction of pollutants into the sewer system and ultimately into our treatment facility.
The industrial users are must abide by federal, state and local requirements through the use of a permit system. The Industrial Wastewater Discharge Permit outlines and references the requirements necessary to comply with all applicable wastewater regulations. Major industrial permits are issued for industries with significant wastewater volumes which can impact the receiving water. Before DNR can issue or reissue a major permit, EPA concurrence is needed. Majors are determined by calculating an EPA score which considers the 6 factors listed below. A score of 80 or more results in classification as a major.
- Toxic pollutant protection
- Wastewater volume/stream flow
- Conventional pollutants
- Public health impacts
- Water quality factors
- Proximity to coastal waters or Great Lakes
All other specific (individual) industrial permits are considered industrial minors. Besides being classified as major or minor, industrial permits are also determined to be complex and non- complex. Complex permits are those surface water discharges with water quality based effluent limits, categorical limits and land disposal systems with groundwater monitoring wells. Industrial Non-complex permits include discharges of low strength wastewater (which may or may not be treated) from small industries discharging to surface water with categorical limits
Compliance monitoring samples are collected by Fond du Lac Regional Wastewater Treatment Resource & Recovery Facility personnel.
Each industrial user’s facility is inspected annually by Fond du Lac Regional Wastewater Treatment Resource & Recovery Facility personnel. As part of these inspections, all operations that use water are reviewed, including any pretreatment system.
The Fond du Lac Regional Wastewater Treatment Resource & Recovery Facility is proud of the effort it makes to control the discharge of pollutants into the sewer system. Our goal is to reduce our environmental footprint and improve our local environment.