Industrial Pretreatment Program
In April of 1985 the New Jersey Department of Environmental Protection (NJDEP) modified NBCUA’s discharge permit declaring the Authority a “Delegated Agency”, requiring the Authority to administer and enforce an Industrial Pretreatment Program (IPP) as a condition of its NJPDES permit to discharge to the Ho-Ho-Kus Brook and to meet the requirements and goals of the National Pretreatment Program. The NBCUA program must also conform to the requirements of the New Jersey Water Pollution Control Act as amended by the Clean Water Enforcement Act of 1990, which mandates certain program requirements that are more restrictive than the National Pretreatment Program.
Since the program’s inception, it has been effective in protecting the NBCUA wastewater treatment plant, the local community and the Ho-Ho-Kus Brook from the negative impacts of non-domestic wastewater. The IPP protects the collection system and treatment facilities from corrosive and explosive chemicals. The biological treatment processes are protected from upset and interference caused by toxic pollutants or excessive oxygen demand. The IPP controls the discharge of pollutants, such as metals, which may pass through the treatment process untreated and cause environmental damage. The NBCUA treatment plant workers are protected from pollutants that may jeopardize their health and safety. In recent years, sludge quality has become an important consideration for the NBCUA and it is largely through the efforts of the IPP that the NBCUA has achieved compliance with stringent sludge quality metals limitations for sludge incineration.
Dischargers of industrial process wastewater to the NBCUA treatment plant must adhere to the provisions of the IPP. These provisions are described in the Appendix A to the Service Contract Rules, Regulations and Standards. In some cases, compliance with the effluent limitations imposed by the IPP requires an industrial user to significantly reduce the amount of pollutants in the industrial process wastewater through installation of pretreatment technology, pollution prevention, or other means, prior to discharging to the collection system. Industrial users are issued Industrial Wastewater Discharge Permits that contain the specific requirements the industry must comply with, which include effluent limitations, monitoring and reporting requirements, and applicable penalties for non-compliance. Each industrial user is inspected and sampled by NBCUA personnel at least once per year, depending on the size, type and compliance status of the industry.
Industrial users discharging to the NBCUA are subject to the Prohibitive Discharge Standards described in the General Pretreatment Regulations. Industries that are classified as categorical facilities, such as pharmaceutical companies or metal finishers, must comply with the technology-based National Categorical Standards promulgated by the USEPA for that industry. The NBCUA regulates 3 categorical industries through the IPP and enforces the categorical effluent limitations developed for each industry. Additionally, the NBCUA has developed local pretreatment limitations for industrial users to address local needs. Industrial users must comply with local pretreatment limitations whether or not they are subject to the National Categorical Standards.
The local pretreatment limitations imposed on industrial users by the IPP were developed to protect the biological processes of the wastewater treatment plant, in addition to meeting the ever changing air emissions limits for sewage sludge incinerators.
As a “Delegated Agency” NBCUA has the authority to enforce the limitation contained in an IPP discharge permit issued to industrial users. The enforcement actions taken against industrial users for permit violations are described in the Enforcement Response Plan (ERP) contained in the Rules and Regulations. The primary purpose of the ERP is to set forth procedures indicating how the NBCUA will investigate and respond to instances of industrial user non-compliance. The goals in undertaking the respective enforcement actions are to secure compliance with pretreatment requirements and, when appropriate, recoup any damages suffered by the NBCUA, the local community, or the environment. The enforcement actions taken in response to industrial user violations in escalating order include a Notice of Violation, Compliance Order, Consent Order, Order to Show Cause, Civil Action, Civil Administrative Penalties, Criminal Action, and termination of services. In deciding which enforcement response to select the NBCUA gives consideration to the magnitude of the violation, duration of the violation, effect of the violation on the Ho-Ho-Kus Brook or other receiving water, effect of the violation on the treatment works, compliance history of the permittee, and good faith of the permittee. The development of an ERP is a federal requirement.
Applications and Forms
The following Forms are available to participants in the IPP Program.
September 19, 2018