The term pre-treatment means the treatment of wastewater by commercial or industrial facilities to remove harmful pollutants before being discharged to a sewer system under the control of a Publicly Owned Treatment Works (POTWs).

Any business or facility contemplating the addition or modification of discharge into the Town of Tonawanda sanitary sewer system are required to complete the pdf Industrial Waste Questionnaire  application.

"Pretreatment" is defined in Title 40 Code of Federal Regulations (40 CFR) Subsection 403.3(o) 

Objectives of the Pre-Treatment Program 

By placing controls and/or limits on levels of certain pollutants in wastewater discharged to your sewer system, you:

• prevent interference with the operation of your wastewater treatment plant
• prevent the introduction of pollutants that could pass-through your wastewater treatment plant untreated into the receiving body of water
• improve opportunities for reuse or recycling of wastewater and sewage sludge prevent the introduction of pollutants that could cause health or safety problems to the public or the environment

 
Meeting These Objectives: The Pre-Treatment Program 

The Pre-Treatment Program is part of the New York State Pollutant Discharge Elimination System program to control the pollutants discharged into sewer systems and to reduce the amount of pollutants released into the environment. Wastewater from homes, commercial buildings, and industrial facilities is collected and transported through a series of pipes—that is, a collection system—to wastewater treatment plants. These plants remove harmful organisms and contaminants from the wastewater before discharge into the receiving creek, river, or lake. 

Most POTWs are designed to treat sanitary (domestic) wastes from households, but not to treat toxic pollutants from industrial or commercial facilities. The toxic pollutants from industrial and commercial facilities may cause serious problems at POTWs. Problems may be prevented by recycling, waste minimization, chemical substitution, pre-treatment, or other best management practices to reduce or eliminate the pollutants from commercial or industrial facilities. 

The U.S. Environmental Protection Agency (EPA) developed the General Pre-Treatment Regulations under 40 CFR Part 403 to set responsibilities for federal, state, and local government, industry, and the public to achieve the National Pre-Treatment Program objectives. 

The Town of Tonawanda’s Pre-Treatment Program was developed and initiated in 1982 and finally approved by the U.S. Environmental Protection Agency in 1984. The 1972 Clean Water Act and the 1978 Federal General Pre-Treatment Regulations required the formation of the program. The General Pre-Treatment Regulations can be found in the Code of Federal Regulations, Title 40, Part 403 or the US EPA’s website. 

The EPA’s General Pre-Treatment Regulations apply to all businesses and industries, which introduce pollutants into the sewer system. The EPA recognized that by regulating the businesses and industries that were known to have pollutants in their wastewater, the Pre-Treatment Program would have greater impact on reducing pollutants in the sewer system. The EPA developed four criteria that a business or industry could fall under, that would designate them as a business or industry that is required to be regulated. These businesses or industries are known as Significant Industrial Users. The four criteria are: 

• An industrial user that discharges an average of 25,000 gallons per day or more of process wastewater;
• An industrial User that contributes a process waste stream making up to 5% or more of the average dry weather flow or organic capacity of the sewage treatment plant;
• An Industrial User designated by the Pre-Treatment Program to reasonably cause an adverse affect on the sewage treatment plant or violate any pre-treatment standard or requirement; or
• An Industrial User that is subject to Federal Categorical Pre-Treatment Standards, these industries are known as Categorical Industrial Users.

In addition to these four criteria, the Town of Tonawanda has established additional criteria that would be used to regulate a business or industry: 

• An Industrial User that has above normal strength sewage. Normal strength sewage is considered sewage with any of the following pollutant loadings: 250 mg/l Biochemical Oxygen Demand {BOD}, 250 mg/l Total Suspended Solids {TSS} and 6.0 mg/l Total Phosphates {TPO4}. Industries discharging greater than normal strength sewage are called Surchargeable Industries, and
• An Industrial User that has the potential for a spill of a substance of concern (pollutant) to enter the sewer system.

Based on these criteria of Significant Industrial User, the Town of Tonawanda accomplishes the objectives of the Pre-Treatment Program by permitting the affected businesses and industries.