New Jersey Discharger - Vol. 6 No. 2 Fall 1998- I

	Vol. 6 No. 2 Fall 1998
A Newsletter About New Jersey's Water Quality Programs

Pretreatment Program Requirements for Non-Delegated Local Agencies
Jim Keil, Bureau of Pretreatment and Residuals

Annual reports must be submitted on the anniversay date of the agency's NJPDES permit.

Many municipal treatment plants in New Jersey receive wastewater from various types of industries. These industries, known as indirect users, often must pretreat their wastewater because it is stronger than the domestic waste generated by residential uses. Without pretreatment, an indirect user's wastewater may upset the biological processes in the receiving treatment plant and may also contaminate the residuals (sludge).

Some indirect users are regulated by the DEP because they discharge to a municipal treatment plant that does not have an approved industrial pretreatment program (non-delegated). Others are regulated by a delegated local agency. To receive "delegated" status, a local agency must demonstrate to the DEP that it has the legal authority, procedures, and resources to adequately administer a pretreatment permitting program.

Alum Tank Non-delegated local agencies have certain pretreatment program requirements specified in their NJPDES discharge to surface water (DSW) permit. These requirements, usually contained in Part IV-A of the permit, require some action on the part of the non-delegated local agency. Some of these requirements include:

Notifying the Bureau of Pretreatment and Residuals of any new source Significant Indirect (Industrial) User (SIU), as defined by N.J.A.C. 7:14A-1.2, prior to discharging into the treatment works of the agency. The agency should provide the following information to the DEP, Division of Water Quality, Industrial Pretreatment Section: the name, address, telephone number and facility contact of all new source SIUs.

Submitting a copy of the existing Sewer Use Ordinance (SUO) or Rules and Regulations to the Industrial Pretreatment Section within 30 days of the effective date of the local agency's NJPDES/DSW permit.

Submitting an annual report to the Industrial Pretreatment Section, Bureau of Pretreatment and Residuals, Division of Water Quality, P.O. Box 029, Trenton, New Jersey 08625. This report is not required if there are no indirect dischargers, as defined by N.J.A.C. 7:14A-1.2. In such cases, a certification letter is required, in lieu of the report, attesting to the absence of such users in the system.
Annual reports must be submitted on the anniversary date of the agency's NJPDES permit with the following information:

Changes in the SUO or Rules and Regulations enacted since the last annual report; and
For the period since the last annual report, the agency must provide a tabulation of the following:
1. name, address, and line of business of new indirect dischargers connecting into the agency's system,
2. if known, names and addresses of indirect dischargers which have gone out of business or relocated out of the agency's service area, and
3. if known, name changes, address changes, etc., for other existing indirect dischargers in the agency's service area.

Developing local limits in accordance with N.J.A.C. 7:14A-19.3(b)2.ii. A non-delegated local agency is required to develop local limits or demonstrate that such limits are not necessary in accordance with N.J.A.C. 7:14A-19.7.

The Bureau of Pretreatment and Residuals plans to conduct regional seminars in the fall to further review, discuss, and clarify these requirements. If you have any questions regarding this matter, please contact Jim Keil, Bureau of Pretreatment and Residuals, at (609) 633-3823.

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Last revision Tuesday, September 08, 1998