Pretreatment Program Quick Links

Services Offered for Pretreatment Program Components
Local Limit Evaluations and Updates  |  Sampling Plans |  New Industry Evaluations  |  Industrial User Permits  |  Industrial User Inspections  |  Industrial Waste Surveys |  Dental Amalgam Implementation

Legal Authority
Ordinance Updates  | Enforcement Response Guides  |  Enforcement Actions

Program Implementation  
Training Events   |  Procedures and Forms 

Development, Updates, and Implementation

KimHEC can comprehensively create or update a Pretreatment Program including local limit calculations, legal authority, procedures and templates as described in the Program Components. KimHEC assists in Pretreatment Program Implementation tailored to the individual community’s needs. We specialize in providing customized assistance in ensuring environmental and wastewater staff have the resources needed to adequately implement pretreatment programs.

Assistance can range from training to hands-on assistance with implementation. KimHEC will participate in industrial inspections and review industrial user reports for compliance.

We specialize in providing communities and their industrial customers with the tools needed to maintain compliance with Pretreament Program requirements. 

Services Offered for Pretreatment Program Components  

Local Limit Evaluations and Updates

KimHEC will evaluate the need to update local limits based on changes since the local limits were developed. KimHEC stresses the importance of monitoring the community’s influent loading to confirm loading from current industries and potentially unidentified industries. KimHEC also provides detailed local limit updates which incorporates analytical data from domestic background and biosolids; KimHEC strives to provide a realistic understanding of the impact of industrial discharges on a community’s wastewater system.

Sampling Plans

Includes required and recommending sampling on an annual basis so that local limit evaluations can be performed after each permit renewal. Flexibility of also summarizing MSOP/NPDES permit requirements or just focused on pretreatment. Communication with contract labs on required reporting limits. Incorporates/takes advantage of sampling already required in the permit (e.g., expanded effluent tests and annual biosolids tests). KimHEC also strives to understand pollutants of concern for each industry; regulations for the industries are frequently out-dated and federal standards do not necessarily identify the appropriate pollutants of concern.

New Industry Evaluations

KimHEC can assist in evaluating new (or newly identified) industries for falling under a categorical standard or are otherwise significant industrial users. KimHEC works to ensure permit applications contain the necessary information to be able to fully evaluate industries so that permits can be developed which are appropriate for the industry’s ability to impact your POTW.

Industrial User Permits

KimHEC-developed Industrial User permits include fact sheets to document the permit decision making process which includes identification of pollutants of concern, monitoring frequencies, monitoring locations, limits, and sample types. KimHEC permits also include the development of self-monitoring report templates to give the industries a template which helps ensure compliance with the program requirements (certification statements, discharge volume documentation, compliance with numerical results, etc.). KimHEC can calculate production-based standards and incorporate that into the permit requirements.

Industrial User Inspections

Assist in the review of records, on-site inspection, and documentation including any follow-up required.

Industrial Waste Surveys

Streamlined procedure which uses a federal database, water records, google map with facility locations and summarized data, elimination process, and one-page survey to narrowed-down list of industries. KimHEC recommends a survey be performed before each local limit evaluation (to confirm the industrial flows).

Dental Amalgam Implementation

KimHEC can help identify dental facilities, customize one-time compliance forms for distribution, and assist in the tracking of facilities returning the forms.

Legal Authority

Ordinance Updates

KimHEC has a process to review required and optional components of the federal streamlining rule and works to customize sewer use ordinances based on the community’s needs. KimHEC can also provide a comprehensive review of the City Code for your utility to ensure redundant or contradictory sections of the code do not exist in different sections. KimHEC provides additional code considerations such as the legal authority for audio and visual documentation during industrial user site visits.

Enforcement Response Guides

KimHEC has developed a template that can incorporate your legal authority and customize the ERP to your community. Significant attention is given to escalating responses appropriate to the violation (for example, minor numerical permit limit violations can be addressed informally with a phone call or email communication).

Enforcement Actions 

KimHEC can assist in compliance determination and responses on behalf of the municipality. NOVs, compliance schedules, fines, and terminations can be drafted as determined by the ERP. KimHEC can assist in the determination of the compliance of industries and evaluates industrial monitoring data for technical and chronic review criteria to determine significant noncompliance. 

Program Implementation  

Training Events  

Lunch ‘n Learn to provide training to Industries and pretreatment/administrative personnel: Includes background on what a pretreatment program is, what the City has to do, and what the industry requirements are. Review common errors/omissions historically observed by the industries. 

Procedures and Forms 

KimHEC has developed and continues to develop standard forms for the implementation of Pretreatment Programs. These forms include permit applications, TTO waiver processes, plant closure procedures, and templates for public notification of significant noncompliance.