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Ames City Government












City of Ames

Water & Pollution Control Department

300 East 5th Street
Building 1
Ames, Iowa 50010

Phone:
(515) 239-5150

FAX:
(515) 239-5251

Water and Pollution Control Department

Pretreatment Program Permitting Procedure

Information  |  Program  |  Links  |  Wastewater Treatment Application  
Local Limits
 |  Questionnaire   |   Enforcement Response   |   Surcharges
Hauled Wastes & Special Discharges   |  
Waste Hauler Tracking Form

 

Quick Links
  Application for Wastewater Treatment
  Pretreatment Permit
  Contract for Wastewater Treatment
  New Sources
  New Categorical Standards
  Local Pretreatment Limits
  Monitoring and Reporting

Application for Wastewater Treatment

Any contributor that wants to discharge wastewater that is not similar to normal domestic wastewater (non-domestic) into the City of Ames municipal sanitary sewer system must fill out an Application for Wastewater Treatment and an Industrial Waste Information Questionnaire. These two forms are used by city staff to determine if the contributor needs to be permitted under the City of Ames Non-Domestic Waste Pretreatment Program.

The first step in the permitting process is to determine if the contributor should be designated as a non-domestic contributor.

A non-domestic contributor is defined as a contributor of wastewater containing gaseous, liquid, or solid material, other than typical domestic wastes, to the municipal sanitary sewer system.  Many commercial or industrial facilities discharge only domestic waste and do not require a pretreatment permit.  Other contributors discharge such small volumes of non-domestic waste that their discharge has an insignificant potential to adversely impact the WPC Facility or the sanitary sewer system.  Such facilities are also exempt from pretreatment permitting requirements.  The Application for Wastewater Treatment and Industrial Waste Information Questionnaire provide the information city staff use to make the determination of which facilities require a pretreatment permit.

If a facility is required to obtain a pretreatment permit, it will be placed in one of three classes as follows:

 

Class 1:  Significant Industrial User (SIU)

  A Significant Industrial User is defined in the EPA federal regulations (40 CFR 403.3(v)) as any contributor to the municipal sanitary sewer system which:
 
  • discharges an average of 25,000 gallons per day or more of process wastewater to the Publicly Owned Treatment Works (POTW), excluding sanitary, non-contact cooling, and boiler blowdown wastewater; or
  • contributes a process waste stream which makes up five percent or more of the average dry-weather hydraulic or organic capacity of the POTW; or
  • is designated as such by the City on the basis that the contributor has a reasonable potential to adversely affect the POTW’s operation or for violating any pretreatment standard or requirement.
  If it is determined that a contributor meeting Class 1 criteria above does not have a reasonable potential for adversely affecting the POTW’s operations or for violating any pretreatment standard or requirement, the Director of the Water and Pollution Control Department may determine that such a contributor is not a Significant Industrial User.
 

Class 2:  Categorical Industrial User (CIU)

  Any industry that is subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR Chapter I, Subchapter N is considered a Categorical Industrial User as well as a Significant Industrial User.
 

Class 3:  Minor Non-Domestic User

  A case-by-case evaluation of the quantity and quality of the contributor’s wastewater and the potential for discharging wastes of a non-domestic nature is used to determine which facilities fall into this category. This class may include wastewater from industry, commercial, landfill, medical facilities, animal facilities, and large governmental facilities.

Pretreatment Permit

All Class 1, 2, and 3 contributors must obtain a Permit for Wastewater Treatment (pretreatment permit) from the City before discharging any non-domestic wastewater to the municipal sanitary sewer system.  The permit will be valid for a specified duration not to exceed five years.  Periodically, but at least every five years, the City will request an updated questionnaire from the contributor.  The updated questionnaire will be used to issue permit renewals or updates.  In addition, notice of anticipated changes in the quality or an increase in pollutants contributed must be given by the contributor to the City six months in advance of the increase or change to allow sufficient time for review by city staff and re-issuance of the pretreatment permit. 

Pretreatment permits will include quality and quantity limitations, monitoring and reporting requirements, and a compliance schedule when appropriate.  Contributors may be required to pre-treat or eliminate the discharge of wastewater which does not comply with the limitations.  Dilution in order to meet the permitted limits is prohibited.

Contract for Wastewater Treatment

In addition to the permit, each contributor must execute a Contract for Wastewater Treatment with the City.  In general, the Contract for Wastewater Treatment is valid for a period not to exceed 20 years. 

New Sources

New sources, as defined in 40 CFR 403.3(m)(1), must meet all applicable pretreatment standards and requirements prior to beginning of discharge.  At least 90 days prior to commencement of discharge, a new source must submit to the City of Ames Water and Pollution Control Department a report that contains information as listed in 40 CFR 403.12(b)(1-5).  New sources shall also be required to include in this report information on the method of pretreatment the source intends to use to meet applicable pretreatment standards. New sources shall give estimates of the information requested in paragraphs (b) (4) and (5) of 40 CFR 403.12.

New Categorical Standards

Within 180 days after the effective date of a categorical pretreatment standard or 180 days after the final administrative decision made upon a category determination submission under 40 CFR 403.6(a)(4), whichever is later, existing non-domestic contributors subject to such categorical pretreatment standards and currently discharging, or scheduled to discharge, to the City sanitary sewer shall be required to submit to the City of Ames Water Pollution Control Department a report which contains the information listed in 40 CFR 403.12 (b)(1)–(7).  At least 90 days prior to commencement of discharge, sources that become Significant Industrial Users subsequent to the promulgation of an applicable categorical standard, shall be required to submit to the City a report which contains the information listed in paragraphs 40 CFR 403.12 (b)(1)–(5).

Local Pretreatment Limits

The City of Ames is required to enforce federal pretreatment standards promulgated pursuant to the Federal Water Pollution Control Act.  These standards are commonly referred to as Categorical Standards and apply only to certain industrial groups or categories (Class 2).  The standards can be found in 40 CFR Part 405 through Part 471.  Where applicable or appropriate, the federal pretreatment requirements will be used to establish the quality and quantity limitations contained in the Pretreatment Permit for those in Class 2.  The City is required by law to use the most stringent of the categorical or local discharge limits in the pretreatment permit.

Upon promulgation of a Federal Categorical Pretreatment Standard for a particular industrial category, the federal standard, if more stringent than the local discharge limitations, will supersede the limitations previously in the pretreatment permit for all facilities included in the federal category.

Since most of the pretreatment facilities in Ames do not fall under a federal categorical standard, the City of Ames has been required to develop local discharge limits to control the pollutant discharges from the non-domestic wastewater dischargers to the Ames sanitary sewer system.  Local limits are calculated by staff, approved by the IDNR, adopted by the City Council, and incorporated into the individual permits. City staff use an Excel spreadsheet to take into account all of the information required in the development of local discharge limits.  Information used to calculate local limits includes, but is not limited to, the following:

  • WPC NPDES permit limits
  • Skunk River water quality standards
  • Federal 40CFR Part 503 land-applied biosolids limits
  • Treatment process inhibition limits
  • Treatment process removal efficiencies
  • WPC Facility influent and effluent flows
  • WPC Facility biosolids mass produced
  • Treatment plant influent/effluent/biosolids data
  • POTW worker safety limits
  • Background domestic contributions
  • Growth/safety factors
City of Ames local limits have been approved by the IDNR as masses allowed into the WPC Facility headworks from non-domestic sources.  (See the City of Ames Pretreatment website.)  Therefore, the Water and Pollution Control Department is able to equitably distribute the allowable masses among the non-domestic facilities.  The individual facility permits may contain concentration and/or mass limits. 

Prior to City Council adoption of new or revised local discharge limits, the City will notify all permitted contributors of the proposed discharge limits and provide an opportunity for comment.  Upon adoption of new or revised limits, the City will provide the contributor a reasonable period of time in which to comply with the new limits.  The City will establish and enforce deadlines for meeting pretreatment limits.

Monitoring and Reporting

Federal pretreatment regulations require that each significant non-domestic contributor monitor and report the quality and quantity of their discharge to the City (self-monitor).  The City must review and report these data to the IDNR and EPA.  The frequency and amount of analysis required will vary, depending on the volume of the discharge and the mass of pollutants being discharged.  The monitoring and reporting requirements for each non-domestic facility will be specified in their pretreatment permit.  If the contributor wishes to monitor more frequently than specified in the permit, the results of this monitoring must be submitted to the City.  Results must be submitted to the City within 10 calendar days of receipt by the non-domestic facility.

In addition to the facility self-monitoring, the City is required by federal regulations to independently sample and analyze each waste discharge to verify compliance with the pretreatment limitations.  If city analytical results do not verify well with non-domestic facility results, monitoring frequency will increase as the City investigates sampling and monitoring differences between the facility’s laboratory and the city’s laboratory.  All samples must be collected and analyzed according to federal analytical methods detailed in 40CFR Part 136.  Samples not sampled and analyzed according to 40CFR Part 136 are unacceptable as analytical data for the pretreatment program.

The minimum frequency of self-monitoring, reporting, and verification monitoring is listed in the following table.  More frequent monitoring and reporting may be required because of the volume and/or nature of the wastewater being discharged.  Monitoring and reporting frequencies will be determined on a case-by-case basis for each non-domestic facility.  When federal pretreatment regulations exist, the more frequent of the monitoring and reporting requirements established by the regulations or the City’s monitoring and reporting requirements will be followed.

Minimum Monitoring and Reporting Requirements
Ames, Iowa

Parameter

Significant/ Categorical Minor Monitored By
Flow Monthly metered and metered during sampling Monthly metered and metered during sampling City and non-domestic facility
Compatible Parameters (CBOD5, COD, TSS, NH3 and TKN) Once/3 months As Needed Non-domestic facility
Incompatible Parameters (metals, organic and inorganic chemicals, pH, temperature, etc.) Once/3 months As Needed Non-domestic facility
Reporting Frequency Once/3 months Once/6 months Non-domestic facility
Verification Monitoring Once/6 months Once/6 months City
The frequency and amount of analysis required will be specified in each contributor’s pretreatment permit.  If the contributor wishes to monitor more frequently than specified in the permit, the results of this monitoring must be submitted to the City within 10 calendar days of receipt by the non-domestic facility.  The results may be submitted with the periodic monitoring report or separately.  In either case the following signed and dated statement must accompany the monitoring results, “I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.  Based on my inquiry of the person(s) who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.  I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”

Periodic monitoring reports must be completed with data obtained through appropriate sampling and analysis performed during the period covered by the report and must cover topics such as status of compliance with the permit provisions, plant upset duration, special discharges, changes is discharge quality or quantity, etc.  All pretreatment samples must be collected and analyzed according to procedures listed in 40 CFR Part 136.

If sampling performed by the contributor indicates a violation, the contributor is required to notify the City within 24 hours of becoming aware of the violation.  The contributor must also repeat the sampling within 10 days of becoming aware of the violation and submit the sample results to the City within 30 days of becoming aware of the violation.  In addition, the contributor must notify the City immediately of any discharge, including any spills or slug loadings, as defined in 40CFR part 403.5(b) (such as discharges resulting from a spill, equipment failure, human error, or negligence, etc.), that may contribute to an interference or other deleterious situation in the POTW (including the sanitary sewer system).  In addition, a written notification must be submitted to the City within five calendar days of the incident.  The notification must include steps the contributor intends to take to prevent future occurrences of the deleterious discharge.

All pretreatment sampling and analysis must be performed in accordance with 40CFR Part 136.  Alternative analytical methods may be approved on a case-by-case basis for Minor Non-Domestic contributors.  Grab samples must be collected for pH, cyanide, total phenols, oil and grease, sulfide, and volatile organics.  For all other parameters, flow-proportional composite sampling techniques must be used whenever possible.  Time-proportional composite sampling techniques may be approved for use on a case-by-case basis.

The City and the contributor shall be required to retain for a minimum of three years any records of monitoring activities and results and shall make such records available for inspection and copying by the EPA and IDNR (and the City in the case of the contributor). This period of retention shall be extended during the course of any unresolved litigation regarding the contributor or the City or when requested by the EPA, IDNR, or the City.

Sampling records shall include at a minimum (in chain-of-custody format) the following:

  • The date, exact place, method, and time of sampling and the names of the person or persons taking the samples
  • The dates analyses were performed
  • Who performed the analyses
  • The analytical techniques/methods use
  • The results of such analyses
The City reserves the right to inspect and copy records of the contributor pertaining to the pretreatment program.  Certain information submitted to the City pursuant to the pretreatment program may be claimed as confidential by the contributor.  Such claims must be made in writing within five working days of the City obtaining the information from the contributor.  If such a claim is asserted within the specified period, the City will treat the information in accordance with the procedures of 40CFR Part 2.  If no such claim is asserted, the City may make the information available to the public without further notice.  Information and data on wastewater constituents and characteristics cannot be kept confidential and must be available to the public without restriction.