Managing Facilities, Due Diligence and Facility Transfers
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discharged to sanitary sewers, storm drains, surface impoundments, and
waterways. Regardless of pretreatment method, industrial effluent
typically retains some pollutants. Minimum National Effluent Standards are
specified for each industry to control the types and quantities of
pollutants entering sewers and receiving waters.
Publicly-owned Treatment Works (POTWs)
NPDES Permits for POTWs: Like other direct dischargers, POTWs
are required to apply for NPDES permits for their discharges to waters
(see discussion supra for permit requirements). However, the
technology-based effluent limitations for POTWs differ
substantially from
those required of all other point source discharges. These differences
reflect the dominant role of POTWs in managing domestic pollutants and
municipal/household wastes, and the dominant role of the federal
government in providing funds to upgrade the pollution control capabili-
ties of these public sewerage agencies. POTWs' unique role in managing
industry's indirect discharges through their implementation of
pretreatment requirements constitutes another important distinction.
The 1972 Amendments made all discharges from POTWs subject to
secondary treatment as of July 1, 1977. As in the case for all other
point sources, EPA determines what constitutes secondary treatment and
more stringent requirements may be placed on POTWs if necessary to
meet water quality standards for the receiving waters.
Requirements for Indirect Discharges
(National Pretreatment
Standards for Industrial Users of POTWs): In order to protect the
operation of POTWs and to prevent the discharge from POTWs of
pollutants which have not received adequate treatment, CWA requires
EPA to adopt and amend, as necessary, national pretreatment standards
for discharges into POTWs. Discharges into POTWs are often referred
to as "indirect discharges" because they are not directly discharged into
receiving waters, but are sent through POTWs to the receiving waters.
Industrial users of POTWs for such "indirect discharges" are not
required to obtain NPDES permits. Rather, POTWs impose restrictions
or "pretreatment
standards" on these industrial users in order to ensure
compliance with their own NPDES permit and its discharge limitations.
POTWs regulate industrial discharges into their system to meet three
objectives:
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