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Industrial Pretreatment Program
The BCUA is required to administer and enforce an Industrial Pretreatment Program (IPP) as a condition of its NJPDES permit to discharge to the Hackensack River and to meet the requirements and goals of the National Pretreatment Program. The BCUA program must also conform to the requirements of the New Jersey Water Pollution Control Act as amended by the Clean Water Enforcement Act of 1990, which mandates certain program requirements that are more restrictive than the National Pretreatment Program.
Since its inception in 1984, the IPP has been effective in protecting the BCUA wastewater treatment plant, the local community and the Hackensack River from the negative impacts of industrial discharges. The IPP protects the collection system and treatment facilities from corrosive and explosive chemicals. The biological treatment processes are protected from upset and interference caused by toxic pollutants or excessive oxygen demand. The IPP controls the discharge of pollutants, such as metals, which may pass through the treatment process untreated and cause environmental damage. The BCUA treatment plant workers are protected from pollutants that may jeopardize their health and safety. In recent years, sludge quality has become an important consideration for the BCUA and it is largely through the efforts of the IPP that the BCUA has achieved compliance with stringent sludge quality metals limitations for beneficial reuse.
The goal of the IPP is to impose only those additional regulations on industry required to achieve the following objectives:
- Protection of capital facilities;
- Protection of the collection system and treatment plant personnel;
- Protection of the community;
- Protection of the environment; and
- Beneficial use of treatment plant sludge.
Dischargers of industrial process wastewater to the BCUA treatment plant must adhere to the provisions of the IPP. These provisions are described in the Rules and Regulations for the Direct and Indirect Discharge of Wastewater to the Bergen County Utilities Authority Treatment Works
(Rules and Regulations). In some cases, compliance with the effluent limitations imposed by the IPP requires an industrial user to significantly reduce the amount of pollutants in the industrial process wastewater through installation of pretreatment technology, pollution prevention, or other means, prior to discharging to the BCUA. Industrial users in the BCUA service area are issued Industrial Wastewater Discharge Permits that contain the specific requirements the industry must comply with, which include effluent limitations, monitoring and reporting requirements, and applicable penalties for non-compliance. Each industrial user is inspected and sampled by BCUA personnel at least once or twice per year, depending on the size, type and compliance status of the industry.
Industrial users discharging to the BCUA treatment works are subject to the Prohibitive Discharge Standards described in the General Pretreatment Regulations. Industries that are classified as categorical facilities, such as pharmaceutical companies or metal finishers, must comply with the technology-based National Categorical Standards promulgated by the USEPA for that industry. The BCUA regulates approximately 22 categorical industries through the IPP and enforces the categorical effluent limitations developed for each industry. Additionally, the BCUA has developed local pretreatment limitations for industrial users to address local needs. Industrial users must comply with local pretreatment limitations whether or not they are subject to the National Categorical Standards.
The local pretreatment limitations imposed on industrial users by the IPP were developed as part of the BCUA's program to exploit opportunities for beneficial use of sewage sludge. The practice of ocean disposal of sewage sludge was banned by the USEPA in 1991
The BCUA has achieved consistent compliance with the NJDEP Class "B" sludge quality criteria for land application of sludge as established by the NJDEP in the 1987 New Jersey State Sludge Management Plan, which defines all NJDEP sludge use and disposal requirements. The NJDEP has recognized the BCUA's efforts to improve sludge quality by officially upgrading the sludge to Class "B" on January 17, 1995. The BCUA's sludge quality also satisfies stringent federal sludge quality standards.
The enforcement actions taken against industrial users for permit violations are described in the Enforcement Response Plan
(ERP) contained in Appendix D of the BCUA's Rules and Regulations
. The primary purpose of the ERP is to set forth procedures indicating how the BCUA will investigate and respond to instances of industrial user non-compliance. The goals in undertaking the respective enforcement actions are to secure compliance with pretreatment requirements and, when appropriate, recoup any damages suffered by the BCUA, the local community, or the environment. The enforcement actions taken in response to industrial user violations in escalating order include a Clarification Request/Warning, Notice of Violation, Compliance Order, Consent Order, Order to Show Cause, Civil Action, Civil Administrative Penalties, Criminal Action, and termination of services. In deciding which enforcement response to select the BCUA gives consideration to the magnitude of the violation, duration of the violation, effect of the violation on the Hackensack River or other receiving water, effect of the violation on the treatment works, compliance history of the permittee, and good faith of the permittee. The development of an ERP is a federal requirement. The BCUA was the first local pretreatment program in New Jersey to draft and implement an ERP.