Industrial Pretreatment Program
The Water Reclamation Facility for Henrico County, Virginia is a 75 mgd regional POTW with 1800 miles of sanitary sewer ranging in size from 8 inches to 84 inches. There is always the potential for an industrial discharge that is not compatible with the biological nature of the facility, thereby causing an upset. Pollutants may also pass-through the facility to the historic James River and cause an environmental problem for the river and our neighbors along the estuary. Bio-solids are dewatered and, by separate contract, applied to farmers’ fields as a soil amendment. Whether the liquid is discharged to the James River, or, the solids are applied to a farmer’s field, it is essential that an Industrial Pretreatment Program (IPP) continuously identifies potential significant industrial users, and permits their discharges.
Industrial Waste Survey
The General Pretreatment Regulations require identification of all possible Industrial Users which might be subject to the Pretreatment Program. Although not required but once every few years, the potential is great that a discharger could be connected to the sanitary system and cause great harm to the facility, and to the river. The Henrico County Industrial Waste Survey (IWS) program continuously monitors the types of commercial or industrial customers being connected to our system. By knowing the nature of the business, we can classify the discharger into one of several two-letter Sub-Classification Codes (see below). The Customer Service Representatives are our ‘first line of defense’ in determining new customer, or new tenant, status. The CSR asks, ‘what is the nature of your business?’ and then proceeds to classify the customer.
Customers added to the billing system are reviewed monthly. If there is any question about the nature of the business, a one page survey form is sent to that customer. The response may initiate a more in-depth joint IWS/Discharge Application form.
Account Subclassification Code System
The subclassification system is based upon simple two-letter codes that represent classes of businesses or industry. Many of the codes used in the County’s system have their foundation in the Environmental Protection Agency’s (EPA) list of CATEGORICAL industries. These are industries that have discharges unique to that category of industry. For example, all industries in the Metal Finishing category will have limitations placed on their discharge for several of the heavy metals, such as copper, nickel, and zinc and total toxic organic compounds. Industries in the Aluminum Forming category on the other hand have limitations placed on them for aluminum, cyanide, zinc and chromium.
A simple two-letter subclassification system helps to manage the data for the non-categorical industries and businesses as well. Restaurant discharges, as an example, are not yet governed by the federal government, but are regulated by County Code for oil and grease. The two-letter system is a simple way to accomplish the goals and objectives of the Monitoring and Compliance Program, as well as allow other users of the billing system to sort data. With over 97,000 billing accounts, being able to sort data by the nature of the business is extremely beneficial to all users.
There are currently over 50 different two-letter subclassification codes in our system. Only a few of the codes will be used routinely, however. A full list of the Sub-Classification Codes can be obtained below.
Enforcement Response Plan (.pdf)
Discharge Application/Industrial Waste Survey (Microsoft Word format)
Industrial Waste Survey (Short Form) (Microsoft Word format)