The Pretreatment Regulations apply to publicly owned treatment works (POTWs) and to industrial users discharging pollutants to POTWs from non-domestic sources. The Pretreatment Regulations prohibit any discharge to a POTW that causes a violation of the POTW?s NPDES permit or disrupts the POTW?s treatment process. With limited exceptions, POTWs that receive industrial waste are required to develop Pretreatment programs. These programs must include mechanisms to ensure that industrial users comply with Pretreatment standards and requirements, which include enforcement if necessary.
The South Fort Collins Sanitation District?s POTW has an approved Pretreatment program and is considered a control authority with regard to the Pretreatment Regulations in their service area. The EPA inspectors conducted a Pretreatment audit at the South Fort Collins POTW on April 15-17, 2019. Violations observed included a failure by the District to update its Pretreatment Rules and Regulations and local limits, failure to implement its procedure for identifying and locating industrial users (IUs) discharging pollutants to the District?s publicly owned treatment works, failure to include all required elements in significant industrial user (SIU) permits, failure to evaluate the need for SIUs to develop slug control plans, and failure to ensure that IUs complied with reporting requirements. On April 24, 2020 the South Fort Collins Sanitation District and the EPA entered into an Administrative Order