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Who Must Develop an Approved Wastewater Pretreatment Program?

Who must develop an approved treatment program for a publicly-owned treatment works.

If a publicly owned treatment worksAdobe Acrobat PDF Document (POTW)–or combination of POTWs owned by the same entity–must develop an approved pretreatment program, the Texas Commission on Environmental Quality (TCEQ) will require it through either a TPDES permit or an enforcement action.


The TCEQ may require the development of a TPDES pretreatment program when the POTW (or combination of WWTPs) meets the following conditions:

  • The total design flow is greater than 5 million gallons per day;
  • Industrial or commercial customers of the POTW discharge pollutants into the wastewater system that either pass through the treatment plant or interfere with its operation; or
  • One or more industrial users of the POTW meet the definition of "categorical industrial user."


The TCEQ may also consider the following factors, and require a POTW to develop a TPDES pretreatment program if applicable:

  • The nature and volume of industrial wastewater received by the POTW;
  • Whether contaminants that could have been removed or controlled by pretreatment have prevented sewage sludge from being used or disposed of as intended;
  • Whether a pretreatment program will make significant differences in water quality in the water that receives effluent from the POTW—for example, in terms of the listed impairments on the 303(d) List or with respect to a total maximum daily load; or
  • The POTW's compliance history.


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