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Developing a New Pretreatment Program

Milestones for POTWs developing pretreatment programs.

If a publicly-owned treatment works (POTW) is required to develop a pretreatment program, the final, technically complete package is due 12 months after the effective date of the Texas Pollution Discharge Elimination System (TPDES) permit.

Schedule of Activities

The permit must include a schedule of activitiesAdobe Acrobat PDF Document (compliance schedule). Submit the activities to the TCEQ Pretreatment Program according to the specified dates specified in the Contributing Industries and Pretreatment Requirements section of your TPDES permit.

Industrial User Survey

The first activity for the permittee will be to conduct an industrial user survey to determine if there are significant industrial users or categorical industrial users discharging to the sewer system. Based on the survey results the TCEQ may terminate the requirement for a pretreatment program or may require continuing the schedule of activities. (Title 40, Code of Federal Regulations, Part 403.8(a)-(c) Exit the TCEQ)


If required to develop a new pretreatment program, complete and submit the applicable checklists with the pretreatment program package: streamlining required nonsubstantial modification submittal, streamlining optional substantial modification submittal, legal authority, enforcement response plan, forms, standard operating  procedures, and sampling protocols.  Contact us to obtain a copy of the checklists.