Nebraska Pretreatment Program Permits

The Nebraska Pretreatment Program functions to protect municipal wastewater collection and treatment systems from damage or overloading by industrial dischargers. NDEE Title 119 - Rules and Regulations Pertaining to the Issuance of Permits under the National Pollutant Discharge Elimination System> sets forth prohibited discharge standards that apply to all industrial users of publicly-owned wastewater treatment facilities and require permits for significant industrial users.

The significant industrial users are determined by one of several means:
 

1) the existence of an industrial category for which pretreatment discharge standards are established in NDEE Title 119 - Rules and Regulations Pertaining to the Issuance of Permits under the National Pollutant Discharge Elimination System,

2) the volume or strength of the wastewater discharged from the facility, or

3) the potential of the industrial user to adversely affect the wastewater collection or treatment facilities.

The authority for establishing the Pretreatment Program is derived from the NPDES program requirements set forth in Section 402 of the Federal Clean Water Act. The issuance procedures and general format of Pretreatment Program and NPDES permits are very similar. Permittees are required to carry out self-monitoring activities, maintain records and submit periodic reports. Compliance activities include report reviews, on-site inspections and compliance monitoring inspections.

Although the Pretreatment Program is really a subprogram of the NPDES program, the administration of this program requires considerably more coordination and cooperation with local municipal officials.

To accomplish this, the Department has entered into Memorandums of Agreement (MOAs) with 11 communities describing respective city and state responsibilities. The agreements vary in nature depending on the size and capabilities of the community. Omaha and Lincoln are the most active municipal partners, accepting responsibility for a large variety of activities including facility sampling, inspections, complaint investigations, permit reviews, and industrial user technical assistance.

Other communities rely more heavily upon the State for compliance inspections and technical reviews. However, all cities have agreed to conduct initial complaint or incident investigations, report significant incidents to the Department and to assist in permit development by reviewing draft permits.

The Department is working with communities throughout the State to get them more involved in the pretreatment program and to improve cooperative efforts in this program.