City of Manchester, NH Official Website

Industrial Pretreatment

Class 3 Commercial BusinessesWelcome to the City of Manchester’s Industrial Pretreatment Site. The purpose of this department is to inspect industries that discharge wastewater to the City’s treatment plant. Toxic industrial loads can easily upset the biological treatment process at the City’s Wastewater Treatment Plant. This is why City Ordinance and Federal Regulations require the Industrial Pretreatment Program.

Numerous bacteria in concentrated amounts of hundreds of millions are grown in the aeration basins. These naturally occurring bacteria breakdown the wastes from home and industrial discharges into carbon dioxide and water. When these bacteria get sluggish, sick and/or die from toxic discharge, the wastewater that enters the plant is treated to a lesser degree and the impact is a dirtier discharge that is sent to the Merrimack River.

The above staff members inspect all Class I industrial users at least once annually. Their wastewater discharge is also sampled at least once annually to determine the concentration and amount of pollutants discharged. They are permitted for up to three years and must self-monitor their wastewater discharge twice annually and submit a report of compliance twice annually.

More can be learned about which industries fall into what category by clicking on that associated link to the left.


Organization & Administration

Two employees administer the City of Manchester’s Industrial Permits, Monitoring and Pretreatment Program. The Pretreatment Supervisor administers the overall program implementation. Assisting the Supervisor is the Pretreatment Inspector, responsible for coordinating field activities and participating in inspections. These two individuals are under the direct supervision of the Chief Sanitary Engineer. This comprises the Industrial Monitoring Section of the Environmental Protection Division. The Environmental Protection Division (EPD) is a Division of the Department of Highways. As a division of the Highway Department, the Environmental Protection Division receives its authority and powers through the Board of Mayor and Aldermen and is advised by a 5-member appointed Highway Commission.

Click this link "History of the Pretreatment Program" if you are interested in learning the progress of the Pretreatment Program from 1980 through present.

Note of Reference

The information below this line is information intended for Manchester's Industrial User's and may seem confusing to the general reader. It sites laws and regulations required of each permitted industry here in Manchester.

Pretreatment Program Purpose & Applicability

The Environmental Protection Agency (EPA) promulgated specific regulations for the purpose of controlling wastewater discharges from industrial users. These regulations prescribe effluent limitations guidelines for existing sources, standards of performance for new sources, and pretreatment standards for new and existing sources pursuant to sections 301, 304 (b) and (c), 306 (b) and (c), 307 (b) and (c) and 316 (b) of the Federal Water Pollution Control Act, as amended (the "Act"), 33 U.S.C. 1251, 1311, 1314 (b) and (c), 1316 (b) and (c), 1317 (b) and (c) and 1326(b); 89 Stat. 816; Pub. L. 92-500. Point sources of discharges of pollutants are required to comply with these regulations, where applicable, and permits issued by States or the EPA under the National Pollutant Discharge Elimination System (NPDES) established pursuant to section 401 of the Act must be conditioned upon compliance with applicable requirements of sections 301 and 306 (as well as certain other requirements).

Section §401.12 Law authorizing establishment of effluent limitations guidelines for existing sources, standards of performance for new sources and pretreatment standards of new and existing sources, provides a detailed explanation of the various numerical sections cited in the above paragraph.
§403.1(a) allows the implementation of the Federal Water Pollution Control Act as amended by the Clean Water Act of 1977 (Pub. L. 95-217). This act establishes responsibilities of Federal, State, and local government, industry and the public to implement National Pretreatment Standards to control pollutants which pass through or interfere with treatment processes in publicly Owned Treatment Works (POTWs) or which may contaminate sludge.

In addition to incorporating the Federal and State statutes, the City of Manchester will implement the provisions of 40 CFR through a combination of the following:

  • Implementation of the EPA Approved Industrial Pretreatment Program
  • Local Sewer Use Ordinance
  • Industrial User Permit System
  • Intermunicipal Agreements
  • Enforcement Response Plan

The City of Manchester is required to develop this program under §403.8 (a), which states that any POTW with a total design flow greater than 5 million gallons per day (mgd) and receiving from Industrial Users pollutants that could pass through or interfere with the operation of the POTW must have an approved program.

National Pretreatment Standards: Prohibited Discharges

The following sections are taken directly from the Federal Register in regards to the requirements of the Federal Industrial Pretreatment Program along with their specific citation.

  • Any user of the POTW, whether or not the User is subject to other National Pretreatment Standards or any national, State, or local Pretreatment Requirements, may not introduce any pollutant(s) which cause pass-through or interference. {§403.5(a)(1)}
  • A user shall have an affirmative defense in any action brought against it alleging a violation of general prohibitions if the User can demonstrate:
  • It did not know or have reason to know that its Discharge, alone or in conjunction with a discharge or discharges from other sources, would cause pass-through or interference
  • A local limit was developed and the User was in compliance with the local limit prior to or during the pass-through and interference
  • A local limit was not developed and the User's discharge prior to or during pass-through or interference did not change substantially in nature or constituents from the User's prior discharge activity. {§403.5(a)(2)(i)&(ii)(A)&(B)}

Specific Prohibitions

In addition, the following pollutants shall not be introduced into a POTW:

  • Pollutants which create a fire or explosion hazard in the POTW with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade using the test methods specified in 40 CFR 261.21. {§403.5(b)(1)}
  • Pollutants, which will cause corrosive structural damage to the POTW and collection system, but in no case discharges with pH, lower than 5.0 §403.5(b)(2)}
  • Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW or collection system resulting in Interference. {§403.5(b)(3)}
  • Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate and/or pollutant concentration which will cause Interference with the POTW. {§403.5(b)(4)}
  • Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40C (104F). {§403.5(b)(5)}
  • Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will cause interference or pass through. {§403.5(b)(6)}
  • Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that may cause acute worker health and safety problems. {§403.5(b)(7)}
  • Any trucked or hauled pollutants, except at discharge points designated by the POTW. {§403.5(b)(8)}

Local Limits

Below is listed the maximum concentrations of chemicals allowed in the effluent discharge of any Manchester industry, commercial, business or residential establishment.

  • Copper - 4.55 mg/l
  • Cyanide (total) - 2.86 mg/l
  • Lead - 0.94 mg/l
  • Mercury - 0.023 mg/l
  • Silver - 0.90 mg/l
  • Zinc - 10.42 mg/l

Screening Levels

Below is a list of acceptable maximum concentrations for certain chemicals. If one of these levels is exceeded by any industry, commercial establishment, business or residential unit then the situation causing the excess contaminant will be reviewed by EPD's monitoring staff. A permit will be issued that reflects the negotiated allowable discharge concentration for that particular parameter. Certain current permits have limits that are above these screening limits, but other safeguards are written into these specific individual permits to offset the increased pollutant discharge.

  • Benzene - 0.13 mg/l
  • BOD - 350 mg/l
  • Carbon Disulfide - 0.06 mg/l
  • Chlorine - 1,500 mg/l
  • Chloroform - 0.41 mg/l
  • 1,2 Dicholorethylene - 0.28 mg/l
  • Sulfide - 1.0 mg/l
  • Sulfate - 150 mg/l
  • Sulfate - 1,500 mg/l (for type II concrete structures)
  • Sulfite - 280 mg/l
  • Suspended Solids - 350 mg/l
  • Tetrachloroethylene - 0.53 mg/l
  • 1,1,1 trichloroethane - 1.55 mg/l
  • Trichloroethene - 0.71 mg/l
  • Oil & Grease - 100 mg/l (Petroleum or mineral origin, Method 1664 HEM/SGT)
  • Oil & Grease - 350 mg/l (Animal & vegetable origin, Method 1664 HEM)

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