The Environmental Protection Agency (EPA) approved the Sanitation Districts' pretreatment program on March 27, 1985. Prior to this formal approval, the Sanitation Districts had established an industrial source control program with the following objectives: (1) to allow the Sanitation Districts' treatment plants to comply with effluent discharge requirements; (2) to protect the public, the environment, Sanitation Districts' personnel, and Sanitation Districts' facilities from potentially harmful industrial wastes; and (3) to ensure that industrial users pay their fair share of treatment operations and maintenance costs.

The Sanitation Districts' pretreatment program has been fully implemented for many years. The Sanitation Districts now regulates a diverse industrial base consisting of over 3,300 industries. These industries include 1,400 Significant Industrial Users (SIUs), among which 619 are included in the federal categorical pretreatment program in 24 different categories. Due to the large number of industrial users and the diversity of the industrial base, the Sanitation Districts' pretreatment program has been enhanced through the use of computer-automated permitting, inspection, and compliance programs that allow for tracking, assessment, notification, and enforcement of all applicable regulations.

Each of the Sanitation Districts' industrial users is required to obtain an Industrial Wastewater Discharge Permit. Permit applications are reviewed by engineering staff to determine if the pretreatment equipment proposed is adequate to meet appropriate discharge limits and to determine compliance with the Sanitation Districts' spill containment, flow monitoring, rainwater diversion, and combustible gas monitoring policies. Secondary review of permits is performed by the Sanitation Districts' project engineering staff, who function as technical specialists in specific fields of industry. One of the major roles of project engineering staff in secondary permit review is to ensure that all federal categorical pretreatment standards are applied correctly. Industrial users discharging without a valid permit are issued a temporary permit, which serves as a control mechanism for the user until a full permit can be obtained. The temporary permit provides the discharger with notification of the Sanitation Districts' effluent limitations and tentative federal categorical determination, and can be revoked at any time if the discharger fails to comply with the Sanitation Districts' requirements. In 1999, 260 Industrial Wastewater Discharge Permits were approved and 137 temporary permits were issued.

The Sanitation Districts maintains an active monitoring program to ensure continued compliance by its industrial users. Sampling for compliance purposes is conducted by both the industrial waste monitoring crew and industrial waste inspectors. The monitoring crew is devoted solely to sampling and obtains both grab and composite samples, while the inspectors collect grab samples in conjunction with on-site inspections of industrial equipment and wastewater sources. During 1999, a total of 2,730 grab and 3,245 routine composite samples were taken. The Sanitation Districts also have a surveillance monitoring program aimed at facilitating the detection of actual and potential problems caused by the illegal discharge of prohibited materials. Under the surveillance program, monitoring crew members work during the early morning hours to set up specialized sampling equipment in the public sewerage system at points upstream and downstream of industrial users suspected of illegal discharges. During 1999, 409 surveillance composite samples were taken. In addition to the Sanitation Districts' monitoring, 1,703 facilities are currently required to perform self-monitoring of their industrial wastewater and report the results to the Sanitation Districts.

The Sanitation Districts also maintain an extensive field inspection program, which includes visiting industrial facilities to investigate their compliance status, identifying industrial sources responsible for treatment plant upsets or incidents, and disseminating information on the pretreatment program to industrial users. A night inspection crew enhances the Sanitation Districts' capability to monitor industrial dischargers and to respond to upset conditions caused by toxic discharges to the sewer during all hours of the day or night. During 1999, theSanitation Districts conducted 16,413 inspections.

Industrial users that are found through inspection or monitoring to be out of compliance are subject to aggressive enforcement action by the Sanitation Districts. Standardized enforcement procedures have been developed to achieve timely and effective compliance. The Sanitation Districts have also been an active member of the Los Angeles County Environmental Crimes Strike Force, which coordinates hazardous waste law enforcement for 17 agencies, including actions against illegal sewer dischargers. At the end of 1999, the Sanitation Districts had 202 dischargers under enforcement.

The Sanitation Districts' pretreatment program was recognized in 1995 with the EPA's National First Place Award for an Outstanding Pretreatment Program in the greater than 100 significant industrial users category. Some of the additional features of the Sanitation Districts' pretreatment program that contribute to the excellence recognized in this award include:

• Public Participation and Outreach - Industrial users, public officials, adjoining sewerage agencies, and the general public are encouraged to participate in the pretreatment program development and implementation. One of the key features is the Industry Advisory Council, a government and industry partnership that strives to develop "cleaner, smarter, and cheaper" regulations for industry. Another feature is the awarding of Certificates of Recognition to significant industrial users that were in complete compliance with Sanitation Districts and EPA wastewater regulations. Certificates were awarded in 1999 to 380 of the 1400 significant industrial users. Other outreach efforts involve extensive public speaking and the preparation and distribution of newsletters, guidelines, technical policies, and other publications to enhance the understanding of the pretreatment program. In 1999, the Sanitation Districts launched an Internet web site for its Industrial Waste Section. The web site includes information on obtaining a permit, various forms and policies, news, and information about the Industrial Waste Section.

• Pollution Prevention - The Sanitation Districts were extremely active in pollution prevention in 1999. Due to its extensive pollution prevention outreach efforts, the Sanitation Districts were awarded a National Pollution Prevention Week 1999 Award from the California Department of Toxic Substances Control. The award was given for "exemplary work and efforts in pollution prevention throughout the year." One of the main pollution prevention projects for the Sanitation Districts during 1999 was conducting a public outreach campaign in the Long Beach and Burbank areas to reduce lindane discharges from medical uses. Outreach materials developed for the campaign included a poster, video, refrigerator magnet, Rolodex card, and flyers in English, Spanish, and Cambodian. Materials were directly mailed to doctors, pharmacies, day care centers, schools, and hospitals in the pilot areas. Mass media outreach resulted in newspaper articles, radio spots, and public service announcements. A web site was also put on-line. The project is being funded with a grant from EPA Region 9 under its Pollution Prevention Leadership Program. The Sanitation Districts' partners for the project are the City of Los Angeles Bureau of Sanitation and the National Pediculosis Association.

The Sanitation Districts also conducted other pollution prevention projects during 1999. The Sanitation Districts continued to work cooperatively with the local air regulatory agency to ensure that mandated, widespread conversion to aqueous cleaners would not result in additional pollutant loadings to the Sanitation Districts' wastewater treatment plants. Action by the Sanitation Districts in this area included special monitoring to characterize the impact of the conversion, analysis of spent aqueous cleaning solutions to determine their pollutant content, and working with air regulators on a survey to determine disposal methods for spent aqueous cleaners. A pollution prevention program was initiated in 1999 to reduced the amount of chlorides being discharged by industry and commercial businesses in the Santa Clarita Valley. Outreach consisted of letters and on-site visits in which businesses were informed that on-site regeneratable water softening units are not allowed and were given assistance in converting to acceptable water softening units. The Sanitation Districts became involved in pollution prevention on a state-wide scale with the appointment of a Sanitation Districts' engineer to the California Source Reduction Advisory Committee, a legislatively-established committee charged with advising the California Department of Toxic Substances Control on how to best use its pollution prevention resources to accomplish meaningful reductions in hazardous waste generated and accomplish environmental improvements.

Finally, the Sanitation Districts partnered with the non-profit Pollution Prevention Center on several solvent usage reduction projects including development of furniture strippers with less methylene chloride, development of water-based brake cleaners, development of non-solvent adhesives, and development of water-based cleaning processes for the printing industry. The Sanitation Districts remain active in the Southern California Pollution Prevention Committee, which consists of representatives from local agencies in the Southern California area who meet to coordinate pollution prevention efforts and complete pollution prevention projects. The Sanitation Districts are also active in the Merit Partnership, a partnership between industry and government in Los Angeles County dedicated to pollution prevention.

• Regulatory Development Input - The Sanitation Districts have provided extensive comment on proposed regulations under the federal categorical pretreatment program, including comments on pretreatment streamlining. Additionally, during 1999, the Sanitation Districts participated with EPA in performing sampling and analysis at metal finishing facilities to provide additional data for the Metals Products and Machinery rulemaking. The Sanitation Districts also actively participate in the EPA’s strategic goals program for the metal finishing industry, which promotes "beyond compliance" behavior by participating metal finishing facilities. Among its efforts in the Strategic Goals program, Sanitation Districts' staff serve on the Technical Review Panel for the program’s Enviroloan effort.

• Environmental Benefits - The pretreatment program has achieved significant reductions in the discharge of heavy metals, toxic organics, and other pollutants to the Sanitation Districts' wastewater treatment plants, and in the mass of pollutants released to the environment. Environmental benefits include reduced air emissions, the production of exceptional quality biosolids that can be beneficially used, production of treated wastewater that consistently meets standards for reuse, and an increased diversity of marine organisms in the receiving environment.