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Environmental Compliance Program

Why Do We Need It?


The Clean Water Act limits the levels of pollutants that non-domestic users are allowed to discharge to the sewer system. The General Pretreatment regulations are part of the Clean Water Act and require municipalities to implement Industrial Pretreatment Programs (IPP) in order to protect their wastewater treatment plants biological treatment systems, to avoid concentrations of various pollutants that could end up in our biosolids, which is recycled as fertilizer, and so that various pollutants are not discharged into the receiving waters. 

Under the Clean Water Act, Genesee County Drain Commissioner Division of Water and Waste Services (GCDCWWS) is legally obligated to implement an IPP to protect the treatment plant and to ensure proper treatment of wastewater. 

In order to meet our Program’s purpose, the following events are performed regularly:

  • Identification of new non-domestic users, as well as changes and/or modifications to existing users.  Upon the request for a sewer connection permit and/or a building permit each non-domestic user is given an Application for Non-domestic Discharge Permit, and the application must be completed before a sewer connection permit and/or occupancy permit is issued by the appropriate department/authority. The application form provides information on business process operations and wastewater characteristics, and is the basis for determining the business' status in the Environmental Compliance Program.

  • Permit facilities as identified in our Sewer Use Ordinance. Our Program currently permits all non-domestic facilities throughout the Division’s jurisdiction. Permitting is one of the most effective ways of educating our businesses in pollution prevention and environmental compliance. Our Environmental Compliance personnel work with businesses such as automotive shops, grocery stores, medical facilities, food service establishments, photo processors, and car washes, as well as larger industry such as Hospitals, Automotive industry, Landfills, and Categorical Users. Our staff helps businesses understand local sewer use regulations and wastewater pollution prevention options. An application form is available on this site.

  • Inspect and monitor non-domestic facilities discharging to the Division’s system. Environmental Compliance personnel conduct facility inspections and sampling of wastewater being discharged from various non-domestic users. The frequency of these events is dependent on the nature of the business and the ability for them to comply with SUO limits. The SUO limits are enforced through the monitoring efforts of the Environmental Compliance staff. The wastewater is tested for various pollutants and helps the businesses understand what limitations there are for discharges to the sewer.

  • Monitor the levels of pollutants entering and leaving our Waste Water Treatment Plants.  Our Program continues to reduce the toxic loadings to the wastewater treatment facilities ensuring that various pollutants are not discharged into the Flint and Shiawassee Rivers.

  • Collect application, permit, monitoring and laboratory analytical fees to support our program. A fee structure was implemented to collect fees from permit holders. Fees in turn support our Program’s requirements and related activities. Applicants pay a fee in order to obtain their wastewater discharge permit. Once permitted they pay an annual pretreatment fee which is determined through characterization of their operations and/or associated waste stream. In addition to an annual permit fee, the User may be required to pay monitoring fees. The monitoring fee is calculated based on the frequency of sampling, the number of events and the fee for the parameters evaluated.  

What is a POTW and how is it regulated?

POTWs (Publicly Owned Treatment Works) commonly referred to as Wastewater Treatment Plants store, treat, recycle, and reclaim municipal sewage and liquid industrial wastes. They are required to have a National Pollutant Discharge Elimination System (NPDES) permit to discharge treated water from its system’s into creeks, rivers, or other waters. This permit regulates the quality and quantity of water the POTW may discharge from its system.

What are Prohibited Discharges? 

Certain wastewater discharges are prohibited for all non-domestic facilities that discharge to POTWs because of the potential hazards these discharges create. Specific prohibited discharges include: 

  • pollutants that would create a fire or explosion 

  • pollutants that would cause corrosive structural damage to a POTW 

  • solid or viscous pollutants that would obstruct flow in a POTW

  • pollutants that result in toxic gases, vapors, and fumes 

  • ignitable wastes 

  • oil and grease

What is an SIU?

Significant Industrial User (SIU) means any Non-domestic User that:

  • Is subject to categorical pretreatment standards

  • Discharges to the POTW an average of 25,000 gallons per day or more of process wastewater. 

  • That has a reasonable potential to adversely affect the operation of the POTW, or to violate any pretreatment standard or requirement.

What are National Categorical Pretreatment Standards? 

Categorical Pretreatment Standard means any regulation containing pollutant discharge limits promulgated by the U.S. EPA in accordance with the Clean Water Act which apply to a specific category of Users and which appear in 40 CFR. More than 40 industrial categories, such as metal finishing, are subject to the categorical standards. Categorical Industrial Users are also SIUs.

How do we collect samples from wastewater?

Environmental Compliance uses some interesting equipment. Pollutants can be sampled over a 24-hour period from businesses that are discharging to the sewer. The samples are taken to the laboratory at the Wastewater Treatment Plant and analyzed for pollutants released by the business. Once the samples have been tested the results are evaluated and studied by the Environmental Compliance Supervisor. The data is used to generate surcharges and enforcement action if necessary.

What is Pretreatment?

Pretreatment is the reduction, the elimination, or the alteration of pollutants in wastewater to a less harmful state prior to discharge of the wastewater to a sanitary sewer system.
The term "pretreatment" refers to the requirement that non-domestic sources control their wastewater before discharge to meet all applicable pretreatment standards and requirements.

When are Non-domestic Users required to obtain a permit? 

GCDCWWS permits all Non-domestic users that discharge to their POTWs. Potential Users under construction should apply for a Discharge Permit at least 90 days prior to discharging to the sanitary sewer.

Existing Users discharging into the POTW shall submit a completed permit application form to the POTW within 60 days of being so directed by the POTW.

How do I obtain a permit for my company? 

To obtain a GCDCWWS Discharge Permit you must complete an Non-domestic Discharge (IPP) Application form and submit it to our Beecher Road office.

Non-domestic Discharge Fees - 2016

Contact Information:

GCDCWWS Accidental Discharge Notification Reporting Flow Chart AR Treatment Plant

Discharge Notification Reporting Flow Chart Linden Treatment Plant


Joseph M. Goergen – Division Plant Superintendant

Melissa Glasgow – Lab Manager

Thad Domick - Environmental Compliance Supervisor

LaTanya Banks – IPP Technician 

Patrice Curtis - IPP Technician

Located at: 
A.R. Treatment Plant
G-9290 Farrand Rd. 
Montrose, MI 48457
Phone: (810) 232-7662
Fax:(810) 232-3280 

Relevant Links:

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