TeTon Environmental, PLLC
Industrial Pretreatment Programs (IPPs)

These regulatory programs are designed to manage industrial wastewater discharges to
sanitary sewer systems.  Municipal IPP work experience includes the following New
Hampshire communities:

Seabrook                                       Bedford                                 Milford
Londonderry                                  Hanover                                Lebanon
Manchester                                    Keene                                   Exeter

Working for small to mid-sized New Hampshire cities and towns, we have managed projects
with engineering values up to approximately $100,000.  The goals of these projects have
ranged from simple permit-writing technical support to developing an entire IPP with all of the
EPA-required elements to manage and control the discharge of industrial wastewater to the
sanitary sewer system.  Several efforts have incorporated pollution prevention elements and
incentives as an integral component of the IPP.  To achieve these project goals, we have
performed the following activities:

•        Evaluated existing IPP files to identify discharges with the potential to adversely affect the
POTW, directed industrial waste surveys to approximately 100+ establishments, and designed
a hierarchical system for ranking the significance of industrial wastewater sources and
developed an industrial user classification system;

•        Evaluated potential pollutant issues, developed a matrix of industry-specific pollutants of
interest and directed development of a Sampling Quality Assurance/Quality Control Plan;

•        Researched and selected database software and developed an extensive computerized
“database” system for managing industrial user information such as manufacturing
processes, average and maximum existing and proposed flows, raw material utilization, activity
logs, and discharge permit request submittals;

•        Directed and participated in public outreach efforts;

•        Developed a pollutant loading and sampling records database model on Microsoft Excel
software that calculates loadings from identified sources and provides a mass balance
comparison to the total loadings monitored at the influent to the wastewater treatment facility;

•        Developed Industrial Discharge Permit Applications to solicit information critical to the
evaluation of proposed discharges and developed the Industrial Discharge Permit format and
language to administer controls;

•        Designed and scheduled sampling programs for numerous industrial and POTW sites
and have coordinated hundreds of sampling events representing thousands of analytical
results;

•        Reviewed and evaluated the analytical results to recommend a list of pollutants
recommended for subsequent regulatory controls; and

•        Have developed innovative regulatory language to incorporate pollution prevention
awareness and activities into the basic structure of a Sewer Use Ordinance (SUO) and
developed a model SUO for the New Hampshire Department of Environmental Services as part
of a federally-funded project.