Industrial Pretreatment Program (IPP)

Purpose & Goals of the City’s Industrial Pretreatment Program

The City of Portsmouth owns and operates two wastewater treatment facilities (WWTF), Peirce Island and Pease, each having National Pollutant Discharge Elimination System (NPDES) individual permits issued by the United States Environmental Protection Agency (USEPA). These 5-year permits allow treated wastewater to be discharged to the ocean via Great Bay. The City has applied for the renewal of these permits and anticipates the final permits to be issued in the very near future. Due to the requested new maximum capacity for treatment of the Peirce Island WWTF, the City expects that the NPDES permit will include a requirement to enhance the City’s current Industrial Pretreatment Program (IPP or Program) to meet USEPA requirements.

The federally approved IPP promotes clean water and in turn regulates specific kinds of wastewater discharges from industrial and commercial businesses to the sewer system. This regulation focuses on wastewater that might not be compatible with the City’s treatment facilities and sewer operations, the water quality of Great Bay, or the City’s sludge (solid materials left over after wastewater is treated) disposal methods. In anticipation of the federal requirements of the renewed permit, the City has undertaken a proactive approach by developing various components of the Program including permitting specific industrial users. The City’s final federally approved Program will be regulated through the City’s Sewer Use Ordinance.

There are several steps involved in enhancing the City's treatment program to meet the anticipated requirements:

1. Compile a list of businesses that discharge wastewater to the City’s sewer system, both from within the City as well as adjacent municipalities.

2. Distribute an initial survey (July 2022) to gather specific business information, such as the type and operations of the business, to help classify each business within the City’s required Program. This survey step is now underway.

3. Conduct a follow-up survey requesting more detailed wastewater information, to better understand some specific facilities’ operations and the type and nature of their sewer discharge to the City’s facilities. This information will allow the City to determine whether the business will require an Industrial Discharge Permit for the City to maintain compliance with the NPDES permits. 

4. Administer an enhanced USEPA and NHDES approved IPP in accordance with current rules and regulations.

In addition to the two surveys described above, the City will take the following necessary steps incorporate IPP elements:

1. Update the Sewer Use Ordinance (SUO) to include the proper legal authority to administer the IPP.
2. Develop local limits for pollutants that could interfere with the wastewater treatment process, overlook contaminants not typically treated at the facility, foster sludge contamination, or create worker health and safety problems.
3. Develop Procedures, such as sampling or inspection protocols and frequency, to ensure compliance with the City’s IPP requirements.
4. Develop an Enforcement Response Plan that contains detailed procedures indicating how the City will investigate and respond to instances of program non-compliance.
5. Develop Program organization and funding to provide sufficient resources and qualified personnel to carry out the procedures included in the approved IPP.

The Department of Public Works held a public meeting for commercial Pease WWTF customers on June 13, 2024. Go to the meeting presentation or view the video recording below.