Industrial Pretreatment Program

The purpose of the Industrial Pretreatment Program (IPP) is to protect the Publicly Owned Treatment Works (POTW) — the system that conveys and the treatment plants that receive wastewater from the City of El Paso — from pollutants that may cause harm or interfere with operation and to protect the environment. The program accomplishes this by implementing and enforcing federal categorical standards, state requirements and limits developed locally.

The main components of the IPP include:

  • Development of technically based local limits (TBLL), which are discharge limits developed based on the concentration of pollutant that can be effectively removed by treatment processes and the discharge limits imposed upon the plants through permits issued by the state.
  • Issuance of permits.
  • Inspection.
  • Sample collection to insure compliance with discharge limits.
  • Enforcement.

The limits in the table below are specific numerical discharge limits established to protect the operation of the El Paso Water's POTW, the quality of water discharged into the Rio Grande and the quality of sludge generated — which is a byproduct of the treatment process that must be disposed via landfilling and that can be used beneficially, such as for composting.

Additional information regarding discharge limits and other requirements may be found in El Paso Water's Public Service Board Rules and Regulations No. 9 and in wastewater discharge permits issued to specific users.

Technically Based Local Limits

The following pollutant limits are established to protect against pass-through and/or interference. No person shall discharge or cause discharge of wastewater or any pollutant into the system that exceeds the local limits listed below. These limits are based upon either flow-proportional or time-proportional composite samples; or grab samples where collection of composite samples is not possible or is impractical. The limits apply at the point where the wastewater is discharged to the POTW. All concentrations are for the total pollutant.

Concentration (mg/L)
Total dissolved solids

The following limits are established for BTEX compounds and are based on grab samples:

Concentration (mg/L)
Ethyl benzene

In addition

  • Fat, grease, oil or wax of vegetable origin in excess of 100 mg/L shall not be discharged.
  • Petroleum substances, whether emulsified or not, in excess of 100 mg/L shall not be discharged.
  • Wastewater having a pH less than 5.5, or greater than 10.5 or possessing any other corrosive property shall not be discharged.
  • Wastewaters containing BOD and/or TSS in excess of 300 mg/L shall be subject to surcharge in accordance with the PSB's Rules and Regulations No. 6.
  • Wastewater containing dye, dye waste or any other coloring agent resulting in a wastewater color concentration in excess of 300 ADMI shall not be discharged.

Discharge Permits

The type of Industrial Wastewater Discharge Permits issued is dependent upon the activities of the facility, whether wastewater is used in those activities and whether wastewater is or is not discharged into the sewer system.

A charge will be assessed for facility permits in which wastewater is discharged to cover EPWater's costs for permitting, inspections and sampling. In some instances, a non-discharge permit is issued at no cost to industries that do not discharge but are performing processes where there is a potential to discharge, or merely to document in writing the no-process-discharge-authorized status of the facility.

An Application for an Industrial Wastewater Discharge Permit is required to help identify the type of permit necessary and to determine permitting requirements. Facilities are inspected at least annually to help to ensure changes have not been implemented that may affect the amount(s) or type(s) of pollutants generated, and to ensure that permit requirements remain applicable to the conditions/activities. Samples are collected on a regular basis to ensure compliance with TBLL and other permit requirements. Enforcement action is taken for issues related to non-compliance.

The following permits require Adobe Acrobat Reader:

Adobe Acrobat Reader icon. Application for Industrial Wastewater Discharge Permit

Adobe Acrobat Reader icon.  Application for Renewal Industrial Wastewater Discharge Permit

NEW: Requirements for BOD Under the Pretreatment Program

Thank you to our partners from the commercial and industrial facilities in El Paso who joined El Paso Water to learn more about Biological Oxygen Demand (BOD), system capacity limits, planned utility expansions, and changes under the Industrial Pretreatment Program that will help to protect utility systems and the environment. Please feel free to reference the presentation shared during the meetings.

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