Programs

Welcome to the KC Water Industrial Pretreatment Program page. Our program is designed to protect Kansas City’s water resources by regulating the discharge of industrial wastewater. We work closely with businesses to ensure compliance with local, state, and federal environmental regulations. Whether you’re a new or existing industrial user, this page provides essential guidelines, forms, and resources to help you meet wastewater discharge requirements, including monitoring for emerging contaminants like PFAS. The Regulatory Compliance Division is dedicated to assisting industries in navigating these regulations to ensure a safe and sustainable water supply for our community.

Direct all required physical paperwork to the address listed below:
KC Water Regulatory Compliance Division
City of Kansas City, Mo.
7300 Hawthorne Rd
Kansas City, MO  64120

WHO NEEDS TO BE IN THE INDUSTRIAL PRETREATMENT PORGRAM:
The Regulatory Compliance Division regulates all industrial users served by KC Water. All industries must comply with Kansas City Municipal Code Chapter 60, Article IV. This requires significant industrial users (SIUs) to participate in the Industrial Pretreatment Program (IPP). These include:

1. Categorical Industrial Users (CIUs) – Facilities subject to national categorical pretreatment standards established by the EPA under the Clean Water Act. Categorical pretreatment standard or categorical standard means any regulation containing pollutant discharge limits promulgated by EPA in accordance with sections 307(b) and (c) of the Act which apply to a specific category of industrial users and which appear in 40 CFR Chapter I, Subchapter N, Parts 405—471.
2. Significant Industrial Users (SIUs) – These are defined in Chapter 60 by their volume of wastewater discharge, pollutant levels, or potential to adversely impact the treatment plant. Significant industrial user means any industrial user which:

• Is subject to categorical pretreatment standards; or
• Purchases, uses, or discharges an average of 25,000 gallons per day or more of water; or
• Discharges a process waste stream which makes up five percent or more of the average dry weather hydraulic or organic capacity of the wastewater treatment plant serving the said industrial user; or
• Accepts waste from another location outside the facility’s boundaries for treatment, storage or disposal; or
• Is designated as significant by the director on the basis that the industrial user has a reasonable potential for adversely affecting the POTW’s operations, for violating this article or for violating pretreatment standards or requirements

Kansas City’s Regulatory Compliance Division

The Kansas City, Missouri Code of Ordinances Chapter 60, Article IV pertains to the regulation of commercial and industrial waste management within the city’s sewer system. This ordinance delineates guidelines and standards to govern the discharge of pollutants from commercial and industrial sources, aiming to safeguard public health and environmental well-being. It mandates permits, sets discharge criteria, establishes monitoring procedures, and enforces compliance measures to uphold local, state, and federal wastewater standards. Additionally, the ordinance advocates for pollution prevention strategies fosters collaboration among stakeholders, and ensures responsible handling of commercial and industrial wastewater to preserve water quality and sustain the efficacy of the municipal sewer infrastructure.

EPA’s Pretreatment Program

The National Pretreatment Program, as outlined under 40 C.F.R. Part 403, is a regulatory framework established by the Environmental Protection Agency (EPA) to manage the discharge of pollutants from industrial and commercial sources into publicly owned treatment works (POTWs). The program aims to protect municipal wastewater treatment plants, receiving water bodies, and public health by controlling the introduction of harmful pollutants into the sewer system. Key components of the National Pretreatment Program include establishing pretreatment standards, issuing permits to industrial users, implementing monitoring and enforcement mechanisms, and promoting pollution prevention and pretreatment best practices. By partnering with state and local agencies, the EPA oversees the implementation and enforcement of pretreatment requirements to ensure compliance with federal regulations and maintain the integrity of the nation’s waterways.

Clean Water Act

The Clean Water Act (CWA) was enacted in 1972 with the primary mission of restoring and maintaining the chemical, physical, and biological integrity of the nation’s waters. This landmark legislation aims to eliminate the discharge of pollutants into navigable waters and protect water quality for drinking, recreation, and wildlife habitat. The CWA regulates point source pollution by establishing wastewater discharge permits and setting water quality standards. Additionally, it provides funding for municipal wastewater treatment infrastructure and supports pollution control programs at the federal, state, and local levels. Over the years, the Clean Water Act has evolved to address emerging environmental challenges, promote pollution prevention, and enhance regulatory enforcement to safeguard the nation’s water resources for present and future generations.

Wastewater Discharge Survey for Industrial Users

New industrial users are required to provide details about the nature and characteristics of their wastewater by completing a wastewater survey before starting any discharge. Existing industrial users must also complete this survey when requested by the Director of KC Water. The Director may periodically update the form and require users to submit updated information. Failure to comply with these requirements may result in service termination and will be considered a violation of city regulations.

Industrial users can submit the required information by completing the appropriate forms below or by referring to Chapter 60, Sec. 60-141 of the Kansas City Municipal Code.

1. Paper Submission:
   • Print the blank form and fill it out manually.
2. Interactive PDF Submission:
   • Right-click on the fillable PDF form below, select “Save link as…,” then save the document to your device.
   • Open the saved file using a PDF reader to complete the form electronically.

   • Print off the application and sign

1. Mail the Completed Form: Once completed and signed, please mail the form to:

Regulatory Compliance Division

c/o Matt Lary, Environmental Compliance Manager

7300 Hawthorne Road Kansas City, MO 64120

1. Review and Permit Determination: KC Water’s Regulatory Compliance Division (RCD) will review the submitted survey to determine if a wastewater discharge permit is required. If so, the RCD will contact the facility and request a full application with pertinent information.

2. Once the application is returned, the RCD will draft a permit and accompanying fact sheet for your review and comments.

3. Categorical Industrial Users (CIU): If your facility is identified as a Categorical Industrial User (CIU), a Baseline Monitoring Report (BMR) must be submitted no later than 90 days before commencing discharge.
4. Final Permit Issuance: After review and any necessary revisions, KC Water will issue the final Industrial User Wastewater Discharge Permit.

Following this process ensures compliance with city regulations and helps protect Kansas City’s water resources. For any questions or assistance, please contact KC Water’s Regulatory Compliance Division.

All IUs are responsible for notifying the City about the following discharges or changes to existing discharge practices:

• changes affecting potential for slug discharge (40 CFR Part 403.8(f)(2)(vi)) 
• potential problems, including slug loadings (40 CFR Part 403.12(f))
• noncompliance and repeat sampling report (40 CFR Part 403.12(g)(2))
• changed discharge (40 CFR Part 403.12(j))  
• changed production (for IUs with limits calculated from a production-based standard) (40 CFR Part 403.6(c)(9))
• hazardous wastes discharge (40 CFR Part 403.12(p)) . See also Hazardous Waste Reporting Requirements for Industrial Users under 40 CFR 403.12(p)&(j)
• bypass (40 CFR Part 403.17)

These notifications alert the City to discharges that can affect the collection system or treatment plant. In addition, the City reserves the right to specifically require IUs to:

• submit reports, as required (40 CFR Part 403.12)
• maintain records of pretreatment activities, as required (40 CFR Part 403.12(o))

Categorical Industries:

Aluminum Forming – 40 CFR Part 467	Asbestos Manufacturing – 40 CFR Part 427	Battery Manufacturing – 40 CFR Part 461
Carbon Black Manufacturing – 40 CFR Part 458	Builders’ Paper and Board Mills – 40 CFR Part 431	Cement Manufacturing – 40 CFR Part 411
Coal Mining – 40 CFR Part 434	Centralized Waste Treatment – 40 CFR Part 437	Coil Coating – 40 CFR Part 465
Dairy Products Processing – 40 CFR Part 405	Copper Forming – 40 CFR Part 468	Electrical and Electronic Components – 40 CFR Part 469
Feedlots (CAFOs) – 40 CFR Part 412	Electroplating – 40 CFR Part 413	Fertilizer Manufacturing – 40 CFR Part 418
Grain Mills – 40 CFR Part 406	Glass Manufacturing – 40 CFR Part 426	Gum and Wood Chemicals Manufacturing – 40 CFR Part 454
Ink Formulating – 40 CFR Part 447	Hospitals – 40 CFR Part 460	Inorganic Chemicals Manufacturing – 40 CFR Part 415
Leather Tanning and Finishing – 40 CFR Part 425	Iron and Steel Manufacturing – 40 CFR Part 420	Metal Finishing – 40 CFR Part 433
Metal Products and Machinery – 40 CFR Part 438	Metal Molding and Casting (Foundries) – 40 CFR Part 464	Mineral Mining and Processing – 40 CFR Part 436
Nonferrous Metals Manufacturing – 40 CFR Part 421	Nonferrous Metals Forming and Metal Powders – 40 CFR Part 471	Oil and Gas Extraction – 40 CFR Part 435
Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) – 40 CFR Part 414	Ore Mining and Dressing (Hard Rock Mining) – 40 CFR Part 440	Paint Formulating – 40 CFR Part 446
Pesticide Chemicals – 40 CFR Part 455	Paving and Roofing Materials (Tars and Asphalt) – 40 CFR Part 443	Petroleum Refining – 40 CFR Part 419
Phosphate Manufacturing – 40 CFR Part 422	Pharmaceutical Manufacturing – 40 CFR Part 439	Photographic Processing – 40 CFR Part 459
Porcelain Enameling – 40 CFR Part 466	Plastics Molding and Forming – 40 CFR Part 463	Pulp, Paper, and Paperboard Manufacturing – 40 CFR Part 430
Soap and Detergent Manufacturing – 40 CFR Part 417	Rubber Manufacturing – 40 CFR Part 428	Textile Mills – 40 CFR Part 410
Steam Electric Power Generating – 40 CFR Part 423	Sugar Processing – 40 CFR Part 409	Waste Combustors – 40 CFR Part 444
Timber Products Processing – 40 CFR Part 429	Transportation Equipment Cleaning – 40 CFR Part 442

Compliance and Enforcement
Kansas City’s Enforcement Response Plan ensures that violations of the Pretreatment Program are consistently identified and addressed. The plan provides clear guidelines for detecting, documenting, and responding to noncompliance, ensuring that every violation receives the appropriate response. It outlines the steps city personnel should follow, from initial actions to follow-up, including timelines and responsibilities, to maintain fairness and consistency in enforcement.

By following these procedures, KC Water ensures that industries understand the consequences of noncompliance and that enforcement actions are not seen as arbitrary. Informal actions, such as phone notifications, compliance meetings, or notices of violation, are often the first steps. However, when necessary, formal enforcement tools—such as administrative orders, emergency actions, legal actions, permit revocation, or cost recovery—are available.

Additionally, federal regulations require KC Water to publish a list of industrial users in significant noncompliance annually. Criteria for significant noncompliance can be found in Chapter 60-181 of KC Water’s regulations.

2024 Significant Noncompliant Industries

The United States Environmental Protection Agency (USEPA) requires KC Water’s Regulatory Compliance Division (RCD) to categorize Kansas City, Missouri industries’ pretreatment performance semiannually as follows:

C = Full Compliance

I = Infrequent Noncompliance

SNC = Significant Noncompliance

The criteria used to determine SNC are identified in the Kansas City Code of Ordinances 60-181, Missouri Code of State Regulations 10 CSR 20-6.100, and Code of Federal Regulations 40 CFR 403.8(f)(2)(vii).

The following industries have been found to be in Significant Noncompliance for one or both of the administrative halves of the year of 2024:

Industry	Significant Noncompliance Parameters	RCD Actions
Ace Image Wear	Did not report in 2024 (1st and 2nd half)	Notice of Violation, administrative fine
Boyle’s Famous Corned Beef	Late reporting over 45 days	Notice of Violation, administrative fine
Brunson Instruments	Late reporting over 45 days	Notice of Violation, administrative fine
Hazmat Inc.	Late reporting over 45 days	Notice of Violation, administrative fine
Heartland Pet Aquamation	Late reporting over 45 days	Notice of Violation, administrative fine
KCMO Department of Veterans Administration Medical Center	Late reporting over 45 days	Notice of Violation, administrative fine
Niagara Bottling, LLC (North)	Failure to follow Cease and Desist Unpermitted Discharge Slug discharge (30,000+ gallons) Late reporting over 45 days	Cease and Desist, Notice of Violation, Compliance inspection, administrative fine
Niagara Bottling, LLC (South)	Late Reporting over 45 days	Notice of Violation, Administrative fine.
Paseo Cargill Energy LLC.	Oil and Grease exceedances, Oil and grease A/V exceedances	Notice of Violation, Administrative fine.
Superior Linen Supply Company	Did not report in 2024 (1st and 2nd half) Failure to renew permit Unpermitted discharge	Notice of Violation, Administrative fine.
Superior Metal Treatment & Equipment, Inc.	Sampling outside the monitoring period Exceeds technical report criteria for pH	Notice of Violation, Administrative fine.
University Health Hospital Hill	Failed to monitor Oil &Grease correctly Failed to monitor Oil & Grease A/V correctly Over 45 days late  (Compliance Schedule)	Notice of Violation, Administrative fine.
University Health Lakewood	Failed to monitor Oil &Grease correctly (1st half) Failed to monitor Oil & Grease A/V correctly (1st half) Failed to monitor Oil &Grease correctly (2nd half) Failed to monitor Oil & Grease A/V correctly (2nd half) Late reporting over 45 days Unpermitted discharge Failure to renew discharge permit	Notice of Violation, Administrative fine.

Per- and Polyfluoroalkyl Substances (PFAS) are a group of human-made chemicals used in various industrial and consumer products since the 1940s, known for their resistance to water, grease, and stains. While these properties made PFAS useful, they also pose significant environmental and health risks due to their persistence in the environment and ability to accumulate in living organisms.

The Regulatory Compliance Division is actively working to address PFAS contamination by:

• Reaching out to industries with a high likelihood of PFAS in their waste streams, such as manufacturers using non-stick coatings, fire-fighting foams, and stain-resistant treatments.
• Conducting preliminary PFAS testing at select industrial sites to evaluate potential contamination and ensure compliance with upcoming regulatory standards.

PFAS are persistent in the environment and resistant to natural degradation. Once released into water systems, they can accumulate in plants, animals, and humans, leading to various health impacts, including:

• Increased risks of kidney and testicular cancers
• Immune system suppression
• Developmental issues in children and fetuses
• Liver and kidney damage

The EPA’s new drinking water standards for PFAS, announced in 2024, set Maximum Contaminant Levels (MCLs) for six PFAS compounds, including PFOA and PFOS. KC Water is aligning its monitoring and testing procedures with these regulations to protect public health and the environment.

For more information on PFAS and ongoing efforts, visit the EPA’s PFAS roadmap or the RCD’s information library.

Project PDFs:

• Wastewater Discharge Permit Application
• Short-Term WW Discharge Permit Application
• Pretreatment Questionnaire

2024 Missouri Water Environmental Association Pretreatment Awards

KC Water’s Regulatory Compliance Division recognizes industries that consistently meet water quality and infrastructure standards. Each year, the city nominates businesses demonstrating commitment to these standards for the Missouri Water Environment Association (MWEA) Pretreatment Awards, which honor excellence in industrial wastewater pretreatment.
Award Criteria for 2024:

General Requirements (All Awards):

• The industry has pretreatment or pollution prevention measures in place.
• Maintains a cooperative relationship with the POTW.
• No significant noncompliance in the past year.
• No serious safety deficiencies in the most recent inspection.

Silver Award:

• · Minor, infrequent permit exceedances (less than 20% over the limit).
• · Infrequent late reports (none more than 30 days overdue).

Gold Award:

• · 100% compliance with pollutant limits and permit requirements.
• · 100% compliance with reporting deadlines.

Platinum Award:

• · Gold Award recipient for five or more consecutive years.

Award Winners:

• Acme Brass Custom Plating, Inc. – Platinum
• A-Luster Metal Finishing – Gold
• Arctic Glacier – Gold
• Bannister Transformation & Development, LLC – Platinum
• Belfonte Ice Cream & Dairy Foods Co – Gold
• Boulevard Brewing Company – Gold
• Cargill – Gold
• Catalent CTS, LLC – Platinum
• Clean Earth (Groundwater) – Gold
• Environmental Specialists, Inc. – Platinum
• Ford Motor Co. – Platinum
• Fortune Fish – Platinum
• Greenfield Environmental Multistate Trust, LLC – Gold
• Heritage Environmental Services – Gold
• Hiles Plating – Gold
• KC Southern Railroad – Knoche Yard – Platinum
• LPF High Performance Coatings, LLC – Gold
• Mark II Transfer Station – Platinum
• Mid American Car -Gold
• Milbank Manufacturing Co. – Silver
• Mizkan Americas – Gold
• Nostrum Laboratories – Gold
• Parker Americas – Platinum
• Paulo Products – Silver
• Quality Finishing Industries – Gold
• Research Medical Center – Platinum
• Saint Joseph Medical Center – Platinum
• Saint Luke Hospital – Plaza – Platinum
• Smithfield Packaged Meats Corp. (North) – Gold
• Smithfield Packaged Meats Corp. (South) – Gold
• Stower Institute for Medical Research – Gold
• Union Pacific Railroad – Neff Yard – Gold
• Vanguard Packing – Platinum