Graphic organizer Grade 11 Careers & CTE

Sedgewell Pretreatment Program: Who Enforces Which Limit

A grade 11 careers organizer mapping EPA, the state agency, a POTW pretreatment coordinator, and an industrial user across nine labeled rows of authority and work.

Grade: Grade 11
Subject: Careers & CTE
Material: Graphic organizer
Time: 30 min
Prep: No prep
Materials: None

Standards

W.11-12.2 Common Core ELA

Write informative/explanatory texts to examine and convey complex ideas, concepts, and information clearly and accurately through the effective selection, organization, and analysis of content.

How this material aligns: The final organizer row asks students to turn the completed authority grid into an explanatory paragraph that conveys how the four actors divide the work.

All materials for W.11-12.2 →

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This material is in the public domain (CC0) and may be copied, edited, and shared freely, without attribution. Updated 2026-09-23.

Objectives

Students will map the authority of four actors in an industrial pretreatment program.
Students will name the job title that does the day-to-day inspection and sampling work at each level.
Students will write an explanatory summary of how enforcement authority is divided.

Vocabulary

Key words: pretreatment, local limits, categorical standard, industrial user permit, self-monitoring report, notice of violation, surcharge

Teacher overview

This organizer is a four-column comparison frame with nine labeled rows, closing with a written summary the student composes from the completed grid. It maps who does what in an industrial pretreatment program, using the fictional Sedgewell water resource recovery facility and a fictional food processor that discharges to its sewer. One misconception is worth naming before students start filling cells. Many assume that the EPA inspects factories. In a state with an approved program, almost every routine inspection, sample, and enforcement notice at an individual business comes from the local utility's own pretreatment staff, and the federal role is to write the standards and audit the programs below it. The organizer is built to make that division visible, so state it plainly and let the grid do the rest.

Sedgewell Pretreatment Program: Who Enforces Which Limit — Grade 11 Careers & CTE

Name: ____________________________ Date: ______________

Organizer

Fill in every blank cell using the class discussion, your notes, and your state's pretreatment pages if you have them. Write short phrases rather than sentences. The last row is a paragraph. All local details refer to the fictional Sedgewell program.

Question	EPA	State environmental agency	Sedgewell pretreatment coordinator	Bowrick Foods, the industrial user
1. What authority does this actor hold over industrial discharges?
2. What does it issue, approve, or sign?
3. What does it inspect or sample?
4. Who reviews or oversees its work?
5. What happens first when a limit is exceeded?
6. Which job title does the day-to-day work?
7. What training or credential does that person usually hold?
8. What does this actor not do, that people often assume it does?
9. Summary paragraph: in four to six sentences, explain how the four actors divide the work, and name the point where federal authority becomes local work.

From Water for Schools (waterforschools.org). This material is in the public domain (CC0) and may be copied, edited, and shared freely.

Completed Exemplar

Question	EPA	State environmental agency	Sedgewell pretreatment coordinator	Bowrick Foods, the industrial user
1. What authority does this actor hold over industrial discharges?	Writes the national pretreatment rules and the categorical standards that apply to specific industries; approves and oversees state programs.	Runs the approved state program; requires the utility to operate a local pretreatment program as a condition of the plant's discharge permit.	Enforces the local limits and the categorical standards on every significant industrial user connected to the Sedgewell sewer.	Must meet the limits in its own permit and treat or control its wastewater before it reaches the sewer.
2. What does it issue, approve, or sign?	Federal regulations and categorical standards; approval of a state program.	The utility's discharge permit; approval of the utility's local limits and enforcement response plan.	The industrial user permit, inspection reports, sampling results, and notices of violation.	Its own self-monitoring reports, signed by a responsible official, plus any compliance schedule it agrees to.
3. What does it inspect or sample?	Rarely samples one business; audits state and local programs and reviews annual reports.	Audits the utility's program, reviews the annual pretreatment report, and samples the plant's own effluent.	Samples the industrial user's discharge at the manhole, inspects its treatment equipment, and reviews its records on a set schedule.	Samples its own discharge at the frequency its permit requires and keeps the chain of custody records.
4. Who reviews or oversees its work?	The federal rulemaking process and the courts.	The EPA regional office during program review.	The state agency during a program audit, and the utility's own management.	The Sedgewell coordinator, and the state if the matter is referred upward.
5. What happens first when a limit is exceeded?	Acts directly only where no approved program exists or where the state has not acted.	Cites the utility under its discharge permit if the local program failed to respond.	Issues a notice of violation, requires a corrective action plan, and can apply a surcharge, a penalty, or disconnection for repeated violations.	Must report the exceedance within the time its permit states, then investigate and correct the cause.
6. Which job title does the day-to-day work?	Environmental engineer or program reviewer in a regional office.	State pretreatment coordinator or permit writer.	Pretreatment coordinator, often working with an industrial waste inspector and the plant laboratory.	Environmental compliance manager, with an industrial wastewater operator running the treatment equipment.
7. What training or credential does that person usually hold?	An engineering or environmental science degree.	An engineering or science degree, often with state inspector training.	A wastewater operator license plus sampling, inspection, and enforcement training; many states certify pretreatment staff separately.	A chemistry, engineering, or environmental background, and in many states an industrial wastewater operator license.
8. What does this actor not do, that people often assume it does?	It does not inspect most individual factories in an approved state.	It does not usually write the local limits; it approves the ones the utility develops.	It does not set the national categorical standards; it enforces them along with local limits.	It does not buy the right to discharge anything by paying a surcharge, since a surcharge covers treatable strength and never covers a prohibited discharge.
9. Summary paragraph	The four actors form a chain in which authority is delegated from the federal level downward, while reports travel back along the same path. EPA writes the national pretreatment rules and the categorical standards, then approves the state program that carries them out. The state makes a local pretreatment program a condition of the Sedgewell plant's own discharge permit, and it audits how that program runs. The point where federal authority becomes local work is the industrial user permit, because the Sedgewell pretreatment coordinator is the person who writes it, samples against it, and issues the first notice when a limit is exceeded. Bowrick Foods sits at the end of the chain, responsible for treating its own waste and for reporting its own exceedances. Someone choosing among these jobs should notice that the federal and state positions mostly review programs, while the utility position is the one that inspects a business and talks to its operators.

Differentiation

Support

Give students the completed exemplar with one column blanked rather than the whole grid, and supply a word bank containing categorical standard, local limits, industrial user permit, self-monitoring report, notice of violation, and surcharge. Let the summary row be written as four separate sentences using provided starters instead of a paragraph.

Extension

Have students add a fifth column for a hauled waste contractor that brings septage to the same fictional plant, then complete all eight rows for it and explain which existing column it most resembles. A strong answer notices that the hauler is permitted and inspected by the same local coordinator but discharges at a receiving station rather than through a sewer connection.

ELL supports

Pair each row label with a plain restatement, for example row 2 as "What paper does this one sign?" and row 5 as "Who gets the first letter when something goes wrong?" Allow single words or short phrases in every cell, and let the summary row be delivered orally to the teacher rather than written.

Extensions

Have students find their own state's list of utilities with approved pretreatment programs, which every delegated state publishes, and check whether the utility serving their school is on it. If it is, students can read the utility's local limits page and list two pollutants with a local limit that surprised them, then explain what a food processor, a metal finisher, or a hospital might discharge that the limit is meant to control.