COMPUTERIZED PRETREATMENT PROGRAMS. Tony C. Jeng EnfoTech & Consulting, Inc. 260 Highway 202/31, Suite 900 Flemington, New Jersey 08822

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1 COMPUTERIZED PRETREATMENT PROGRAMS Tony C. Jeng EnfoTech & Consulting, Inc. 260 Highway 202/31, Suite 900 Flemington, New Jersey Martha Rivera Puerto Rico Aqueduct and Sewer Authority P.O. Box 7066 Barrio Obrero Station Santurce, Puerto Rico SUMMARY POTWs and industrial users can save resources, improve efficiency, and achieve better regulatory compliance by computerizing their pretreatment programs. This paper presents the pretreatment computer project completed at the Barceloneta Regional Wastewater Treatment Plant (BRWTP) of Puerto Rico Aqueduct and Sewer Authority (PRASA) and discusses project experiences and results. PRASA saves significant resources because DMR data are submitted electronically by industrial users and automatically processed by a Server. After the computerization project, PRASA responds very efficiently to the management, EPA and State inquiries on the pretreatment program. Compliance assessment, tracking of violations and payment of fines are more accurate and timely. Industrial users participated in the electronic DMR system save resources and money because all the monitoring data are processed, with minimum human intervention, by computers from analytical laboratories to permittees and finally to the regulatory agency. All paper works have been completely eliminated. Industrial users can better focus on engineering aspects of the pretreatment program rather than entering data and preparing reports. KEYWORDS - Pretreatment, Software, Savings, Compliance, DMRs INTRODUCTION Publicly Owned Treatment Works (POTWs) subjected to EPA s National Pretreatment regulations are required to establish local regulations to control and monitor discharges from industrial users. Some of key elements for a successful pretreatment program involve understanding of user discharge characteristics, familiar with regulatory requirements governing the pretreatment program, developing valid permit limits, and tracking discharge monitoring data and permit compliance. Vast amounts of information will be compiled and must be managed under a pretreatment program. Revisions of user permits will be better justified if users monitoring data can be easily incorporated into headwork loading analyses. Future treatment plant upgrades and regulation changes will add layers of complexity to the pretreatment program. It is evident that computerizing pretreatment programs will streamline the pretreatment program, improve program effectiveness and result in time and money savings for both POTWs and industrial users. EnfoTech & Consulting Inc. has computerized pretreatment programs for many POTWs that range from 5 MGD to 80 MGD. The PRASA pretreatment computer project is comprehensive and is selected for presentation in this paper. Background description of PRASA s project is described below. Puerto Rico Aqueduct and Sewer Authority (PRASA) operates 71 wastewater treatment plants. Barceloneta regional wastewater treatment plant (BRWTP) is one of treatment plants that receive heavy loadings from industrial users. BRWTP is a 8.3 MGD treatment facility that performs primary - 1 -

2 sedimentation and advanced activated sludge treatment, followed by aerobic solids digestion. BRWTP serves more than 25 significant industrial users that account for 90% of the load to the plant. Because PRASA operates all of Puerto Rico s POTWs and implements their industrial pretreatment programs, BRWTP s pretreatment program had to be consistent with those throughout the island. The scope of PRASA s responsibilities and the complexity of industrial operations at Puerto Rico s wastewater treatment facilities called for sophisticated information management tools for local limits development, pretreatment monitoring tracking, and violations and enforcement tracking. Due to vast amount of monitoring data received by PRASA each month, an electronic DMR system is a significant advantage. Some of major computer requirements for PRASA s pretreatment program are: 1. Ability to model pretreatment limits for different POTWs based on plant s characteristics. 2. Ability to automatically generate pretreatment permit documents using flexible permit templates defined by PRASA (such as templates for pharmaceuticals, food industry, laundry, metal finishing, etc.) 3. Ability to track discharge limits, revise them, and issue interim limits. 4. Ability to receive user monitoring data electronically and import them to a central database. 5. Ability to interface with laboratory information management system for importing sample data. 6. Ability to schedule compliance inspections through a central calendar. 7. Ability to schedule compliance sampling trips, generate chain-of-custody, laboratory work load reports, and track sample results. 8. Ability to automatically report noncompliance including DMR submission violations, and significant noncompliance. 9. Ability to generate notice of violation (NOV) letter using a flexible NOV letter format (customizable by PRASA). The NOV letter shall incorporate findings or causes of violations from the central database. 10. Ability to calculate fines, user surcharges, and tracking of payments. 11. Generate annual 403 reports (pretreatment) for EPA. 12. All the pretreatment information is managed in a central location and is accessible to staff based on the proper data access privilege assigned to each individual. The pretreatment information system must be powerful, easy-to-use, and expandable to provide services to all the 71 POTWs and 300 significant users. METHODOLOGY Microsoft Windows environment was selected as the platform for the pretreatment computer system. The final computer systems implemented at PRASA consist of three major sub-systems and four add-on modules. Three subsystems are POTW Administration and Compliance System (PACS), the DMR Data Server, and Wastewater Data Management System (WDMS). The four add-on modules include the Process DMR, DMR Client, EDI, and Compliance Sample. The computer project was divided into four major tasks: (1) pretreatment program management, (2) electronic DMRs, (3) external data interface with laboratory information management system, and (4) compliance sample scheduling and data tracking. Based on the requirements of each project task, proper sub-systems and add-on modules were selected to deliver required functionality. Brief description of each sub-system and add-on module is provided below. For pretreatment program management: the POTW Administration and Compliance System (PACS) is used. PACS is the center piece of the pretreatment computer management system

3 PACS provides a powerful local limit modeling tool that expands local limit calculations beyond those used in EPA s pretreatment computer program (PRELIM) to include sludge management, worker health and safety standards. PACS also adjusts local limit equations to accommodate requirements, such as acute and chronic water quality standards, that use different time scales. PACS enables POTWs to allocate loads to dischargers for individual pollutants based on several options (including uniform concentration, contributory flow, mass proportional, and selected reduction). An example local limit modeling screen is illustrated in Figure 1. Figure 1: Local Limit Modeling Screen Generating pretreatment permits become an effortless task under PACS. POTWs can merge their own boiler plate permit text with information stored in the database PACS. Pretreatment permits generated from PACS will contain permit conditions specific to each industrial user. PACS automatically evaluates DMR data against EPA compliance criteria and flags violations for both regular noncompliance and significant noncompliance. PACS automatically issues notice of noncompliance letters and tracks all enforcement actions. An example monitoring data tracking screen is shown in Figure

4 Figure 2: Monitoring Data Tracking Screen POTWs can schedule inspection trips using a central calendar database. After trips have been recorded in the database, PACS will generate inspection reports to help field inspections. Inspection results can be recorded and tracked in PACS. PACS can be easily integrated with many popular office software. Data stored in PACS can be easily exported to 18 other popular software packages, such as Word for Windows, WordPerfect, Excel, Lotus, etc. For electronic DMRs: The electronic DMR (EDMR) system consists of the DMR Data Server, the WDMS program, the DMR client module, and the Process DMR module. Brief description of each EDMR system component is described below: The DMR Data Server is installed at POTWs to serve as an electronic mail box for DMRs submitted by industrial users. Major system functions provided by the DMR Data Server include: Manages DMR certifier s information and PIN numbers Administrates login security Receives electronic DMRs Validates DMRs data integrity before acceptance Issues confirmation numbers back to senders to acknowledge receiving DMRs Manages DMR revisions Maintains communication logs for each electronic DMR Records processing status of each DMR Stores File Transfer Validation module for data integrity checks Controls Data Access Security Industrial users will use Wastewater Data Management System to track permits and monitoring requirements, record monitoring data, and prepare DMRs. A copy of the DMR Client module is also installed at industrial user locations to allow them to communicate with the DMR Data Server. DMRs can be electronically submitted to POTWs via modems. Industrial users have the option to send DMRs via modems or by diskettes. If DMRs are sent via modems, IUs will receive a receipt confirmation number from the Server when a DMR has been successfully registered at the Server. POTWs have the option to review DMR submissions on a daily basis and track all the data communications. On the date of each DMR submission deadline, POTW can use the Process DMR module to browse DMRs from the Data Server and process them (import them to PACS) at a push-ofa-button. All processed DMRs are recorded in PACS for future compliance evaluations and tracking. An example processing DMRs screen is shown in Figure

5 Figure 3: Processing DMRs screen For External Data Interface with LIMS: An external data interface (EDI) module was developed and implemented at POTWs. The EDI module allows POTWs to electronically import sample results and monitoring data to PACS. Types of monitoring data suitable for the EDI module are user daily monitoring data, inspection samples, compliance sample data, and on-line field monitoring data. The EDI module can be tailored by the POTW to import different file layouts provided by different data sources. The EDI module uses a file template concept to allow users to setup different file transfer procedures for importing data from different file formats. File transfer procedures can be saved in the database and be reused for the same file format in the future. For Compliance Sample Scheduling and Tracking: A Compliance Sample module was developed for POTWs and integrated with PACS. The Compliance Sample module allows POTWs to maintain a centralized calendar for scheduling sampling trips. Scheduling is performed via an easy-to-use calendar interface. In additional to schedules, sample requirements, sample bottle sizes, and sample preservation methods are also recorded in the database. The sample module will generate chain-of-custody, laboratory work load reports, and schedule reports. A typical compliance sample screen is shown in Figure 4. Figure 4: An example Compliance Sample screen The above three major subsystems and four add-on modules represent a suite of system components for POTWs to implement a sophisticated pretreatment management system that meets their local requirements and fits their computing environment. PRASA s pretreatment computer project focuses on two major objectives. Firstly, PRASA needs to obtain a uniform procedure for calculating local limits. Secondly, PRASA wants to electronically process - 5 -

6 vast amounts of DMR data and efficiently manage them to meet regulatory compliance and reporting requirements. PACS, the DMR Data Server, the WDMS program, the DMR Client module, and the EDI module were selected as the core components to form PRASA s pretreatment information management system. A schematic diagram showing modules and implementation techniques is illustrated in Figure 5. PRASA Computer Pretreatment Project Operating at PRASA Send DMRs Download Validation File Process DMRs WDMS Work Station (IU) Manages permits Tracks monitoring data Calculates and prints DMRs Assists compliance evaluation Generates electronic DMRs Login DMR data server via modem and sends DMRs Retrieves File Transfer Validation module Send DMRs Modem (IU) Download File Validation DMR Data Server (PRASA) Administrates Logins Receives IUs DMRs Stores File Transfer Validation module Controls Data Security Issue Validation File PACS Work Station (PRASA) Calculates local limits Manages permits Imports DMRs electronically Manages DMRs Tracks user inspection data Performs compliance evaluations Tracks enforcements Issues revised File Transfer Validation module WDMS Work Station (IU) Modem (IU) Figure 5: Implementation Diagram for PRASA s Pretreatment System RESULTS PRASA s pretreatment system was delivered in phases beginning in 1995 and completed in February The electronic DMRs system began production in February All the pretreatment permits, monitoring data, and enforcement records are stored in the PACS database. Coordination of field inspections and compliance samplings are made easier with a scheduling database that is centrally managed by the system. Issuing notices of noncompliance and tracking payments of fines are much easier and efficient under the new computer system. A sophisticated data access security feature has been implemented in PACS to allow the system administrator to establish different user groups and maintain proper data access privilege for each authorized user on the system. PRASA is operating PACS and the DMR Data Server from two local computers. PRASA is upgrading its computers so that the entire pretreatment computer system can be migrated to a local area network environment when computers are ready. At which time, information stored in PACS can be shared across the Authority

7 Eight industrial companies in Barceloneta area participated in the electronic DMRs beginning in February, PRASA is planning to expand the electronic DMRs system to all POTWs that receive industrial discharges in the island. Eventually, all the industrial users will be encouraged to submit their DMRs electronically to PRASA and all the compliance sampling data will be automatically linked from a PRASA s central laboratory to the PACS system. The implementation of computer pretreatment program and electronic DMR system will provide significant resource savings to PRASA. Pretreatment staffs will be able to focus more on engineering aspects of the pretreatment program rather than handling paper, keying data, and preparing reports. Pretreatment departments will be able to accurately and efficiently respond to the PRASA s management and EPA s inquiries on pretreatment program. Industrial users participated in the electronic DMR system have enjoyed the automation of permit tracking, monitoring data management, and report generation provided by the WDMS program. PRASA s policy to eliminate paper work and waive paper submissions also provides additional incentive to industrial users, as it helps industrial users to save resources and money. The pretreatment computer program promises to simplify PRASA s pretreatment program while increasing their efficiency and quality, and to help industrial users save resources by complying with a paperless reporting system. CONCLUSION Implementing an integrated computerized pretreatment system will give the PRASA and its industrial users several advantages. Industrial users better recognize the formidable pretreatment requirements and regulatory constraints imposed on PRASA as well as the potential problems industrial discharges can create for treatment facilities. PRASA, in turn, has gained a clearer understanding of how important it is for industrial users to have well-defined discharge limits and permit conditions. Implementing the computer system will result in accurate and consistent pretreatment limit calculations, consistent and well-organized pretreatment permits, and timely compliance checks and enforcement actions. Compliance monitoring and enforcement tracking will become more accurate and efficient for PRASA and industrial users. The computer project also facilitated PRASA s responses to EPA inquiries about pretreatment and enable timely submission of complete, accurate reports from both POTWs, despite limited staffing and heavy work loads. ACKNOWLEDGMENTS PRASA s pretreatment computer project was completed under the technical direction of PRASA pretreatment program and Barceloneta Advisory Council. Especially, Mr. Manual Hormaza (Chairman of Barceloneta Advisory Council), Mr. Carlos Bassat (Director of Environmental and Safety of Merck Sharp & Dohme Quimica de Puerto Rico, Inc.), Dr. Mary Buzby (Principal Scientist, Merck & Co., Inc.), and Ms. Dianna Kocurek (a partner at Tischler/Kocurek) have significant contributions to the success of the project. REFERENCES Guidance Manual on the Development and Implementation of Local Discharge Limitations Under the Pretreatment Program - U.S. EPA (12/1987) Technical Support Document for Water Quality-based Toxics Control - US EPA,Office of Water (3/1991) General Pretreatment Regulations for Existing and New Sources of Pollution - 40CFR, Part

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