A Tale of Two Cities and One Awful Smell A CWT Story. DAN PARNELL Industrial Permitting Manager Pacific NW Pretreatment Workshop
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1 A Tale of Two Cities and One Awful Smell A CWT Story DAN PARNELL Industrial Permitting Manager Pacific NW Pretreatment Workshop September 14, 2016
2 Overview What s a CWT? Pretreatment Who Dunnit Lessons Learned Hint: Look at the previous bullet Environmental Services l Pollution Prevention Services Group 2
3 What s a CWT? The thing that keeps you up at night? Environmental Services l Pollution Prevention Services Group 3
4 What s a CWT? Kinda like your uncle that builds dioramas with stuffed mice is unique. Industries accepting hauled waste are unique Assume liability on behalf of generator. Discharge permit is not a cost of doing business, IT IS their business. Discharge Permit, Rates and Surcharges are a significant costs for CWT. Environmental Services l Pollution Prevention Services Group 4
5 What s a CWT? Centralized Waste Treatment - 4 Subparts Subpart A - Metals Subpart C - Organics Subpart B - Oils Environmental Services l Pollution Prevention Services Group 5
6 What s a CWT? May accept, treat, & discharge more than 1 subcategory Metals Metal Treatment Subpart A limits apply here L o c a L Oils Organics Oil Treatment Organic Treatment Subpart B limits apply here Subpart C limits apply here L i m i t s Environmental Services l Pollution Prevention Services Group 6
7 What s a CWT? What if the facility accepts septage? Metals Metal Treatment Subpart A limits apply here Lucky you! L o c a L Oils Organics Non Regulated Waste Oil Treatment Organic Treatment Non Regulated Waste Treatment Subpart B limits apply here Subpart C limits apply here L i m i t s Environmental Services l Pollution Prevention Services Group 7
8 What s a CWT? The 4 th Subpart provides for commingling of multiple waste streams D Metals Metal Treatment Oils Oil Treatment Subpart D limits apply here Organics Organic Treatment BUT Environmental Services l Pollution Prevention Services Group 8
9 What s a CWT? To get Subpart D, CWT must have proper treatment technology: OR Environmental Services l Pollution Prevention Services Group 9
10 What s a CWT? demonstrates Equivalent treatment Treatment system achieves comparable pollutant removals to EPA technologies May be demonstrated through literature, treatability tests, or self-monitoring data Environmental Services l Pollution Prevention Services Group 10
11 What s a CWT? A Few CWT Permitting Scenarios: Environmental Services l Pollution Prevention Services Group 11
12 References Effluent Guidelines Program Centralized Waste Treatment: Environmental Services l Pollution Prevention Services Group 12
13 A Pretreatment Whodunnit A Tale of Two Cities and One Awful Smell (August 2014 June 2015) Environmental Services l Pollution Prevention Services Group 13
14 C D North Portland Industrial Area Stuck in the middle with ewww A Columbia Blvd. Wastewater Treatment Plant CWT - 5 permitted, only 4 involved B Environmental Services l Pollution Prevention Services Group 14
15 C August 2014 D B Described as sickly sweet chemical odor A 1 Strong Chemical Odor Associated w/ CWT A Batch Discharge Discharge ceased Odor ceased H 2 O 2 Treatment then discharged w/o odor Environmental Services l Pollution Prevention Services Group 15
16 C October 2& Creamed corn D The Big One Strong Odor High Chlorine Demand 2 WWTP >100% hypochlorite demand Rotten eggs A Putrid Sickly sweet chemical B 1 Environmental Services l Pollution Prevention Services Group 16 2 Odor originating south of WWTP.
17 C D October 2014 June 2015.but not for long Multiple odor complaints along stretch of road A 2 Described as Putrid Creamed corn Smell of the ocean B 1 Environmental Services l Pollution Prevention Services Group 17 2
18 Preliminary Diagnosis Putrid + Creamed Corn + Smell of the Ocean = Dimethyl Sulfide (DMS) Degradation product of Dimethyl Sulfoxide (DMSO) DMSO Odorless Sewer Bacteria DMS Objectionable Odor Little dab will do you! 20 ppb Environmental Services l Pollution Prevention Services Group 18
19 Sources of DMSO Solvent used in electronic components manufacturing CWTs did not receive any waste from potential sources But not in Portland Or did they???? Environmental Services l Pollution Prevention Services Group 19
20 2 E. coli violations C D October 18-20, 2016 The Really Big One! Same symptoms: Hypo Demand Awful Smell Unhappy Operators and Residents A and Confused Pretreatment Manager B 1 2 But. Environmental Services l Pollution Prevention Services Group 20
21 We got a hit in a primary effluent sample!!! No DMS detected, but Semi-volatile analysis finds 2-Butoxyethanol ~18 mg/l Sweet smell Biodegradable Shouldn t be oxidized by hypochlorite Environmental Services l Pollution Prevention Services Group 21
22 Sources of 2 Butoxyethanol Ubiquitous solvent/cleaning agent used in Inks Paints Asphalt CWT B stated that it was used in chemical toilets to control odors. And. Environmental Services l Pollution Prevention Services Group 22
23 C D a Pump Station Maintenance Employee Reported the same odor at a Pump Station Guilds Lake PS B A CWT B instructs portalet haulers to stop using the chemical. Environmental Services l Pollution Prevention Services Group 23
24 Guilds Lake PS Investigation Nov 2014 Start sampling collection system from PS to CWT B B And. Environmental Services l Pollution Prevention Services Group 24
25 the Problems Stop No Incidents in November or December Problem Solved! Kinda Environmental Services l Pollution Prevention Services Group 25
26 Questions? But.. Even slug discharges gotta take time off for the holidays! Environmental Services l Pollution Prevention Services Group 26
27 they start again on February 12 Thanks, but we were expecting chocolates a card flowers would have been nice Environmental Services l Pollution Prevention Services Group 27
28 C 2 through 8 or 9 or whatever D The Bad News! Recurring Incidents Feb through June 2015 Pretreatment Program Manager s position on all of these slug discharges? A Fetal! B 1 Environmental Services l Pollution Prevention Services Group 28
29 The Bad News! Recurring Incidents Feb through June 2015 Diesel High Cl demand Sickly Sweet Chemical Operations Normal Cl demand Creamed Corn High DO demand Petroleum Normal DO demand Environmental Services l Pollution Prevention Services Group 29
30 The Bad News! Recurring Incidents Feb through June 2015 Strong, very unpleasant rotten egg, chemical odor Residents Overpowering petroleum/gasoline odor woke family up, causing nausea and headaches Aka: the folks gathering their pitch forks and torches garbage odor Environmental Services l Pollution Prevention Services Group 30
31 The Bad News! Recurring Incidents Feb through June 2015 In April, things Really Heat Up LEL Sensor at Guilds Lake PS Residents weren t the only thing ready to blow Environmental Services l Pollution Prevention Services Group 31 B
32 C D The Good News! Recurring Becomes Predictable Composite Samplers set up in key locations on June 23rd A B Environmental Services l Pollution Prevention Services Group 32
33 The Good News! Recurring Becomes Predictable Great news!! June 24 th we get another slug! Sampling reveals: Dimethyl Sulfide Kinda like you needing a root canal is great news Environmental Services l Pollution Prevention Services Group 33
34 C D The Good News! Recurring Becomes Predictable Dimethyl Sulfide (DMS) detected A B Environmental Services l Pollution Prevention Services Group 34
35 The Good News! Recurring Becomes Predictable Two sources generated DMSO in Hillsboro, OR Environmental Services l Pollution Prevention Services Group 35
36 DMSO Takes a Road Trip!!!! CWS Pretreatment join in the sleuthing 2 Sources in Hillsboro Industry 1 sent DMSO to CWT B Industry 2 sent DMSO to Seattle area Hillsboro Portland Or did it. Environmental Services l Pollution Prevention Services Group 36
37 DMSO Takes a Road Trip!!!! It did but then DMSO was sent to CWT B in Portland Hillsboro Saw Pikes Place, Space Needle, drank lots a coffee but there s no place like home Portland Environmental Services l Pollution Prevention Services Group 37
38 Resolution DMSO was hauled to CWT B by 3 rd party haulers CWT B unaware of DMSO presence CWT B stopped accepting waste from hauler of Industry 1 (non-travelling DMSO) Environmental Services l Pollution Prevention Services Group 38
39 Resolution Industry 2 was not aware of DMSO return trip to Oregon Industry 2 instructs WA CWT not to send DMSO back to Oregon Sorry, every other state Environmental Services l Pollution Prevention Services Group 39
40 Lessons Learned CWT B not adequately characterizing waste CWT B lacked adequate treatment CWT Discharge Permit Modifications: 1. Develop waste acceptance plan 2. Develop treatability plan 3. Retain discharge samples 4. Prohibit discharge of DMSO CWT B had to turn away lots of customers Environmental Services l Pollution Prevention Services Group 40
41 Questions? Special Thanks to our friends: Clean Water Services Pretreatment Program!!! Environmental Services l Pollution Prevention Services Group 41
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