Mark Kelly, PE Industrial Waste Engineer July 25, 2013

Transcription

1 Mark Kelly, PE Industrial Waste Engineer July 25, 2013

2 What is The Sewer Use and Wastewater Control Ordinance? Sets requirements for sanitary sewer users Regulates the discharge of pollutants into the collection system Enables the Water Authority to achieve compliance with U.S. EPA National Pollutant Discharge Elimination System (NPDES) and Southside Water Reclamation Plant (SWRP) effluent and sludge limits.

3 Injury to Workers from Hazardous Fumes Limitations on Sludge Disposal Options and/or Greater Expense Corrosion of Collection System and/or Treatment Plant Explosions Interference with Wastewater Treatment Facility Pass-Through of Toxics into Surface Waters

4 Why a new Ordinance? A requirement of the new U.S. EPA National Pollutant Discharge Elimination System (NPDES) permit for SWRP

5 What will be changed? Fats, Oils, and Grease Policy created Sewer Use and Wastewater Control Ordinance updated to match EPA model Technically Based Local Limits updated Enforcement Response Plan updated

6 Ordinance Process EPA MODEL PRETREATMENT ORDINANCE Office of Wastewater Management/Permits Division Reviewed 40 CFR 403 Pretreatment regulations Reviewed other Publicly Owned Treatment Works (POTWs) Pretreatment Ordinances

7 Ordinance Process Draft Ordinance Public Participation Meetings Ordinance, ERP, FOG Policy posted online Incorporation of Comments Submitted to EPA by October 1, 2013 EPA has comments or gives certificate of approvability Ordinance posted publicly for one month Water Authority Board approves and incorporates new ordinance

8 Ordinance Requirement: Fats, Oil and Grease (FOG) Capacity, Management Operations, and Maintenance (CMOM) Plan with an emphasis on FOG Policy FOG policy is a re-evaluation of the existing Ordinance Grease Removal System (GRS) Requirements Maintenance Inspections Record Keeping Best Management Practices (BMPs) 8

9 Changes From The Previous Ordinance: Fats, Oil and Grease Maintenance: Minimum cleaning every 6 months 25% rule 9

10 FOG Policy: Pumper Requirements Must use a pumper that is in compliance Complete Evacuation All chambers must be pumped No decanting or discharging of wastewater back into trap Manifests Must be provided Date, time, volume, condition Prohibitions Discharging of unprocessed GRS waste at SWRP Blending 10

11 Changes From The Previous Ordinance: Dental Amalgam Separators Incorporated into the ordinance Exemption expanded for not greater than three amalgams per 12 months Best Management Practices 11

12 Ordinance Requirement: Industrial Permits Various Industrial Permit Changes: Appeal Process Transfer of permits is possible Permit submittals based upon postmark

13 Ordinance Requirement: Industrial Permits Cease and desist orders clarified Administrative Assessments: power to assess at least $1, per violation per day Is spelled out in Rate Ordinance passed 6/19/13 Ordinances.aspx

14 Ordinance Requirement: Technically Based Local Limits (TBLLs) For specified pollutants: Domestic manhole, industrial discharge, and plant influent water quality results determine SWRP loading Plant influent and effluent water quality results determine SWRP removal efficiency Plant influent loading compared with NPDES effluent limits and sludge disposal limits If an influent loading is too high, local limits change

15 Ordinance Requirement: Technically Based Local Limits (TBLLs) Removal Efficiencies Parameter Removal % Aluminum 92% Ammonia 98% Arsenic 43% Boron 36% Cadmium 87% Chromium 95% COD 91% CBOD 97% Copper 89% Cyanide 67% Fluoride 6.1% Lead 92% Mercury 97% Molybdenum 79% Nickel 62% Selenium 60% Silver 92% TSS 97% Zinc 90%

16 Ordinance Requirement: Technically Based Local Limits (TBLLs) Domestic Manhole Concentrations Analyte Conc. (mg/l) Aluminum Ammonia 33.6 Arsenic Boron Cadmium Chromium COD 547 Copper Fluoride Lead Mercury Molybdenum Nickel Selenium Silver TSS 258 Zinc 0.399

17 Ordinance Requirement: Technically Based Local Limits (TBLLs) Pollutant Previous TBLL, mg/l (unless noted) 2013 TBLL, Daily Maximum Composite mg/l (unless noted) 2013 TBLL, Monthly Average mg/l (unless noted) Criteria Basis Comments Aluminum Chronic WQS No Change Ammonia None NPDES Permit Limits New Limit Arsenic Digester Inhibition No Change Boron None 699 Irrigation WQS New Limit Cadmium Chronic WQS No Change Chromium Digester Inhibition No Change COD None 5,139 NPDES Permit Monthly Limit New Limit CBOD None 2,107 NPDES Permit Monthly Limit New Limit Copper Digester Inhibition Lower Limit Cyanide Digester Inhibition No Change Fluoride Acute/Chronic WQS (Isleta Pueblo) Lower Limits Lead Acute/Chronic WQS Lower Monthly Av. Limit Mercury NPDES Permit Limits Lower Monthly Av. Limit Molybdenum Isleta Chronic WQS Lower Monthly Av. Limit

18 Ordinance Requirement: Technically Based Local Limits (TBLLs) Pollutant Previous TBLL, mg/l (unless noted) 2013 TBLL, Daily Maximum Composite mg/l (unless noted) 2013 TBLL, Monthly Average mg/l (unless noted) Criteria Basis Comments Nickel 2 2 Digester Inhibition No Change Selenium NM Acute/ Isleta Wildlife WQS Lower Limits Silver 5 5 Acute WQS No Change TSS None 5514 NPDES Permit Monthly Limit New Limit Zinc Nitrification Inhibition No Change Formaldehyde Safety No Change TPH Safety No Change Oil and Grease Operations Lower Limit Phenolic 2 2 Safety No Change TTO 3.2 None CFR Categorical Limit Removed Benzene Safety No Change BTEX Safety No Change ph s.u s.u. 1 Corrosion Higher Upper Limit Temperature 140 F 140 F 1 Safety No Change

19 Changes From The Previous Ordinance: Enforcement Response Plan (ERP) Reimbursement of all Water Authority monitoring costs for samples in violation Administrative Assessments for each discharge violation All citations changed to Administrative Assessments Online:

20 Changes From The Previous Ordinance: Enforcement Response Plan (ERP) Discharge Violations Current AA Proposed AA 100% <Result<120% of Limit $ % <Result<150% of Limit $ $ % <Result<200% of Limit $ $ % <Result<500% of Limit $ >501% of Limit $500 AA $ $ AA doubles after missing RTC sampling Reporting Violations Current Proposed Grace Period 30 days 5 days First occurrence, AA $ $ Subsequent occurrence, AA $ $400.00

21 Other Changes Wastewater Operator Certification Level III Required for monitoring technicians. Title of Industrial Waste Engineer has been changed to Industrial Pretreatment Engineer.

22 Comments Due by August 16, 2013 Website: Comment Cards