2016 Industrial Waste Pretreatment Seminar A "How To" Guide for Pretreatment. November 2, 2016

Transcription

1 2016 Industrial Waste Pretreatment Seminar A "How To" Guide for Pretreatment November 2, 2016

2 How to Guide: Classification, Permitting & Enforcement Lisa Lucht, P.E. Nichole Schaeffer, P.E. Jennifer Sorensen, P.E.

3 Title Overview How do you classify an industry? What must be in a permit? How do you enforce a permit?

4 Title Classification Who needs to be classified? Industrial Survey New Businesses Re-classify Industries Manufacturing directories High water users Complete follow up Communicate with building department Review all new business license applications Changes to process (Add? Remove?) Evaluate at annual site inspection New survey every WW discharge permit cycle

5 Title Classification Conduct Site Inspection Raw materials * Manufacturing Process * How are raw materials transformed? * Go beginning to end Water used * Manufacturing * Cleaning * Product? * Equipment? Water discharged Water hauled * What is being discharged? * Pretreatment? ***Ask Questions They are the experts!***

6 Title Classification Types of Industries CIU Categorical Industrial User Regulated by 40 CFR developed by USEPA SIU Significant Industrial User > 25,000 gpd process wastewater Or 5% of the hydraulic loading of the WWTP NSCIU Non-significant Categorical Industrial User < 100 gpd process wastewater Must be defined in your ordinance

7 Title Classification Types of Industries Zero CIU Zero Discharge Categorical Industrial User Regulated by 40 CFR - does not discharge process wastewater NSRIU Non-significant Regulated Industrial User Not a CIU or SIU need monitoring Potential for upset or pass through Surcharge User Surcharge Industrial User Discharges high BOD, TSS or Ammonia Nitrogen Surcharge costs to offset the cost to treat waste Industries may have two or more different classifications.

8 Title Classification Tools Use 40 CFR Regulations Use Development Documents (help interpret regulations) Ask USEPA or WDNR for help

9 Title Classification Effluent Guidelines

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11 Title Classification Effluent Guidelines Select Existing Regulations

12 Title Classification - Examples Categorical Industrial User Cold forming of copper wire No water used to make product Cleaning final product CIU 40 CFR Subpart A Copper Forming (h) Alkaline Cleaning

13 Title Classification - Reclassify Reevaluating for permit renewal Annual site inspection Change of pretreatment staff Notification from industry on change of process Start hauling process waste Zero Discharge?

14 Title Classification - Examples Re-classification Example Electroplating industry CIU 40 CFR 413 Removed electroplating from process in 1990 s Not electroplating > different categorical process Reclassified 40 CFR 420 Iron and Steel MFG Subpart K Alkaline cleaning

15 Title Permitting

16 Title Who Needs a Permit? Required CIU SIU Optional Non- Significant CIU Non- Significant Regulated IU Zero- Discharge CIU Surcharge IU Depends on PT Program

17 Title Permitting Create Master Permit All SUO References are Included Cut Individual Permits from Master Consistency Across All Permits One Permit to rule them all"

18 Title Permit Contents Basic IU Info/Title Page Industry Name & Address Classification New Source or Existing Source Authorized Representative Contact Name Issuance & Expiration Date Length of permit cannot exceed length in ordinance Recommend 4 year permits to allow more time to evaluate permit

19 Title Permit Contents IU Process Info Sampling Location Description Facility Description Operation Start Date Source of process wastewater Pretreatment Equipment Discharge Flow Rates Process wastewater Dilute waste streams Non-Regulated (non-dilute) Average and Max-Average* *Max Avg Q = 20% of Avg Q Threshold of notification

20 Title Permit Contents Monitoring Requirements Effluent History IU Performance Pollutants Routine & Semi-Annual Effluent Limits Most Stringent LL vs. Categorical *Monthly Categorical Limits - CIU Dependent Need CWF? Monitoring Frequency & Sample Type Comply with 40 CFR 136 sampling requirements

21 Title Pollutants Most Stringent Limits Daily Max Include Monthly Avg (if any) Sample Type Grab or Composite Frequency Daily, Weekly, Qtrly, Mo, SA

22 Title Permit Contents Organic Parameters Total Toxic Organic (TTO) Toxic Organic Management Plan (TOMP) Additional Monitoring Organics/Non-Routine Appendix Violation reporting and resampling requirements Submittal Requirements Self-Monitoring Report signed by Authorized Representative SMR Due Dates Where to submit reports

23 Title Permit Contents Additional Record Keeping Additional Reporting Requirements Spill Plan Notification Requirements Flow Monitoring Auto-sampler Maintenance 90-Day Compliance Report (1 st time Cat. Permitee) Certification Statement Requirement Update Every Two Years Accidental Spill Upset Maintain Hauled Waste Records Zero Dischargers TTO Certification Zero-Discharge Certification Employee Spill Training Annually Bypass of Pretreatment System Change in Manufacturing (20%)

24 Title Recommended Appendices Site Map/Sampling Location(s) Prohibited Discharge Limitations TTO List (CIU Dependent) Organics Full List Various Reporting Forms SMR/Semi-Annual Certification Statement Zero-Discharger Certification TTO Certification Hauling Logs

25 Title Permitting Draft and Final Allow Industry 30 Days to Review Prepare Fact Sheet Document Revisions

26 Title Enforcement Analytical Violations Reporting Violations

27 Title Enforcement What is an Analytical Violation? Daily limit exceeded Monthly limit exceeded One Sample Taken During Month Daily Violation Monthly Violation 2 separate violations

28 Title Enforcement What are the enforcement procedures? Outlined in Enforcement Response Plan (ERP) Summary of enforcement requirements From your Sewer Use Ordinance Enforcement may vary

29 Title Enforcement Analytical Violation Required Enforcement Actions Notification within 24 hours of receiving data Resample within 30 days of becoming aware of violation Send Notice of Violation

30 Title Enforcement Analytical Violation Enforcement actions that may vary Compliance Meeting with Industry Escalation of Sampling How and when fines are assessed: Adjudication Court Add to water/sewer bill Fine issued with NOV Administrative fee

31 Title Enforcement Analytical Violations Notice of Violations (NOV) Document Issue within 30 days Provide response due date Mail NOV by certified mail

32 Title Enforcement Analytical Violations Determine source of violation Repair source of violation Submit letter summarizing findings & repairs Investigate violation Industry NOV Requirements May not find source of violation

33 Title Enforcement - Analytical What to do if an industry continues to be in noncompliance? Compliance Agreement (Consent Order) Work together to determine how industry will come into compliance Compliance Order (Mandate) Municipality determines how industry will come into compliance If compliance order is not met Disconnect Sewer

34 Title Enforcement Reporting Violations Self-Monitoring Report (SMR) Failure to submit SMR Incomplete SMR Incomplete chain-of-custody Not signed by authorized representative NOV Failure to report violation Failure to submit NOV response Spill Plan Failure to submit Spill Plan Failure to do annual employee spill plan training Failure to report spill Change Notification Failure to notify authorized representative change Failure to notify of production change

35 Title Enforcement When is a report or notification considered to be a violation? Issue Reporting NOV Written response required from industry Enforcement Response Plan Same as analytical NOV How will they prevent a future reporting violation?

36 Title Questions Lisa Lucht, P.E. Environmental Engineer Nichole Schaeffer, P.E. Environmental Department Manager Jennifer Sorensen, P.E. Environmental Engineer