Industrial Pretreatment What s it all about? Grace Scott Pretreatment Coordinator Water Division Michigan DNRE michigan.

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1 Industrial Pretreatment What s it all about? Grace Scott Pretreatment Coordinator Water Division Michigan DNRE scottg@ michigan.gov

2 Michigan DNRE

3 Wyandotte Chemical 1969

4 National Steel 1969

5 McLouth Steel Detroit River 1965

6 Trenton WWTP Interference

7 Bronson WWTP

8 Louisville, Ky Toxic Discharge

9 Louisville, Ky - Explosions

10 Anderson, IN Fish Kill

11 Worker Dies, 3 Firefighters Hurt May 7, Unusual incident in Middleton, Ohio took the life of a city worker, and hospitalized 3 firefighters. The worker was conducting a non-entry inspection of a manhole when he lost consciousness and fell down inside the manhole.

12 DPW Employee and Firefighter Die Sept 6, 2010 TARRYTOWN NY A village firefighter and a longtime department of public works employee both died after the DPW worker apparently became overcome by fumes in a manhole while responding to a sewer backup. A firefighter that went in to try to save him also died. Neither used any protective mask or breathing apparatus when entering the manhole.

13 BP pipeline break Hammond, In.

14 Industrial Pretreatment Program Requirements 1. NPDES Permit 2. State Permit 3. Order of the Department

15 The Federal Connection EPA NPDES State NPDES Permit Pretreatment Program Industrial User

16 Evolution of Pretreatment Regulations 1963 MI Act 245 amended to prohibit indirect pollution CFR Part 128 promulgated CFR Part 403 promulgated POTW program approval deadline 1985 Michigan - Part 21 Rules Pretreatment Implementation Review Task Force( PIRT ) report released

17 Evolution of Pretreatment Regulations (Cont.) Domestic Sewage Study (DSS) Report to Congress PIRT Rules promulgated DSS regulations promulgated Removal credit/pollutant eligibility revised 1995 Michigan Part 23 Pretreatment Rules Program Modification Regulation Streamlined 2005 Streamlining and Electronic Reporting

18 Part 23 Rule Revisions Pending PA 91 of 2004, restricts the Department s rulemaking authority for Part 31 Water Resources programs after December 31, 2006.

19 Industrial Pretreatment Program ( IPP ) A water pollution control program designed to prevent pollutants from passing through municipal WWTPs in amounts that could harm the environment. The IPP is also designed to protect municipal WWTPs from discharges that could upset the WWTP, contaminate the biosolids, damage the municipal infrastructure or create worker healthy/safety concerns.

20 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

21 Discharges to Municipal WWTPs In general, municipal WWTPs were designed to treat sanitary (domestic) sewage using biological and physical processes. Biological processes occur when bacteria and other small organisms to break down pollutants in wastewater for use as food.

22 Local Limitations WWTPs treat incoming wastewater from all sources - domestic, commercial and industrial The pollutants contributed by these sources will vary because no two municipalities are exactly alike WWTPs have limited capacities for treating pollutants. (The capacities are determined through an analysis called a headworks study ) These studies are used to develop local limitations

23 Allocation Example A WWTP can treat 100 pounds per day of phosphorus. 40 pounds come from households, leaving 60 pounds per day available to industrial/commercial users. If only 1 industry is in town, the local municipality could allocate all 60 pounds to that industry.

24 Allocation Example If there are 3 industries in town, the municipality would likely share the 60 pounds between them through some form of capacity allocation.

25 Industrial Pretreatment Program ( IPP ) In Michigan, the local municipality implements the IPP; DNRE and EPA have oversight responsibilities The IPP is an enforcement-based program Federal IPP requirements are found in Title 40 of the Code of Federal Regulations, Part 403; Michigan IPP requirements are in Rule of the Michigan Administrative Code

26 IPP Municipalities Vary in size, from the very large (Detroit) to the very small (Holly). An IPP is required by the EPA when a WWTP has a design flow greater than 5 MGD or receives discharges from an industry that performs federally-regulated processes. Michigan rules require an IPP whenever there s a categorical industrial user or when a there s a possibility of interference and/or pass through without regard to WWTP size

27 CATEGORICALLY REGULATED PROCESSES Metal Finishing Electroplating Organic Chemical Formulation Pharmaceuticals Metal Molding and Casting Pulp and Paper Manufacturing And many more

28 Categorical Processes Found in Title 40 of the Code of Federal Regulations, Parts (and counting ) Numerous EPA Guidance Materials on Categories, etc., available from EPA online at:

29 IPP Legal Authority Rules or Ordinance Approved by the DNRE Establishes the authority for the municipality to implement the IPP Authority for issuing permits, setting discharge limits, conducting inspections, issuing fines for violations, requiring pretreatment systems, etc Interjurisdictional Agreements define the requirements and conditions between municipalities IJAs often limit flows /loadings, & define responsibilities of each party to implement the program All contributing jurisdictions MUST have pretreatment limits and requirements at least as restrictive as the Control Authority

30 Procedures Identify all possible non-domestic users Identify the character and volume of pollutants Notify industrial users of requirements Receive and analyze self monitoring reports Issue wastewater discharge permits to all Significant Industrial Users (SIUs) Maintain a list of SIUs

31 Industrial User Permits Includes effluent limits on the discharge Reporting and Notification requirements Slug Control Requirements Records retention requirements Sampling requirements 40 CFR Part 136 test methods must be used Sampling locations and type representative and accessible

32 Procedures (con t) Inspect each SIU annually Sample each SIU annually Enforcement Response Plan Allocation Procedures (if non-uniform limits) Publication of users in Significant Non-Compliance

33 IPP Inspections The inspector will need to inspect manufacturing processes and all areas where wastewater is generated Floor drains and chemical storage areas must be reviewed to determine slug/spill potential The pretreatment system must be evaluated

34 ENFORCEMENT DNRE and EPA require that municipalities enforce IPP requirements Municipalities are required to enforce violations of discharge limits, late reports, missed schedules, and other IPP requirements Enforcement tools include notices, violation letters with compliance schedules, consent agreements, fines, termination of service

35 Questions?