COMPLYING WITH YOUR INDUSTRIAL PRE-TREATMENT PERMIT INDIANA CHAMBER OF COMMERCE CONFERENCE OCTOBER 24, 2017 PERMIT AGENDA

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1 COMPLYING WITH YOUR INDUSTRIAL PRE-TREATMENT PERMIT INDIANA CHAMBER OF COMMERCE CONFERENCE OCTOBER 24, 2017 Erik D. White, PE Michael Golando, Esq COMPLYING WITH YOUR INDUSTRIAL PRE-TREATMENT PERMIT AGENDA Understanding Basic Requirements Real-World Examples for Compliance Future Potential Impacts to Pre-Treatment Permits Questions/Discussion 1

2 CLEAN WATER ACT (CWA) Objective To restore, protect and maintain the chemical, physical and biological integrity of the nation s waters Restore and protect the nation s waters NPDES Permit program National Pretreatment (POTW) program Waters? CWA Section 502(7): navigable waters = waters of the US, including territorial seas For NPDES purposes (40 CFR 122.2) includes but not limited to: Surface waters only. State dependent for groundwater Waters currently, in the past, or may be used for interstate or foreign commerce Interstate waters including wetlands Tributaries Adjacent waters and waters with a significant nexus WATER QUALITY PROGRAM IMPLEMENTATION Indirect Dischargers - Pretreatment permits USEPA State POTW or regional authority (local limits) - A FACILITY CAN HAVE MORE THAN ONE TYPE OF PERMIT - IF A FACILITY HAS AN INDIVIDUAL NPDES PERMIT, IT S OFTEN BETTER TO NOT SEEK COVERAGE UNDER A GENERAL PERMIT 2

3 PART OF THE NATIONAL PRETREATMENT PROGRAM Pretreatment Program Objectives (40 CFR paraphrased) Prevent introduction of pollutants to a POTW that would cause interference, including interference with use/disposal of municipal sludge Prevent introduction of pollutants to a POTW that will pass through or otherwise be incompatible with such works Improve opportunities to recycle and reclaim municipal and industrial wws and sludges Essentially Protect the POTW Prevent pass-through Prevent interference Prevent exceedances of POTW s NPDES Permit Maintain sludge quality Protect worker safety Protect infrastructure INDUSTRIAL USER APPLICABILITY 40 CFR 403.3(V) Significant Industrial User Subject to Categorical Pretreatment Standards Discharges 25,000 gallons per day or more of process wastewater to POTW Contributes wastestream which makes up more than 5% or more of capacity Reasonable potential for adversely affecting POTW s operation or for violating any pre-treatment standard or requirement 3

4 - TYPICAL CONTENTS General and specific prohibitions Categorical pretreatment standards (if applicable) Local limits Sewer-use ordinances Standard conditions (e.g. notifications) Sometimes requirements for: Slug control plans Best management practices plans Pollution minimization plans Development General and specific prohibitions Established at the federal level. Categorical pretreatment standards Established at the federal level. Local limits Developed by the POTWs. Reference 40 CFR 403.5(a) & (b) 40 CFR Parts Requirements for development found in 40 CFR & 403.8(f)(4). Local limits are often found in the local sewer use ordinance. Applicability All IUs CIUs Commonly all IUs or all SIUs, but depends on the allocation method used when developing limits Purpose Provide for general protection of the POTW. Categorical pretreatment standards or local limits may be more stringent. Minimum standards based on available treatment technology and pollution prevention measures for controlling nonconventional and toxic pollutants that could cause pass through, interference, and such at the POTW. Local limits may be more stringent. Provide site-specific protection for a POTW and its receiving waters. Categorical standards may be more stringent. INDUSTRY PERSPECTIVE ON PERMIT CONTENTS Know your permit What are my limits Sampling: Frequency Know the rules get a copy of EPA document #300-R Guidance for Conducting a Pretreatment Compliance Inspection Method (Composite? Grab?) Flow proportioned Time proportioned Who is collecting Who is analyzing Splitting Discrepancies Flow measurements 4

5 INDUSTRIAL USER PERMIT HAMMOND PERMIT Local Limits: Split sampling with Hammond Sanitary District Parameter DM MA Frequency TSS 44,000 lbs/d 30,000 lbs/d Daily Chloride 2,800 mg/l Report (mg/l) 5x/week COD 88,000 lbs/d 55,000 lbs/d Daily TKN Report (lbs/d) Report (lbs/d) Daily BOD Report (lbs/d) Report (lbs/d) 2x/year ph s.u s.u. Continuous Current surcharges: Flow $2.31/1000Gal, COD $0.19/lb, TSS $0.31/lb, and TKN $1.00/lb. TECHNOLOGY BASED EFFLUENT LIMITS (TBELS) Developed independently of receiving water conditions Based on treatment and control technology capabilities and performance Does not prescribe what technology a facility implements Assigns a minimum level of effluent quality or % removal Per category (POTW or specific industry) Per pollutant Per wastewater Expression in Regulations Secondary Treatment Standards for POTWs Effluent Limit Guidelines for Industrial Dischargers 5

6 LOCAL LIMITS CONSIDERATIONS Domestic Loadings not easily controlled Industrial User Loadings some level of control No pass through No interference POTW s NPDES Compliance margin of safety Allowance for removal credits? LOCAL LIMITS EXAMPLES Parameter Indianapolis East Chicago Hammond 1, 2 Dichlorethane NL NL 1.1 1,1,1 Trichoroethane NL NL 1.6 Ammonia NL 77 NL Arsenic NL Benzene NL NL 0.13 Bis (2 exthylhexyl) Phthalate NL 1.03 NL Cadmium Choride NL NL 2800 Chromium (hex) 3.4 NL NL Chromium (Total) Copper Cyanide (amenable) NL Cyanide (Total) NL NL 9.0 Ethyl Benzene NL NL 1.6 Fluoride NL 2.9 NL Fluorenthene NL 0.96 NL Iron (dissolved) NL NL 3.9 Lead Parameter Indianapolis East Chicago Hammond Mercury Methylene Chloride NL NL 4.2 Molybdenum NL 0.2 NL Nickel Oil & Grease NL PCB's NL NL Below MDL Phenol Phosphorous NL 5.5 NL Residual Chlorine NL 0.4 NL Silver NL Surfactants (MBAS) NL NL Thallium NL 4.3 NL Toluene NL NL 1.4 Xylenes, Total NL NL 2.0 Zinc

7 FUTURE POTENTIAL IMPLICATIONS FLOW Extreme Weather Events Combined Sewer Overflow Population Growth Lack of Funding FUTURE POTENTIAL IMPLICATIONS - AMMONIA Concentration (mg/l) Ammonia-N (@ ph 7.0 & 20 o C) Acute Aquatic Life Chronic Aquatic Life Old New

8 FUTURE POTENTIAL IMPLICATIONS - TDS TDS Population Growth Softeners Drinking Water Treatment Increase and Improvements Lack of Technologies to Treat for TDS FUTURE POTENTIAL IMPLICATIONS - TDS (More Toxic) K > HCO 3 > Mg > Cl > SO 4 > Na, Ca (Less Toxic) 8

9 TAKE-AWAYS Understand your types and amounts of discharges Process water Sanitary Stormwater Know your facility operations Categorical pre-treatment limits Know your POTW Local Limits State of Permits TAKE-AWAYS BROAD AUTHORITY Select violations considered significant non-compliances (from 40 CFR (f)(2)(viii) w/emphasis added) Any other violation of a Pretreatment Standard or Requirement as defined by 40 CFR 403.3(l) (daily maximum, long-term average, instantaneous limit, or narrative Standard) that the POTW determines has caused, alone or in combination with other Discharges, Interference or Pass Through (including endangering the health of POTW personnel or the general public); Any other violation or group of violations, which may include a violation of Best Management Practices, which the POTW determines will adversely affect the operation or implementation of the local Pretreatment program. PRACTICAL IMPLICATIONS FOR MONITORING WHO IS SAMPLING? PROPER SAMPLE LOCATION AND TECHNIQUE? APPROPRIATE ANALYTICAL METHOD? SPLIT SAMPLES - WHO S RESULT IS FOR COMPLIANCE? 9

10 Questions 10