PRETREATMENT LOCAL LIMITS WHAT IT MEANS TO INDUSTRIES

Similar documents
The City of Grand Forks Industrial Pretreatment Program

*** DRAFT - NOT YET FILED ***

OVERVIEW OF POTW PRETREATMENT PROGRAM REQUIREMENTS

Pretreatment Streamlining Rule

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

WHERE DO THE PRETREATMENT PERMIT LIMITS COME FROM??? Amy Varinoski City of Mebane

Essential Pretreatment program knowledge and requirements in accordance with 40 CFR 403

Local Limits Evaluation. Genet Belete Oregon DEQ Pretreatment Program

GOALS OF THE CLEAN WATER ACT

RENEWAL OF FDEP FACILITY PERMITS: THE PRETREATMENT PERSPECTIVE

Albany County Water Purification District (District) Mercury Minimization Program Policy

PRETREATMENT STREAMLINING FINAL RULE FINALLY APPROVED

Streamlining a Pretreatment Program

The Use of Best Management Practices (BMPs) as Industrial Local Pretreatment Limits

FACT SHEET and NPDES WASTEWATER DISCHARGE PERMIT EVALUATION. Department of Environmental Quality Western Region-Salem Office

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

C. To improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.

NPDES Electronic Reporting Rule 40 CFR 127

N.J.A.C. 7:14A-1 POLLUTANT DISCHARGE ELIMINATION SYSTEM SUBCHAPTER 21. REQUIREMENTS FOR INDIRECT USERS

Peltier, Hannah. Rufus,

Mark Kelly, PE Industrial Waste Engineer July 25, 2013

PRETREATMENT PROGRAM LOCAL LIMITS

Color Code: Red => Required Changes Green => Recommended Changes Yellow => Attention Only ORDINANCE NO.

VWEA Pretreatment Training Course: Categorical Standards

Industrial User Survey

CITY OF SIOUX FALLS ADMINISTRATIVE RULES. Chapter 77 Public Works / Water Reclamation. Article 77:01 INDUSTRIAL PRETREATMENT PROGRAM

Frequently Asked Questions for Permitting

Why Change? Current Pretreatment Program Proposed Changes. Categorical General Permit Miscellaneous General Permit

A Class I Permit is issued to any user who meets any one of the following conditions:

HOW TO REALLY SURVIVE AN EPA AUDIT Greg V. Arthur, US EPA, Region 9

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

Public Notice. Issuance of Industrial Waste Discharge Permit

Lisa Knerr

INDUSTRIAL PRETREATMENT PROGRAM 101. MWEA IPP Seminar 2017

APPENDIX C ADEQ CHECKLIST FOR 208 PLAN AMENDMENTS

*** DRAFT - NOT YET FILED ***

SPARTANBURG SANITARY SEWER DISTRICT SIGNIFICANT INDUSTRIAL WASTEWATER DISCHARGE PERMIT PERMIT NO. SIC NO. (S)

Clark County Water Reclamation District January 1, 2017

A. Narrative Statement

Kentucky Division of Water Drinking Water Quality

Public Notice. Issuance of Industrial Waste Discharge Permit

FACT SHEET FOR 2 nd DRAFT GENERAL PERMIT NO. ARG590000, CONCENTRATED ANIMAL FEEDING OPERATIONS (CAFO) IN THE STATE OF ARKANSAS

City of Westbrook DEPARTMENT OF PLANNING, ENGINEERING & CODE ENFORCEMENT

NPDES COMPLIANCE MONITORING STRATEGY AND ANNUAL COMPLIANCE INSPECTION PLAN OCTOBER 1, SEPTEMBER 30, 2018

Pretreatment Standards. General and specific prohibitions Categorical standards Local limits

BOROUGH OF NORTH EAST PRETREATMENT ORDINANCE ORDINANCE NUMBER 884

AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM

4.0 INDUSTRIAL/COMMERCIAL DISCHARGE PERMITS

NPDES Electronic Reporting Rule 40 CFR 127

Wastewater Pretreatment 101

TITLE 252. DEPARTMENT OF ENVIRONMENTAL QUALITY CHAPTER 606. OKLAHOMA POLLUTANT DISCHARGE ELIMINATION SYSTEM (OPDES) STANDARDS

Overview of Washington State s Pretreatment Program Scott Mallery, P.E. Pretreatment Engineer September 2012

Joshua Balentine Tetra Tech, Inc. CWEA Conference Napa, CA February 3, 2015

CHAPTER 2 WASTEWATER REGULATORY ISSUES

Ordinance 896 EXHIBIT B FOG SEPARATOR REQUIREMENTS

SIGNIFICANT USER WASTEWATER DISCHARGE PERMIT. City of Las Cruces, at. Utilities Department Regulatory Environmental Services Section

ARTICLE 6 SPECIAL PERMITS FOR SIGNIFICANT INDUSTRIAL USERS INTO TOWN'S WASTEWATER SYSTEM

40 CFR - Code of Federal Regulations - Title 40: Protection of Environment

Rational IPP Permitting

FACT SHEET GENERAL KPDES PERMIT FOR STORM WATER POINT SOURCE DISCHARGES CONSTRUCTION ACTIVITIES

TITLE 252. DEPARTMENT OF ENVIRONMENTAL QUALITY CHAPTER 606. OKLAHOMA POLLUTANT DISCHARGE ELIMINATION SYSTEM (OPDES) STANDARDS

Industrial Pretreatment Program Industrial User Guide

Guide to Industrial Waste Fees for Commercial and Industrial Users

Municipal Authority of Westmoreland County. Industrial Pretreatment Program Provisions

TITLE 250 DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

Paper 5. Sanitary Sewer Overflow Peak Excess Flow Treatment Facility Options Paper. I. State/EPA Efforts to Address Sanitary Sewer Overflows

INDUSTRIAL WASTEWATER DISCHARGE AND PRETREATMENT RULES

RCRA INFORMATION BROCHURE

LOCAL LIMITS METHODOLOGY,, ISSUES,, AND ALTERNATIVES

Total Polychlorinated Biphenyls (PCBs).

Proposed New 18 CFR Part Hydraulic Fracturing in Shale and Other Formations:

Photographic Processing Facility Sector Control Policy

INDUSTRIAL PRETREATMENT PROGRAM 2009

314 CMR: DIVISION OF WATER POLLUTION CONTROL

Arapahoe County Water and Wastewater Authority Rules and Regulations APPENDIX C

No user shall introduce or cause to be introduced into the POTW the following pollutants, substances, or wastewater:

Section 1. Town of Braselton Industrial Pretreatment Program. Background, Legal Authority and Introduction

RE: AFIN: NPDES Permit No.: AR

Texas Commission on Environmental Quality Page 1 Chapter Industrial Solid Waste and Municipal Hazardous Waste

(1) Final effluent limitations shall be required for pollutants that meet any of the following conditions:

Minnesota Pollution Control Agency Municipal Division

GENERAL FATS, OILS, & GREASE (FOG) PERMIT

WASTEWATER PROBLEMS ASSOCIATED WITH SOLVENTS

TITLE 252. DEPARTMENT OF ENVIRONMENTAL QUALITY CHAPTER 690. WATER QUALITY STANDARDS IMPLEMENTATION SUBCHAPTER 1. INTRODUCTION

Milwaukee Metropolitan Sewerage District. User Charges. Chapter 17, MMSD Rules

Pretreatment Regulations of the Allegheny County Sanitary Authority, Revised 7/22/10

Septic Waste Hauler Guidelines

Categorical Standards Primer

Pretreatment Compliance Inspection. Summary Report

3:00 p.m. - 3:30 p.m.

Appendix O. NPDES Permit

RULE NO. 19 PRETREATMENT PROGRAM WASTEWATER DISCHARGE PERMIT

DOMESTIC AND NON-DOMESTIC (INDUSTRIAL, COMMERCIAL, INSTITUTIONAL) USE OF PUBLIC WASTEWATER FACILITIES TOWN OF BRASELTON SEWER USE ORDINANCE

ZERO DISCHARGE PERMIT APPLICATION

Clean Water Act 101 USE IT OR LOSE IT. Hank Graddy Sierra Sentinels July 10, 2017

Upper Blackstone Water Pollution Abatement District

Wastewater ENVIRONMENTAL SETTING. Wastewater Collection

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT. Program Tracked under NPDES Permit Number: AR

Calculation of Local Limits

Rules Governing Implementation, Administration and Enforcement of Industrial Pretreatment Program Requirements

Transcription:

Click to edit Master title style PRETREATMENT LOCAL LIMITS WHAT IT MEANS TO INDUSTRIES SPEAKERS Scott Smith Shri Vani Sripada February 20, 2014

Click to edit Master title style WHAT ARE LOCAL LIMITS & WHY ARE THEY IMPORTANT? February 24, 2014 2

Click WHAT to edit ARE Master LOCAL title LIMITS? style What are Local Limits? Wastewater limitations that apply to Categorical or Significant commercial and industrial facilities that discharge to a publicly owned treatment works (POTW). Local limits are developed to meet the pretreatment program objectives and site specific needs of the local POTW and the receiving stream. Local limits control the pollutants in the wastewater discharges from commercial and industrial facilities and apply at the end of pipe from the facility. February 24, 2014 3

WHAT ARE LOCAL LIMITS? Click to edit Master title style INDUSTRY END OF PIPE LIMITS COLLECTION SYSTEM POTW KPDES EFFLUENT PERMIT LIMITS RESIDENTIAL AREA February 24, 2014 4

Click WHY to ARE edit LOCAL Master title LIMITS style IMPORTANT? Purpose To protect the POTW s operations; and To ensure that discharges from the POTW comply with State and Federal requirements. February 24, 2014 5

WHY ARE LOCAL LIMITS IMPORTANT? Click to edit Master title style Operational Impact Financial (surcharges) Lower effluent limits Increased monitoring & reporting requirements Require the installation of more expensive control equipment Require changes of raw materials Limit plant expansion May 8, 2013 6

Click WHY to ARE edit LOCAL Master title LIMITS style IMPORTANT? It s the law POTWs are required to establish local limits CFR Citation Description 40 CFR 403.2 40 CFR 403.5(c)(3) 40 CFR 403.3(l) Objectives of the General Pretreatment Regulations are to prevent pass through, interference, and improve opportunities to recycle and reclaim wastewater and sludge. Specific effluent limits shall not be developed and enforced without individual notice to persons or groups who have requested such notice and an opportunity to respond. Pretreatment Standard means any regulation containing pollutant discharge limits promulgated by the EPA in accordance with section 307 (b) and (c) of the CWA, which applies to Industrial Users. This requirement includes prohibitive discharge limits established pursuant to 403.5 and Best Management Practices. February 24, 2014 7

Click WHY to ARE edit LOCAL Master title LIMITS style IMPORTANT? CFR Citation Description 40 CFR 403.5(c)(1) Each POTW shall continue to develop local limits as necessary and effectively enforce the limits. 40 CFR 403.8(f)(1)(iii)(C) Permits must contain effluent limits based on applicable categorical standards, local limits, and State and local law. May 8, 2013 8

Click to edit Master title style WHEN ARE LOCAL LIMITS DEVELOPED? February 24, 2014 9

Click WHEN to edit ARE Master LOCAL title LIMITS style DEVELOPED? A permit? When there is a problem with treatment plant or with industries??? February 24, 2014 10

Click WHEN to edit ARE Master LOCAL title LIMITS style DEVELOPED? Local Limits are developed when the city: has an approved Pretreatment Program; receives wastewater from a Significant Industrial User; receives wastewater from other non-domestic sources that have had: Pass through of pollutants at the POTW s treatment system and result in violation of effluent limitations or receiving water standards; Interfere with POTW s collection or treatment works, such that regulatory compliance or operating costs are significantly affected; Sludge pollutant levels limiting biosolids use/disposal; Toxic gases, vapors or fumes causing worker health and safety concerns. February 24, 2014 11

Click WHEN to edit ARE Master LOCAL title LIMITS style DEVELOPED? Other factors that trigger local limits POTW experiences a significantly different influent flow or pollutant characteristics; Modification to treatment plant or processes; Changes To KPDES permit discharge limitations; New sludge disposal practices; New Water Quality standards for receiving stream; New or increased industrial discharges to POTW; or KPDES discharge or sludge disposal violations. February 24, 2014 12

Click ARE to LOCAL edit Master LIMITS title REVIEWED/REVISED? style Local limits can be reviewed and revised POTWs must review/revise limits under 40 CFR 403.5(c)(1), following permit issuance or reissuance [ 40 CFR 122.44(j)(2)(ii)]. EPA recommends that the adequacy of local limits be reviewed if: Current wastewater treatment plant performance fails or will fail to attain applicable NPDES; Changes occur in state, or local permit requirements or other operational objectives, including water quality objectives of receiving waters; or The performance shortcomings may be reasonably attributed to pass through or interference caused by a Pollutant of Concern (POC). February 24, 2014 13

Click to edit Master title style WHEN CAN YOU GET INVOLVED? May 8, 2013 14

WHEN Click to CAN edit Master YOU GET title INVOLVED? style Opportunities for involvement Anytime! Communicate with your local POTW Pretreatment Coordinator on a regular basis and before public notices of local limits When the city adopts/revises their Sewer Use By- Laws/Ordinance When changes are made to Industrial User Permits Through other notifications (newspaper notices, direct mailings, etc.) to individual users. When there are changes to the POTW s KPDES Permit February 24, 2014 15

Click WHEN to edit CAN Master YOU title GET style INVOLVED? Put your company & program in an anticipatory mode! Understand the basics of the local limit/pretreatment programs; Understand the operational limitations of the POTW; Meet on a regular basis with your POTW Operator and Pretreatment Coordinator; Make sure your POTW Operator knows in advance of any modifications to your operation; Notify your POTW Operator if you have emergency discharges/releases from your operations; Ask questions!! Stay involved!! February 24, 2014 16

Click to edit Master title style TYPES OF INDUSTRIES SUBJECT TO LOCAL LIMITS & CATEGORICAL STANDARDS February 24, 2014 17

TYPES Click to edit OF INDUSTRIES Master title style SUBJECT TO LOCAL LIMITS & CATEGORICAL STANDARDS Categorical Standards Uniform, technology-based, and applicable nationwide. Developed by EPA, they apply to specific categories of Industrial Users and limit the discharge of specified toxic and non-conventional pollutants to POTWs. Expressed as numerical limits and management standards, the categorical standards are found at 40 CFR 405 through 471. They include specific limitations for 35 industrial sectors. Limits are different depending on whether the industry is NEW or EXISTING February 24, 2014 18

CATEGORICAL STANDARDS FOUND AT 40 CFR CHAPTER I SUBCHAPTER Click to edit Master N 405-471 title style February 24, 2014 19

TYPES OF INDUSTRIES SUBJECT TO LOCAL LIMITS & Click to edit Master title style CATEGORICAL STANDARDS Pretreatment Requirements Apply to: All non-domestic sources of wastewater that discharge to a Publicly Owned Treatment Works (POTW); There are additional requirements for: All Significant Industrial Users (SIUs), Certain requirements only apply to Categorical Industrial Users (CIUs). *As categorical standards differ from locally developed limits, categorical industries must comply with whichever limits are more stringent. February 24, 2014 20

TYPES OF INDUSTRIES SUBJECT TO LOCAL LIMITS & CATEGORICAL STANDARDS Click to edit Master title style Types Of Industrial Users All Industrial Users Significant Industrial User Non-Significant Industrial User Categorical Non-Categorical Non- Significant Categorical February 24, 2014 21

TYPES OF INDUSTRIES SUBJECT TO LOCAL LIMITS & Click to edit Master title style CATEGORICAL STANDARDS Significant Industrial Users: Categorical Industries Industrial Users: Any industry which discharges an average of 25,000 gpd of process wastewater to the sewer system (excluding sanitary, contact cooling and boiler blowdown wastewater) Any industry which is designated by the city on the basis that the industrial user has a reasonable potential for adversely affecting the operation of the collection system or treatment plant, or violating any pretreatment requirement. Non-Categorical Industrial Users, which are not categorized under Categorical Pretreatment Standards February 24, 2014 22

TYPES OF INDUSTRIES SUBJECT TO LOCAL LIMITS & Click to edit Master title style CATEGORICAL STANDARDS Non-Significant Categorical Industrial Users: Subject to Categorical Pretreatment Standards Never discharges >100 gpd of total categorical wastewater (excluding sanitary, non-contact cooling and boiler blowdown wastewater, unless specifically included in the pretreatment standard) Industrial User, prior to the city s finding, has consistently complied with all applicable Categorical Pretreatment Standards and requirements User annually submits the certification statement required in 403.12(q) Never discharges any untreated wastewater February 24, 2014 23

Click CATEGORICAL to edit Master STANDARDS title style Vs. LOCAL LIMITS Categorical Standards Local Limits Developed by EPA POTW Objective Uniform national control of Industrial Users POTW/Receiving Water Protection Regulated Industries specified in CWA All non-domestic dischargers Pollutants Basis Priority Pollutants (toxic & nonconventional only) Technology based Any Pollutant Technically based on site-specific factors Applicability End of regulated process(es) Depends on development method May 8, 2013 24

Click to edit Master title style KPDES PERMIT LIMITS February 24, 2014 25

Click KPDES to edit PERMIT Master LIMITS title style Permit requirements for the pretreatment program: Issued to city every five years Contains pretreatment program requirements based on the city s evaluation of the industrial users that discharge to the treatment plant. Implementation of Local Limits is part of the Pretreatment Program requirement During their permit period, cities submit DMRs of influent and effluent sampled according to permit conditions Also an Annual scan summary of Metals, Volatiles and Semi-Volatile parameters will be submitted at the time of applying for a permit February 24, 2014 26

Click KPDES to edit PERMIT Master LIMITS title style Kentucky DOW s Analysis: KY analyzes the city s data to determine the reasonable potential for metals; volatile; & semi-volatile parameters based on Water Quality Standards and the treatment plant performance reported on monitoring reports. Standard limits are imposed in the permit (BOD, suspended solids etc.). Based on the analysis, additional limits are imposed for metals, volatiles and semi volatiles. Additional limits imposed by the state affect the stringency of local limits. February 24, 2014 27

Click to edit Master title style DEVELOPMENT OF LOCAL LIMITS February 24, 2014 28

Click DEVELOPMENT to edit Master OF title LOCAL style LIMITS Identification of initial list of pollutants of concern Collect and Analyze data Run Calculations Decide on form of local limits that are to be adopted Draft local limits ordinance and briefing documents Submit it to the state for its review and approval Make the proposed local limits available for public comment and individual notice to the affected parties Once comments are addressed and accepted by the state, local limits are adopted and implemented February 24, 2014 29

Click DEVELOPMENT to edit Master OF title LOCAL style LIMITS Local limits are developed based on: Average flow from the industries; Total average flow that is entering POTW; Removal efficiency (in percentage) of pollutants of concern; Domestic concentrations ; KPDES Permit Limits; Analysis performed by the State (SSTWAM) to test the reasonable potential to impose limits on pollutants February 24, 2014 30

DEVELOPMENT Click to edit Master OF title LOCAL style LIMITS Factors affecting local limits calculations: Flow from industries Concentration of pollutants discharged by industries Discharge concentrations to the stream which affects the KPDES permit limits Water Quality Standards of streams to which treatment plant is discharging February 24, 2014 31

Click to edit Master title style QUESTIONS INDUSTRY SHOULD ASK February 24, 2014 32

Click QUESTIONS to edit Master INDUSTRY title style SHOULD ASK If you discharge <25,000 gpd what is the basis of designating your industry as a Significant Industrial User? What is the basis of my sampling frequency? What is Kentucky s position requiring additional sampling to determine compliance? What does the treatment facility receive in terms of domestic and non-domestic flow? Did the receiving stream Water Quality Standards impact my permit? Are the local limits allocated uniformly to all industries? If not, why and what are your limits? February 24, 2014 33

Click QUESTIONS to edit Master INDUSTRY title style SHOULD ASK What is the public participation procedure in your city? Can I look at Discharge Monitoring Reports (DMRs) and annual pretreatment reports submitted by the city to the state? Did the city s stormwater issues impact my permit? Are there any new industries coming in? If so, how does it impact my limits? Can a contractor be used to administer the Industrial Pretreatment Program? Are there any qualifications required? February 24, 2014 34

Click to edit Master title style HOW CAN YOU HELP YOURSELF? February 24, 2014 35

Click HOW to CAN edit Master YOU HELP title style YOURSELF? Regularly check: Your effluent numbers Your discharge flow Lab reports Your treatment process Alternatives to decrease flow and concentration discharging to the treatment plant Effluent numbers discharging from the City February 24, 2014 36

Click HOW to CAN edit Master YOU HELP title style YOURSELF? Obtain data submitted by POTW on Local Limits Review conditions in your Industrial User Permit Have a copy and review City s Sewer Use Ordinance Have a copy of the city s KPDES Permit and understand the applicable limits in the Permit Comment on Local Limits, during the Public Notice February 24, 2014 37

Click IMPORTANT to edit Master POINTS title style TO BE NOTED Local Limits re-evaluation and implementation schedule To address the issues that arise from chronically occurring Sanitary Sewer Overflows, Division of Water may require Cities to develop and implement a Sanitary Sewer Overflow Plan(SSOP) Elements of SSOPs: Sewer Overflow Response Protocol (SORP); Capacity, management, Operation and Maintenance Program (CMOM); Or other actions deemed necessary by Division of Water February 24, 2014 38

Click to edit Master title style QUESTIONS?? February 24, 2014 39

Click to edit Master title style THANK YOU from Smith Management Group www.smithmanage.com LEXINGTON 859-231-8936 LOUISVILLE 502-587-6482 February 24, 2014 40