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Protecting POTWs with out a Formal IPP

Protecting POTWs with out a Formal IPP. Michigan Water Environment Association Annual Conference June 2013. Curtis M. Goodman Marquette Area Wastewater Treatment Facility. Jerald O. Thaler, P.E. Fishbeck, Thompson, Carr & Huber, Inc. Agenda.

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Protecting POTWs with out a Formal IPP

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  1. Protecting POTWswithout a Formal IPP Michigan Water Environment Association Annual Conference June 2013 Curtis M. Goodman Marquette Area Wastewater Treatment Facility Jerald O. Thaler, P.E. Fishbeck, Thompson, Carr & Huber, Inc.

  2. Agenda • The Marquette Area Wastewater Treatment Facility (MAWTF) • Our Challenge • Industrial Waste Control (IWC) Program • Program Implementation • Program Procedures • Perspective

  3. The MAWTF • Owned by City of Marquette, Marquette Township, and Chocolay Township • Operated by City of Marquette • 3.85 MGD design; 2.7 MGD current • 88 miles of separated sanitary sewer, with 11 lift stations • History: • 1869 Initial Collection System • 1953 Primary Plant • 1978 Secondary Upgrade #1 (RBC) • 2008 Secondary Upgrade #2 (AS with nitrification and Bio-P)

  4. The MAWTF

  5. Our Challenge • Received request to accept nondomestic waste • Power plant ash pond leachate • Groundwater remediation project • Available capacity; desire to help local economy • IPP not currently required by NPDES permit “It is understood that the permittee does not receive the discharge of any type or quantity of substance which may cause interference with the operation of the treatment works; and, therefore, the permittee is not required to immediately develop an industrial pretreatment program in accordance with Section 307 of the Federal Act.“

  6. Our Challenge • Responsible for protecting collection system, treatment plant, and worker health/safety • Develop IPP? • More regulations • More manpower and costs • Desired alternative • Informal IPP, but similar technical basis • Streamlined procedures • No major changes to Sewer Use Ordinance

  7. Marquette IWC Program • Objective • Protect MAWTF from effects of nondomestic pollutants without formal IPP • Apply basis for local limits • Pollutants of Concern • Maximum Allowable Headworks Loadings • Maximum Allowable Industrial Loadings • Collection System Limitations

  8. Potential Effects of Nondomestic Pollutants • Michigan Department of Environmental Quality

  9. Pollutants of Concern (POCs) • MDEQ-recommended for IPP • Typical compatibles: BOD, TSS. Total-P, Ammonia, FOG • Typical toxics: As, Cd, Cr, Cu, CN, Pb, Hg, Mo, Ni, Se, Ag, Zn • Site-Specific • Metals from power plant ash pond leachate • Organics from groundwater remediation project

  10. Maximum Allowable Headworks Loadings (MAHLs) • Not-to-exceed total pollutant mass to plant • Calculated via headworks loading evaluation • Basis of Design • NPDES/Rule 57 pass-through • Sludge quality • Biological inhibition • Highly site-specific

  11. Maximum Allowable Industrial Loadings (MAILs) • Not-to-exceed pollutant mass to plant from nondomestic sources MAHL

  12. Collection System Limitations CSLs) • Not-to-exceed pollutant concentration to sewer • Calculated via scientific literature and experience • Flow obstruction • Fire/explosion • Toxic fumes • Structural corrosion • City of • Mount Clemens, MI • Courier-Journal Louisville, KY

  13. IWC Implementation • Pretreatment currently required, where necessary, by Sewer Use Ordinance • Integrate into existing trucked waste policy • Redefine “transported” waste • Update procedures with new technical basis • Already includes cost recovery provisions • Already subject to MDEQ approval and audits

  14. IWC Procedures

  15. IWC Procedures • Sampling/analysis of POCs (by Generator) • Set maximum allowable flow rate (by MAWTF)

  16. IWC Procedures • Discharge plan (by Generator); must be satisfactory to MAWTF

  17. IWC Procedures • Approval (by MAWTF)

  18. IWC Procedures • Acceptance (by Generator)

  19. IWC Cost Recovery • Fees for process wastes • $0.10 per gallon (local) • $0.13 per gallon (non-local) • Fees for groundwater remediation disposal and rinse waters • $0.0914 per gallon • Generator responsible for sampling/analysis and any transportation costs

  20. So Far, So Good • Reasonable manpower and cost burden • Minimal effect on operations, discharge quality, and sludge quality • Improved communication between MAWTF staff and nondomestic users • Nondomestic discharges yet to be regulated • Hospital

  21. Perspective • Even if no IPP, responsible for protecting: • Collection system • Treatment plant • Worker health/safety • Informal IWC can be an effective alternative for smaller communities with limited resources • Technical basis similar to IPP • Need site-specific headworks loading evaluation

  22. Thank you. Any questions? For further information, feel free to contact us: Curtis M. Goodman Marquette Area Wastewater Treatment Facility 300 West Baraga Marquette, MI 49855 (906) 228-0486 / cgoodman@mqtcty.org Jerald O. Thaler, P.E. Fishbeck, Thompson, Carr & Huber, Inc. 5913 Executive Drive, Suite 100 Lansing, MI 48911 (517) 887-4080 / jothaler@ftch.com

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