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25th Annual U.S. EPA Region VI Pretreatment Association Workshop Liquid Waste Transporter

25th Annual U.S. EPA Region VI Pretreatment Association Workshop Liquid Waste Transporter Enforcement Stories August 5, 2009 Ms. Erin La Rue Pretreatment Compliance Specialist City of Austin Austin Water Utility. What are the Goals of a Liquid Waste Transporter Program?.

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25th Annual U.S. EPA Region VI Pretreatment Association Workshop Liquid Waste Transporter

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  1. 25th Annual U.S. EPA Region VI Pretreatment Association Workshop Liquid Waste Transporter Enforcement Stories August 5, 2009 Ms. Erin La Rue Pretreatment Compliance Specialist City of Austin Austin Water Utility

  2. What are the Goals of a Liquid Waste Transporter Program? • Protect Publicly Owned Treatment Works • Reduce Sanitary Sewer Overflows • Protect Public Health and the Environment

  3. Levels of Authority • Congress – Legislation – Clean Water Act • EPA – Federal Code of Regulation, Title 40 • TCEQ – Texas Water Code – Vernon’s Civil Statues – Adopts Federal Regulations • Local POTW – Austin Water Utility Wastewater Regulations, Chapters 15-5 and 15-10 of the Austin City Code of Ordinances – Empower Rulemaking: Implement and Interpret TX & US Regulations

  4. Texas Transporter Regulations • Texas Administrative Code, Title 30,Part 1, Chapter 312, Subchapter G • Texas Administrative Code, Title 30, Part 1, Chapter 312, Subchapter B • Texas Administrative Code, Title 30, Part 1, Chapter 330, Subchapter A

  5. City of Austin OrdinancesLWT Regulation • City of Austin, Code of Ordinances, Chapter 15-5 Private Sewage Facilities, Article 2 Liquid Waste Haulers. • City of Austin, Code of Ordinances, Chapter 15-10 Wastewater Regulations, Article 9 Regulation of Liquid Waste Haulers

  6. Authority and Procedural Considerations • Federal Waste Regulation– 40 CFR Authority to Investigate • LWT Program Procedures Manual • Control Mechanisms: annual permits (explicit and detailed requirements/vary requirements for permittee history of non-compliance), POTW discharge privileges, case-by-case special POTW discharge authorizations process, wastewater service contracts

  7. Compliance Monitoring • Samples are collected from all waste vehicles at the • time of discharge at the POTW by receiving station • Subset of samples are randomly selected daily by • laboratory staff for testing (pH, COD) • Special “emergency” sample bottle kits are kept at the POTW receiving station e.g. Staff notice unusual odors, • colors, etc. (for more extensive tests: FOG’s and Organics) • Detailed information required on manifest ticket for each • separate waste generator load (except chemical toilet • waste, where multiple trips can combine to one load—document • number of toilets serviced on each ticket of combined toilet waste)

  8. LWT Program Violations • Falsifying records or reports • No Manifest Trip Ticket • Illegal Discharge • Operating Without Current Annual Permit/Annual Vehicle Inspection • Other Ordinance Violations • History of Non-Compliance

  9. LWT Investigations • Illegal dumping by Liquid Waste Transporters Most likely to occur at: - Manholes - Large Grease Traps (2000 gal. or larger) - Creeks, Lakes, Watersheds - Storm Sewers - Cleanouts - Treatment Facilities (direct slug to POTW) - Package Plants (haulers with access) - During transport (open valve slightly)

  10. “Ideal” LWT Compliance Case • Educate Public—Observe & Report • Ability to respond at the time/location witness reports violation occurring • Obtaining time/date stamped still photos and/or video (no audio) • Obtaining sufficient detail (license plate, suspect physical description) on a signed witness statement • Obtaining valid suspect identification (line-up recognition)

  11. Illegal Dumping?

  12. Assisting Other Environmental Law Enforcement Investigations • What We Can Do For You: - Regulatory Files and Permits - Provide Technical Knowledge of Wastewater Operations and Standard Industry Practices - Provide Scientific Knowledge - Sampling Methodology (Standard Methods) - Laboratory Analysis (access – save you $$$) - TV sewer lines (placement of video cameras) - Membership in Local Environmental Task Force

  13. “Real World” Issues • Incident 06/08/09 A liquid waste hauler may not knowingly accept and transport a hazardous waste §15-5-24 (B) Prohibition Hazardous Wastes (EPA definition) Sample collected correctly Valid Chain of Custody Gas Detector Alarm Records Gas Detector Calibration Records Complete Witness Statement Multiple Witnesses—Coherent Picture Plant Flow Schematics

  14. Overview • What are our goals? • How can we improve our local regulations? • How can we utilize existing resources (people, equipment, media coverage)? • Elements for pursuing legal action? GOOD LUCK!!

  15. Erin La Rue Pretreatment Compliance Specialist erin.larue@ci.austin.tx.us Tel: (512) 972-1060 Fax: (512) 972-1260

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