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Got Capacity? A Case for Special Allocation Limits

Got Capacity? A Case for Special Allocation Limits. Jerald O. Thaler, P.E. Previously. Surcharge Rate Updates/A 21st Century Approach (MWEA Administrators Conference, January 2010) Surcharges recover cost of treating extra-strength industrial waste

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Got Capacity? A Case for Special Allocation Limits

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  1. Got Capacity?A Case for Special Allocation Limits Jerald O. Thaler, P.E.

  2. Previously • Surcharge Rate Updates/A 21st Century Approach (MWEA Administrators Conference, January 2010) • Surcharges recover cost of treating extra-strength industrial waste • Rates should be regularly updated to current costs • New methodology based on USEPA software • More accurate O&M cost breakdown • Straightforward calibration • Efficient annual updates For copy of presentation, please e-mail jothaler@ftch.com

  3. Program • Objective Discuss advantages of combining SALs with extra-strength surcharge program • Agenda • The Available Capacity Conundrum • SALs as a Solution • USEPA/MDEQ Position • Implementation • Potential Revenue Impact

  4. IPP Local Limits • Widely successful protecting WWTPs against detrimental effects of industrial wastes • www.michigan.gov/deq

  5. The Available Capacity Conundrum • Many wastewater utilities currently experiencing lower flows and loadings • Magnified by local limits, which are often: • Uniform not-to-exceed concentrations • Applied to all nondomestic users • Difficult to adapt to special needs • Result is available capacity that cannot be accessed and loss of potential revenue

  6. A Solution • Why not more flexible local limits? • Could use available capacity to assist industrial users, thereby promoting local economy • Great match for surchargeable compatibles • Treatable via existing system • Improve asset utilization • Enhance surcharge revenues

  7. Special Allocation Limits • Extension of traditional local limits, with option to assign alternate user-specific limits • Provide the ultimate in flexibility • Rapidly gaining acceptance across MI • Ann Arbor • Bay City • Flint • Genesee County • Lansing • Wyoming

  8. SALs to the Rescue • Dairy-based industry considered locating new facility in community • Requested applicable local limits • Assessed need/cost of pretreatment system • Ended up selecting alternate site in Indiana • Community has available WWTP capacity and interest in increasing surcharge revenues • To improve economic development opportunities in future, now implementing SALs

  9. SALs to the Rescue • Existing landfill facility considering expansion in community • Involved major capital investment • Ongoing issue with ammonia local limits required pretreatment system upgrade • Community has available WWTP capacity and interest in increasing surcharge revenues • To enable treatment to be “subcontracted” to WWTP, now implementing SALs

  10. Traditional Local Limits • MAHL = not-to-exceed mass to protect WWTP • MAIL = portion of MAHL available to SIUs • Uniform allocation of MAIL over total SIU flow

  11. SAL-based Local Limits • Portion of MAIL set aside as reserve • Uniform allocation of MAIL, less reserve, over total SIU flow

  12. USEPA Position on SALs • May select any allocation method producing enforceable local limits which: • Prevent pass-through and interference • Comply with prohibitions in Federal regulations • Subject to review by approval authority

  13. MDEQ Position on SALs • Legal authority in Sewer Use Ordinance • Constraints • Total influent mass cannot exceed MAHL • Total allocated mass, including any septage, cannot exceed MAIL • Assigned limit cannot exceed any applicable collection system limitation • Approvable written procedures

  14. Step 1 – Classify SIUs

  15. Step 2 – Check MAHL/MAIL Status

  16. Step 3 – Select Appropriate SAL

  17. Potential Revenue Impact • As condition of agreement, can use SAL as basis for calculating surcharge

  18. Perspective Got capacity? • Combining SALs with your extra-strength surcharge program can: • Increase asset utilization • Enhance surcharge revenue • Promote local economy

  19. Acronyms • IPP – Industrial Pretreatment Program • MAHL – Maximum Allowable Headworks Loading • MAIL – Maximum Allowable Industrial Loading • MDEQ – Michigan Department of Environmental Quality • O&M – Operating and Maintenance • SAL – Special Allocation Limit • SIU – Significant Industrial User • USEPA – U.S. Environmental Protection Agency • WWTP – Wastewater Treatment Plant

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