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PRETREATMENT “POTPOURRI”

PRETREATMENT “POTPOURRI”. 2006 Pacific Northwest Pretreatment Conference Martie Groome City of Greensboro NC martie.groome@ci.greensboro.nc.us. TODAY’S TOPICS. SIU Annual Meetings Permit Notebooks North Carolina Pretreatment Certification Program BOD Split Samples Enforcement.

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PRETREATMENT “POTPOURRI”

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  1. PRETREATMENT “POTPOURRI” 2006 Pacific Northwest Pretreatment Conference Martie Groome City of Greensboro NC martie.groome@ci.greensboro.nc.us

  2. TODAY’S TOPICS SIU Annual Meetings Permit Notebooks North Carolina Pretreatment Certification Program BOD Split Samples Enforcement

  3. SIU ANNUAL MEETINGS General Information Annual Meeting “Themes” SIU ANNUAL MEETING TODAY

  4. SIU ANNUAL MEETINGS • All Permitted Industrial Users • Mandatory Attendance by at least one person from each SIU/IU • We provide lunch (for up to 2/SIU) • “If you feed them, they will come (and not complain about it).” • Assigned Seats at Lunch • POTW Tours • “Perfect Compliance” Awards • Framed Certificates

  5. ANNUAL MEETING THEMES • “Your New Permit” (every 5 years) • American Canoe Association Decree • New Enforcement Response Plan • Sewer Use Ordinance Modification • Sampling and Monitoring • Compliance/Significant-Noncompliance • Inspections • NPDES Permit Renewal for POTWs

  6. SIU ANNUAL MEETING THEMES“Your New/Renewed SIU Permit” • Every 5 years when permits renewed • Each permittee must pick up permit in person and sign for it • Signatory Official or Delegated Person • Annual Meeting Begins 30-Day Period for written comments • Review of: • General/Special Conditions • Permit Process

  7. SIU ANNUAL MEETING THEMESAmerican Canoe Association Decree • First “Annual Meeting” was when ACA decree was issued by the court • Review of requirements for City of Greensboro • Penalties for non-compliance with NPDES limits • Asked for help from SIUs • “Is there a Bull’s Eye on Your Back? • Educated SIUs about THEIR 3rd Party Suit Liability

  8. SIU ANNUAL MEETING THEMESNew Enforcement Response Plan • Presentation of New Draft ERP • Complete Revamp of ERP • “Tier System” • Much more detailed • Annual Meeting Opened 60-day comment period on ERP document • Zero written comments received from SIUs/IUs

  9. SIU ANNUAL MEETING THEMESSewer Use Ordinance Modification • Presentation of Draft Document • Changes in Civil Penalty Ceilings • Changes Brought about by PT Streamlining Regulations • Annual Meeting Will Open 60-Day Comment Period on Draft Document • When taken to City Council, can say that major stakeholders were actively involved in process

  10. SIU ANNUAL MEETING THEMESSampling and Self-Monitoring • Self-Monitoring Requirements • “What Does your SIU/IU Permit Say?” • Review of 40 CFR Part 136 • Methods, Containers, Holding Times • Equipment Vendor Presentation • Composite Sampler Operation/ Maintenance • Flow Meter Operation/ Maintenance

  11. SIU ANNUAL MEETING THEMESCompliance/Significant NonCompliance • Compliance with Reporting Requirements • 24 Hour Reporting for Non-compliance, Spill/Slug Load Notification, Report Due Dates • Compliance with Monitoring Requirements • Routine Monitoring, Non-compliance resampling event within 30 days • Compliance with Effluent Limitations • Calculation of Significant Non-compliance • Implications of SNC • How to “sample yourself out of SNC”

  12. SIU ANNUAL MEETING THEMESInspections • How SIU and the POTW can get more out of Annual Inspections • Preparing for Annual Inspection • Changes Since Previous Inspection • Make sure processes are operational • Review of Any Required Plans • Common Deficiencies Found During Inspections • SIU Response to Inspection Report • POTW sends draft report with 2 week comment period-Notify POTW of any errors or omissions • Correct any deficiencies within required timeframe

  13. SIU ANNUAL MEETING THEMESNPDES Permit Renewal for POTWs • Presentation of New NPDES Permit(s) • New Limits [Can POTW meet them?] • New Parameters to Monitor • New Pollutants of Concern (e.g. low level Hg) • New Requirements/General Conditions • Discussion of Impacts on SIUs • New SIU Limits, New Parameters to monitor • Compliance History of POTWs • Problem Parameters • Whole Effluent Toxicity

  14. SIU PERMIT NOTEBOOKS General Information Notebook Contents

  15. SIU PERMIT NOTEBOOKSGeneral Information • Three-Inch Ring Binder with 10 Tabs • “Greensboro Water Resources” on Spine • Picked Up In Person at Annual Meeting • Signatory Official or Delegated Person • Must Be Maintained by SIU Contact • Available during Inspections • No Longer any excuses….. • “I didn’t know the SUO required that…” • “The permit got lost in the mail…” • “My dog ate the permit…”

  16. SIU Permit, Permit Fact Sheet, Local Pollutant Allocations Sewer Use Ordinance Inspection Reports Compliance Letters/SNC Worksheets Enforcement Response Plan Permit Application Plans [Slug/TOMP/PMP] Sampling/Reporting 40 CFR Part 136 Certified Labs List Data Submittal Forms & Certification Stmt. General Correspondence General/Misc. Information Tab Flow Meter Calibrations SIU PERMIT NOTEBOOKSContents:

  17. NORTH CAROLINA PRETREATMENT CERTIFICATION PROGRAM Why Did We Do It? How Did We Do It? What Goals Did We Have? General Information Certification Levels

  18. NC PT Certification Program:Why Did We Do It??? • “The Florida Experience” [1998-2000] • Six NC PT folks attend Florida PT Certification Schools • 5-Day Class [Mon-Thurs = Class, Fri = Exam] • The “dream” begins….. • Survey at 1999 NC Annual PT Conference • “If we build it, will you come???” • Overwhelming Answer….YES!

  19. North Carolina:How Did We Do It? • North Carolina Pretreatment Consortium • Sponsoring Organization [Incorporated Non-profit] of NC Pretreatment Professionals • Dedication of PT Certification Board • Original 6 [and 4 more as of 2006] • City of Charlotte, NC [1st 3 years] • Water Plant Training Center [convenient, FREE!] • SIU Inspection and Sampling Practical

  20. WHY DO IT???What Goals Did We Have? • NC PT Certification Board Goals • Promote Statewide Consistency in Implementation of State PT Regulations • Hiring/Staffing Assistance • Training Assistance to Small POTWs • “I’m all alone in this big, scary pretreatment world” • Networking Opportunities-Peer to Peer • Professional Development • Some cities give bonus for “certification”

  21. NC Pretreatment Certification Program • Stand Alone Voluntary PT Course • Certification Board [Original 6 Members] • All Had Completed 3 Florida levels • Original Authors of All North Carolina Manuals • Developed Instructor Notes/Taught 1st Classes • Held Annually Since 2001 • All 3 Grade Levels have now been held • All instructors must have successfully completed level they are teaching

  22. NC PT CERTIFICATION PROGRAM • Tuition: $250.00 [including exam] • Maximum of 20 students per class • One Week Class [Monday-Friday] • Classes Monday-Thursday • Exam on Friday • Now Held at Hotel in Durham NC • PT Consortium covers cost of instructors hotel rooms, meals, travel, etc. • Levels held simultaneously

  23. PT Program History PT Communications Safety Traffic, pathogens, hazard awareness FOG POTW Treatment Processes Primary, secondary, tertiary Sampling Purpose/preparation PT Sampling Event Sampling and Flow Equipment “Special” Parameters Field Analyses Sampling Practical Troubleshooting PT Math Grade I Topics“PT Sampling Specialist”

  24. Rules and Regulations SIUs Industrial Waste Survey Inspections Industrial PT Processes SIU Permit Process PT Data Review, Validation and Interpretation Compliance Judgment Enforcement Intro Compliance Judgment Practical (SNC by Hand) Grade II Topics“PT Compliance Specialist”

  25. Program Administration (1.5) SUO Multi-Jurisdictional Agreements Federal Categorical PT Standards Hauled Waste Hazardous Waste Headworks Analysis Local Limits Development Plan Review Advanced Enforcement PT Annual Report Special Topics WET, RPA, TMDLs Grade III Topics“Pretreatment Coordinator”

  26. BOD POTPOURRI Split Sample Policy BOD Split Samples BOD Seed Issues

  27. Split Sample Policy • Will Split Samples with SIU anytime • Prior Notice to POTW that split is requested • SIU contact must be present with appropriate sample container(s), Chain of Custody and cooler when POTW staff arrive to “take off” sample • SIU contact will be notified within 30 minutes of arrival of POTW staff

  28. Split Sample Policy • As per State regulations, State certified laboratory must be used for all analyses • Must submit all QA/QC and COC information from sample in order for sample to be considered for compliance • Results averaged if all QA/QC and COC information is accurate and complete

  29. BOD Seed Issues“Polyseed” vs. POTW “Witch’s Brew” • Seed Must be Added to BOD Samples That Do Not Contain Bacteria • Chlorinated effluents, extreme pH values • Some Labs purchase “Polyseed” • Dehydrated “Bugs in a bottle” • Some Labs Make Their Own Seed • “Witch’s Brew” from POTW Sources • You will get different answers from a split sample using different seeds

  30. BOD Seed Issues“Polyseed” vs. POTW “Witch’s Brew” • Polyseed is “generic” bacteria • POTW “witch’s brew” are bacteria from the POTW that treats the WW • Over time POTW bacteria have become acclimated to that particular waste and can break it down more readily…thus BOD will be higher every time! • BUT….Much more indicative of what actually happens in your plant

  31. BOD Seed Issues“Polyseed” vs. POTW “Witch’s Brew” • Split Samples Results are not accepted for BOD for compliance or surcharge purposes unless commercial laboratory uses “site-specific” seed from POTW • Commercial Laboratory must come and pick up “Witch’s Brew” • Greensboro makes seed ~one gallon at a time and freezes it in small containers • Assures consistent seed oxygen depletion • Additional QA/QC check on BOD analysis

  32. BOD Seed Issues“BOD Seed Didn’t Meet Criteria…” • What does that mean? • 18th Edition Standard Methods says: • “The DO uptake of seeded dilution water should be between 0.6 and 1.0 mg/L.” • Seeded Dilution Water DO uptake too high • May or may not be a data issue • Review data and “how high” • Seeded Dilution Water DO uptake too low • Will most likely cause data issues • All BOD samples that were seeded may be low

  33. BOD/CBOD CALCULATION FORMULA BOD/CBOD (in mg/l) = (Initial D.O.- 5 Day D.O.) * 300 mls sample used [After 5 days, sample must have an oxygen depletion of at least 2 mg/l and must have D.O. residual of at least 1.0 mg/l to be considered a valid BOD result.]

  34. BOD CALCULATION: • Given the following information calculate the BOD: • mls sample in 300 ml BOD bottle = 15 mls • Initial D.O. reading = 8.4 mg/l • 5 Day D.O. reading = 4.2 mg/l • Seed correction = 0.7 BOD=(8.4 mg/l - 4.2 mg/l) – 0.7 mg/l * 300 = 15 mls sample 70 mg/l

  35. QC FOR BOD/CBOD • Daily Glucose/Glutamic Acid QC Standard • Should be 198 ± 30.5 mg/l* • Daily Seed Correction • Should be 0.6-1.0 mg/l* • Daily Dilution Water Depletion • Should be < 0.2 mg/l* • Valid Result: Dilution(s) that depletes > 2.0 mg/l of oxygen and has > 1.0 mg/l left after 5 days* *Data Must be “Qualified” if any of these criteria are not met

  36. BOD: “Qualified” BOD Results[Due to Seed Correction – Take 1] ^Note: 3 mls Seed added to each bottle except Seed and Dilution Water Seed Correction not within range of 0.6-1.0 mg/l

  37. BOD: “Qualified” BOD Results[Due to Seed Correction and GGA – Take 2] ^Note: 3 mls Seed added to each bottle except Seed and Dilution Water Seed Correction not within range of 0.6-1.0 mg/l GGA Also Out of Control BOD Average of “Valid” Dilutions = 295 mg/l

  38. ENFORCEMENT Administrative Enforcement Actions Innovative Civil Penalties “Enforcement Consent Agreement”

  39. Administrative Enforcement Actions CTJM HERE • Required PT Training Conducted by SIU Signatory Official for all Employees • Required Attendance By SIU Officials at Training Seminars • NC Pretreatment Consortium Industrial User Training Workshops • Required Attendance at Seminar/ Lecture/CTJM by Greensboro Industrial Waste Section!

  40. Innovative Civil Penalties • Percentage of Civil Penalties Held in Abeyance and Returned IF: • Used for Additional PT/PP Processes/Equipment • Used for Installation of Permanent Sampling and Monitoring Equipment • AND Activities completed within required time frame

  41. ENFORCEMENT CONSENT AGREEMENT • Agreement Between POTW and SIU Concerning Enforcement Actions for SIU Permit/SUO Violations • Purpose: • Both parties agree to “keep the lawyers out” of the enforcement process • Economical and amicable settlement • Timely/Streamlined enforcement actions • Public Document that includes all aspects of the situation, both bad and good

  42. ENFORCEMENT CONSENT AGREEMENT • This is NOT an AO • Strictly an enforcement tool implemented after the fact, not to bring SIU back into compliance • Special circumstances involved • Not for run-of-the-mill violations • Some negotiation between POTW/SIU • What statements will be included in document

  43. ENFORCEMENT CONSENT AGREEMENT CONTENTS • Stipulated Facts • Stipulated Violations • Special Circumstances • Civil Penalties • Calculation of Maximum Potential $$$ • Calculation of Actual Civil Penalty Issued • Directive to Pay Civil Penalty • Final Settlement of Issue

  44. ENFORCEMENT CONSENT AGREEMENT • Keeps a “technical” issue out of the “legal” realm [abyss!] • Promotes future relationship with SIU • Requires good relationship (trust) prior to incident • PT Program continuity important • Documents “BPJ” enforcement decisions

  45. ENFORCEMENT CONSENT AGREEMENT • “The agreements, statements, stipulations, findings and actions taken herein are made for the purpose of settling this enforcement matter economically and amicably and they shall not be used for any other purpose, except for any proceedings to enforce the provisions of this enforcement consent agreement….”

  46. ECA CASE STUDY • Friday, March 27, 1992 [it had to be a Friday, of course!] • POTW Influent pH = 13.0 • PT staff traced problem through collection system trunkline monitoring • Traced to chemical blending company • Inventory engineer near collapse! • “But the tank was full at 5:00 last night…”

  47. ECA CASE STUDY • Verbal Cease and Desist Order Issued • Shut Down until cause identified (3 days) • 20,000 gallons of 50% NaOH to sewer • Murphy’s Law at its finest… • pH meter malfunction for previous 2-3 wks • “Assumptions” by operations staff • NaOH into POTW via air scrubber towers • Tank/valve did not fail • Control system failure

  48. ECA CASE STUDY • Company President sent SIU technical staff to POTW to work for 3-4 days! • Effluent titrations every 15 minutes X 3 days for neutralization operation • Tankers of H2SO4 from another IU • Total kill of biomass • Fish kill for 3 miles downstream…due to low Dissolved Oxygen NOT pH… • Investigated polymer addition for loss of biosolids to effluent

  49. WHAT HAPPENED AT POTW? • Only 1 pH violation for that Friday • ~36 Hour Retention Time at POTW • 3 MG EQ Tank used to divert part of slug • Neutralization of rest of POTW effluent • No other violations • As soon as “slug” passed through POTW, we began “reseeding” from waste activated sludge pipeline connected to other Greensboro POTW • Met Monthly and weekly average limits for BOD, TSS and ammonia nitrogen!!!

  50. WHY AN ENFORCEMENT CONSENT AGREEMENT? • Certain Facts Not Usually Included in an NOV Needed to be Documented • Ultimate in cooperation by SIU • SIU Shut Down cost SIU ~$500,000 • Murphy’s Law • NOVs/$21,514Civil Penalty in document • BPJ Decision by PT Staff • State did NOT issue civil penalty to COG • Fish replacement costs only [paid by SIU]

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