TYPICALVILLE

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TYPICALVILLE

• An Introduction to Pretreatment

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Today's Presentation

• Goals of Pretreatment Program
• History of Pretreatment
• Pretreatment in North Carolina
• The Program
• Major program elements
• Files
• Inspections / Guidance / Training
• Summary and Contacts

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Develop and Implement Right Pretreatment Program

• Creating a Pretreatment Program that
• Protects the POTW
• Environmentally sound
• Technically feasible
• Judicially defensible
• There is a delicate balance between these goals
  and protecting the POTW!
• If Program doesnt do what you need it to do,
  change it!
• Too harsh or too weak, causes extra work

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TYPICALVILLE
WWTP
Aeration Basin Digester
River
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History of the Pretreatment Program

• 1972 Clean Water Act
• 1978- Federal Pretreatment regulations
  established
• 1982- EPA approval of the NC Program
• 1983-84 - majority of NC POTW Pretreatment
  Programs approved
• 1987-90 - major revision to NC and Federal
  pretreatment regulations
• 2005 Streamlining of the Pretreatment Program

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Got Pretreatment?

• Publicly Owned Treatment Works (POTWs) required
  to have Pretreatment Program if process
  wastewater from Significant Industrial User (SIU)
  is accepted
• POTW city, town, county, Sanitary District,
  Sewer Authority
• federally owned are exempt

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Got Pretreatment?

• What is an SIU?
• To understand this, first learn -
• What is an IU?
• What is a Pretreatment Program supposed to do?

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Whats an IU?

• User
• Person that discharges wastewater into the
  collection system
• Industrial User (IU).
• broadly intended to cover any User of the
  collection system (and WWTP) that is not a house
• maybe even some houses, too, for example someone
  doing large amounts of commercial cooking in
  their home

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Whats the Purpose of the Pretreatment Program?

• Prevent Pass Through
• clean rivers, groundwater, and land
• compliance with NPDESsludge limits
• Prevent Interference
• properly functioning compliant WWTPs and
  collection systems
• Promote the beneficial use of biosolids
• good sludge for land application or composting
• Protect Worker Health and Safety
• healthy people

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Three Limiting Criteria
Biological Inhibition
Aeration Basin
Influent
Pass Through NPDES and WQS
Nitrification
Aerobic/Anaerobic Digester
Effluent
Sludge Standards Ceiling and Cumulative
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Pass Through cadmium load- based on NPDES
Commercial
NPDES Permit Limit 2 ?g/l equal to NC Water
Quality Std. bec stream flow zero at 10 year
drought (7Q10)
SIUs
NPDES Permit
WWTP
5 MGD 50 RR
Limits
Influent 4 ug/l MAHL 0.1668 /day
Water Quality Standards
Sludge Standards
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Inhibition cadmium load
Commercial
SIUs
NPDES Permit
WWTP Activated Sludge
Limits
1,000 ?g/l (41.7 lbs/ day) Influent to prevent
inhibition
Water Quality Standards
Residential
Sludge Standards
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Sludge cadmium load-based on 40 CFR 503
Commercial
SIUs
NPDES Permit
WWTP 50 RR
Limits
93 ug/l (3.9 lbs/day) Influent to prevent sludge
problems
5 MGD
Water Quality Standards
Sludge Standards- 34 lbs/acre
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Evaluation of the most limiting criteria at the
POTW

• 1) Pass Through Criteria - 4 ug/l
• 2) Biological Inhibition Criteria - 1,000 ug/l
• 3) Sludge Criteria - 93 ug/l
• Use the most limiting factor as the Maximum
  Allowable Headworks Load (MAHL)
• MAHL 4 ug/l or 0.1668 lbs/day
• based on passthrough

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Headworks Analysis (HWA)

• We have just performed an HWA, the technical
  basis of the Pretreatment Program!

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What is a Significant Industrial User (SIU)?

• An IU with the potential to cause
• Pass Through (NPDES problems)
• Interference (collection system problems and
  inhibition)
• Bad biosolids
• Poor Worker Health and Safety

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What is a Significant Industrial User (SIU)?

• large manufacturing facilities that discharge
  industrial process wastewater
• small industries such as a little metal finishing
  shop or a textile business
• companies that arent typically considered
  industries such as hospitals or commercial
  laundries

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What is an SIU?

• Significant Industrial User 15A NCAC 2H
  .0903(b)(34)
• gt25,000 gal/day of process wastewater
• gt5 MAHL for any parameter
• covered under Federal Categorical Pretreatment
  Regulations as a CIU
• any facility which the Control Authority or DWQ
  believes has the potential to adversely impact
  the POTW

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Whats a CIU?

• CIUCategorical Industrial User
• A subset of SIUs (all CIUs are SIUs)
• an SIU that is covered by a specific Federal
  Categorical Regulation
• metal finisher
• pharmaceutical

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Whats a non-SIU?

• IU that is not an SIU
• may or may not be issued a local IUP or other
  individual control mechanism

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Pretreatment Program in North Carolina

• 674 Active SIUs (1200 in 1995, 900 in 2003, 784
  in 2005)
• 30 metals
• 17 textile
• 11 food processors
• 5 laundries
• 3.8 pharmaceuticals
• 3.4 OCPSF (Organic chemicals, plastics, and
  synthetic fibers)
• 30 other

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Pretreatment Program in North Carolina

• 113 Active Pretreatment Programs
• 260 local POTW Pretreatment Coordinators and
  consultants
• DWQ/DENR
• Pretreatment, Emergency Response, and Collection
  Systems Unit (PERCS)
• Regional Staff
• Other DWQ and DENR staff interaction

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DWQ Responsibility

• DWQ is Approval Authority
• Delegate DWQs responsibilities for Industrial
  Users under General Statutes to POTW.
• Approve POTWs Pretreatment Program, including
  review of each element and IUP.
• Compliance judgement and enforcement for failure
  to implement Pretreatment Program
• Training and Support!

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POTW Responsibility

• POTW is Control Authority
• POTW is permittee of Approval Authority (DWQ)
• Develop and Implement DWQ approved Pretreatment
  Program
• Control Industrial Users through IUP and SUO
• Perform compliance judgment and take enforcement
  against IUs for failure to comply with IUP and
  SUO

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SIU Responsibility

• SIU is Permittee of POTW
• Controlled by POTW
• Comply with SUO and IUP
• Keep POTW informed of SIU operations, including
  notification of changes before they make the
  change.

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POTWs Role

• POTWs role toward SIUs same as DWQs role
  toward NPDES/Non-discharge permittees
• POTWcollection system like river basin
• LTMP/STMPHWA vs. ambient monitoring network,
  basin plans, level Bs, TMDLs, RPAs
• SUO vs NCGS .0100s .0200s
• Permits, Compliance, Enforcement, Inspections and
  Audits
• PAR to DWQ versus QNCR to EPA
• Goal is same - clean environment

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Pretreatment Regulations

• Federal Clean Water Act
• Federal General Pretreatment Regulations - 40 CFR
  403
• NC General Statutes
• State Administrative Code - 15A NCAC 2H .0900

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Full Program versusModified Program

• Modified Program - 34 Programs
• POTW combined permitted flow of 2 MGD or less AND
  have 3 or less SIUs
• DWQ determines who qualifies
• Short Term Monitoring Plan (once per 5 years)
• submit smaller PAR
• about currently
• Full Program - 79 Programs
• Long Term Monitoring Plan (on-going)
• Full PAR Required

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Major Program Elements

• Sewer Use Ordinance (SUO)
• SIU Permits (IUP)
• Industrial Waste Survey (IWS)
• Long Term Monitoring Plan (LTMP)
• Short Term Monitoring Plan (STMP)
• Headworks Analysis (HWA)
• Allocation Table (AT)
• Sampling and Inspection
• Enforcement Response Plan (ERP)
• Pretreatment Annual Reports (PAR)

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Sewer Use Ordinance (SUO)

• Adopted by the POTWs governing board
• Prohibited discharges
• Gives the POTW the authority to Control Users
• Deny or Halt discharge
• Establish Local Limits
• Issue permits
• Enforce permits
• Issue penalties

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What is a SIU Permit (IUP)?

• IUP Industrial User Pretreatment Permit
• SIU Significant Industrial User
• Like DWQ permits, IUPs are issued under NCGS
  143-215.1
• DWQ Directors authority under NCGS is delegated
  to POTW.
• Purpose is to protect POTW and environment.
• Same format as NPDES permits Includes limits,
  monitoring, reporting, general and specific
  conditions.

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Pretreatment Permits versus Pretreatment Equipment

• SIU definition not tied to whether Industrial
  User (IU) has treatment units
• Not all SIUs have pretreatment equipment, but
  all SIU have pretreatment permits (IUPs)
• Not all IUs (Industrial Users) are SIUs
• Not all IUs with pretreatment equipment are SIUs
• non-SIUs can be issued non-SIU (or local) IUPs

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SUO and IUP

• POTW is Control Authority
• POTW controls what IU discharges and under what
  conditions
• SUO and IUP are Control Mechanisms
• SUO is general control of all IUs
• IUP is individual control mechanism for one
  specific SIU or non-SIU
• If SUO and IUP dont do what you need them to do,
  change them!
• Too harsh, too weak, causes extra work

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Industrial Waste Survey (IWS)

• Survey all industries connected to POTW
• Satellite communities who tells who?
• Determine who needs controlling or regulating
  (who is an SIU)
• Do you know when someone new is planning to move
  to town?
• Or only find out after already here!
• Do you know when an IU or SIU makes a change to
  their process?
• Or only find out after already made it!

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Investigating your Collection System
To the POTW
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Long Term or Short Term Monitoring Plan

• POTW Site-Specific Sampling Plan
• collects data for use in
• Headworks Analysis (HWA)
• WWTP removal rates
• WWTP inhibition criteria
• WWTP influent uncontrollable load
• Local Limits
• NPDES/Non-discharge permit
• Other applications
• Full Programs Long Modified Short Only
  difference is frequency.

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LTMP/STMP Pollutants of Concern (POCs)?

• NPDES Permit Limited Pollutants of Concern
• Sludge Regs- As, Cd, Cu, Pb, Hg, Mo, Ni, Se, and
  Zn
• EPA Required- Cd, Cr, Cu, Pb, Ni, Zn
• SIU IUP Limits- Ag, CN, Chlorides, Fluoride,
  organics
• Not all POTWs have the same POCs
• A POTWs POCs can change over time

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Typical LTMP/STMP Monitoring Locations at a WWTP
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Typical LTMP Monitoring Frequencies

• Full Programs have LTMPLong Term Monitoring
  Plan
• Influent and Effluent - Quarterly
• Aeration Basin- Semi-annually
• Sludge to Disposal- per sludge permit
• Some POTWs do more
• Some POTWs allowed to do less in DWQ approved LTMP

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Typical STMPMonitoring Frequencies

• Modified Programs have STMP- Short Term
  Monitoring Plan
• Influent and Effluent- 4 times once every 5
  years
• Aeration Basin- once every 5 years
• Sludge to Disposal- per sludge permit
• Some POTWs do more

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LTMP/STMP Detection Levels

• Detection levels must be approved by DWQ in
  LTMP/STMP
• Comp Guide, Chapter 4, Appendices 4-A, 4-C, and
  4-D, page 3
• Some POTWs use lower
• Some POTWs allowed to use higher in DWQ approved
  LTMP/STMP

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LTMP/STMP Guidance

• Find yours.
• Understand and follow it.
• Comprehensive Guide, Chapter 4
• Data Summaries - forms on website
• separate column for less than sign
• average, max, and min
• If LTMP/STMP doesnt do what you need it to do,
  change it!
• Too much, too little data, useless data
• Effluent LTMP/STMP date on DMRS
• All pollutants

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Headworks Analysis (HWA)

• Technical Analysis of a WWTP
• Passthru, inhibition, sludge
• Maximum Allowable Headworks Loading (MAHL)
• Maximum Allowable Industrial Loading (MAIL)
• HWA Workshops typically in January February,
  with at least one other during year. PERCS
  specifically invites POTWs with HWAs due, but all
  are welcome!

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Allocating the pollutant load

• Cadmium Allocation

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Allocating Cadmium
0.02502 lbs.day (15 ug/l _at_ 0.2 MGD)
Commercial
0.1084 lbs.day (162 ug/l _at_ 0.8 MGD)
0.01668 lbs./day (1 ugl _at_ 1.89
MGD) combined Uncon.
SIU 2
SIU 1
NPDES Permit
WWTP
0.0834 pounds/ day to meet NPDES Limit
5 MGD
Limits
50 RR
0.1668 pounds/ day Influent
Water Quality Standards
Sludge Standards
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Allocation Table (AT)
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Allocation Table

• SIU IUP limits
• compute pounds/day
• Sum of SIU permitted load
• Compare against the MAHL and MAIL
• No over allocation!
• Find yours.
• Understand it.
• Comprehensive Guide, Chapter 6

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HWA and MAHL

• How can I get a larger MAHL?
• Bigger river
• better removal rate
• site-specific inhibition criteria
• more land for sludge disposal

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Pass Through cadmium load- based on NPDES
Commercial
NC WQS 2 uq/l 7Q10 5 MGD (IWC 50) NPDES Perm
it Limit 4 ?g/l
SIUs
NPDES Permit
WWTP
5 MGD 50 RR
Limits
Influent 8 ?g/l MAHL 0.3336 /day to meet
NPDES Limit
Water Quality Standards
Sludge Standards
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Compliance Judgement

• Is the SIU in compliance with IUP or not?
• Compliance judgement responsibilities and
  required time frames in ERP.

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Sampling of SIUs

• Must be performed per IUP
• 15A NCAC 15H .0908(d) and 40 CFR 403.8(f)(2)(v)
• 40 CFR 136
• DWQ Chain of Custody forms found in Comprehensive
  Guide, Appendix 7-A and B
• Data Summaries
• good detection levels
• separate column for less than sign
• average, max, min, and lbs/day

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Reporting by SIUs

• Must be performed per IUP
• Must submit reports on time
• IUP Part II, 2-sampling reports and 24 hour
  notification of violations
• Most other IUP conditions, including
• Part II, 4 - additional monitoring
• Part II, 7 - pretreatment unit operations
• Part II, 23 - re-application
• Part II, 25 - changes in operation
• Part II, 30 - potential problems
• SIU communicate early and often

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Inspections

• REQUIRED ANNUALLY AT ALL SIUs
• POTW staff goes on-site to SIU to confirm SIU in
  compliance
• Production changes
• Pretreatment Unit operation
• sampling and data summary sheets
• Are they the same as what SIU sent you?
  Especially important if SIU not required to
  submit lab sheets and chain of custody
• Slug/Spill Control Plan needed, followed
• Housekeeping
• Schematic/Diagram in application/permit adequate

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Enforcement Response Plan (ERP)

• Enforcement that is timely, effective, fair, and
  equitable
• Response time for POTWs issuance of Notices of
  Violation, etc.
• Required fines/penalties
• Required follow-up actions
• Enforcement actions must escalate

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Sampling, Inspection, and Enforcement

• Find your IUPs and ERP.
• Understand and follow them.
• Comprehensive Guide, Chapter 6 - IUP
• Comprehensive Guide, Chapter 7 - Compliance
  Judgement, Sampling, and Inspection
• Comprehensive Guide, Chapter 8 - Enforcement
• If IUPs and ERP dont do what you need them to
  do, change them!
• Too harsh, too weak, causes extra work

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Pretreatment Annual Report (PAR)

• Annual Progress Report
• DWQ review of these documents
• Pretreatment vital signs
• accuracy
• compliance judgement
• Complete PAR required for Full Programs
• Modified Programs must submit SIU in SNC info
• Due March 1st. 2 copies to PERCS Unit
• Classes in Jan and Feb of each year

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Files - Organized

• Can you easily find everything?
• Chronological order
• For each major program element (HWA, LTMP, IWS,
  etc.), have file with
• the element itself
• your submittal letter to DWQ
• approval letter back from DWQ
• for SIU related info by SIU-later slide
• Need SIGNED paper copies. For SUO and maybe ERP,
  need documentation of adoption.
• Mark received date on everything!

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Files - Complete

• keep at least 3 years (recommend 5)
• for major elements that are in effect for long
  periods, such as HWAs, IUPs, SUO, keep latest
  version and one before that (6-10 years)
• eliminate / clarify redundant copies
• keep previous versions separate or marked void
• toss draft versions or keep separate marked
  draft
• Categorical determinationforever?

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Files

• For SIU specific files, strongly recommend file
  by SIU rather than by item
• For example, file for each SIU, folders inside
  for different items for that SIU
• IUP, with transmittal letter, synopsis,
  application, and DWQ approval letter
• inspections
• NOVs and SIU responses
• Correspondence, possibly separated by POTW and
  SIU
• Data, possibly separated by POTW collected and
  SIU collected

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Funding

• Fair and Equitable
• Defendable
• Based on actual costs
• Examples
• Permit Charge
• Sampling Cost Recovery Charges
• Administration Charge
• LTMP Charge
• Do you have enough money?

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Pretreatment Implementation Flow Chart
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DWQ Inspections and Audits

• DWQ staff goes on-site annually to POTW to
  perform detailed review of POTWs Pretreatment
  Program
• program elements
• files
• sampling and data summary sheets
• compliance judgement/enforcement
• SIU correspondence
• inspections of SIUs

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DWQ Guidance and Training

• DWQ Guidance - Comprehensive Guidance for North
  Carolina Pretreatment Programs or Comp Guide
• Training
• One-day workshops on PAR, HWA, and coming soon -
  IUPs
• Phone calls, emails, meetings, letters
• Web site
• http//h2o.enr.state.nc.us/percs/

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POTW Support and Training

• POTWs -
• Annual Pretreatment Workshop - presented by
  Pretreatment Workshop Planning Committee
• Pretreatment Consortium - www.ncpretreatment.org
• Voluntary Certification Program
• One on one support

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Summary

• You are now ready (hopefully)!
• Find and read your Pretreatment Program Elements
  in your files
• element itself
• submittal letter to DWQ
• approval letter from DWQ
• especially IUPs, AT, LTMP/STMP, ERP
• Read Comprehensive Guide
• especially Chapters 7 and 8
• Call us with any questions

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Develop and Implement Right Pretreatment Program

• Creating a Pretreatment Program which
• Protects the POTW
• Environmentally sound
• Technically feasible
• Judicially defensible
• There is a delicate balance between these goals
  and protecting the POTW!
• If Program doesnt do what you need it to do,
  change it!
• Too harsh or too weak, causes extra work

67
PERCS Unit Contacts

• Pretreatment, Emergency Response, and Collection
  Systems (PERCS) Unit
• Supervisor Deborah Gore, 807-6383
• Dana Folley, 807-6311 Catawba, Chowan, Lumber,
  New, Roanoke
• Monti Hassan, 807-6314 - Hiwassee, Little
  Tennessee, Neuse, Yadkin
• Sarah Morrison, 807-6310 - Broad, Cape Fear,
  French Broad, Tar-Pam
• email firstname.lastname_at_ncdenr.gov
• PERCS Fax - 919-807-6489
• PERCS Offices - Archdale Building, 13th floor
• NC DWQ PERCS1617 Mail Service CenterRaleigh, NC
  27699-1617
• DWQ Main Number - 919-807-6300