Source Control Planning for Municipal Wastewater System ...

Source Control Planning for Municipal Wastewater System

Permit Compliance

2018 TCEQ Autumn Environmental Conference and Expo

Baltazar Lucero-Ramirez, P.E.

Water Quality DivisionTexas Commission on Environmental Quality

Source Control Approach

Source Control Approach1. Identify pollutant(s) of concern

2. Find sources of pollutant(s)

3. Determine control strategies

4. Set realistic reduction goals

5. Implement strategies

6. Monitor progress

7. Reassess and make adjustments

8. Communicate results

1. Identify Pollutant(s) of ConcernWhat is the concern?

Prohibited discharges into publicly owned treatment works (POTW)?

Excessive wastewater treatment plant (WWTP) loading?

WWTP pass-through or interference?

Texas Surface Water Quality Criteria?

• Whole Effluent Toxicity Failures • Toxicity Identification and Reduction Evaluations• Sludge limits

TPDES permit limit violations?

Prohibited Discharges to POTWs[40 CFR §403.5(b)]

Pollutants which create a Fire or Explosion Hazard

Pollutants which will cause corrosive damage and not below pH 5.0 S.U.

Solid or viscous pollutants in amounts which will cause flow obstructions

Any pollutants discharged at a flow rate and/or concentration that will cause interference

Prohibited Discharges to POTWs[40 CFR §403.5(b)]

Heat in amounts which will inhibit biological activities

Oil, non-biodegradable cutting oil, or products of mineral oil origin in amounts which will cause interference or pass through

Pollutants that cause toxic gases, vapors or fumes within the POTW

Any trucked or hauled pollutants, except at discharge points designated by the POTW

1. Identify Pollutant(s) of Concern

WWTPIndustrial

Commercial

Domestic

Hauled Waste

Other Sources?

Pollutant Sources

1. Identify Pollutant(s) of Concern (cont.)

Why might these pollutants and types of facilities be a concern?

Fats, oil, & grease (FOG)

Mercury

PhosphorusTotal

Dissolved Solids (TDS)

Breweries Food Processors

Metal Finishers

Soap & Detergent

Mfg.

1. Identify Pollutant(s) of Concern(cont.)

“Look for diamonds in your backyard”

Chemicals added to the collection system or WWTP

Hauled waste accepted at the WWTP (grease or grit waste, septic, RCRA, CERCLA)

Illegal dumping

Water or wastewater sludge discharged into the collection system

2. Find Sources of Pollutant

Identify sewer sub-basins in your collection

system

Sample at locations that capture each

sub-basin

Identify sub-basins with

high pollutant contributions Sewer Collection System Sub-Basin Map City of

Folsom, CA

3. Determine Prevention and Control Strategies (cont.)

Public Education?

• Requires dedicated outreach• Sensible to public perception• Continuous effort to maintain

desired behavior change

Suitable for multiple sources difficult to control (domestic)

3. Determine Prevention and Control Strategies (cont.)

• Best Management Practices (BMPs)• Requires meetings, education, and

negotiations• High start-up effort, verification

BMPs implemented

Suitable for sector-specific identified sources

Voluntary Reduction?

3. Determine Prevention and Control Strategies (cont.)

• Requires legal authority (ordinance) and enforcement • See Texas Water Code §26.176

• High start-up efforts to develop and implement

• May include requirements: permits & effluent limits, BMPs, and fees

• Compliance monitoring & inspections

Suitable for contributing industrial sources

Implement a Partial Pretreatment Program?

3. Determine Prevention and Control Strategies (cont.)

Calculate and rank contributions of total loading from identified sources

4. Set Reduction Goals

Determine how much the WWTP can treat

Determine effluent concentration goal (permit limit, water quality standard)

Calculate allowable influent

concentration based on effluent

limit

Where,[L]in = Allowable influent loading

(mass)[C]eff = Effluent limit concentration

(mass/volume)Q = Wastewater flow

(volume/time)RE = Removal efficiency

(design or measured )

𝐿𝐿 𝑖𝑖𝑛𝑛 =𝐶𝐶 𝑒𝑒𝑒𝑒𝑒𝑒 ∗

𝑄𝑄1 − 𝑅𝑅𝑅𝑅

4. Set Reduction Goals (cont.)

• Does the loading from the identified contributing sources exceed allowable influent (headworks) loading or inhibition limit?

• What reduction is needed at the headworks and from each source or group of sources?

• Set realistic reduction goal(s)• Consider a safety factor

Compare loading from sources to allowable influent loading to set reduction goal

5. Implement Strategy

Select the control strategies to be implemented• Consider how progress will be

measured• How will you know if your actions

are successful?• Multiple strategies can be used

(more than one for each type of source)

• Consider implementation period, resource needs, costs, and benefits

5. Implement Strategy (cont.)

Budget

Funding

Buy-in

Cost/benefits

Planning and ImplementingEducation and outreach activities

Meetings and negotiations

Pretreatment program development

Monitoring and evaluating

Communicating results

6. Monitor Progress

Continue sampling

Collection system sub-

basins

WWTP influent and

effluentContributing

facilities

Track compliance or

progress toward goal

Graph data to visualize trends and evaluate

and monitor progress

7. Reassess & Adjust

Are the implemented strategies achieving the

goal (consistently)?

• If not, why not?

Look for additional sources that can be

prevented or controlled

• Have new sources moved into town and not identified?

• Have facilities added new sources?

• Continuously update the list of potential sources

8. Communicate Results

Management

Public

FacilitiesWIFM

Source Control Case Studies

Case Study: WCWD Vehicle Service Facility Pollution Prevention Program

West County Wastewater DistrictEstablished a voluntary pollution prevention (P2)

program

• 46 vehicle service facilities

• 24 discharge wastewater (not permitted, but must comply with local limits in ordinance)

• 22 facilities are “zero” discharge

Case Study: WCWD Vehicle Service Facility P2 Program

West County Wastewater District

Each facility gets BMP

information

Required annual

sampling of Cu, Hg, Pb,

and Zn(at WCWD expense)

Implement BMPs to get free annual

sampling.....or.....

Resampling done at

customer expense

when exceeding local limit if BMPs not

implemented

Case Study: WCWD Vehicle Service Facility P2 Program

19.9

0.5449.9

0.0735.1 0.14

0.0012 0.0002

02468

101214161820

1995 1998

Zinc

Lead

Copper

Mercury

Zinc Lead Copper Mercury

Vehicle Service Monitoring Results for Zn, Pb, Cu, & Hg (1995- 98)

Case Study: 2013 City of Cleburne

Feb. 2013 - POTW failed sublethal WET tests (Water Flea - Ceriodaphnia dubia)

Began investigating potential sources in the industrial park

Sampled sewer system

• Found high selenium levels downstream from an industry, power plant, and the POTW, but no known sources ???

Case Study: 2013 City of Cleburne (cont.)

• Lab started using inductively coupled plasma mass spectrometry (ICP-MS) & helium collision cell

Further investigation revealed false-positive

results for selenium due to bromide interference

Found industry started discharging a

wastestream containing bromide

25% of POTW effluent reused at power plant so

may also elevate bromide levels in influent

Case Study: 2013 City of Cleburne (cont.)

• Conducted study to demonstrate WET failures due to bromide

• TPDES permit and City required industry to not discharge wastestream containing bromide

The City did NOTwant a WET

limit in permit

Brewery Case StudyCity requested assistance

from TCEQ’s Small Business and Local

Government Assistance Program (SBLGA)

Excessive TSS discharge from brewery was

allegedly causing pass through and

interference

Recurring TSS violations and enforcement

action

City’s Industrial Waste Ordinance had a limit for

BOD5 but not for TSS

Brewery installed anaerobic biological treatment:

BOD5 <300 mg/L

TSS measured downstream of

discharge ~ 2,000 mg/L

Brewery Case Study (cont.)

WWTP• Design Flow: 0.85 MGD• Average Flow: 0.35 MGD• Industrial Flow: 0.247 MGD • Hydraulic loading: 30 %

(% design flow)• Hydraulic loading: 70 %

(% actual flow)

TPDES permit was expiring and the renewal application was submitted

Storm Water & Pretreatment Team worked with the City and SBLGA to address the situation.

Brewery Case StudyOutcome

Issued TPDES permit that required implementation of a partial pretreatment program

Conduct industrial

waste surveyUpdate

ordinance

Develop and adopt

technically-based local

limits for conventional

pollutants and metals

Develop enforcement

response plan and

procedures

Source Control and Reduction of Phosphorous

CASE STUDY: 2013 CITY OF SEGUIN

Phosphorus Limit

TPDES Permit Renewal

• POTW effluent samples collected

High Concentration of Phosphorous

• Draft TPDES permit with P limit

City says “No’

• Submit a P reduction study workplan

CASE STUDY: 2013 CITY OF SEGUIN

The phosphorous

reduction study began from 2011 to

2014.

Samples were taken

from different location.

Identified BMPs to

control the source.

CASE STUDY: 2013 CITY OF SEGUINSamples were collected from different locations: IU’s effluentManholes downstream of IU Upstream of WWTP lift station and WWTP influent

CASE STUDY: 2013 CITY OF SEGUINFurther Investigation Results: Narrowed down to two

industrial users (IUs) that discharge to the POTW.

Poultry Processor (PP)Influent Flow: 1 million gallon per day (MGD) • Poultry processing facility• Major source of influent phosphorus

to POTW

Construction Equipment Manufacturer (CEM)Influent Flow: 0.01 MGD• Equipment cleaning• Occasionally having higher

phosphorus concentration than PP

• 12.6mg/L

Average Influent

P

• 14.9 mg/L

Average Influent

P

CASE STUDY: 2013 CITY OF SEGUINActions taken to reduce phosphorus concentration

PP

• Installed a system of pipes, pumps, and tanks to capture the marinade

• Eliminated cleaning products that contain phosphorus (e.g. Trisodiumphosphate)

• Added ferric sulfate to the wastewater treatment process to lower phosphorus levels

CEM

• Reviewed Safety Data Sheets list to identify chemicals that contained phosphorus

• Cleaned out oil-water separators that are used to dump mop buckets and floor scrubbers

• Reviewed correlation of fats, oils, and grease (FOG) levels to phosphorus levels

Phosphorus Source Control Resources

Phosphorus Management Plan Guide (Minnesota Pollution Control Agency, 2006)

Six Municipalities, One Watershed: A Collaborative Approach to Remove Phosphorus in the Assabet River Watershed (EPA 820-R-15-097, 2015)

Summary

• Identify known and potential sources of pollutants of concern

Know your service area and

contributors

• Influent, effluent, and sludge limits for current and draft permits

• Look for trends (anticipate limits)

Be familiar with your TPDES permit

requirements

• Look for trends• If not making progress, ask “why

not?”

Set goals, monitor and evaluate progress, and

reassess strategies

Summary

• Acknowledge past and current efforts

• Justify future efforts

Keep management,

public, & facility sources

informed of activities and

progress

• What was done and how• Dealing with barriers• Lessons learned

Share your knowledge

SOME SECTOR-SPECIFIC RESOURCES FOR:

• Food Processing• Mercury

• Breweries• Phosphorus

Food Processing Source Control Resources EPA Multimedia

Environmental Compliance Guided for Food Processors (EPA 305-B-99-005) http://www.epa.gov/complia

nce/resources/publications/assistance/sectors/multifood.pdf

Minnesota Technical Assistance Program http://mntap.umn.edu/food/

wastewater.htm

Food Processing Source Control Resources

Waste Reduction in Food Processing http://infohouse.p2ric.org/ref/02/01228.pdf

Wastewater Reduction and Recyclingin Food Processing Operations http://infohouse.p2ric.org/ref/24/23261.htm

Meat, Food, and Dairy Processing Industry-Waste Streams & Pollution Prevention http://www.waterboards.ca.gov/coloradoriver/water_is

sues/programs/pretreatment/docs/rev_food_processors.pdf

Mercury Reduction ResourcesMercury-Added Products Found at

Drinking Water & Wastewater Treatment Facilities The Northeast Waste Management Officials’

Association (NEWMOA) http://www.newmoa.org/prevention/mercury/pr

ojects/WWT/Mercury-AddedProductsatWWTPlants.pdf

EPA Dental Amalgam http://www.epa.gov/hg/dentalamalgam.html

Mercury Source Control Resources

Blueprint for Mercury Reduction Guidance for WWTPs Western Lake

Superior Sanitation District

http://www.wlssd.com/WLSSD_Blueprint_Mercury_Reduction.pdf

Mercury Source Control Resources EPA Recommended Management and

Disposal Options for Mercury-Containing Products Consumer products: home items Medical pharmaceutical products Consumer products: automotive parts Commercial products Alternatives to Mercury-Containing Products http://www.epa.gov/mercury/mgmt_options.ht

ml#commercial

Brewery Source Control Resources

Examples of EPA Brewery Inspections http://www.epa.gov/region9/water/pretreatme

nt/files/firestone-brewery-ins.pdf http://www.epa.gov/region09/water/pretreatm

ent/files/sierra_nevada_brewery_2004-10-08_inspection.pdf

Questions?