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Lowering your Surcharges or "Water discharge fees" to a local P.O.T.W.

Contrary to what many industrial or food plants think, the local municipality or P.O.T.W., in general does get excited about spills or high BOD or TSS loading from their pretreatment customers because it means more income to them. A municipality is not out to make a profit. Their goal is to treat the city's water at the lowest cost possible.

A typical cost to a pretreatment customer usually is made up of a number of components. There may be a base charge for flow, then additional charges for TSS, BOD, ammonia or amines. There may be limits on metals or other specific chemistries. If you are a chemical industry, there may be isolated compounds that are limited if they are very hard to break down. Fats, Oil and grease may be a big component, since this can cause foaming and filamentous problems at a municipality. Some other areas that might be of concern include

Corrosives (pH), Flammable or Explosive Materials, High strength Organic Compounds, Hydrogen Sulfide, Solids & Food Waste, High Temperature streams, Dental office waste and mercury.

Actually, to municipalities, many times a pretreatment customer can be a nightmare. Most municipalities are designed for a flow of low BOD and high ammonia. The plant needs to run a very old sludge age in order for their nitrifiers to achieve complete conversion of ammonia to nitrate. When industrial facilities contribute to the incoming stream, the make-up of the influent is quite different. Often times, the BOD is very high, but with occasional swings only. This can interrupt the nitrification cycle, or stop it completely if the BOD is very high and all the ammonia is consumed instead by the carbon bacteria. Some plants do not have to nitrify, and instead have to supplement nutrients if the incoming BOD is high from a pretreatment customer. If there are major swings, additional work to try to control the system must also be performed, additional testing, additional treatment chemicals and increase in sludge that needs to be hauled off all can be a result from wide swings in pretreatment streams.

Bakeries, Food processing, Breweries and wineries, Meat and fish processing, Commercial laundries, Soft drink bottlers,

Dairy products, Landfill leachate, Vac trucks, hospitals, Aquatic animal production, Tanker truck cleaning and car washes or any type of remediation may be some of the types of facilities that are required to pretreat or disclose what they are sending to a POTW treatment plant.

Sewer costs may vary but most average approximately $1.50 per thousand gallons but can range from $0.20 to about $8.00 per thousand gallons. Surcharges for BOD5 could range from $0.025 to up to $3.00 per pound!

Stricter Nitrogen controls due to new TMDL regulations may mean higher surcharges. Great Lakes TMDL Regulations

may impact your effluent treatment program if you are near waterways in this area. Heavy Metal limitations may impact some customers.

Cooling Water Intake Structures CWA §316(b) EPA is developing regulations under section §316(b) of the Clean Water Act. Section §316(b) requires that the location, design, construction and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact.

Final Regulations pertaining to the Pretreatment Program, go to: 40 CFR Part 403 (general pretreatment regulations)

http://www.access.gpo.gov/nara/cfr/waisidx_02/40cfr403_02.html

The EPA now provides a Technically-Based Local Limits Guidance Manual for municipalities that operate pretreatment programs. This manual provides guidance to municipalities on the development and implementation of local controls for discharges of industrial or commercial wastes to sewage treatment facilities. The manual provides technical assistance and guidance on:

While your municipality may include some of their own limitations, they all must follow federal limitations.

Title 40--Protection of Environment Chapter I--Environmental Protection Agency Part 403--general pretreatment regulations for existing and new sources of pollution

The federal government has established discharge limits for specific industries, called categorical dischargers.

Categorical industries include the following:

Aluminum forming Metal foundries, Battery manufacturing, Nonferrous metal manufacturing, Coil coating, Pesticide manufacturing, Copper forming, Petroleum refining, Electrical/electronic components, Pharmaceutical manufacturing,

Electroplating Circuit-board manufacturing, Porcelain enameling Iron/steel manufacturing, Pulp/paper mills, Leather tanning finishing, Wood preserving, Metal finishing, Inorganic chemical manufacturing, Centralized waste treatment

http://www.epa.gov/water/

What is the cost of non-compliance? Costs may include additional surcharges, sampling fees, lab fees, fees for testing, fees for enforcement, fees for administration and violation penalties. Fines: Some municipalities have fines of up to $50,000 per violation per day. Companies with discharge or permit violations are subject to fines of up to $10,000 per violation per day. Dischargers are also liable for any damages and additional costs caused by their discharges.

Noncompliance on a pretreatment permit has sometimes caused municipalities to force a plant to install permanent pretreatment equipment. Costs may include additional handling fees, legal fees, accounting fees, etc. Below is an example from one municipality on some of the types of additional fees that could be added to your bill for pretreatment costs.

Ok, say you are a pretreatment customer, what can you do to make life easier for the municipality? The first thing is to perform analyses and testing to know exactly what you are sending to the POTW so there are no "surprises". Nothing is worse than an "oops" that is found out after the fact than by a warning. Many municipalities know you will have process problems, need to send more sometimes or even have an upset at the plant or a spill. Their biggest concern is knowing what is coming, then they can decide how to react to whatever is being sent to them. Preparation is always an easier route to take than reactionary measures. It may sound relatively simple and easy, but it is very important to the municipality.

Pollution Prevention-any time you can make changes to the existing plant process that can reduce water and waste prior to dischange, the savings will be significantly larger. Some things to consider: Cut waste to reduce Wastewater Surcharges,

implement a waste reduction program, implement a proactive maintenance schedule, recycle and reuse or streams, automation, Grey water reuse, reuse of cooling water, especially if it is non-contact, use high pressure rather than high volume for cleaning surfaces, install automatic control valves, etc.

What are some of the pretreatment options? Sometimes operating an industrial wastewater pretreatment facility can be more or less expensive than discharging raw wastes to the POTW. Obviously an evaluation study of your plants’ waste load and calculation of the treatment cost per pound of waste removed should be performed. Monitoring of the plant to measure water use, waste load discharged, biomass (sludge) produced by the pretreatment facility, and all costs.

Pretreatment costs can be calculated by totaling costs for interest, depreciation, maintenance, labor, biomass disposal, power, and management. These computations can be simplified by entering the data into a computer spreadsheet program that calculates loads, removal rates, efficiencies, running averages, and ratios. To obtain total waste treatment costs, municipal sewer charges and surcharges need to be added to the pretreatment costs.

Some plants install high or low strength segregation systems for individual process lines. This allows low strength process wastewater to discharge to the plant sewer and high strength to be pre-treated at a lower volume. Smaller vessels are needed and pretreatment is more efficient and effective on a lower volume basis with just specific treatment needs.

Flow Equalization- Sometimes something as simple as an Equalization tank can make flows to the POTW even out the flow and to protect against surges or slug loadings that might interfere or be incompatible with the POTW.

Some plants have wide swings in pH, BOD, etc. By simply adding a storage tank for equalization, streams are mixed and flows, pH and/or compounds are evenly mixed and lowered than previously slug feeding toxic or high strength streams. Minimal capital cost is required and no additional monitor and control is usually necessary.

Total Pretreatment may be a variety of pieces of equipment depending upon your plant processes. These may include any or all of the various options available for treatment including water softening, ion exchange, Activated carbon, oil/water separation, sedimentation or Gravity separation, aerobic or anaerobic biological treatment, Chlorination, UV and ozone treatment, sand filtration, and "mixed bed" de-ionization. These types of equipment can be utilized to treat most types of wastewater to meet stringent pretreatment standards or eliminate costly sewer surcharges.

Bioaugmentation- This is one of the easiest and cheapest ways to pretreat almost any stream prior to discharge and significantly impact FOG, BOD, and specific organics on a permit that can cause high surcharges. In some cases an existing tank is converted to a small pretreatment tank. In other cases, a small tank is added to a system to allow for some additional treatment. Bioaugmentation can be simple and accomplished in as little as a few hours and still add significant treatment benefits.

 Sometimes a small holding tank with a recirculation/transfer system is installed. Some plants install larger tanks up to 24 hours holding time with a small recirculating pump for mixing and aeration to allow the bacteria time to grow and multiply. Most bacteria that are used in wastewater degradation have a life span of 20 minutes to 2 hours, so even a small amount of time to allow them to grow and reduce the organics can significantly impact treatment efficiencies. Some people just add bacteria to a wide spot in the line if there is a long pipe leading to a municipality and allow the existing flow mixing, aeration and time to get to the city to actually achieve some BOD degradation. (Municipalities practice this type of treatment daily in lift stations to remove fats, oils and grease, and the principal is the same. Major changes are seen with the addition of a small amount of bacterial products.)

Small daily doses of bacteria are added to many systems. The cost of the bioaugmentation program vs. the savings on a pretreatment surcharge can be significant. Case histories on pretreatment have shown savings up to one million dollars a year!!!

Two food and chemical plants that needed to pretreat prior to a local POTW. Bioaugmentation programs were implemented. At plant #2, COD removal was 24-39% prior to bioaugmentation. After only a few months on the program, the plant was achieving between 70-79% COD removal. Below, a graph of COD reduction at plant #1.

We have worked with many food plants, papermills, a textile mill and chemical plants that have all needed to reduce BOD and TSS prior to discharge to a local POTW. Significant savings have been realized at all plants.

Nutrient addition- Some plants just need to add nutrients such as N and P to supplement the system and make it easier for the bacteria downstream in the biological wastewater treatment plant to achieve degradation of the organics. Work with your local POTW pretreatment coordinator to see how this minor addition of commodity chemicals can significantly help the treatment plant and lower your surcharges. Anytime addition of chemicals or bacteria is added further upstream from the plant, the more efficient the system will be and the more time for degradation. Take advantage of the time the wastewater is in the pipes moving towards the wastewater treatment plant. Biological activity can and does occur in the pipes if the conditions are right.

Beneficial reuse- What are you sending to the wastewater treatment plant? Are there streams at your plant that even though you might consider them waste, they might be a raw component to some other plant or of use elsewhere?

There are numerous government grants, programs, loans and awards for development of a Beneficial Reuse or Recycling program at your plant.

Governor's Awards for Environmental Excellence

Beneficial Reuse options with Environmental Leverage

Pollution Prevention Remaining competitive in the 21st century requires many businesses and organizations to use pollution prevention strategies that maximize production efficiency and minimize waste. Within the last decade, many enterprising companies and local governments have adopted pollution prevention (P2) as an integral part of their operational strategies. The best way to control expenses and liabilities associated with solid waste, air emissions or wastewater is to eliminate the processes and raw materials that created them in the first place. This may include reuse, recycle, preventative maintenance, beneficial reuse options, or just simple changes in good housekeeping practices.

The Office of Pollution Prevention, Federal or state EPA, local DEQ. Waste minimization is one of the focus areas for OPP. EPA’s latest such effort is the National Waste Minimization Partnership Program. This voluntary program encourages results by publicly recognizing and showcasing the source reduction, recycling, and advanced manufacturing accomplishments of member partners who commit to reduce wastes containing the Waste Minimization Priority Chemicals. They provide on their website a databases with rules, regulations, training, software to make it easier for calculations, publications and papers, annual reports, newsletters, fact sheets, etc.

http://www.epa.gov/oppt/opptdb.htm

http://www.epa.gov/opptintr/library/ppicdist.htm

Pollution Prevention Information Clearing House

The awards recognize municipalities and industries, including Tribal Nations and U.S. military commands for demonstrating outstanding technological achievements or an innovative process, method or device in their waste treatment and pollution abatement programs. The objectives of the program are to educate the public about the contributions that publicly-owned wastewater treatment facilities make to clean water; to encourage public support for municipal and industrial efforts in effective wastewater management, biosolids management, and wet weather pollution control; and to recognize communities that go much beyond the minimum needed to meet Clean Water Act requirements.

Awards are presented for outstanding operations and maintenance (O&M) at publicly-owned wastewater treatment facilities, exemplary biosolids management, pretreatment program excellence, stormwater management excellence, and combined sewer overflow (CSO) control program excellence.

http://www.epa.gov/owm/mtb/intnet.htm

INDUSTRIAL WASTE REWARDS AND RECOGNITION PROGRAM
Each year, the Industrial Waste Program recognizes significant industrial users of the sewer system that have maintained an excellent record of compliance with rules and regulations for the previous calendar year.

Awards may be for voluntarily implemented an innovative pollution prevention strategy, significantly updated their pretreatment equipment or methods, significantly reduced the amount of wastes being discharged to the sewers,

or significantly reduced their water use.

EPA Proposes Trading Program to Clean Up America’s Waters; U.S. Environmental Protection Agency has proposed a Water Quality Trading Policy to increase the pace and success of cleaning up impaired rivers, streams and lakes throughout the country. The policy encourages incentives to maintain high water quality where it exists, as well as restoring impaired waters.

Under the proposed policy, industrial and municipal facilities would first meet technology control requirements and then could use pollution reduction credits to make further progress towards water quality goals. In order for a water quality trade to take place, a pollution reduction "credit" should first be created. EPA's water quality trading policy states that sources should reduce pollution loads beyond the level required by the most stringent technology requirements in order to create a pollution reduction "credit" that can be traded.

EPA’s proposed policy is available online at: http://www.epa.gov/owow/watershed/trading.htm.

http://www.epa.gov/owow/watershed/trading/handbook/factsheet.html

Some of these may include

The Clean Water Act Title II - Grants for Construction of Treatment Works (Sections 201-221)

http://www.epa.gov/owm/cwfinance/index.htm

Today, the Clean Water State Revolving Fund (CWSRF) program is recognized as the most successful federal water quality funding program in the nation's history. The CWSRF program, which replaced the Construction Grants program, provides funding for the construction of municipal wastewater facilities and implementation of non-point source pollution control and estuary protection projects. Other wastewater management related funding is available through Water Pollution Control Program Grants for states, Water Quality Cooperative Agreements for states, municipalities and others, and Clean Water Indian Program Grants. EPA also provides assistance when communities wish to explore the privatization of wastewater facilities.

http://www.epa.gov/water/funding.html

Misc. websites

http://www.pollutiononline.com/

http://www.epa.gov/opptintr/p2home/