HomeMy WebLinkAboutPP_Pretreatment Program Update 2020MWMC Industrial Pretreatment Program Update
Michelle Miranda & Shawn Krueger
July 10, 2020
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To prevent the introduction of pollutants which will interfere with the operation of the treatment plant and collection system.
To prevent the introduction of pollutants which will pass through the treatment works.
To improve opportunities to recycle and reclaim municipal and industrial wastewaters and biosolids.
To protect treatment plant and collection system workers.
To protect the environment.
Federal Industrial Pretreatment Program Goals
SK: Good Morning Commissioners, we’ll start with some background for you… The industrial pretreatment program is a federal program with the following goals:
prevent the discharges of pollutants that can interfere with our operations or pass through to the river, un-treated
improve opportunities to recycle and reclaim wastewater and biosolids
protect workers, infrastructure, and the environment
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Compliance with the federal requirements of 40 CFR 403.8(f)(1)
In Schedule E of the MWMC’s National Pollutant Discharge Elimination System (NPDES)
Model Pretreatment Ordinance and technically based local discharge limitations for industrial users of the MWMC POTW.
Legal Authority
EPA
Clean Water Act
DEQ
NPDES Permit
Model Ordinance
Local Codes
SK: The foundation of the pretreatment program is the legal authority to implement it. The “you shall” comes from the federal statute, the CWA, and it is publicized in the Federal
Code of Regulations Part 403. Then the requirements flow “downhill” if you will, to Oregon State Statutes, our NPDES permit, and to municipal code, locally in the form of a Model Pretreatment
Ordnance, that is incorporated into each city codes.
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Organizational Chart
Intergovernmental agency formed in 1977
Regional WPCF online in 1984
Service area population 220,000
MM: The MWMC formed an IGA with the Cities of Eugene and Springfield in 1977 that laid out the functional processes of the NPDES permit. The COE takes care of the operations side of
the permit and the COS takes care of the administration side. Each city has their own pretreatment programs that function separately under the model pretreatment ordinance. The regional
WPCF went online in 1984 and currently has a service area population of 220K.
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City of Eugene
21 Significant Industrial Users
2 Non-discharging Categorical Industrial Users (NDCIU)
11 NDCIUs not subject to zero discharge limits
739 Food Service Facilities Under a PMP
10 Photoprocessors Under a PMP
113 Dental facilities subject to 40CFR Part 441
22 PMP requirements issued to brewers, wine makers and distillers.
17 Mobile Waste Haulers
MM: IPP’s use an Industrial Waste Survey to identify and locate sources of indirect dischargers aka Industrial Users which may be subject to the Pretreatment Program. IU’s are then
classified into categories: SIU’s and CIU’s are defined as IU’s that discharge 25K GPD or more of process water and/or have a reasonable potential for adversely affecting the POTW,
which are subject to local limits and/or Federal categorical standards; Non-Significant Users, which are subject to local limits and/or General Requirements specific to their business
practices such as FSE’s, photoprocessors, dental facilities, and brewers, wine makers, and distillers.
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Eugene Permitted Industries
MM: These are our permitted industries across Eugene.
SIU/CIU
7 Metal Finishing 433
5 Wood Products
2 Brewery
2 Dairy Products
1 Paint Manufacturer
1 Industrial Laundries
1 In-vitro diagnostic substance manufacturer
1 University
1 other (Hyundai, Hynix, Avago, Arkham Industries)
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City of Springfield
19 Significant Industrial Users
1 NDCIU not subject to zero discharge limits
204 Food Service Facilities Under a PMP
1 Photoprocessors Under a PMP
25 Dental facilities subject to 40CFR Part 441
3 PMP requirements issued to brewers, wine makers and distillers.
SK: This slides shows a breakdown of the permitted facilities located in Springfield which include SIU’s, CIU’s, and Non-Significant Users which are regulated under our PMP and subject
to specific General Requirements.
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Springfield Permitted Industries
SK: These are our permitted industries spread across Springfield.
SIU/CIU
2 Metal Finishing 433, one of which is an NDCIU and no longer discharges process wastewater
2 Organic Chemical manufacturers primarily supporting wood products industry
4 Wood Products
1 Industrial Laundries
1 Bakery
2 Non-dairy frozen dessert manufacturers
3 healthcare facilities. 2 hospitals and one facility primarily engaged in diagnostic testing
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Local Limits / Federal Regulations
Local Limits (R4.0503-B) Specific Restricted Substance Limitations
No industrial user shall discharge wastewater containing pollutants in excess of:
Arsenic, total 0.3 milligrams per liter
Cadmium, total 0.3 milligrams per liter
Chromium, total 2.0 milligrams per liter
Copper, total 1.5 milligrams per liter
Cyanide, total 2.6 milligrams per liter
Lead, total 1.4 milligrams per liter
Mercury, total 0.05 milligrams per liter
Nickel, total 1.7 milligrams per liter
Silica Gel Treated Hexane Ext. Material 100 milligrams per liter
Phenols, total 3.5 milligrams per liter
Silver, total 0.8 milligrams per liter
Zinc, total 1.6 milligrams per liter
or further limitations as may from time to time be ordered by the City Manager, or concentration limits set by any local, state or federal regulatory agency having jurisdiction, whichever
is stricter.
Federal Regulations – 40CFR Parts 405-741
Categorical Industrial User (CIU)
SK: Local Limits are specific to the POTW and apply to all SIU’s in the service area.
POTW’s are required to assess and revise LL’s, if necessary.
LL’s
Protect the POTW
Protect the receiving waters
Improve biosolids disposal options
Protect POTW personnel
Our permitted industries contribute about 1.08 MGD of flow to the plant (~3.0%).
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Sampling and Inspection
1 Inspection/year
Minimum of 2 sampling events per year
Additional sampling and inspections dependent upon compliance history, size of discharge, perceived risk
SK: At minimum, all permitted industries are inspected once a year and sampled twice per year for each pollutant of concern. Additional sampling and inspections may occur depending
on compliance history, volume of discharge and overall risk to the POTW.
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Covid-19 Program Impacts
In March 2020, staff began working remotely in response to Oregon’s statewide “Stay at Home Order”. The following is a summary of impacts:
All city sampling and inspections were put on hold
Review of industry self-monitoring reporting continued
Communication with permitted industries and commercial users remained intact
Training opportunities moved to the virtual environment
Weekly staff meetings were held remotely
Some Significant Industrial Users (SIUs) reported a reduction in business or changing of production hours
No noticeable impacts to flow at the plant from SIU’s
MM: In March, IPP staff from both cities began working remotely in response to Oregon’s statewide stay at home order. During this time, all city sampling and inspections were put on
hold, communication with our permitted industries and commercial users remained intact along with review of SM reports for compliance. There were some SIU’s who reported a reduction
in business or modification of production hours; however there were no noticeable impacts to flow at the plant from SIU’s.
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In addition to the pending streamlining changes, several other activities will impact the IPP and require Commission input. Those include:
Future Necessary Program Activities
Updates to Cities Code and Revisions to Model Ordinance
Local Limits Evaluation and Revision
Revised Fish Consumption Numbers
Willamette Total Maximum Daily Load (TMDL)
MM: Some future changes that will impact our programs and need Commission input include streamlining changes, updates to our ordinance and codes, finalization of our local limit revisions,
and changes to federal and state rules related to fish consumptions numbers and TMDLs on the Willamette River. We are still in a holding pattern with making any changes, until our
NPDES Permit is re-issued (current permit is expired and administratively extended by DEQ)
Legal Counsel has advised staff to hold off on soliciting final public comment and implementation of both major and minor program modifications until the permit is re-issued. The delay
will avoid a situation where we have approved program modifications that the cities are legally obligated to implement without a mechanism to incorporate into the extended NPDES permit,
with the potential of placing the cities in violation of that permit.
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Updates to Cities Code and Revisions to Model Ordinance
SK: Both the Eugene and Springfield Teams are working collaboratively to revise the MWMC’s current Model Ordinance to make updates to our program and to align better with the current
Federal Pretreatment Regulations.
Revisions to the MWMC’s Model Ordinance will not be finalized until our administratively extended NPDES Permit is re-issued.
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Local Limits Evaluation and Revision
2019 Technical Evaluation of Local Limits
Current limits are protective of plant processes
Some changes anticipated to future local limits
MM: In 2019 we completed a technical evaluation of our current local limits. The results of that study indicated that our current limits are protective of our treatment plant processes.
Based on the results of this technical evaluation, staff anticipates some changes to future local limits, but any changes will not be finalized until our administratively extended
NPDES Permit is re-issued.
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NA
Proposed Local Limits Revision
MM: This table is snap shot of what changes we anticipate. The pollutants listed in red would become more restrictive and the ones in green would become less restrictive. The pollutants
in black will either go away such as chromium or become an industry specific limit such as cyanide and phenol.
Red = limits to become more restrictive.
Green = limits to become less restrictive.
Chromium. Other than a few SIUs subject to the metal finishing categorical standard, no SIU has any pretreatment processes that control chromium. Eliminating the local limit for chromium
would still result in SIUs that are subject to the metal finishing standard daily maximum limit of 2.77 mg/L and monthly average limit of 1.71 mg/L to continue to be compliant with
these limits.
Cyanide. The effluent limitations in the metal finishing category are more stringent (1.20 mg/L) than the current local limit. The average headworks loading for cyanide from 2010 –
2018 was 0.98 lbs./day, or approximately 5.6% of the MAHL.
Phenol. Monitoring results from plant influent and effluent are consistently non-detects and sampling from the uncontrolled sources for this study show those sources to also be non-detects.
Proposing a permit specific limit for non-polar oil and grease in place of the 100mg/L limit.
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Revised Fish Consumption Numbers
Fish are nutritious and are an important part of a healthy diet.
However, some fish may contain contaminants at levels that could lead to health problems.
SK: Legislative revision of these consumption rates in Oregon will likely impact mercury limits at the MWMC regional facility. Pretreatment Programs may have to establish revised limits
for industrial dischargers and/or create pollution prevention programs to address this pollutant.
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Mercury
Temperature
Bacteria
Willamette Total Maximum Daily Load (TMDL)
Dischargers to the Willamette River will be required to reduce amounts of:
SK: Under the TMDL, dischargers to the Willamette River will be required to reduce the amount of Mercury, temperature and bacteria going into the sanitary sewer. Pretreatment Programs
may be required to be involved in Mercury and temperature reduction efforts to include expanded PMPs, industrial regulation and other efforts.
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Why Pretreatment?
MM: We share a treatment plant and we live on the river to which the treated water is discharged to. The Industrial Pretreatment Program is designed to reduce the level of potentially
toxic pollutants discharged by industries and other non-domestic wastewater sources into municipal wastewater systems, and thereby, reduce the amount of pollutants released into the
environment from these sources and work to ensure the protection of worker safety, the sewage treatment plant operations, biosolids and water quality.
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Shawn Krueger, Environmental Services Supervisor
City of Springfield
skrueger@springfield-or.gov
541-736-1018
Michelle Miranda, Operations Manager
City of Eugene
mmiranda@eugene-or.gov
541-682-8615
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