A 25 Year History of Industrial Pretreatment in the City of Fremont

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Industrial Pretreatment Beginning

NPDES Permit of 1982 dictated that an Industrial Pretreatment Program be established by the City to protect the sewerage, POTW (publicly owned treatment works), and receiving stream (Sandusky River) from industrial wastewater pollution.

The City hires Frank A. Thomas & Associates as consulting engineers to develop the “City Industrial Waste Pretreatment Program.”

Industrial Pretreatment Beginning

Frank Thomas & Associates aided the City to develop Chapter 922 of the Codified Ordinance of the City of Fremont, Use of Public Sewers. Goal is for Sewer Use Ordinance to be used as “the vehicle for achieving quantifiable improvements of industrial discharges that would otherwise be detrimental to the POTW and sludge disposal management system.”

Sewer User Ordinance was passed by council as an emergency measure on October 18, 1984.

Industrial Pretreatment Beginning

Industrial surveying begins as all local businesses are required to submit detailed information concerning their operations.

The original roster of Industrial Users (IU) is developed and permits are issued to IU’s.

Substantial correspondence between the City and OEPA, which aided in program development. 1984-1989.

Industrial Pretreatment

In 1990 revisions to the Pretreatment Regulations required the City to develop an implementation schedule, while changes were made to the Reporting and Modification Guidance.

At this time, as per OEPA requests, our Enforcement Management Strategy and Violation Schedule for Civil Penalties (fines) is developed and more fervently implemented.

Industrial Pretreatment

Program Modifications Every five year per our NPDES permit, a

technical justification of our local limits is performed and implemented.

Minor changes made in 2000 that affected the Quarterly IUVR reporting periods, gave City more time to compose the report.

In 2006, OEPA allows City to incorporate program for FSE FOG BMP’s.

Industrial Pretreatment

Program Modifications In 2008, City modifies the industrial

Pretreatment Program to comply with the Streamlinig Rule per the OAC 3745-3.

Changes were made to SUO to include: Slug Control Requirements, BMP’s as local limits, definition(s) of SNC, and a minor change was made to the EMS as it pertains to resampling events.

1ST Program in Ohio on incorporate Rule.

Surcharge Factor Calculation

(AVE BOD x 6) + (AVE TSS x 7.32) + 6336 9750

No record of technical justification on the

origin of the formula. Equates to $0.23/pound of BOD and $0.13/pound of TSS.

Surcharge Factor

Data for Lamson’s Lager Brewery: Average monthly BOD = 1500 mg/l Average monthly SS is = 1500 mg/l. The BOD would be multiplied by 6 and the SS by 7.32,

as indicated in the above surcharge factor formula.

F = (6 x 1500) + (7.32 x 1500) + 6336 = SF of 2.70 9750 If Lamson’s had a calculated monthly sewer bill of $1,000.00 This $1,000.00 would be multiplied by 2.70 with a resultant Final sewer bill of $2,700.00 being assessed.

H.J. Heinz Company

World’s largest manufacture of ketchup and condiments.

Fremont facility built in 1937 and multiple upgrades throughout the years.

Original IU the program and still very active. Pollutants of Concern: BOD, TSS, pH. Average Flow: currently 300,000 gpd, but during

fresh tomato season flows could be over 1 MGD

H.J. Heinz

Process Description: Only pretreatment is pH adjustment with H2SO4 and NaOH. They do have an old “clarifier” that was used

during fresh tomato season, which is now used for catching the first flush of cleanup events and are metered back slowly to prevent slug discharges.

Flow monitoring utilizing Parshall flume. 24 hour pH monitoring

H.J. Heinz

Enforcement History: Several instances of slug load discharges for

both BOD and TSS. pH excursions (limit 6.0-10.0 S.U.) Several Findings & Orders have been issued

over the years, but overall a very good corporate citizen.

Heinz has studied treating their wastewater on site, but has yet to be affordable.

H.J. Heinz

More Heinz Images

The Fremont Company

An original IU that processes raw cabbage into sauerkraut. Simply cut, core, and put cabbage into vats (with salt) to ferment.

One of the largest kraut producers east of the Mississippi River.

Pollutants of Concern: BOD, TSS, pH, and organic acids. Slug loads of kraut juice.

Average flow: annual average 12,000 gpd, during season flow average 33,000 gpd.

The Fremont Company

Process Description: All process wastewater flows through a hydrosieve and is then is pH adjusted with KOH.

Flow measured using Parshall flume. 24 hour pH monitoring.

The Fremont Company

Enforcement History Several instances of BOD and pH violations

and a few slug load discharges due to kraut juice release.

Green Bay Packaging

An original IU that manufactures paper cardboard products, specifically large boxes. Largest customer is Whirlpool Corporation. Pollutants of Concern: Oil & Grease (Total

Petroleum Hydrocarbon), Cu, BOD. Average Flow: 18,000 gpd.

Green Bay Packaging

Process Description: All wastewater flows

to central sump and any oil is removed by a oil-wicking hose and deposited in a waste barrel.

Green Bay Packaging

Enforcement History Several instances of slug load discharges due

to releases of starch. Cu found in green/blue inks caused violations

occasionally, switched to low Cu inks. Oil & Grease violations caused by positive

interference of an amino acid in inks, modified permit to limit TPH.

Green Bay Packaging

Green Bay Packaging

American Municipal Power (AMP)

The AMP Fremont Energy Center (AFEC) is a natural gas combined cycle (NGCC) facility that AMP purchased in July 2011 from FirstEnergy Generation Corp. AMP will supply intermediate power to participating AMP member communities. Intermediate power is energy needed Monday – Friday during the 16 highest demand hours.

AMP Details 707-megawatt (fired) facility (with a capacity of 544 MW as an

intermediate power source) Includes duct-firing that allows an additional 163 MW of

generation during peak demand periods. $500 million transaction closed on July 28, 2011

American Municipal Power (AMP)

AMP Details Continued Categorical IU governed by 40 CFR 423.17 Average flow: Survey estimated 864,000 gpd, but

data shows we are averaging 303,424 gpd. Note: AMP averages 4.0 MGD water consumption

per day with peaks draws of over 5.0 MGD. Interim Permit issued on February 1, 2012, our

newest IU. Pollutants of Concern: Cr, Zn, TDS, Flow. Monitor Flow via Emerson Rosemount mag meters.

American Municipal Power (AMP)

Crown Battery Mfg.

Manufacturer of automotive, industrial, and marine lead/acid batteries.

Original IU and is subject to production based Categorical Standards 40 CFR 461 C for Pb and Cu.

Pollutants of Concern: Pb, Cu, Mo,TDS. Average Flow: 4,000 gpd and is a batch

discharger.

Crown Battery Mfg.

Enforcement History There have been several Findings and Orders issued

for Pb related violations over the years. In July 1993, the City was requested by OPEA to

investigate Pb discharges to the sewer system. Significant Pb deposition found in City sewer and in

December of 1993 during cleaning event, water was not captured and flushed to POTW.

Elevated Pb levels above 40 CFR 503 limits found in sludge resulting in massive cleanup in biosolids inventory.

Crown Battery Mfg.

Enforcement History Cont. Crown Battery paid for the pressing and

disposal of 1,096.63 tons of sludge (1.59 MG) Total cost over $100,000 and $4,000 penalty. Lessons Learned: Keep a watchful eye on the

collection system and capture all resultant cleanup water. “COMMUNICATION!!!”

Crown battery has cleaned sewer twice since this event with no negative impacts seen.

Rexam Beverage Can

Manufacturer of two-piece aluminum cans for the beverage industry, primarily Coke products.

Original IU and is subject to production based Categorical Standards 40 CFR 465.44 D for Cr, Cu, Zn, Fluoride, P, Mn, TTO and TPH.

Originally Stroh’s Container, then American National Can.

Pollutants of Concern: TPH Average Flow: 100,000 gpd

Rexam Beverage Can

Process Description Wastewater primarily the result of can

washing process and treatment includes lime stabilization, sludge dewatering (filter press), and clarification. Also utilize oil/water separator and recover as much as possible.

HF used remove metal oxides in cans, but fluoride ions removed in treatment process.

Krohne magnetic meters record flow.

Rexam Beverage Can

Enforcement History Very few instances of non-compliance, but a

few NOV’s issued for various violations, TPH. PTI (lack thereof) for a extra lamella clarifier.

P.H. Glatfelter

Glatfelter (FKA Mead Paper, FKA MeadWestvaco, FKA Moore Business Forms) has been operating in Fremont since 1985. The company is classified as a converting facility, applying carbonless coatings onto paper so that the resulting product can be used by customers to produce two or more part business forms. An original IU.

The decline of carbonless business forms in favor of computer generated forms has caused the company to diversify into other coating applications such as ink jet and color tinted paper.

P.H. Glatfelter

Pollutants of Concern: Cu, Zn, BOD, TSS and SAS 305*

Average Flow: 3,631 gpd and is a batch discharging IU.

Process Description: Glatfelter has a pre-treatment system for it’s liquid process wastes. It is known as a PACT (Powdered Activated Carbon treatment) system. The system uses specialized bacteria to consume organic wastes. The bacteria cling to particles of carbon. Chemicals are used to “floc” (cause the carbon particles to attract to each other), forming aggregates which, in time, fall out due to their weight.

Plate Setter (Polisher)

P.H. Glatfelter

Enforcement History Occasional NOV’s for various parameters. 2001 Mead Paper begins the use of a solvent

used to keep ink in solution, while encapsulated in carbon paper.

Chemical is identified as SAS 305 and use of solvent occurs before City approval.

POTW notices turbid cloudy effluent with no identifiable causes, (filamentous bacteria).

P.H. Glatfelter

Enforcement History Cont. City begins search for problem by calling and

questioning all IU’s concerning any changes. City finds that similar situation occurred in

Chillicothe, home of another Mead facility, which used SAS 310.

Several meetings were held, including a Show Cause Hearing with representatives from OEPA, ODH, Mead, the City, Nisseki, Ph.D. toxicologist, etc.

P.H. Glatfelter

Enforcement History Cont. Mead issued Findings & Orders issued for

violating SUO and fined $30,000. Required to cease and desist the use of

SAS 305 and/or perform treatablity testing. City ordered by OPEA to perform SAS 305

analyses on sludge, final effluent, downstream Sandusky River, terresstial samples, earthworms where sludge was disposed, etc.

P.H. Glatfelter

Enforcement History Cont. Only two labs in Ohio could perform SAS 305

analysis, Mead and OEPA. A local limits is developed for SAS 305 and a

stringent monitoring schedule is implemented. Mead decided to install Ultrafiltration

Activated Carbon system to remove any residual SAS 305 and switches to a soy based solvent for capsule manufacturing.

P.H. Glatfelter

Enforcement History Cont. Mead cleans collection system of its’ facility

numerous times to remove all traces of SAS 305, but traces remain.

Monitoring requirements for SAS 305 remain in Mead’s permit until 2008.

Lessons Learned: Proper notification to City officials and approval prior to use could have prevented most of this. “COMMUNICATION!!”

Inoac Exterior Products

Automotive spoiler manufacturer that uses ABS (Acrylonitrile Butadiene Styrene) plastic resins in blow molding machinery.

An original IU that has undergone several name changes, Sterling Inoac, Aeroquip Inoac, Eaton Inoac, and current name.

Inoac Exterior Products

Pollutants of Concern: TPH, Acetone/ Isopropyl Alcohol, organic solvents (MEK), Butyl Acetate.

Average Flow: 4,025 gpd Process Description: Oil/water separator, grinding pump all flows to manhole.

Inoac Exterior Products

Enforcement History A few NOV’s for minor violations, TPH. Modified permit to limit TPH instead of Total

Oil & Grease because of wax component found on polishing pads, which were found to be non-detrimental to collection system.

Ludlow Composites

Founded in 1943 in Fremont, Ohio, Ludlow Composites Corporation is a worldwide manufacturer of PVC (vinyl) foams, SBR (synthetic) latex foam rubber and latex foam rubber. An original IU.

Pollutants of Concern: Zn, BOD. Average Flow: 5,595 gpd. Process Description: Settling tanks, flocculation,

Alar sludge extraction, sand polishing filter.

Ludlow Composites

Enforcement History Several Finding & Orders for violations of Zn

and BOD limits. No NOV’s since 2009. Civil penalties (fines) are typically used to

help fix the problem, such as allowing IU to use $ to pay for system upgrades, monitoring equipment, etc.

Historic Industries

According to the Economic Policy Institute, rise in the trade deficit

with Mexico alone since NAFTA was enacted led to the net displacement of 682,900 U.S. jobs.

Historic Industries

Everedy Battery was an original IU that made batteries (AA, AAA, 9V, C, D).

Had a mercury cleanup of sewer system in mid 90’s, no issues at POTW as we learned to plug sewers during remediation events.

Historic Industries

Clauss Cutlery was an original IU that made an assortment of cutting tools.

Categorical IU that also plated tools they made (Ni, Cr) and used organic solvents such as TCE (trichloroethene), viynl chloride, 1,1,1-trichloroethene.

Soils of facility site contaminated with Cr, Ni and TCE and are being remediated.

Historic Industries

Nickles Bakery was an original IU that served as a full service bakery.

Wastewater generated was result of cleanup events

No major violations or enforcement events, but BOD, TSS , and Oil & Grease were pollutants of concern.

Historic Industries

Peter Eckrich was and original IU that made smoked sausages, cold cuts, hot dogs, corn dogs, Vienna sausages, breakfast sausages, bacon, and bologna.

City ordered the installation of a DAF for FOG issues, but closed soon after in 1988.

Historic Industries

Kellogg/Keebler/Sunshine Biscuit was not an original IU, but should have been. Majority of cheese for Cheez-It crackers was

made at this facility. City discovered rancid discharge and began

monitoring. Dairy became largest BOD loader. City required installation of pH neutralization. Kellogg helped pay for IFAS study before

closing facility in 2008. City lost $700K per year in surcharge revenue.

Historic Industries

American Welding & Tank was an original categorical IU that manufactured steel tanks for liquid propane storage.

Deletion of the phosphate tank coating process, which was subject to Federal Categorical Pretreatment Standards 40 CFR 433A, allowed the City to remove AWT for the IU list as they no longer discharge process wastewater to the City sewer system.

Historic Industries

Great Lakes Sugar was an original IU that manufactured sugar from sugarbeets through the following processes: beet slicing and sugar extraction, pulp processing, purification by the addition of lime and CO2, evaporation, crystallization, centrifuging, drying and conditioning.

Used a series of treatment ponds prior to discharge and at times grew organisms that would end up on TSS filters. Coagulation at discharge point helped organism settle in our primary tanks as our POTW is less than 500 yards away.

Historic Industries

Imperial Plating Company was an original Categorical IU that was subject to 40 CFR 413A for their electroplating of common metals.

Pollutants included plating metals Cr, Ni, while Cu and CN were also a concern.

NOV’s, Findings and Orders occurred occasionally, typically for Cr or Ni.

Ceased operation in 2004. (CRO)

Historic Industries

Kelsey-Hayes was an original IU that was a full operation foundry, which supplied the automotive industry with brake discs.

Problems occurred when scrap iron was smelted that contained residual Pb and would cause pollution of both the water and air.

During rain events foundry sand washed to sewers and overloaded our primary tanks. Fixed problem be paving grounds and installing tanks to intercept solids during rain events.

Historic Industries

Seawin, Inc. is an industry that manufacturers pneumatic valves and fittings using brass, aluminum and stainless steel.

Short pretreatment history as Seawin eliminated all process wastewater in 1996.

At times they had problems with Cu, Pb and Zn.

Historic Industries

Eaton Controls was in industry that produced electrical controls for a variety of applications. Soon after passing of NAFTA, facility was closed. Coincidence?

Quikut was an industry that made knives and cutlery products. Metals were the primary pollutants of concern.

Patrick Hueston Dailey

“The Great Lakes are a diamond on the hand of

North America.”