LOCAL LIMITS TO ATTRACT & KEEP JOBS

MWEA Biosolids & IPP Joint Conference

Presented by

Richard Grant, P.E.

Carey Bond, P.E.

September 27, 2011

PROPOSED AGENDA

A Better Process for Regulation via Local Limits

Provide Protection for all Public Owned Treatment Works

(POTW) facilities … while

Providing for Industrial & Commercial Needs

PROTECT THE POTW

Provide Protection for all POTW facilities

… COLLECTION AND TREATMENT FACILITIES

1)Determine Pollutants of Concern POCs

2)Collect & Analyze Data

3)Calculate MAHL for each POC

4)Designate & implement the Local Limits

5)Address collection system concerns

LOCAL LIMITS TO KEEP/ATTRACT

JOBS Strike a balance between IPP/Biosolids Compliance

and the Community‟s objectives: JOBS

How do we develop CONFIDENCE in the capacity that

can be offered to industry?

Local Limits Process

Maximum Allowable Headworks Loading (MAHL) Evaluation

Local Limits – with Tiered Allocation

LOCAL LIMITS TO KEEP/ATTRACT

JOBS The Carrot

Mobilize … Your POTW‟s Available Capacity

Currently „hidden‟ with uniform allocation

Re-allocate the „hidden‟ capacity

Everybody gets what they need … but no more

The Stick

New industry also brings new issues

NOVs vs Verbal/pre-emptive warning(s), meetings

Publication of SNC

Elevated enforcement actions

LOCAL LIMITS PROCESS

First Step: Maximum Allowable Headworks Loading

(MAHL) Evaluation

Determine your POTW‟s capacity

15+ parameters (metals, BOD, TSS, ammonia, phos?)

Determine capacity currently used by existing customers

Should be re-evaluated every 4-5 years (permit cycle)

MAHL looks at protecting the POTW from pass-

through, interference & biosolids contamination

“NPDES” Effluent Limits

Rarely Restrictive for Metals

Interference

Pass Through

Industries/Commercial Discharges

NOT Largely Affecting Phosphorus

NOT Affecting MPN Coliforms

Pass- Through Protection?

Metals (e.g. Ni, Cu, CN, Ag)

BOD/TSS Slug Loading (foaming)

“Stuck Digester” pH

UNIFORM

CONCENTRATION

LIMIT

LOWER-FLOW IUs

CONCENTRATION LIMIT

If APPLIED If APPLIED

mg/l mg/l LIMITING CRITERIA

Ag 0.148 Ag 0.54 Ag Digstn Inhib:

As 0.015 As 0.01 As SLDG Dispsl:

Cd 0.011 Cd 0.03 Cd SLDG Dispsl:

CN 0.055 CN 0.13 CN Digstn Inhib:

Cr 0.919 Cr 3.48 Cr SLDG Dispsl:

Cr6 0.232 Cr6 0.91 Cr6 NPDES #:

Cu 0.233 Cu 0.17 Cu Digstn Inhib:

Hg 0.0050 Hg 0.02 Hg SLDG Dispsl:

Hg-wv 0.0002 Hg-wv 0.00 Hg-wv NPDES #:

Mo 0.132 Mo 0.16 Mo SLDG Dispsl:

Ni 0.163 Ni 0.11 Ni Digstn Inhib:

Pb 0.277 Pb 1.05 Pb SLDG Dispsl:

Se 0.017 Se 0.01144 Se SLDG Dispsl:

Zn 1.763 Zn 2.85 Zn SLDG Dispsl:

INTERFERENCE?E.G. DIGESTION INHIBITION

Land Appliation Limits - Frequently Restrictive

Metals: Max. & Cumulative Loadings

Phosphorus: Max. & Cumulative Loadings

BIOSOLIDS CONTAMINATION?

LOCAL LIMITS PROCESS

Second Step: Allocation of MAHL and Local Limits

Don‟t waste the capacity!

Wasted capacity occurs with Uniform Allocation

e.g. Why give every user the same limit for arsenic? For Zinc? etc

Give capacity to only those who need it:

Consider using EPA Process for Tiered Local Limits

Consider using dynamic process modeling

Work with existing and potential industrial and commercial customers to determine their needs

Consider mass based limits

INDUSTRIAL & COMMERCIAL NEEDS

Providing for Industrial & Commercial Needs

Food Processors: BOD5, COD, TSS, Zn, As!

Manufacturing Examples: Zn, Cu, FOG

Pharmaceuticals: BOD, TSS, Zn, Cu

Metal Finishers: Cu, Ni, Cr, Zn

Byproducts: FOG, Zn, COD

Recyclers: FOG, BOD, TSS

Laundries: FOG, TSS

Restaurants: FOG

CONSIDER ALSO COLLECTION SYSTEM EFFECTS

CAPACITY=CARROT…ATTRACT/KEEP INDUSTRY

Permits vs Agreements

How capacity is allocated

BOD/TSS agreements are common for assured capacity

Metals/toxics permit allocation is typical

Allocation is a negotiation process; Once Issued,

Permits are not negotiable

Combined Waste formula, combined capacity from

domestic & industrial

Where it makes sense (e.g. older plants)

A Permit indicating agreement?

Consider adding a signature page for industry “we

agree… “ or “we concur”

MOBILIZE HIDDEN CAPACITY

Historically, POTWs have had ample capacity …

left unused due to UAL method

Examples of unused „left-overs‟

The resident needs a little zinc for dandruff shampoo

… but not for residential electroplating/galvanizing

The food processor needs (unusual) micronutrients,

BOD, TSS … but not copper, nickel or chrome

Why not take the actual needs into account?

TIERED ALLOCATION OF MAHL

Organized by LEAST capability of pollutant control:

Example:

Tier 1 – Residential/small commercial

Tier 2 – Commercial, Large flow/low strength

Tier 3 – Septage or hauled waste

Tier 4 – Low flow/higher strength, industrial,

Categorical industries

MOBILIZE HIDDEN CAPACITY Tiered LLs; identifies both local limits required to

protect environment and hidden, unused

capacities

MOBILIZE HIDDEN CAPACITY A Close Look at Your POTW …

Each POTW is unique for many reasons

MOBILIZE HIDDEN CAPACITY

A Close Look at Your POTW …

Everyone wants a “piece of the pie”

Example for Zinc

9%

16%

3%

14%

8%

50%

Zinc Allocation for Anytown, MI

City Domestic

City Non-Domestic

(Commercial)

Existing SIU

Non-City Customers in

Service Area

Reserve Amount

Leftovers for Future IUs

Comparison of Tiered Local Limits at various Septage Flowrates

0 gpd Septage 12,000 gpd Septage 48,000 gpd Septage 120,000 gpd Septage

TIER 4 LL TIER 4 LL TIER 4 LL TIER 4 LL

Ag 3.62 Ag 3.66 Ag 3.77 Ag 4.0

As 0.226 As 0.222 As 0.209 As 0.180

Cd 0.18 Cd 0.18 Cd 0.18 Cd 0.18

CN 2.07 CN 2.09 CN 2.17 CN 2.34

Cr 21.4 Cr 21.6 Cr 22.3 Cr 23.9

Cu 6.29 Cu 5.87 Cu 4.56 Cu 1.61

Hg 0.0002 Hg 0.0002 Hg 0.0002 Hg 0.0002

Mo 3.8 Mo 3.8 Mo 3.7 Mo 3.63

Ni 2.91 Ni 2.90 Ni 2.86 Ni 2.78

Pb 1.57 Pb 1.51 Pb 1.33 Pb 0.91

Se 0.22 Se 0.21 Se 0.20 Se 0.16

Zn 10.1 Zn 9.8 Zn 8.9 Zn 6.8

12,000 gpd Septage 48,000 gpd Septage 120,000 gpd Septage

UNIFORM Alloc'n UNIFORM Alloc'n UNIFORM Alloc'n

Ag 1.939 Ag 1.939 Ag 1.939

As 0.129 As 0.129 As 0.129

Cd 0.090 Cd 0.090 Cd 0.090

CN 0.972 CN 0.972 CN 0.972

Cr 10.03 Cr 10.03 Cr 10.03

Cu 3.044 Cu 3.044 Cu 3.044

Hg 0.0002 Hg 0.0002 Hg 0.0002

Mo 1.74 Mo 1.74 Mo 1.74

Ni 1.38 Ni 1.38 Ni 1.38

Pb 0.794 Pb 0.794 Pb 0.794

Se 0.152 Se 0.15 Se 0.15

Zn 5.943 Zn 5.943 Zn 5.94

NEW MAHL CALCULATIONS - METALS

JOBS: WHY HERE & HOW...

Big Industry2012 is looking for 100% compliance

with discharge and environmental permits

Global companies need global collaboration and

confidence in day-to-day operations (ISO certification)

Reputation

Why should an industry invest in YOUR

community?

Reliable, scientifically-based, demonstrated capacity

that is available for their use

Fair & equitable allocation of capacity

JOBS: WHY HERE & HOW...

Capacity may be allocated by permit, and

Longer-term Service Capacity Agreement

Industry-friendly approach

Shift in thinking – the “Carrot” and the “Stick”

Risk assessment – „reserve increases w noncompl.‟

Longer term capacity agreements help pay for

operations and improvements

Protect your town from untimely industrial

relocations

CASE STUDIES: DAVENPORT, IA

Initial Local Limits and MAHL were challenged

Uniform Allocation produced VERY low limits

MAHL assumptions refuted & edited

Utilized Tiered Allocation:

“New Capacity” mobilized

New Local Limits were achievable

Win-win solution identified for the POTW and

Industrial Consortium

CASE STUDIES: OSCODA TWP, MI

MAHL evaluation for Septage Receiving

Tiered Allocation for septage metals including

lead, copper, zinc

Acceptable septage volume identified

Developed a Business Model to identify correct

septage charge

Evaluated septage receiving competition

Village could not compete with the Big Tank solution

nearby, halted a $1 million capital expenditure that

would have been a losing proposition

CASE STUDIES: BERLIN TWP, MI

Landfill leachate acceptance evaluation

Metals MAHL indicated leachate could be

accepted

Utilized process modeling to identify

improvements necessary to accept high ammonia

wastewater for an ammonia sensitive outfall

CASE STUDIES: BLOOMINGDALE, MI

Local fruit processor – ready to leave town

High BOD wastewater

Highly seasonal

Service Capacity Agreement was developed

Win-win solution with capital buy-in for industrial

service capacity

New capacity mobilized using MBBR

BOD service capacity allocated to allow for

seasonal component

CASE STUDIES: PLAINWELL, MI MAHL evaluation conducted in 2010/2011

Identified higher industrial limits for 7 of 14

metals, ranging from 2.6-63x higher than

previous local limits

Developed sulfide local limits to protect POTW

Previous Local Limits/Problems

Mill discharged slug of paper whitener

Past toxicity event from metal finisher – too much

nickel killed the digester. LF disposal required for

biosolids. Culpability denied. Negotiations fail.

Win-Win Relationship impossible.

CASE STUDIES: STURGIS, MI

Industry needed to find best method to handle

new high-strength BOD wastewater stream

Industry: reluctant to be „in the wwt business‟

Collaboration/assistance to identify cost

effective options in town

Extensive demonstration

Cost estimates

Service Capacity Agreement

CASE STUDIES: STURGIS, MI

Next Steps?

City‟s Digester was upgraded and is now ready

to accept concentrated food waste

Reduce aeration energy

Generate biogas energy

CAPACITY=CARROT…ATTRACT/KEEP INDUSTRY Compatibles Capacity

BOD/TSS loading at Headworks =expensive

• Capex: $2000-4000/lb BOD capacity

• Opex: aeration energy = 40-45% of total

BOD/TSS loading to biosolids processes?

• Waste-to-Energy (and for Septage)

• Capex: $300/lb BOD capacity

• Opex: minimal energy, potential generation

CAPEX -ANAEROBIC DIGESTION

0.00

0.50

1.00

1.50

2.00

2.50

3.00

0 2 4 6 8 10 12

Cost

$M

/ M

GD

WWTF Capacity (MGD)

F&V Digester Projects Digesters by Others

LET‟S RE-CAP Uniform Allocation Method: can be wasteful

Capacity = necessary for new industrial jobs

Tiered Allocation: mobilizes „hidden‟ capacity

Negotiations are Important: industry needs vs wants

Permits & Service Capacity Agreements: „ink it‟

POTW: You have the Final Answer (authority)!

Ya‟all Keep Ur MAHL (& Local Limits) Current!

CHECK THE MAHL ASSUMPTIONS!It‟s Much Quicker Today to Check Each Effect

NEW INDUSTRY CAUTIONS

Watch: Industries in bad financial conditions

Slug Loadings: intentional or unintentional … these

are an enforcement challenge/prioritize

Exotic or newer products & raw materials

Political eagerness? jobs need to be long-lasting

Biosolids Drying – for Class A reuse

END?

END

BIOSOLIDS DRYING

Biosolids Drying – for Class A reuse

Applicable to any lagoon-use alternative

Cost is about half of land application

Takes 6 to 8 weeks per lagoon per 10yrs

BENEFICIAL REUSE: EPA exemption for use as topsoil at a

construction site

BIOGAS TO HEAT