Pollutant Minimization Plans

Carol Injasoulian

Lab/Industrial Pretreament Manager

City of Bay City

27 September 2018

Waste Prevention Hierarchy

The goal of the PMP is to reduce the POTW’s effluent discharge of the target

pollutant, and to meet (as soon as is practicable) the water quality based

effluent limit (WQBEL) for that pollutant

PMP Goal/Objective

Identification of potential pollutant sources contributing to discharge levels

Reasonable, cost-effective activities designed to reduce or eliminate pollutant loadings from identified sources

Tracking source reduction implementation & source monitoring

Monitoring the POTW’s treatment processes

Resources and staffing

Implementation of cost-effective control measures for pollutant contributors

PMP Important ElementsProgram Plan (1 of 2)

Initial PMP will require approval from MDEQ, after that, an annual status report will be required which includes

A list of potential sourcesA summary of actions taken to reduce or eliminate pollutant dischargesPollution source reduction implementation, source monitoring results, Annual Plant sampling results Proposed adjustments to the Program Plan

PMP Important ElementsProgram Plan (2 of 2)

Potential Sources Evaluation (1 of 5)

Potential Sources Evaluation (2 of 5)

Background Pollutant Loading

Rainfall Stormwater (if combined system or Inflow/Infiltration is

suspected) Receiving water (Upstream & Downstream of Facility

Discharge point/points) Historical Data Tap Water

** Especially important with ubiquitous pollutants and pollutants with ultra low level limits

Potential Sources Evaluation (3 of 5)

System Potential Pollutant Loading

Industrial Districts Commercial Districts Interceptor Sampling Untouchables/Self regulating Residential Sampling POTW Plant Chemicals / Processes Other (Retention Treatment Basins,

Marinas, locally unique districts) if applicable

Potential Sources Evaluation (4 of 5)

Known & Potential Sources

ID known and potential local sources of the pollutant by group (Internet searches, Regulatory Guidance Documents)

Previously Collected Data Facility Provided Chemical Inventory Lists

** Create a source tracking map which annotates all known and potential sources

Potential Sources Evaluation (5 of 5)

Determine & Implement Control Strategies (1 of 2)

Program Plan next should describe the POTW’s prioritized approach for development of Control Strategies POTW Process control POTW Response Plan for when the pollutant is detected

Best Management Practices (BMPs) Best Available Technologies (BATs) Best Control Technologies (BCTs) Pollutant Chemical Alternatives (if available) Facility Process Control Study

Best Approach is to require the polluting Facility to implement it’s own PMP and submit progress reports, which can be nested into your annual PMP report

Public Education Plan Inflow and Infiltration Reduction

When the discharger can be reasonably expected to be in compliance with the WQBEL, then the PMP requirements can be

requested to be removed from the permit.

Where a POTW believes it has identified all known sources of mercury, and has fully implemented control strategies (within it’s authority) with respect to those sources, yet remains unable to meet the WQBEL, it should document those findings in its annual

reports, and revise subsequent program plans accordingly

When is a PMP Completed?

Lessons Learned (1 of 4)

Ultra Low Limits & Ubiquitous pollutants require careful management (Cu source identification study, sampling and sample handling to prevent contamination and false high results) Historical Background levels will not be accounted for Blank Subtraction is not allowed by regulatory community

PMPs are a marathon not a sprint Good research can be enlightening (Copper Sulfate Dosing to

control swimmers itch in recreational lakes & Antifouling Paint) Never forget to determine your residential and drinking water

loading (Cu, Pb, formeldahyde)

Lessons Learned (2 of 4)

Address Public Education and it’s role in pollution reduction If the method changes and a new lower detection limit is

determined, you may be required to implement a PMP for a pollutant you have already minimized

Failing to sample your plant process and removal capabilities is short sighted and highly not recommended (all plants are unique)

If you suspect that you are not going to be able to meet the WQBEL, start requesting help from your regulators in your plan (Coal Fired Plants, Dental Amalgam rule)

Lessons Learned (3 of 4)

Form partnerships with stakeholders (trade associations, industrial or commercial representatives, local solid and hazardous waste officials, municipal and county health officials, POTW treatment plant, pretreatment staff, engineering, collections environmental or other public interest organizations, technical assistance providers, academics, equipment vendors, analytical labs

This should be a collaboration effort between POTW Operators, Lab Staff, IPP staff, engineering, and collections systems staff, streets, sanitation, parks, etc …

Any others … ??????

Lessons Learned (4 of 4)

The Past

The FuturePrevention

Minimization

Reuse

Recycling

Energy Recovery

Disposal

Waste Prevention Hierarchy Changing the Paradigm

https://www3.epa.gov/npdes/pubs/pt_region5_mercury_pmp_guidance.pdf

Reference This resource was loosely used as the basis for this presentation and far more detailed, although specific for mercury the program details can be used for any pollutant with a WQBEL that a POTW cannot meet. It originates from our EPA Region 5 Office.