April 26, 2019 Murray, KY

Ray Kassab, EHS Manager – Catalent BiologicsBob Kahle, Project Director – SES Environmental

Challenges of Wastewater Permitting and Reporting

KY AWMA - Environmental Practitioners’ Workshop

The GoalSES has been providing compliance services to industrial users throughout the country. • The purpose of this presentation is to highlight

the permitting and compliance challenges encountered by Industry and provide guidance to prepare for these challenges in advance…

The Discussion• Wastewater Permitting 101• Ongoing Compliance• Sampling / Monitoring Requirements• Record Keeping & Reporting

Wastewater Permitting (Indirect)1) Who Are You and what do you do?

• Are you a significant industrial user?• Based on discharge flow?• Based on industrial category?• Regulatory authority?

2) Where are you?• Delegated (Approved)

Pretreatment program• Issued / regulated locally• Non-delegated POTW Programs• Regulated by the State

3) Where do you need to go?• Federal Categorical and Local Regulatory Limits

WW Permitting

1. What is your approach?2. What is the relationship between your

business and the government?a) Bottom Up – Legal; POTW/Contractor; or

State regulatory authorityb) Top Down - Political

WW Permitting

Application Process:There are currently 66 approved Industrial Pretreatment programs and 3 developing Industrial Pretreatment programs in Kentucky.

a) Point of Process Dischargeb) Combined Wastestream

WW Permitting

Approved Pretreatment Dischargers to a POTW in KY are regulated under 401 KAR 5:057; Sections 1 through 17

401 KAR5:057Section Section

1. Purpose and Applicability 10. Variances from categorical pretreatment standards

2. Maintenance of most stringent requirements

11. Confidentiality

3. Prohibited Discharges 12. Net-gross calculation

4. Categorical Standards 13. Upset provisions5. Removal Credits 14. Bypasses6. Pretreatment Program

Requirements15. Modification of POTW

pretreatment programs7. Approval/Revision of

Pretreatment Programs16. Pretreatment program

reinvention pilot projects8. POTW approval

procedures/Removal Credits17. “Cabinet” replaces “Director”

9. Reporting Requirements

401 KAR5:057Section Section

1. 40 CFR 403.1 10. 40 CFR 403.132. NWPCA, USC 1251-1387 11. Confidentiality: KRS 224,

10-210, 212, and 2243. 40 CFR 403.5 12. 40 CFR 403.154. 40 CFR 403.6 13. 40 CFR 403.165. 40 CFR 403.7 14. 40 CFR 403.176. 40 CFR 403.8 15. 40 CFR 403.187. 40 CFR 403.9 16. 40 CFR 403.208. 40 CFR 403.11 17. “Cabinet” replaces

“Director”9. 40 CFR 403.12

WW Permitting

Industrial User Permit Determinations:• Significant Industrial User (SIU) which:

§ Discharges >25,000 GPD§ Contributes 5+% of capacity to POTW

headworks, or § Is deemed so by the controlling authority; or

• Categorical Industrial User as prescribed in 40 CFR 403.6

Both often apply!

WW PermittingPretreatment Limitations are based on Pretreatment Standards:• Prohibited Discharges - 40 CFR Part 403.5• Local Limits – typically pH, BOD, TSS, O&G,

ammonia, phosphorus, trace metals• Categorical Pretreatment Standards 40 CFR 403.6

v Effluent Limitation Guidelines (ELGs) 40 CFR Parts 405 to 471§ Pretreatment Standards for Existing Sources (PSES)§ Pretreatment Standards for New Sources (PSNS)

Partial List of CategoricalsFull List: https://www.epa.gov/eg/industrial-effluent-guidelines

WW PermittingProhibited Discharges - 40 CFR Part 403.5• General – No Pass Through or Interference• Specific:

§ Pose an explosion hazard§ Damage to the POTW§ Flow Obstruction§ Excessive Heat§ Anything that emits Toxic Gases§ Trucked or Hauled Pollutants (Can be Permitted)

Permitting

WW Permitting

Local POTW Limits are determined by Headworks StudiesThey are performed every 5 years or when significant changes occur:• Capacity• Additional SIUs and/or CIUs• Changes in regulatory limits

(New Impairment for ReceivingWaters)

WW PermittingTypical Allocation of Local Loadings / Limits –

The User Pie

Residential

Commercial

Industrial

Infiltration

Storm Water

Community Growth

WW Permitting

Industrial User Permit Determinations:• Point source discharge• Combined Wastestream

• When Process Discharge(s) can not be segregated from non-process discharges.

• Industrial dischargers will be assigned the lowestnumerical pollutant limits among:

• Local / ordinance maximums• Federal categorical limits (daily max / monthly avg)• In some cases: Based on past performance

Combined Wastestream Formula:

• CT = alternative concentration limit for the combined wastestream.• Ci = categorical Pretreatment Standard concentration limit for a

pollutant in the regulated stream i.• Fi = avg daily flow (at least a 30-day avg) of stream i to the extent

that it is regulated for such pollutant.• FD = avg daily flow (at least a 30-day avg) from dilution waters.• FT = avg daily flow (at least a 30-day avg) through the combined

treatment facility (includes Fi, FD and unregulated streams).• N = The total number of regulated streams.

WW Permitting

WW PermittingIndustrial User Permit Determinations:It is the responsibility of the permit applicant to provide the information to include:

• Engineering• Production• Sampling, and • Chemical Analysis• ACCURATE maps and facility diagrams!

“… so that the Control Authority can make its determination”

STAY AWAY FROM ESTIMATES!!!

Ongoing Permitting Case Study

Combined Process and Sanitary Wastestreams• Due to utilization of estimates, the zinc limit

could likely be exceeded on Day 1.

Case StudyCase Study Background:Benchtop metal etching of small metal parts (40 CFR Part 433 Metal Finishing Category)

a) Primarily discharged in small batches; 2-35 gallons

b) 1,300 gallons per day vs. Campus discharge > 100,000 gpd, WWTP throughput > 10MGD

c) Jammed Certified Clean Mfg Areas into an office building not designed for production

Case Study

Options:a) Segregation of the process and sanitary

flows is not cost effectiveb) Combined Wastestream Formulac) Relocate the process

Case Study

Points of Contention:a) Dilution Flow determination (Estimated) was

too high. 9,850 gpdb) Process and Non-regulated source

determination was too low. 1,400 gpd• Cooling tower blowdown is a non-

regulated source NOT dilution water.• Sanitary discharge was overestimated

Case Study

Chemical TownBranch WWTP Local Limits (mg/L)

West Hickman WWTP Local Limits (mg/L)

Avg. Daily Category

433 Limits (mg/L)

CWF Avg. Daily CWF

Limits (mg/L)

Based on Flow

Estimates

CWF Avg. Daily CWF

Limits (mg/L)

(Limited Dilution)

Cadmium 0.009 0.032 0.07 0.0088 0.0312

Chromium 2.77 2.77 1.71 0.2161 0.761

Copper 0.42 3.38 2.07 0.2616 0.921

Lead 0.24 0.49 0.43 0.0543 0.191

Nickel 2.39 3.98 2.38 0.3008 1.06

Silver 0.49 0.59 0.24 0.0303 0.107

Zinc 3.24 4.1 1.48 0.1870 0.659

Cyanide 0.18 0.86 0.65 0.0821 0.289

Uncle Joe’s Metal Finishing, Lexington, KY

Case StudyWater Balance A (Water Use)

Case StudyWater Balance B (Outfall Discharge)

Case StudyZinc Mass Balance

Concentration (mg/L)

Pounds/Day Discharge (GPD)

0.119 0.0026 20% Cooling Tower BD0.891 0.0097 74% Metal Finishing

Other Processes0.0375 0.00019 1.5% RO System Reject0.027 0.00009 0.5% Boiler BlowdownTotal 0.0126

0.0005 4% SanitaryBuilding A 24-Hour Composite0.139 0.0131 @ 11,276 GPD

Case Study

Chemical TownBranch WWTP Local Limits (mg/L)

West Hickman WWTP Local Limits (mg/L)

Avg. Daily Category

433 Limits (mg/L)

CWF Avg. Daily CWF

Limits (mg/L)

Based on Flow

Estimates

CWF Avg. Daily CWF

Limits (mg/L)

(Limited Dilution)

Cadmium 0.009 0.032 0.07 0.0088 0.0312

Chromium 2.77 2.77 1.71 0.2161 0.761

Copper 0.42 3.38 2.07 0.2616 0.921

Lead 0.24 0.49 0.43 0.0543 0.191

Nickel 2.39 3.98 2.38 0.3008 1.06

Silver 0.49 0.59 0.24 0.0303 0.107

Zinc 3.24 4.1 1.48 0.1870 0.659

Cyanide 0.18 0.86 0.65 0.0821 0.289

Uncle Joe’s Metal Finishing, Lexington, KY

Case Study - Takeaways

Points of Contention:a) Dilution Flow determination (Estimated) was

too high. 9,850 gpdb) Process and Non-regulated source

determination was too low. 1,400 gpd• Cooling tower blowdown is a non-

regulated source NOT dilution water.• Sanitary discharge was overestimated

We Finally Have a Permit!

REVIEW EVERY WORD & VALUE!!!

… but it is only a draft.

We Finally Have a DRAFT Permit!

• Permittee review period• Best opportunity for changes/corrections• Typically ~30 days• Be on the lookout for it! (hardcopy, email?)

• Public comment period (30 days)• Permitting authority will address each item /

concern• But perhaps not to submitter’s satisfaction

Can Your Facility Comply on Day 1? If not, negotiate a Compliance Schedule

We Finally Have a DRAFT Permit!

Don’t Forget about Surcharge Levels?• Solids (TSS)• Organics (BOD / COD)• Oil & Grease

Can amount to $1,000sper month!

We Finally Have a DRAFT Permit!

… and accidental release prevention plans.

• Slug Control Plan• Toxic Organic Management Plan (TOMP)• SPCC – Oil Spill Prevention (>1,320 gals)

All require ACCURATEmaps and facility diagrams

We Finally Have a Permit!

Your team should:

REVIEW EVERY WORD … AGAIN!

… Now you have to comply.

Ongoing Permit Compliance

Additional parameters of concern:• Flow

§ Methods of measurement§ Backup instrumentation (No Estimates ?)§ Frequency

Additional parameters of concern:• pH/DO

§ Methods of Measurement§ Frequency (Footnotes!)

Permit Compliance

Additional parameters of concern:• Mercury (Method 1631/PPT)

Permit Compliance

Additional parameters of concern:• Nutrients

§ Phosphorous§ Ammonia/Nitrogen

Permit Compliance

Sampling / Monitoring RequirementsSample Types:

• Grab

• Composite• Flow-proportioned• Time-sequenced

Sampling Frequencies• New Permit

Ø Laboratory Samples and Field Measurements§ Weekly for the first 3 to 4 weeks.

Sampling / Monitoring Requirements

Sampling Frequencies• Ongoing

Ø Flow – Once per month to dailyØ Field Measurements – During Sampling

to daily.Ø Laboratory Samples

§ Weekly§ Monthly§ Quarterly§ 2 x per year

Sampling / Monitoring Requirements

Reporting

New PermitCompliance Date Report; 40 CFR Part 403.12(d) – 90 DaysBaseline Monitoring Report; 40 CFR Part 403.12(b) – 180 Days

Reporting

Reporting

Ongoing/Reissue• Periodic Reports – 40 CFR Part

403.12(e)§ Monthly§ Quarterly§ Semi-Annual§ Annual§ …or as requested by the Control

Authority

Reporting

Periodic Non-Compliance• Outside of discharge limits• Omission of data• Missed deadline

Significant Non-Compliance (SNC)1) Chronic – 66% of samples are

greater than a regulatory limit during a 6 month period.

2) Technical Review – 33% of thesamples are 1.2x the regulatory limit (1.4x the limit for a conventional pollutant) during a 6 month period.

3) Failure to attain a compliance within 90 daysfollowing a scheduled compliance due date

SNC Violation Criteria (Cont.)4) Failure to submit a report within 30 days of the

of the due date.5) Failure to accurately report a non-compliance

issue.6) Any violation or group of violations which the

Control Authority considers “significant”

Significant Non-Compliance

Habitual Offenders are Published Annually in the Local Newspaper

Inspections

Inspections

WW Record Retention• WW monitoring data/reports: 3 years (min.) • Sludge analyticals: 5 years (min.)or longer as specified by the regulatory authority

Performance Tracking

SpreadsheetsAdvantages Disadvantages

User Friendly Data Loss

Simple to Update No Reminders

Inexpensive Lack of management notifications

Performance Tracking

Web-Based Systems• Subscription Services

Advantages Disadvantages

Management-to-Field connectivity (mobile devices)

Expensive for tight budgets

Automatic reminders Not all are user friendlyAutomatic notificationsDirect issue of work ordersReal-time recordkeepingMulti-facility managementCost effective – several firms

• Develop a ‘compliance calendar’ for all WW permit requirements• MS Excel, Web-based systems

• Target pollutant discharges at <50% of limit• Provide compliance margin for:

• Process variation• Sampling and Analytical variation

• Conduct monitoring at upstream WW sources• City water can influence pH and metals• Cooling water systems are not ‘clean’ sources• Cafeteria practices can elevate O&G, TSS,

COD/BOD, P, Ammonia

• WW Treatment Tips• O&G inhibits metals removal, and increases BOD• Chelating Agents inhibit metals removal• In-house monitoring of: pH, COD, nutrients,

metals, visual observation of solids• Routinely inspect/clean the compliance sampling

location & equipment. REPLACE TUBING!

Some Known Chelators

• WW Treatment Tips (Continued)• Chemical dosing should be confirmed routinely

(daily+)• pH probes should be checked daily, calibrated

(weekly+), • Arrange for split sampling with agency or if self-

monitoring have surplus sample held at lab

Sleep Peacefully J

• Ensure contract lab knows your permit limits, to receive early alert of elevated level(s)

• Conversion from ‘continuous’ to ‘batch’ discharge can help ensure all WW discharges within limits

Can’t Beat it? Batch it!

• Research Laboratory experienced intermittent Hg spikes in discharge.

• Over 40 lab sinks combine into common sewer

• Consolidation of sinks, changing of sink traps, and cleaning of sewer line was not sufficient

Can’t Beat it, Batch it!Results:• Since low level Hg method requires grab sample, it

was not representative of daily discharge.• Since combined flow was only 500 gpd, feasible to

hold wastewater until Hg analysis is complete. Lessons Learned:• No controls? Call 1-800-UR-BEAT!• Poly tanks, piping, valves, containment - ~$20k• Although facility was prepared to ship Hg

contaminated WW off-site, all batch tank samples in compliance!

Batch, Test, and Release

BatchTank 1

(full, awaitingHg test results)

Batch Tank 2

(filling)

LabWastewater

ToPOTW

Mix Tanks using:1) Air Sparge,2) Electric

Agitator, or3) Recirculation

pumps

Size each tank to hold sufficient volume to ensuretest results returned from lab (e.g. 7 days = 3,500 gal tanks)

SampleTaps

BTR – Large System

Water Preservation & Pollution Prevention Program (WP4)

Key Objectives:1. Ensure that all piping locations and connections are documented

3. Identify all sources of water and users4. Evaluate sources & characteristics of wastewater & storm water5. Evaluate water and/or wastewater treatment operations

• Improve treatment capabilities / efficiencies / control6. Identify & eliminate risk of spills or releases to the environment7. Identify opportunities for improved control (zero discharge, batch/test/release)

• Pave the road for successful water conservation projects

2. Identify & eliminate improper connections

Water Preservation & Pollution Prevention Program (WP4)

Key Deliverables:1. Updated sewer maps (process, sanitary, and storm water) 2. Create Water Process Flow Diagrams (PFDs)

• WW Sources, WWT schematic, & connections to outfall(s)

3. Complete water & mass balances for Pollutants of Concern (POCs)4. Best Practice Recommendations / Continuous Improvement

• Find-It / Fix-Its• Longer-term program / system enhancements

5. Failure Mode and Effects Analysis (FMEA) – Prioritized

• Ray Kassab, EHS Manager, Catalent Biologics– Phone: (812) 336-9286– Email: ray.kassab@catalent.com

• Bob Kahle, Project Director – SES Environmental– Phone: (502) 526-5179– Email: b.kahle@sesadvantage.com