Protecting POTWswithout a Formal IPPMichigan Water Environment
AssociationAnnual Conference
June 2013Curtis M. Goodman
Marquette Area Wastewater Treatment Facility
Jerald O. Thaler, P.E.Fishbeck, Thompson, Carr
& Huber, Inc.
AgendaThe Marquette Area Wastewater
Treatment Facility (MAWTF)Our ChallengeIndustrial Waste Control (IWC)
ProgramProgram ImplementationProgram ProceduresPerspective
The MAWTFOwned by City of Marquette,
Marquette Township, and Chocolay Township
Operated by City of Marquette3.85 MGD design; 2.7 MGD current88 miles of separated sanitary sewer,
with 11 lift stationsHistory:
1869 Initial Collection System 1953 Primary Plant 1978 Secondary Upgrade #1 (RBC) 2008 Secondary Upgrade #2 (AS
with nitrification and Bio-P)
The MAWTF
Our ChallengeReceived request to accept nondomestic
waste Power plant ash pond leachateGroundwater remediation project
Available capacity; desire to help local economy
IPP not currently required by NPDES permit“It is understood that the permittee does not receive the discharge of any type or quantity of substance which may cause interference with the operation of the treatment works; and, therefore, the permittee is not required to immediately develop an industrial pretreatment program in accordance with Section 307 of the Federal Act.“
Our ChallengeResponsible for protecting collection
system, treatment plant, and worker health/safety
Develop IPP? More regulations More manpower and costs
Desired alternative Informal IPP, but similar technical basis Streamlined procedures No major changes to Sewer Use Ordinance
ObjectiveProtect MAWTF from effects of nondomestic
pollutants without formal IPPApply basis for local limits
Pollutants of ConcernMaximum Allowable Headworks LoadingsMaximum Allowable Industrial LoadingsCollection System Limitations
Marquette IWC Program
Potential Effects of Nondomestic Pollutants
Michigan Department of Environmental
Quality
Pollutants of Concern (POCs)MDEQ-recommended for IPP
Typical compatibles:BOD, TSS. Total-P, Ammonia, FOG
Typical toxics:As, Cd, Cr, Cu, CN, Pb, Hg, Mo, Ni, Se, Ag, Zn
Site-Specific Metals from power plant ash pond leachate Organics from groundwater remediation
project
Maximum Allowable Headworks Loadings (MAHLs)
Not-to-exceed total pollutant mass to plantCalculated via headworks loading evaluation
Basis of Design NPDES/Rule 57 pass-through Sludge quality Biological inhibition
Highly site-specific
Maximum Allowable Industrial Loadings (MAILs)
Not-to-exceed pollutant mass to plant from nondomestic sources
MAHL
Collection System Limitations CSLs)Not-to-exceed pollutant concentration to
sewer Calculated via scientific literature and
experience Flow obstruction Fire/explosion Toxic fumes Structural corrosion
City of Mount Clemens, MI
Courier-Journal Louisville, KY
IWC ImplementationPretreatment currently required,
where necessary, by Sewer Use Ordinance
Integrate into existing trucked waste policy Redefine “transported” waste Update procedures with new technical
basis Already includes cost recovery provisions Already subject to MDEQ approval and
audits
IWC Procedures
IWC ProceduresSampling/analysis of POCs (by
Generator)Set maximum allowable flow rate (by
MAWTF)
IWC ProceduresDischarge plan (by Generator); must
be satisfactory to MAWTF
IWC ProceduresApproval (by MAWTF)
IWC ProceduresAcceptance (by Generator)
IWC Cost RecoveryFees for process wastes
$0.10 per gallon (local) $0.13 per gallon (non-local)
Fees for groundwater remediation disposal and rinse waters $0.0914 per gallon
Generator responsible for sampling/analysis and any transportation costs
So Far, So GoodReasonable manpower and cost
burdenMinimal effect on operations,
discharge quality, and sludge qualityImproved communication between
MAWTF staff and nondomestic usersNondomestic discharges yet to be
regulated Hospital
PerspectiveEven if no IPP, responsible for
protecting: Collection system Treatment plant Worker health/safety
Informal IWC can be an effective alternative for smaller communities with limited resources
Technical basis similar to IPP Need site-specific headworks loading
evaluation
Thank you.
Any questions?
Jerald O. Thaler, P.E.Fishbeck, Thompson, Carr & Huber, Inc.
5913 Executive Drive, Suite 100Lansing, MI 48911
(517) 887-4080 / [email protected]
Curtis M. GoodmanMarquette Area Wastewater Treatment Facility
300 West BaragaMarquette, MI 49855
(906) 228-0486 / [email protected]
For further information, feel free to contact us:
