Mark Kelly, PE Industrial Waste Engineer July 22, 2013
What is The Sewer Use and Wastewater Control Ordinance? Sets requirements for sanitary sewer users Regulates the discharge of pollutants into the collection system Enables the Water Authority to achieve compliance with U.S. EPA National Pollutant Discharge Elimination System (NPDES) and Southside Water Reclamation Plant (SWRP) effluent and sludge limits.
Limitations on Sludge Disposal Injury to Workers Options and/or from Hazardous Greater Fumes Expense Corrosion of Collection System and/or Treatment Plant Explosions Interference with Wastewater Pass-Through of Treatment Facility Toxics into Surface Waters
Why a new Ordinance? A requirement of the new U.S. EPA National Pollutant Discharge Elimination System (NPDES) permit for SWRP
Ordinance Process EPA MODEL PRETREATMENT ORDINANCE Office of Wastewater Management/Permits Division http://www.epa.gov/npdes/pubs/pretreatment_model_suo.pdf Reviewed 40 CFR 403 Pretreatment regulations Reviewed other Publicly Owned Treatment Works (POTWs) Pretreatment Ordinances
Ordinance Process Draft Ordinance Public Participation Meetings Ordinance, ERP, FOG Policy posted online Incorporation of Comments Submitted to EPA by October 1, 2013 EPA has comments or gives certificate of approvability Ordinance posted publicly for one month Water Authority Board approves and incorporates new ordinance
Ordinance Requirement: Fats, Oil and Grease (FOG) Capacity, Management Operations, and Maintenance (CMOM) Plan with an emphasis on FOG policy FOG policy is a re-evaluation of the existing Ordinance Grease Removal System (GRS) Requirements Maintenance Inspections Record Keeping Best Management Practices (BMPs) Enforcement Response Plan 7
Changes From The Previous Ordinance: Fats, Oil and Grease Maintenance: Minimum cleaning every 6 months 25% rule 8
Changes From The Previous Ordinance: Fats, Oil and Grease Clarifies who needs grease removal systems food service establishments, wastewater discharge permit holders, automotive shops, vehicle fueling stations, any other fats, oil, and grease dischargers Clarification of ordinance violations Must use a pumper that is not in violation 9
FOG Policy: Pumper Requirements Complete Evacuation All chambers must be pumped No decanting or discharging of wastewater back into trap Manifests Must be provided Date, time, volume, condition Prohibitions Discharging of unprocessed GRS waste at SWRP Blending 10
Ordinance Requirement: Septage Haulers Discharges: Must be in compliance with Section 3-2-1 Prohibited Pollutants TPH: 100 mg/l FOG: 100 mg/l (animal/vegetable) pH: 5.0 – 12.0 No remediation water
Ordinance Requirement: All Discharges Administrative Assessments: power to assess at least $1,000.00 per violation per day Is spelled out in Rate Ordinance passed 6/19/13 http://www.abcwua.org/Legislation___Ordinances.aspx
Changes From The Previous Ordinance: Enforcement Response Plan (ERP) Reimbursement of all Water Authority monitoring costs for samples in violation Administrative Assessments for each discharge violation All citations changed to Administrative Assessments Online: http://www.abcwua.org/Industrial_Pretreatment.aspx
Changes From The Previous Ordinance: Enforcement Response Plan (ERP) Discharge Violations Current AA Proposed AA 100% <Result<120% of Limit $50.00 121% <Result<150% of Limit $100.00 $75.00 151% <Result<200% of Limit $200.00 $100.00 201% <Result<500% of Limit $300.00 >501% of Limit $500 AA $300.00 $500.00
Other Changes Wastewater Operator Certification Level III Required for monitoring technicians. Title of Industrial Waste Engineer has been changed to Industrial Pretreatment Engineer.
Comments Due by August 16, 2013 Website: http://www.abcwua.org/Industrial_Pretreatment.aspx Comment Cards pretreatment@abcwua.org
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