Fishbeck, Thompson, Carr & Huber, Inc.

Got Capacity?A Case for Special Allocation Limits

Jerald O. Thaler, P.E.

Previously

Surcharge Rate Updates/A 21st Century Approach (MWEA Administrators Conference, January 2010) Surcharges recover cost of treating extra-

strength industrial waste Rates should be regularly updated to current

costs New methodology based on USEPA software

More accurate O&M cost breakdown Straightforward calibration Efficient annual updatesFor copy of presentation, please e-mail jothaler@ftch.com

Program

ObjectiveDiscuss advantages of combining SALs with extra-strength surcharge program

Agenda The Available Capacity Conundrum

SALs as a Solution

USEPA/MDEQ Position

Implementation

Potential Revenue Impact

IPP Local Limits

Widely successful protecting WWTPs against detrimental effects of industrial wastes

www.michigan.gov/deq

The Available Capacity Conundrum

Many wastewater utilities currently experiencing lower flows and loadings

Magnified by local limits, which are often: Uniform not-to-exceed concentrations Applied to all nondomestic users Difficult to adapt to special needs

Result is available capacity that cannot beaccessed and loss of potential revenue

A Solution

Why not more flexible local limits? Could use available capacity to assist industrial

users, thereby promoting local economy Great match for surchargeable compatibles

Treatable via existing system Improve asset utilization Enhance surcharge revenues

Special Allocation Limits

Extension of traditional local limits, with

option to assign alternate user-specific limits Provide the ultimate in flexibility

Rapidly gaining acceptance across MI

Ann ArborBay CityFlint

Genesee CountyLansingWyoming

SALs to the Rescue

Dairy-based industry considered locating new facility in community Requested applicable local limits Assessed need/cost of pretreatment system Ended up selecting alternate site in Indiana

Community has available WWTP capacity and interest in increasing surcharge revenues

To improve economic development opportunities in future, now implementing SALs

SALs to the Rescue

Existing landfill facility considering expansion in community Involved major capital investment Ongoing issue with ammonia local limits

required pretreatment system upgrade Community has available WWTP capacity and

interest in increasing surcharge revenues To enable treatment to be “subcontracted” to

WWTP, now implementing SALs

Traditional Local Limits

MAHL = not-to-exceed mass to protect WWTP MAIL = portion of MAHL available to SIUs Uniform allocation of MAIL over total SIU flow

METROPOLITAN WWTP – BOD5

10 mgd0.5 mgd SIUs

MAHL = 16,500 lb/day

SafetyFactor

Background

SIUs0.5 mgd @ 1,500 mg/L

MAIL

9.5 mgd @ 110 mg/L

10% MAHL

SAL-based Local Limits

Portion of MAIL set aside as reserve Uniform allocation of MAIL, less reserve, over

total SIU flow

METROPOLITAN WWTP – BOD5

10 mgd0.5 mgd SIUs

MAHL = 16,500 lb/day

SafetyFactor

Background

SIUs0.5 mgd @ 1,000 mg/L

Reserve 2,100 lb/day (33% MAIL)

MAIL

USEPA Position on SALs

May select any allocation method producing enforceable local limits which: Prevent pass-through and interference Comply with prohibitions in Federal regulations

Subject to review by approval authority

MDEQ Position on SALs

Legal authority in Sewer Use Ordinance Constraints

Total influent mass cannot exceed MAHL Total allocated mass, including any septage,

cannot exceed MAIL Assigned limit cannot exceed any applicable

collection system limitation Approvable written procedures

Step 1 – Classify SIUs

Local Limit (CLCL LIM) = 1,000 mg/L

Surcharge Threshold (CSURCH) = 250 mg/L

Background (CBKGD) = 110 mg/L

Classification for

BOD5

ABCX…

(misc. other) B

where: X - Discharger to be regulated via SAL

Significant Industrial User

Acme ManufacturingUSA Automotive, Inc.Standard PlatingSmith Foods

Discharge Flow, gal/day

50,000100,00025,000

250,00075,000

where: A - Surcharging Specific Discharger (>CSURCH & <CLCL LIM)

where: B - Nonsurcharging Specific Discharger (>CBKGD & <CSURCH)

where: C - Nonspecific Discharger (<CBKGD)

METROPOLITAN WWTPINDUSTRIAL PRETREATMENT PROGRAM

Status of Status ofApproved Approved

MAHL MAIL

Maximum Allowable Headworks Loading (MAHL) 16,500 lb/day- Safety Factor @ 10% of MAHL 1,650 lb/day

- Background 9.500 mgd @ 110 mg/L 8,710 lb/day

Maximum Allowable Industrial Loading (MAIL) 6,140 6,400 lb/day- Septage 0.000 mgd @ 1,000 mg/L 0 0 lb/day

- Allocated to SIUs 2,890 2,890 lb/day

Remaining 3,250 3,510 lb/day20% 21% of MAHL

MAIL

Fraction

Acme Manufacturing 50,000 gpd @ 1,000 mg/L 420 lb./day 7%

USA Automotive, Inc. 100,000 gpd @ 250 mg/L 210 lb./day 3%

Standard Plating 25,000 gpd @ 110 mg/L 20 lb./day <1%Smith Foods 250,000 gpd @ 1,000 mg/L 2,080 lb./day 34%

… (misc. other) 75,000 gpd @ 250 mg/L 160 lb./day 3%

Allocated to SIUs 2,890 lb./day

X

B

A

BC

SIU

Classification

Significant

Industrial User

Allocated

Discharge Flow

Allocated

Concentration

Allocated

Discharge Mass

BOD5

METROPOLITAN WWTP

INDUSTRIAL PRETREATMENT PROGRAM

MASS ACCOUNTING FOR

Step 2 – Check MAHL/MAIL Status

Status of Status ofApproved Approved

MAHL MAIL

Maximum Allowable Headworks Loading (MAHL) 16,500 lb/day- Safety Factor @ 10% of MAHL 1,650 lb/day

- Background 9.500 mgd @ 110 mg/L 8,710 lb/day

Maximum Allowable Industrial Loading (MAIL) 6,140 6,400 lb/day- Septage 0.000 mgd @ 1,000 mg/L 0 0 lb/day

- Allocated to SIUs 4,980 4,980 lb/day

Remaining 1,160 1,420 lb/day7% 9% of MAHL

MAILFraction

Acme Manufacturing 50,000 gpd @ 1,000 mg/L 420 lb./day 7%

USA Automotive, Inc. 100,000 gpd @ 250 mg/L 210 lb./day 3%

Standard Plating 25,000 gpd @ 110 mg/L 20 lb./day <1%Smith Foods 250,000 gpd @ 2,000 mg/L 4,170 lb./day 68%

… (misc. other) 75,000 gpd @ 250 mg/L 160 lb./day 3%

Allocated to SIUs 4,980 lb./day

BOD5

METROPOLITAN WWTP

INDUSTRIAL PRETREATMENT PROGRAM

MASS ACCOUNTING FOR

Classification Discharge Flow Concentration Discharge MassIndustrial UserSIU Significant Allocated Allocated Allocated

A

BCX

B

Step 3 – Select Appropriate SAL

Potential Revenue Impact

As condition of agreement, can use SAL as basis for calculating surcharge

Allocated Flow = 250,000 mgdSurcharge Rate = $0.20 /lb

Extra-Strength BOD5 Surcharge – Smith Foods

METROPOLITAN WWTP

$0

$10,000

$20,000

$30,000

$40,000

0 500 1,000 1,500 2,000 2,500

Mon

thly

Cha

rge

Discharge Concentration, mg/L

CS

AL

CLC

L LI

M

CT

HR

ES

H

CB

KG

D

Perspective

Got capacity? Combining SALs with your extra-strength

surcharge program can: Increase asset utilization Enhance surcharge revenue Promote local economy

Acronyms

IPP – Industrial Pretreatment Program MAHL – Maximum Allowable Headworks Loading MAIL – Maximum Allowable Industrial Loading MDEQ – Michigan Department of Environmental Quality O&M – Operating and Maintenance SAL – Special Allocation Limit SIU – Significant Industrial User USEPA – U.S. Environmental Protection Agency WWTP – Wastewater Treatment Plant

Fishbeck, Thompson, Carr & Huber, Inc.

Thank You!