nacwa 2017 national pretreatment and pollution prevention

Massachusetts Water Resources Authority

Presentation to the

NACWA 2017 National Pretreatment and Pollution Prevention Workshop

Significant Industrial User Meetings

May 18, 2017

Carolyn M. FioreDeputy Chief Operating Officer for

Programs, Policy and Planning


• Independent State Authority• Created in 1984 by Act of Legislature• Provides wholesale water and sewer services to the greater Boston Area

• Operates 2 wastewater treatment plants (Deer Island and Clinton WWTPs)

• Operates 2 drinking water treatment plants (John J. Carroll and William A Brutsch DWTPs)

MWRA ESSENTIAL STATISTICS

• 2.55 million people served• 5,500 businesses and 890,000 households served• 230 MGD of water supplied, 350 MGD of wastewater treated

• 45 sewerage communities and 51 water communities

• 5,400 miles of local sewers, 228 miles MWRA interceptor sewers• Two MWRA wastewater treatment plants serving 45 cities/towns• Two MWRA water treatment plants serving 51 cities/towns

Deer Island Treatment Plant

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Quabbin and Wachusett Reservoirs

• Managed in the Toxics Reduction and Control Department• 48 Employees

– Director– Inspections and Permitting Group– Sampling Group– Data Management and Enforcement Group

• Responsibilities – IPP– Permitting/Inspections for construction or other activities near MWRA infrastructure– Sampling at CSO facilities during wet weather– Emergency Response for Spills to Sewer

MWRA’s Industrial Pretreatment Program

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Demographics of SIUs (2016)

54 with Flows ≥ 25,000 GPD

75 Regulated by National Categorical Standards

111 have Reasonable Potential to Violate (not incl. Categorical)

1 has Potential to Adversely Affect POTW

0 with BOD ≥ 5% Average Dry Weather Hydraulic Flow

History of SIU Meetings: 24 Years and Counting

• Developed in 1993 as outreach to explain new complex permit charges to SIUs

• Several presenters explained MWRA’s mission, goals, pretreatment program structure, new charges, and relationship to EPA and federal regulations

These meetings usually take place in the spring each year.

TRAC updates the users on program changes, challenges, new initiatives, compliance issues.

TRAC provides tours of its facilities some years (DI, Fore River Pelletizing Plant, Carroll Water Treatment Plant)

WWTPO and WTP operators are eligible for TCH’s (credits towards license renewal for attendance at these meetings)

Presentations are also prepared on current activities within/outside of MWRA (the following slide shows a recent set of presentations)

The SIU Meetings

Prevent pass through of pollutants into receiving waters

Improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges

Prevent interference with operation of treatment plant, including protecting worker health and safety

• Inspections• Permitting• Monitoring• Enforcement

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Pretreatment Program Objectives

• Regulations and Local Limits

• Industrial Survey

• Inspections

• Permitting

• Monitoring

• Enforcement

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Elements of the Pretreatment Program

The MWRA system has approximately 1200 permitted users204 were Significant Industrial Users (SIU’s)

• 900 Total Facility and gas/oil separator Inspections in FY15

• Over 270 Enforcement Actions for all Industries and separators

• Over 3500 monitoring actions in FY16 (sampling at industries, NPDES sampling at MWRA facilities, special projects and CSO Treatment studies)

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Pretreatment Program Activities 2016

• MWRA determines a monitoring point score for each sampling location for each SIU by following the seven steps set forth in MWRA regulations.

An explanation of MWRA’s Annual Charges to Permittees


“Boston Area Beach Water Quality”

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• MWRA has assisted in monitoring Boston Harbor beaches since 1996

• Daily monitoring/beach flagging program has now been in place for more than ten years

• Beaches postings occur if majority of sampling sites at a given beach fail to meet limits

• Precautionary postings follow heavy rainstorms; different beaches have different rainfall thresholds

Current Status of Boston Harbor Beaches Monitoring

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Massachusetts Toxics Use Reduction Act

• Companies must:– Report toxics use

– Pay fees

– Plan toxics reduction

• 2006 Amendments:– Designates higher and lower hazard substances

– Resource Conservation Planning – energy, water, materials

– Integrates Environmental Management Systems into TUR

Adopted 1989 Effective 1990

Expanded 2006

SNC A and B (Discharge Violations)

• MWRA Zinc Limit = 1.0 mg/l, (TRC = 1.2 mg/l)• 3 Samples in Period Oct ‐ Mar• 2/3 (66.7%) in violation = SNC A• 1/3 (33.3%) in violation at >1.2 x limit of 1.0 = SNC B

• 1 Sample in Period Jan ‐ June• 1/1 (100%) in violation, greater than limit and at >1.2 x limit = SNC A + B

Oct Nov Dec Jan Feb Mar Apr May Jun.08 1.1 2.5

Molybdenum Concentrations in Biosolids in FY09

• Pending NPDES Permits – Local Limits

• Molybdenum

• Wipes‐ Flushable? And FOG (Fats. Oils and Grease)

• PIMS (Pretreatment Information Management System)

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TRAC Challenges, Opportunities and Initiatives

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Demolition

A-Side Extended Contactor - Before


• An explanation of MWRA’s Annual Charges to Permittees• Ultra‐violet Disinfection at MWRA’s Carroll Water Treatment facility• MWRA Drinking Water Quality (National Award Winner!)• Boston Area Beach Water Quality • Boston Harbor Beaches Monitoring• An Overview of Toxics Use Reduction and Resource Conservation in Massachusetts• Self Monitoring and the Responsibilities of the Permittee• Significant Industrial Users and Significant Noncompliance• Issues Affecting the Treatment Plants/Residuals

– Molybdenum– Phosphorus– Copper

• CSOs and 9 Minimum Controls• Major MWRA Construction Projects• EPA Regulations

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Distinguished Guest Speakers

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Meeting Tips

• Serve Food!• Offer on more than one date, vary morning/afternoon • Arrange Operator technical credit hours with state• Solicit ideas for presentation from SIUs• Require registration of each individual attending• Provide nametags for staff and visitors• Hand out certificates for credit hours at the end of the meeting

Tour Tips

• Provide tours of POTW/water facilities • Plan for all types of weather• Note safety and walking requirements, etc., in registration packets• Note limitations for photographers• Pre‐arrange for tour safety (facility provided hard‐hats, safety glasses, e.g.)

• Have staff join tours to keep track of wanderers• Offer time for direct staff interaction with SIUs• Vary tour destinations year to year


[email protected]

617‐788‐4929

Contact Information

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nacwa 2017 national pretreatment and pollution prevention

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