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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 - PowerPoint PPT Presentation
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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 [email protected]
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
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)
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
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!