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Got Capacity? A Case for Special Allocation Limits

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Presentation on theme: "Got Capacity? A Case for Special Allocation Limits"— Presentation transcript:

1 Got Capacity? A Case for Special Allocation Limits
Jerald O. Thaler, P.E.

2 For copy of presentation, please e-mail
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 updates For copy of presentation, please

3 Program Objective Agenda
Discuss 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

4 IPP Local Limits Widely successful protecting WWTPs against detrimental effects of industrial wastes

5 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 be accessed and loss of potential revenue

6 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

7 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 Arbor Genesee County Bay City Lansing Flint Wyoming

8 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

9 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

10 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

11 SAL-based Local Limits
Portion of MAIL set aside as reserve Uniform allocation of MAIL, less reserve, over total SIU flow

12 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

13 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

14 Step 1 – Classify SIUs

15 Step 2 – Check MAHL/MAIL Status

16 Step 3 – Select Appropriate SAL

17 Potential Revenue Impact
As condition of agreement, can use SAL as basis for calculating surcharge

18 Perspective Got capacity?
Combining SALs with your extra-strength surcharge program can: Increase asset utilization Enhance surcharge revenue Promote local economy

19 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


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