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 email@example.com PreviouslySurcharge Rate Updates/A 21st Century Approach (MWEA Administrators Conference, January 2010)Surcharges recover cost of treating extra-strength industrial wasteRates should be regularly updated to current costsNew methodology based on USEPA softwareMore accurate O&M cost breakdownStraightforward calibrationEfficient annual updatesFor copy of presentation, please
3 Program Objective Agenda Discuss advantages of combining SALs with extra- strength surcharge programAgendaThe Available Capacity ConundrumSALs as a SolutionUSEPA/MDEQ PositionImplementationPotential Revenue Impact
4 IPP Local LimitsWidely successful protecting WWTPs against detrimental effects of industrial wastes
5 The Available Capacity Conundrum Many wastewater utilities currently experiencing lower flows and loadingsMagnified by local limits, which are often:Uniform not-to-exceed concentrationsApplied to all nondomestic usersDifficult to adapt to special needsResult is available capacity that cannot beaccessed 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 economyGreat match for surchargeable compatiblesTreatable via existing systemImprove asset utilizationEnhance surcharge revenues
7 Special Allocation Limits Extension of traditional local limits, with option to assign alternate user-specific limitsProvide the ultimate in flexibilityRapidly gaining acceptance across MIAnn ArborGenesee CountyBay CityLansingFlintWyoming
8 SALs to the RescueDairy-based industry considered locating new facility in communityRequested applicable local limitsAssessed need/cost of pretreatment systemEnded up selecting alternate site in IndianaCommunity has available WWTP capacity and interest in increasing surcharge revenuesTo improve economic development opportunities in future, now implementing SALs
9 SALs to the RescueExisting landfill facility considering expansion in communityInvolved major capital investmentOngoing issue with ammonia local limits required pretreatment system upgradeCommunity has available WWTP capacity and interest in increasing surcharge revenuesTo enable treatment to be “subcontracted” to WWTP, now implementing SALs
10 Traditional Local Limits MAHL = not-to-exceed mass to protect WWTPMAIL = portion of MAHL available to SIUsUniform allocation of MAIL over total SIU flow
11 SAL-based Local Limits Portion of MAIL set aside as reserveUniform allocation of MAIL, less reserve, over total SIU flow
12 USEPA Position on SALsMay select any allocation method producing enforceable local limits which:Prevent pass-through and interferenceComply with prohibitions in Federal regulationsSubject to review by approval authority
13 MDEQ Position on SALs Legal authority in Sewer Use Ordinance ConstraintsTotal influent mass cannot exceed MAHLTotal allocated mass, including any septage, cannot exceed MAILAssigned limit cannot exceed any applicable collection system limitationApprovable written procedures
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