Presentation is loading. Please wait.

Presentation is loading. Please wait.

Sidney Innerebner, PhD, PE, CWP Indigo Water Group.

Similar presentations


Presentation on theme: "Sidney Innerebner, PhD, PE, CWP Indigo Water Group."— Presentation transcript:

1 Sidney Innerebner, PhD, PE, CWP Indigo Water Group

2 Disclaimers 2 Many of the images and videos that we use in our training materials were collected from the internet over the span of many years. We have made every effort to reference the original source. When possible, we’ve contacted webmasters for permission to use these materials. If you are the owner of an image or video and don’t want us to use it, please let us know and we’ll remove it from our training materials immediately. Indigo Water Group, LLC has made attempts to verify the information provided in this web-based training against respected reference materials including Manual of Practice 11 by Water Environment Federation and the Sacramento Manuals. Neither the Author nor the Publisher, Indigo Water Group, assumes any responsibility for errors, omissions, or contrary interpretation of the subject matter herein.

3 Our Goals Today Clean Water Act Clean Water Act Federal Pretreatment Program Federal Pretreatment Program Pollution Prevention Programs Pollution Prevention Programs Industry Examples Industry Examples 3

4 Introduction   Clean Water Act was passed by Congress in 1972 to restore and maintain the integrity of the nation’s waters.   Only 39 years ago – in my lifetime!   The Act establishes regulations for commercial and industrial process wastewaters.   Made it illegal to discharge to waters of the United States without a permit 4

5 Two Classes of Dischargers Direct Dischargers Direct Dischargers Discharge to surface water Discharge to surface water National Pollution Discharge Elimination System National Pollution Discharge Elimination System Permit issued by State or EPA Permit issued by State or EPA Indirect Dischargers Indirect Dischargers Discharge to collection system Discharge to collection system National Pretreatment Program National Pretreatment Program Permit Issued by POTW Permit Issued by POTW 5

6 Wastewater Basics POTWs collect wastewater and transport via a collection system to the wastewater treatment plant. POTWs collect wastewater and transport via a collection system to the wastewater treatment plant. Treatment processes to remove harmful organisms and other pollutants Treatment processes to remove harmful organisms and other pollutants Designed to treat typical residential wastewater and biodegradable commercial / industrial wastewater (conventional pollutants) Designed to treat typical residential wastewater and biodegradable commercial / industrial wastewater (conventional pollutants) Municipal POTWs are not designed to treat toxic pollutants. Municipal POTWs are not designed to treat toxic pollutants. 6

7 Wastewater Treatment Plants have Three Types of Capacity Hydraulic Capacity Hydraulic Capacity Organic Load (BOD5) and Suspended Solids Capacity or Biological Treatment Capacity Organic Load (BOD5) and Suspended Solids Capacity or Biological Treatment Capacity Solids Handling Capacity Solids Handling Capacity Each type of capacity must be protected and not exceeded for the WWTP to function Each type of capacity must be protected and not exceeded for the WWTP to function 7

8 Treatment Capacity Utilized by Domestic and Industry Many industries discharge their wastewaters, with or without pretreatment, into sewers servicing Publicly Owned Treatment Works (POTWs) Many industries discharge their wastewaters, with or without pretreatment, into sewers servicing Publicly Owned Treatment Works (POTWs) Non-regulated industries and light commercial activities often get lumped in with domestic wastewater sources Non-regulated industries and light commercial activities often get lumped in with domestic wastewater sources Schools Schools Day Camps Day Camps Restaurants Restaurants Churches Churches Offices Offices 8

9 POTWs have a fixed capacity to handle POTWs have a fixed capacity to handle Unexpected increases in industrial loads Unexpected increases in industrial loads Population growth Population growth Stormwater flows (I&I) Stormwater flows (I&I) POTWs must meet tighter effluent limits POTWs must meet tighter effluent limits Ammonia, Nitrate, and Phosphorus Ammonia, Nitrate, and Phosphorus Metals Metals Can limit loads accepted (local limits) Can limit loads accepted (local limits) Sometimes dilution is the solution – it’s amazing what 45 inches of rain a year will do for your discharge limits! Sometimes dilution is the solution – it’s amazing what 45 inches of rain a year will do for your discharge limits! Wind River Ranch Wind River Ranch Town of Meeker Town of Meeker 9

10 Possible Solutions Expand the POTW facility to meet the increased demand - $$$$$ Expand the POTW facility to meet the increased demand - $$$$$ All Colorado discharge permits require All Colorado discharge permits require Planning for expansion at 80% of capacity Planning for expansion at 80% of capacity Must be under construction at 95% of capacity Must be under construction at 95% of capacity Exception is limited service area Exception is limited service area 10

11 Possible Solutions More expensive for smaller facilities due to economy of scale More expensive for smaller facilities due to economy of scale Wild Basin Lodge, 2000 gpd, $0.35 Million $175/gal Wild Basin Lodge, 2000 gpd, $0.35 Million $175/gal Wind River Ranch, 4000 gpd, $0.5 Million $125/gal Wind River Ranch, 4000 gpd, $0.5 Million $125/gal Brush, at 1.7 mgd, $16.2 Million $9.50/gal Brush, at 1.7 mgd, $16.2 Million $9.50/gal Carbondale, a t 1.5 mgd, $12.5 Million $8.33/gal Carbondale, a t 1.5 mgd, $12.5 Million $8.33/gal Clifton, at 4.0 mgd, $22.8 Million $5.70/gal Clifton, at 4.0 mgd, $22.8 Million $5.70/gal L/E WWTP, at 50 mgd, $75 Million $1.50/gal L/E WWTP, at 50 mgd, $75 Million $1.50/gal Funding????? Funding????? 11

12 Possible Solutions Water Conservation? Water Conservation? Initiate an industrial pretreatment program to reduce the strength of the waste Initiate an industrial pretreatment program to reduce the strength of the waste Sometimes municipalities and industry collaborate to build or expand a POTW Sometimes municipalities and industry collaborate to build or expand a POTW City of Brush, Colorado City of Brush, Colorado Town of Dinuba, California Town of Dinuba, California City of Allendale, Michigan City of Allendale, Michigan Institute a pollution prevention program Institute a pollution prevention program 12

13 Clean Water Act Technology Based Limits (BMP) Technology Based Limits (BMP) Water Quality Standards Water Quality Standards Use Protection Use Protection Stream Standards Stream Standards Permits Required for All Dischargers; direct and indirect Permits Required for All Dischargers; direct and indirect Revolving Fund Construction Loan for Municipalities Revolving Fund Construction Loan for Municipalities 13

14 Pretreatment Program Components Industrial Waste Survey Industrial Waste Survey Permitting Permitting Inspections Inspections Sampling Sampling Reporting Reporting Data Management/Compliance Evaluations Data Management/Compliance Evaluations Enforcement Enforcement Other controls—BMPs, Sector Controls and Spill/Slug Control Other controls—BMPs, Sector Controls and Spill/Slug Control 14

15 The Big Picture: Why Enact Pretreatment? Prevent Prevent Interference Interference Corrosion Corrosion Explosions Explosions Worker Health and Safety Worker Health and Safety Biosolids Contamination Biosolids Contamination Pass Through Pass Through Industrial Users Contributing Toxic Pollutants to POTWs Industrial Users Contributing Toxic Pollutants to POTWs NPDES/CDPS Requirement NPDES/CDPS Requirement 15

16 Generator’s Responsibility: The purpose of the pretreatment program is to ensure that the Industrial User that generates the pollutants is responsible to manage the waste stream. The purpose of the pretreatment program is to ensure that the Industrial User that generates the pollutants is responsible to manage the waste stream. Do not pass the responsibility and liability onto the taxpayers – average sewer bill in Colorado Do not pass the responsibility and liability onto the taxpayers – average sewer bill in Colorado Internalizes the real cost of doing business Internalizes the real cost of doing business Tragedy of the Commons by Harding Tragedy of the Commons by Harding When everyone must absorb their real costs, it levels the playing field in the business world When everyone must absorb their real costs, it levels the playing field in the business world 16

17 Who Must Have a PT Program? POTWs with POTWs with Combined design flow > 5 MGD and/or Combined design flow > 5 MGD and/or Receiving flow from SIUs, CIUs and/or Receiving flow from SIUs, CIUs and/or Receiving pollutants which pass through or interfere Receiving pollutants which pass through or interfere Approval Authority (EPA or State) may require program be developed, regardless. Approval Authority (EPA or State) may require program be developed, regardless. Defines categories of industrial users Defines categories of industrial users Hauled wastes have special rules Hauled wastes have special rules 17

18 Pretreatment Chain of Command 18

19 POTW Legal Authority [40 CFR § 403.8(f)(1)] u Deny or condition discharges u Require compliance u Control through permit or similar means u Require compliance schedules to comply u Inspect, survey, and monitor u Enforce u Comply with confidentiality requirements 19

20 Industrial Waste Survey Identify sources of indirect discharge--the introduction of pollutants into a POTW from any non- domestic source Identify sources of indirect discharge--the introduction of pollutants into a POTW from any non- domestic source Identify and locate all possible Industrial Users which might be subject to the POTW’s Pretreatment Program Identify and locate all possible Industrial Users which might be subject to the POTW’s Pretreatment Program Identify and locate all possible Significant Industrial Users which might be subject to your POTW’s Pretreatment Program Identify and locate all possible Significant Industrial Users which might be subject to your POTW’s Pretreatment Program 20

21 Classification of Industrial Users All Industrial Users Significant Industrial Users -Categorical -Non-categorical Non-Significant Users Sector Control ProgramNot Significant 21

22 Significant Industrial User Subject to Federal categorical standards Subject to Federal categorical standards Discharges 25,000 GPD or more of process wastewater Discharges 25,000 GPD or more of process wastewater Contributes 5 % or more of hydraulic or organic capacity of the POTW treatment plant Contributes 5 % or more of hydraulic or organic capacity of the POTW treatment plant Has a reasonable potential for adversely affecting the POTW or for violating any standard or requirements Has a reasonable potential for adversely affecting the POTW or for violating any standard or requirements 22

23 Categorical Industrial User Applicable to specific industry categories Applicable to specific industry categories Arose from 1976 EPA/NRDC agreement Arose from 1976 EPA/NRDC agreement Currently at 55 categories Currently at 55 categories (4 are being proposed) (4 are being proposed) Found in 40 CFR Parts Found in 40 CFR Parts Applicable to direct & indirect dischargers Applicable to direct & indirect dischargers 23

24 Categorical Industries Part Dairy Products Processing Part Grain Mills Part Canned and Preserved Fruits and Vegetables Processing Part Canned and Preserved Seafood Processing Part Sugar Processing Part Textile Mills Part Cement Manufacturing Part Feedlots Part Electroplating Part Organic Chemicals, Plastics and Synthetic Fibers Part Inorganic Chemical Manufacturing Part Soap and Detergent Manufacturing Part Fertilizer Manufacturing 24

25 Part Petroleum Refining Part Petroleum Refining Part Iron and Steel Manufacturing Part Iron and Steel Manufacturing Part Nonferrous Metals Manufacturing Part Nonferrous Metals Manufacturing Part Phosphate Manufacturing Part Phosphate Manufacturing Part Steam Electric Power Generating Part Steam Electric Power Generating Part Ferroalloy Manufacturing Part Ferroalloy Manufacturing Part Leather Tanning and Finishing Part Leather Tanning and Finishing Part Glass Manufacturing Part Glass Manufacturing Part Asbestos Manufacturing Part Asbestos Manufacturing Part Rubber Manufacturing Part Rubber Manufacturing Part Timber Products Processing Part Timber Products Processing Part Pulp, Paper and Paperboard Part Pulp, Paper and Paperboard Part The Builders’ Paper and Boardmills Part The Builders’ Paper and Boardmills 25

26 Part Meat Products Part Meat Products Part Metal Finishing Part Metal Finishing Part Coal Mining Part Coal Mining Part Oil and Gas Extraction Part Oil and Gas Extraction Part Mineral and Mining Processing Part Mineral and Mining Processing Part 437-Centralized Waste Treatment Part 437-Centralized Waste Treatment Part Pharmaceutical Manufacturing Part Pharmaceutical Manufacturing Part Ore Mining and Dressing Part Ore Mining and Dressing Part 442- Transportation Equipment Cleaning Part 442- Transportation Equipment Cleaning Part Paving and Roofing Materials(Tars and Asphalt) Part Paving and Roofing Materials(Tars and Asphalt) Part 444-Hazardous Waste Combustors Part 444-Hazardous Waste Combustors Part 445-Landfills Part 445-Landfills Part Paint Formulating Part Paint Formulating Part Ink Formulating Part Ink Formulating Part Gum and Wood Chemicals Manufacturing Part Gum and Wood Chemicals Manufacturing Part Pesticide Chemicals Part Pesticide Chemicals 26

27 Part Carbon Black Manufacturing Part Photographic Processing Part Hospitals Part Battery Manufacturing Part Plastics Molding and Forming Part Metal Molding and Casting Part Coil Coating Part Explosives Manufacturing Part Porcelain Enameling Part Aluminum Forming Part Copper Forming Part Electrical and Electronic Components Part Nonferrous Metals Forming and Metal Powder The CWA(304(m)) requires that every two years EPA develop and publish plans for effluent guidelines, review, revision, development, and adoption. 27

28 Pretreatment Program is Based on “End-of Pipe” Standards Technology Based Limits Technology Based Limits Prohibited Discharges Prohibited Discharges Categorical Limits Categorical Limits Local Limits Local Limits Consensus between IU and POTW Consensus between IU and POTW Communities sometimes put up with a lot of abuse to retain jobs Communities sometimes put up with a lot of abuse to retain jobs 28

29 Prohibited Discharges Corrosive Corrosive Flammable Flammable Hazardous – D or F listed waste under RCRA Hazardous – D or F listed waste under RCRA Pass Through Pass Through Interfere with operation of POTW or sludge disposal Interfere with operation of POTW or sludge disposal 29

30 Pass Through and Interference The POTW has a fixed treatment capacity for flow and load The POTW has a fixed treatment capacity for flow and load Not just toxics interfere with operation Not just toxics interfere with operation Excessively high concentrations of BOD and TSS Excessively high concentrations of BOD and TSS Septic material Septic material Grease (give example) Grease (give example) Seemingly benign substances like salt (give example) Seemingly benign substances like salt (give example) Slug loading or “binge” treatment (give example) Slug loading or “binge” treatment (give example) 30

31 31

32 Characteristics of Industrial Wastewaters High strength High strength Low nutrient to BOD ratios Low nutrient to BOD ratios Often high temperature Often high temperature Most flow occurs during shift change and/or cleaning processes (CIP) Most flow occurs during shift change and/or cleaning processes (CIP) May have weekly or seasonal variations May have weekly or seasonal variations LOTS of opportunities for prohibited discharges, pass through, and interference LOTS of opportunities for prohibited discharges, pass through, and interference 32

33 Brewery Wastewater BOD > 1200 mg/L BOD > 1200 mg/L HIGHLY variable HIGHLY variable Mostly soluble Mostly soluble Lots of VFAs Lots of VFAs Primaries remove 10-15% of influent BOD Primaries remove 10-15% of influent BOD Hops and Grains = TSS Hops and Grains = TSS Nutrient deficient Nutrient deficient 33

34 Brewery Wastewater TS can be very high TS can be very high TSS = mg/L TSS = mg/L BOD = 1,000 – 15,00 mg/L BOD = 1,000 – 15,00 mg/L Nitrogen = mg/L Nitrogen = mg/L Phosphorus = 10 – 30 mg/L Phosphorus = 10 – 30 mg/L Temperature = 30 o C Temperature = 30 o C 34

35 Dairy Wastewater BOD of whole milk = 100,000 mg/L BOD of whole milk = 100,000 mg/L Influent averages 900 – 5000 mg/L BOD Influent averages 900 – 5000 mg/L BOD High temperature ~35 o C from clean in place (CIP) process High temperature ~35 o C from clean in place (CIP) process Not usually nutrient limited Not usually nutrient limited High fat and grease High fat and grease DAFT often used as front end process DAFT often used as front end process 35

36 Dairy Wastewater TS can be very high TS can be very high TSS = 100 – 1,000 mg/L TSS = 100 – 1,000 mg/L BOD = 900 – 5,000 mg/L BOD = 900 – 5,000 mg/L Nitrogen = mg/L Nitrogen = mg/L Phosphorus = 10 – 100 mg/L Phosphorus = 10 – 100 mg/L Temperature = 30 o C Temperature = 30 o C 36

37 Petroleum Refinery WW Main influent compounds are ammonia, phenols, and sulfide Main influent compounds are ammonia, phenols, and sulfide Activated carbon sometimes added to adsorb organics Activated carbon sometimes added to adsorb organics May be P and/or micronutrient limited May be P and/or micronutrient limited High temperatures High temperatures 37

38 Petroleum Refinery WW BOD = 150 – 250 mg/L Phenol = mg/L Oil = 100 – 300 mg/L Salts, chromium, and lead 38

39 Categorical Limits BACT for specific industry BACT for specific industry Establish national pollution control requirements Establish national pollution control requirements Organized by the industrial process used by the IU Organized by the industrial process used by the IU Categorical standards are applied to regulated wastewaters at the end-of-process or treatment Categorical standards are applied to regulated wastewaters at the end-of-process or treatment Can seem unfair to municipalities with tighter standards Can seem unfair to municipalities with tighter standards Phosphorus limit for CIU versus Municipal WWTP Industrial WWTP versus Municipal WWTP 39

40 Local Limits Protect the POTW Protect the POTW Protect the receiving waters Protect the receiving waters Improve biosolids disposal options Improve biosolids disposal options Protect POTW personnel Protect POTW personnel Examples Examples Grease – the number one cause of sanitary sewer overflows and blockages Grease – the number one cause of sanitary sewer overflows and blockages Copper at the Boulder WWTP Copper at the Boulder WWTP Copper at the Frisco WWTP Copper at the Frisco WWTP Hauled waste age at the Meeker WWTP Hauled waste age at the Meeker WWTP 40

41 41

42 Let’s Talk About Grease and Traps for a Few Minutes Who needs a trap? Who needs a trap? How big will it be? How big will it be? What can be plumbed to it? What can be plumbed to it? How often to pump? How often to pump? Who keeps records? Who keeps records? What about additives? What about additives? What if the user does everything right, but grease is still leaving their trap and causing problems? What if the user does everything right, but grease is still leaving their trap and causing problems? 42

43 43

44 Local Limits Local limits are specific to the POTW Local limits are specific to the POTW POTWs are required to assess and revise, if necessary, every five years POTWs are required to assess and revise, if necessary, every five years Not industry-specific, apply to all IUs in the service area. Not industry-specific, apply to all IUs in the service area. Water Quality-based standards, may be enforced at the end-of-pipe Water Quality-based standards, may be enforced at the end-of-pipe Sometimes forces an industry to treat in excess of their categorical standards Sometimes forces an industry to treat in excess of their categorical standards 44

45 Types of Permit Limits Limits may be concentration based or mass based Limits may be concentration based or mass based Concentration based is good because accurate flow data can be hard to get Concentration based is good because accurate flow data can be hard to get Mass based loads (ppd) don’t always protect the treatment plant Mass based loads (ppd) don’t always protect the treatment plant Cheese brine discharge Cheese brine discharge Turkey Processing Plant Turkey Processing Plant Town of Dinuba, California Town of Dinuba, California WTP residuals discharge impacts wastewater plant WTP residuals discharge impacts wastewater plant Nevada cyanide discharge Nevada cyanide discharge Septage receiving Septage receiving 45

46 Bad Actors in POTWs and Industry – Blame the Other Guy End of Pipe Limits cost money End of Pipe Limits cost money Industry attitude can be to get as close to the limit as possible Industry attitude can be to get as close to the limit as possible In some cases (really bad actors) industry may even plan to violate periodically In some cases (really bad actors) industry may even plan to violate periodically Corporate pays for infrastructure, local pays for operations, maintenance and fines Corporate pays for infrastructure, local pays for operations, maintenance and fines Corporate sets local up for failure Corporate sets local up for failure Creative sampling can hide a lot of problems Creative sampling can hide a lot of problems 46

47 Bad Actors in POTWs and Industry – Blame the Other Guy Operators at POTW often blame industry for all their problems, whether cause and effect can be shown or not Operators at POTW often blame industry for all their problems, whether cause and effect can be shown or not WTP Residuals Dump WTP Residuals Dump Turkey Plant and Municipal WWTP Turkey Plant and Municipal WWTP POTW levy fees for processing BOD, TSS, etc. POTW levy fees for processing BOD, TSS, etc. IU often feels unfairly penalized by POTW IU often feels unfairly penalized by POTW Sometimes, IU find that being a direct discharger is better Sometimes, IU find that being a direct discharger is better City of Fort Morgan has 4 direct IU dischargers City of Fort Morgan has 4 direct IU dischargers When Industry has control, they often do better When Industry has control, they often do better 47

48 Enforcement Civil Penalties or Fines Civil Penalties or Fines Sometimes Criminal Penalties Sometimes Criminal Penalties Supplemental Environmental Projects Supplemental Environmental Projects Violating industry and POTW agree to include commitments by industry to implement specific P2 activities in the settlement as partial relief for the original violations Violating industry and POTW agree to include commitments by industry to implement specific P2 activities in the settlement as partial relief for the original violations Reduces the fine that must be paid Reduces the fine that must be paid Provides “extra” environmental benefits to the public Provides “extra” environmental benefits to the public Gives regulator a way to channel funds outside of a budget cycle Gives regulator a way to channel funds outside of a budget cycle 48

49 Significant Noncompliance (will be published in largest local newspaper) Chronic violations Chronic violations Technical Review Criteria (TRC) violations Technical Review Criteria (TRC) violations Failure to meet, within 90 days, a compliance schedule milestone Failure to meet, within 90 days, a compliance schedule milestone Failure to submit a report within 30 days of the due date Failure to submit a report within 30 days of the due date 49

50 SNC (continued) Violation that causes pass-through or interference Violation that causes pass-through or interference Discharge that causes imminent endangerment Discharge that causes imminent endangerment Example: Elko, Nevada and that sweet smell Example: Elko, Nevada and that sweet smell Example: Corroded concrete pipe Example: Corroded concrete pipe Failure to accurately report noncompliance Failure to accurately report noncompliance Other violations that adversely affect the POTW Pretreatment Program Other violations that adversely affect the POTW Pretreatment Program 50

51 Enforcement Enforcement Response Plans Enforcement Response Plans Reflect POTW’s responsibility to enforce pretreatment requirements & standards. Reflect POTW’s responsibility to enforce pretreatment requirements & standards. Identify how the POTW will investigate noncompliance. Identify how the POTW will investigate noncompliance. Specifies officials responsible for each type of enforcement. Specifies officials responsible for each type of enforcement. Specifies types of and time frames for taking escalating enforcement for anticipated types of violations. Specifies types of and time frames for taking escalating enforcement for anticipated types of violations. 51

52 Informal vs. Formal Enforcement Informal Informal phone calls phone calls meetings meetings warning letter warning letter show cause notices/meetings show cause notices/meetings Formal Formal administrative orders administrative orders civil suites civil suites criminal suites criminal suites termination of service termination of service 52

53 Administrative vs. Civil vs. Criminal Enforcement Administrative - Authorized by Control Authority’s legal authority without involvement of a court. Administrative - Authorized by Control Authority’s legal authority without involvement of a court. Civil - Lawsuit filed in a civil court. Civil - Lawsuit filed in a civil court. Criminal - Prosecution for willful, negligent, knowing, and/or intentional violations. Criminal - Prosecution for willful, negligent, knowing, and/or intentional violations. 53

54 Administrative Penalties EPA - $32,500 per violation/day EPA - $32,500 per violation/day POTW enforces lesser penalties per violation/day POTW enforces lesser penalties per violation/day Penalties Warranted for: Penalties Warranted for: Significant Noncompliance Significant Noncompliance Repeated Instances of Noncompliance Repeated Instances of Noncompliance Failure to Respond to Informal Enforcement Failure to Respond to Informal Enforcement Discharges Causing Harm, Pass Through, and/or Interference Discharges Causing Harm, Pass Through, and/or Interference Unpermitted Discharges and Bypasses Unpermitted Discharges and Bypasses 54

55 Problems with PT Program Penalty Driven Penalty Driven Depends on Self-Monitoring Depends on Self-Monitoring Focuses discharger on end-of-pipe instead of factory floor Focuses discharger on end-of-pipe instead of factory floor Doesn’t minimize pollution at the source Doesn’t minimize pollution at the source May actually encourage more pollution by setting the “minimum” amount of treatment required May actually encourage more pollution by setting the “minimum” amount of treatment required Industry knows industry best Industry knows industry best 55

56 Regulatory Basis for Pollution Prevention - P2 - Programs Until recently, P2 has been an after-thought of environmental regulations Until recently, P2 has been an after-thought of environmental regulations Hazardous waste minimization first endorsed in 1984 RCRA reauthorization (HSWA) introduced P2 by stipulating that generators must have a P2 plan Hazardous waste minimization first endorsed in 1984 RCRA reauthorization (HSWA) introduced P2 by stipulating that generators must have a P2 plan Stated that reduction or elimination of hazardous wastes should take priority over waste management after generation Stated that reduction or elimination of hazardous wastes should take priority over waste management after generation 56

57 Pollution Prevention Act (P2) PPA enacted in 1990 PPA enacted in 1990 Focus is to Reduce, Recycle, Reuse at the source Focus is to Reduce, Recycle, Reuse at the source Some grant monies available Some grant monies available Largely non-regulatory approach – volunteer program Largely non-regulatory approach – volunteer program P2 is inherently a Best Management Practice (BMP) P2 is inherently a Best Management Practice (BMP) Savvy industries can improve operations and profit with a P2 plan Savvy industries can improve operations and profit with a P2 plan 57

58 P2 Act Goals Funding of state technical assistance programs Funding of state technical assistance programs Integration of P2 into EPA activities Integration of P2 into EPA activities Establishes a P2 information clearinghouse Establishes a P2 information clearinghouse Reporting on P2 activities as an addition to the Toxics Release Inventory Requirements Reporting on P2 activities as an addition to the Toxics Release Inventory Requirements Note: non-regulatory except reporting requirement Note: non-regulatory except reporting requirement 58

59 What P2 is NOT? End of pipe treatment End of pipe treatment Incineration or disposal Incineration or disposal Burning waste for energy recovery Burning waste for energy recovery Transferring waste from one medium to another Transferring waste from one medium to another Incorporation of waste into products or by- products Incorporation of waste into products or by- products

60 P2 Hierarchy

61 Manufacturing Cheese Curds = 15% while Whey = 85% Curds = 15% while Whey = 85% Whey Characteristics Whey Characteristics BOD of 30,000 – 50,000 mg/L BOD of 30,000 – 50,000 mg/L 5% to 6% total solids 5% to 6% total solids 70% of solids are lactose 70% of solids are lactose 4% to 9% of solids are protein and minerals 4% to 9% of solids are protein and minerals Internal recycling and recovery of “waste products” for P2 Internal recycling and recovery of “waste products” for P2 Still need some wastewater treatment Still need some wastewater treatment

62 163 oF Milk Separator Coagulation Knitting & Cooking Brining Pressing Ripen Shred Package Cream Starter/ Rennet Whey Salt Water Salt Fines Cheese Curd knitting Curds

63

64 163 oF Milk Separator Coagulation Knitting & Cooking Brining Cream Starter/ Rennet Whey Salt Water Filter Fines Pasteurize Chiller Salt

65 Screen for Fines Separator UF Membrane Crystallizer Evaporator Condenser Evaporator Concentrate Whey Cream Whey Whey Protein Concentrate Permeate Retentate Cow Water Pasteurize Reduced Lactose Permeate Lactose Dryer

66 Ultra-filtration membrane Crystalizer Ultra-filtration membrane

67 That’s not the whole story Clean in Place (CIP) Clean in Place (CIP) Nitric acid Nitric acid Phosphoric acid Phosphoric acid Sodium hydroxide Sodium hydroxide Hot water Hot water Acids and “cow water” used multiple cycles Acids and “cow water” used multiple cycles Eventually – all water goes to wastewater treatment plant (WWTP) Eventually – all water goes to wastewater treatment plant (WWTP) Resource recovery happens even here! Resource recovery happens even here!

68 Voluntary Programs Most P2 programs have been voluntary Most P2 programs have been voluntary 33/50 Program – Very successful! 33/50 Program – Very successful! Reduce the emissions of 17 of the most toxic chemicals by 33% by 1992 and by 50% by 1995 Reduce the emissions of 17 of the most toxic chemicals by 33% by 1992 and by 50% by 1995 Voluntary programs should emphasize Voluntary programs should emphasize A non-regulatory manner in promoting P2 A non-regulatory manner in promoting P2 Address non-regulated (small) industries that don’t have mandatory requirements Address non-regulated (small) industries that don’t have mandatory requirements 68

69 Types of Voluntary Programs Education outreach and technical assistance Education outreach and technical assistance Bill stuffers Bill stuffers Demonstration projects Demonstration projects POTW offers amnesty for initial inspection / fix POTW offers amnesty for initial inspection / fix Awards for successful companies Awards for successful companies MUST be presented as voluntary MUST be presented as voluntary 69

70 Problems with Voluntary Programs Providing information and training may not be sufficient, especially for smaller industries Providing information and training may not be sufficient, especially for smaller industries Not everyone has access to expert authority Not everyone has access to expert authority Non-participants may gain an unfair competitive economic advantage Non-participants may gain an unfair competitive economic advantage Industries and municipalities appreciate a fixed target for treatment goals Industries and municipalities appreciate a fixed target for treatment goals 70

71 Problems with Voluntary Programs Technical assistance program may pose liability issues to the POTW Technical assistance program may pose liability issues to the POTW Difficult to provide assistance when many industries consider their waste to be “proprietary” Difficult to provide assistance when many industries consider their waste to be “proprietary” Contradictory enforcement vs. assistance roles for POTW Contradictory enforcement vs. assistance roles for POTW POTW becomes liable for providing legal advice POTW becomes liable for providing legal advice 71

72 Market Forces are Better Than Peer Pressure Industrial Dischargers Respond to the Bottom Line Industrial Dischargers Respond to the Bottom Line Charge per pound or gallon Charge per pound or gallon Offer rebates for good behavior Offer rebates for good behavior Increase water price to encourage smart usage Increase water price to encourage smart usage Offer amnesty for trying process changes Offer amnesty for trying process changes Once P2 programs begin, many industries find they save money Once P2 programs begin, many industries find they save money Much more creative solutions when the goal, and not the methods, are specified Much more creative solutions when the goal, and not the methods, are specified 72

73 Rules of Thumb for Starting a P2 Program Is that really waste or is it product going down the drain? Is that really waste or is it product going down the drain? Train employees to recognize the difference Train employees to recognize the difference Examples Examples Brine solution recovery at a cheese processing plant Brine solution recovery at a cheese processing plant Leak in an orange juice line Leak in an orange juice line Employees washing “empty” vessels Employees washing “empty” vessels “Cow Water” “Cow Water” Sugar beet pulp at Western Sugar Sugar beet pulp at Western Sugar Spent chloroform in an organic laboratory Spent chloroform in an organic laboratory 73

74 If it’s already out, keep it out! Minor changes to floor practices can mean huge cost savings Minor changes to floor practices can mean huge cost savings Water brooms are a huge waste of water and source of pollution Water brooms are a huge waste of water and source of pollution Reese Foods and grease Reese Foods and grease Hoopston Foods and overspillage Hoopston Foods and overspillage Coors Brewing Company and hops / grains Coors Brewing Company and hops / grains 74

75 If it’s already out, keep it out! Segregate waste streams where possible Segregate waste streams where possible Mixed wastes are harder to treat almost always Mixed wastes are harder to treat almost always If they can be treated separately for less, do it! If they can be treated separately for less, do it! Know the difference between a barrel of wine and a barrel of waste? Know the difference between a barrel of wine and a barrel of waste? Examples of good segregation practices Examples of good segregation practices ConAgra Beef ConAgra Beef Rocky Flats Environmental Test Site Rocky Flats Environmental Test Site Coors Brewing Company Coors Brewing Company 75

76 Water Audits Often find hidden sources of pollutants Often find hidden sources of pollutants Overflowing tanks Overflowing tanks Sinks running when not needed Sinks running when not needed Inefficient equipment Inefficient equipment Lots of little leaks add up! Lots of little leaks add up! Multiple plants can be pitted against one another for greatest reductions Multiple plants can be pitted against one another for greatest reductions 76

77 Not Just for Industry Grease traps Grease traps Englewood’s Citizen Roundup Englewood’s Citizen Roundup Pollution warnings on storm sewers Pollution warnings on storm sewers Bill stuffers for service area Bill stuffers for service area 77

78 The Emerging Approach One goal of a PT or P2 Program is to make sure that pollutants are removed and not just transferred to another media One goal of a PT or P2 Program is to make sure that pollutants are removed and not just transferred to another media Canada is starting to look holistically Canada is starting to look holistically Does removing 1 mg/L of ammonia justify the pollution caused by the coal-fired power plant needed to generate the power required for its removal? Does removing 1 mg/L of ammonia justify the pollution caused by the coal-fired power plant needed to generate the power required for its removal? Europe has some cradle to grave liability for white goods Europe has some cradle to grave liability for white goods 78

79 Indigo Water Group 626 West Davies Way Littleton, Colorado


Download ppt "Sidney Innerebner, PhD, PE, CWP Indigo Water Group."

Similar presentations


Ads by Google