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

2. For copy of presentation, please e-mail jothaler@ftch.com
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