Massachusetts Water Resources Authority Carolyn M. Fiore Deputy Chief Operating Officer, for Programs, Policy, and Planning John A. Riccio Director, Toxic Reduction and Control Carl M. Pawlowski Manager, Residuals Operation
Origin and History of the National Pretreatment Program • Federal Water Pollution Control Act 1972 • Now known as the Clean Water Act • Legislation protecting surface water quality of the United States • Established EPA to direct and implement regulations limiting Established EPA to direct and implement regulations limiting pollutants discharged to surface waters of US (NPDES). • • Provided legal authority to establish National Pretreatment Provided legal authority to establish National Pretreatment Program (June 1974) – to regulate industries that discharge to POTW’s
Pretreatment Program Objectives Prevent pass through of pollutants into receiving waters Improve opportunities to recycle and reclaim municipal and p pp y p industrial wastewaters and sludges Prevent interference with operation of treatment plant, including protecting worker health and safety
Elements of the Pretreatment Program • Regulations and Local Limits • Industrial Survey • Inspections • Permitting Permitting • Monitoring • Enforcement
Pretreatment Program Activities 2013 The MWRA system has 1158 permitted users 212 were Significant Industrial Users (SIU’s) 212 were Significant Industrial Users (SIU s) • 953 Total Facility and gas/oil separator Inspections in FY13 • 323 Total Enforcement Actions for all Industries and separators of which 130 were to SIU’s • 3073 Total monitoring actions in FY13 (sampling at industries, NPDES sampling at MWRA facilities, and special projects) p g p p j )
TRAC Challenges, Opportunities and Initiatives • M l bd Molybdenum • Permit Fee methodology • Wipes- Flushable? and FOG (Fats, Oils and Grease) • PIMS (Pretreatment Information Management System)
Massachusetts Water Resources Authority Why is it a problem? Molybdenum
EPA Regulations • EPA EPA published the biosolids regulations known as the 503s in bli h d th bi lid l ti k th 503 i February 1993 • Molybdenum limit – 75* *will be revisited • • Risk assessment issues due to several factors including wide Risk assessment issues due to several factors including wide variance in background mo concentrations region to region
MADEP Regulations • MADEP publishes 310 CMR 32 sludge rules shortly thereafter • Mo limit 10/25 mg/Kg – 10 for grazing land – Otherwise 25 Otherwise 25 • MADEP to review mo limit when EPA finalizes 503s
Molybdenosis • A disease of ruminants, especially cattle, caused by dietary intake A di f i t i ll ttl d b di t i t k of excessive molybdenum with resultant copper deficiency, characterized by persistent diarrhea and, especially around the eyes a fading of coat pigment eyes, a fading of coat pigment. • Ratio of Copper to Molybdenum < 10:1 • Ratio of Cu to Mo worst case in 2013 is 21:1
Molybdenum Concentrations in Biosolids (mg/kg) March 2013-February 2014 (yellow notebook) y (y ) 80 70 EPA Interim Limit 60 50 40 DEP Type 1 Limit 30 20 10 0 M A M J J A S O N D J F Molybdenum DEP Type 1 Limit EPA Interim Limit Previous 12 Months
State Amount (tons) Connecticut 6,158 Maryland 5,458 New York 3,576 Maine 2,233 Indiana 1,994 Ohio 1,910 Fl Florida id 1 875 1,875 Rhode Island 1,768 Virginia 1,363 G Georgia i 1 352 1,352 Pennsylvania 1,132 Missouri 850 M Massachusetts h tt 794 794 Vermont 143
Molybdenum in MWRA Pellets Monthly averages (mg/Kg) y g ( g g) Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 19.1 17.0 16.3 14.1 14.3 20.0 23.5 30.5 33.3 41.5 38.6 31.9 2004 25.2 19.2 19.2 16.8 16.7 22.2 35.6 40.3 35.7 36.6 32.0 26.6 2005 11.7 10.2 11 7 10 2 9.7 13.1 17.0 16.4 21.8 22.3 27.2 27.0 27.6 17.1 9 7 13 1 17 0 16 4 21 8 22 3 27 2 27 0 27 6 17 1 2006 2006 15.1 16.3 15.7 12.0 13.8 15.3 24.9 34.5 33.9 35.0 30.5 28.6 2007 21.0 14.5 13.6 11.7 12.5 15.5 20.3 20.5 19.7 18.8 NA 15.8 2008 11.8 10.1 7.6 6.6 8.0 12.4 11.2 10.5 11.5 11.5 11.1 15.9 2009 18.8 17.1 21.8 18.3 10.1 14.1 16.6 26.5 23.9 18.2 22.0 18.8 2010 15.7 15.5 13.4 11.6 11.6 14.7 19.1 23.8 20.2 17.7 15.0 13.2 2011 13.3 13.0 12.9 17.1 17.2 16.8 20.9 26.3 30.3 29.2 28.7 28.0 2012 20.1 15.5 11.4 9.9 12.9 15.5 16.0 23.2 26.2 28.3 32.4 32.5 2013
Molybdenum versus Average Monthly High Temperatures in Boston 35.0 90 80 30.0 70 25.0 60 20.0 50 40 15 0 15.0 30 10.0 20 5.0 10 0.0 0 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC mo temp
Molybdenum: Sources and Solutions? • • Cooling Towers (approx 5000) Cooling Towers (approx 5000) • Industry Sources (Chromating Baths) • Stormwater runoff – Contaminated from sources containing Mo, such as b rake pad dust, motor oil from garages, bus washes
“Brainstorming” Strategies for Molybdenum Compliance • S Seek MWRA variance from DEP limit k MWRA i f DEP li it • Seek DEP Rule Change (DEP should adopt federal limit of 75 mg/Kg) • Education Program and other outreach (mailings like FOG and g ( g wipes issue) • Voluntary Program to switch to phosphorous based corrosion Voluntary Program to switch to phosphorous based corrosion control for cooling systems
Strategies for compliance con’t. • MWRA regulations to ban all Mo discharges from cooling towers, boilers, and all industrial sources • MWRA adopt local limit for all sources • D Do not market pellets in Mass. (1% to Mass – target is 10%) t k t ll t i M (1% t M t t i 10%) • “Salt Licks” • Do Nothing
TRAC’s Next Steps on Molybdenum • Continue staff review and data analysis on pellet concentrations, Deer Island influent loadings and industrial inputs Deer Island influent loadings, and industrial inputs • Legal staff is investigating the mechanics of a rule change or variance i • Began an outreach to chemical suppliers to gather background information on the # of customers using Mo • Developing a timeline for changing MWRA Sewer Use Rules and p g g g Regulations • TRAC is increasing source investigations by adding analysis for TRAC is increasing source investigations by adding analysis for Mo to our sampling protocols.
Fats, oil and grease (FOG) and Wipes – Flushable or not??? • 7000 Restaurants in district; no permits; Municipal Board of Health 7000 Restaurants in district; no permits; Municipal Board of Health Inspections only (non MWRA) • • Municipal permit: Towns are responsible for informing MWRA of Municipal permit: Towns are responsible for informing MWRA of blockages • Plan – Municipal Officials Meeting to discuss municipal trap program and Plan Municipal Officials Meeting to discuss municipal trap program and share information • FOG significantly increases the agglomeration of “flushable” wipes g y gg p
Wipes – Flushable or not???? • Washington Suburban Sanitary Commission. Wipes cited as primary cause of 15,810-gallon sewage spill. WSSC has already spent $1.4 million installing , g g p y p g grinders in 17 of its 49 pump stations. • P Portland, Oregon also had wipes problems. A class action lawsuit vs. Kimberly- tl d O l h d i bl A l ti l it Ki b l Clark Corporation and Costco Wholesale Corporation on behalf of consumers problems in their home plumbing due to wipes that are labeled flushable. The lawsuit asks for $5 million due to the “deceptive, improper or unlawful conduct in the marketing, manufacturing, distribution, and sale of flushable wipes,” in violation th k ti f t i di t ib ti d l f fl h bl i ” i i l ti of the New Jersey Consumer Fraud Act and the New York Deceptive Practices Act General Business Law.
Wipes….. • MWRA, during a storm event at BWPS in February 2013, a heavy rag accumulation was associated with clogging of the pumps and rag accumulation was associated with clogging of the pumps and grinders. Temporary screens were installed to remove the heavy loading of rags. Non biodegradable rags have the potential to cause SSO – a violation of our NPDES permit. cause SSO a violation of our NPDES permit.
Septage Facility
Braintree-Weymouth Pump Station I mpacts • Excessive number or rags entering the system has been associated with clogging of grinders and pumps. g p p
Outreach and Education MWRA has begun outreach regarding proper disposal of wipes and other materials and other materials. • MWRA school education program: 2014 Essay, Poster and Video Contest • Web-site Update with What not to Flush page W b it U d t ith Wh t t t Fl h MWRA is considering: • Billboard Messages • Outreach to Senior Community Centers/Developments • Social Media such as YouTube, Industry Facebook pages and Twitter feeds • Links to Town Web-sites • Coordinate an information television news piece • Coordinate an information television news piece
http://www.mwra.com/03sewer/html/toiletnottrashcan.html MWRA.COM Website Updated •
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