Carolyn M. Fiore Deputy Chief Operating Officer, for Programs, - - PowerPoint PPT Presentation

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
• f 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

Molybdenum

Why is it a problem?

EPA Regulations EPA bli h d th bi lid l ti k th 503 i

• EPA published the biosolids regulations known as the 503s in

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 di f i t i ll ttl d b di t i t k

• A disease of ruminants, especially cattle, caused by dietary intake
• f 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 )

60 70 80

EPA Interim Limit

30 40 50

DEP Type 1 Limit

10 20 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 id 1 875 Florida 1,875 Rhode Island 1,768 Virginia 1,363 G i 1 352 Georgia 1,352 Pennsylvania 1,132 Missouri 850 M h tt 794 Massachusetts 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

2004

19.1 17.0 16.3 14.1 14.3 20.0 23.5 30.5 33.3 41.5 38.6 31.9

2005

25.2 19.2 19.2 16.8 16.7 22.2 35.6 40.3 35.7 36.6 32.0 26.6

2006

11 7 10 2 9 7 13 1 17 0 16 4 21 8 22 3 27 2 27 0 27 6 17 1

2006

11.7 10.2 9.7 13.1 17.0 16.4 21.8 22.3 27.2 27.0 27.6 17.1

2007

15.1 16.3 15.7 12.0 13.8 15.3 24.9 34.5 33.9 35.0 30.5 28.6

2008

21.0 14.5 13.6 11.7 12.5 15.5 20.3 20.5 19.7 18.8 NA 15.8

2009

11.8 10.1 7.6 6.6 8.0 12.4 11.2 10.5 11.5 11.5 11.1 15.9

2010

18.8 17.1 21.8 18.3 10.1 14.1 16.6 26.5 23.9 18.2 22.0 18.8

2011

15.7 15.5 13.4 11.6 11.6 14.7 19.1 23.8 20.2 17.7 15.0 13.2

2012

13.3 13.0 12.9 17.1 17.2 16.8 20.9 26.3 30.3 29.2 28.7 28.0

2013

20.1 15.5 11.4 9.9 12.9 15.5 16.0 23.2 26.2 28.3 32.4 32.5

Molybdenum versus Average Monthly High Temperatures in Boston

90 35.0 70 80 25.0 30.0 40 50 60 15 0 20.0 20 30 10.0 15.0 10 0.0 5.0 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 brake pad dust, motor oil from garages, bus washes

“Brainstorming” Strategies for Molybdenum Compliance S k MWRA i f DEP li it

• Seek MWRA variance from DEP limit
• 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 t k t ll t i M (1% t M t t i 10%)

• Do not market pellets in Mass. (1% to Mass – target is 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

i variance

• 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 tl d O l h d i bl A l ti l it Ki b l

• Portland, Oregon also had wipes problems. A class action lawsuit vs. Kimberly-

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 th k ti f t i di t ib ti d l f fl h bl i ” i i l ti the marketing, manufacturing, distribution, and sale of flushable wipes,” in violation

• f 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 W b it U d t ith Wh t t t Fl h

• Web-site Update with What not to Flush page

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

MWRA.COM Website Updated

• http://www.mwra.com/03sewer/html/toiletnottrashcan.html

Other TRAC Issues

• Permit Fee Methodology Review

P i di i – Periodic review necessary – New considerations, types of fees – Across-the-Board increases? Targeted?

• Pretreatment Information Management System (PIMS)

– Database for tracking all pretreatment program activities Database for tracking all pretreatment program activities – Need to update for Electronic Reporting (CROMERR) – MIS/TRAC looking at options to update technology