THE ADVANCE GUARDS:

Industrial Pretreatment as the first line of defense What is Industrial Pretreatment?

• A system of identifying, tracking and mitigating potential threats to the sewer system, human life and the environment from non- domestic dischargers on the collection system. • In other words….. • Knowing what’s on the system, what’s being discharged and making sure that it’s not going to screw anything up. Environmental Awareness Over Time

• Age of Enlightenment (1650-1810): People were just starting to link health hazards with environmental pollution • Industrial Revolution (1810 – 1890): Birth of environmental science and common interest growing in clean drinking water and sanitation. • Progressive Movement (1890-1920): Reform of working conditions, slum housing, food adulteration, sanitation, drinking water, polluting industries, hunting laws and mining practices. • 20th Century (1920-1999): Laws are enacted to protect the environment. EPA and other regulatory agencies are created. • 21st Century (2000-present): Global droughts and fresh water shortages as weather patterns change. Regulations tighten to protect fresh water sources. Why Do We Regulate Industry? Pittsburgh Pa - November 25, 1913. Explosion along 33rd Street, destroyed 5300 feet of a 10’ x 8’ trunk line. Sewer containing solvents and “pickling juice” backed up and then ignited. Pittsburgh Bottling’s walls were pushed several inches away by the blast, that took place 20 feet away and 15 feet below the ground. Pittsburgh Rivet: 10 feet from the blast, the entire exterior wall destroyed. Petroleum Products: Two 12,000 gallon gasoline tanks, 25 tons each, on top of the explosion, were lifted several inches. Why do we regulate Industry? Chicago Ill – May 30th, 1937 One man is killed and two others injured when a sewer gas explosion launches a manhole cover over 75 feet into the air. The cover crashed through a skylight of a nearby building and down an elevator shaft. Why do we regulate Industry? Louisville KY – February 13, 1981 A hexane discharged from a Ralston Purina plant ignited in the sewer. The explosion destroyed 13 miles of sewer Took 20 months to repair Cost Ralston Purina $27.9 million dollars. Why do we Regulate Industry? and the Environment 88 Sites in Michigan - Tittabawassee/Saginaw River (Midland) - Tar Lake (Mancelona) - Ossineke Ground Water (Alpena) - Northernaire Plating (Cadillac) - Clare Water Supply (Clare) - Charlevoix Municipal Water (Charlevoix) - Torch Lake (Houghton) 365 Superfund Sites in EPA Region 5 1848 Superfund Sites Total in US. Are U.S. Regulations Effective? Guadalajara Mexico – April 22, 1992 Gasoline in the sewer system exploded, destroying 5 miles of the sewer. 252 people confirmed dead 500 people injured 600 people still missing 15,000 people left homeless Estimates range from $300M to $1B in damages. Laws for Industrial Pretreatment

• Rivers and Harbor Act 1899 (Refuse Act) • The Federal Control Act of 1948. • (CWA) (1972) • 40 CFR 403 (1981) • The Federal regulations regarding Industrial Pretreatment • Among other things, it says that State and Local laws can supersede it, if those are more strict regulations. • Michigan 323 Part 23 • Lists the minimum requirements for Industrial discharges from the state level. • Local Ordinances (SUO) • Lists the requirements for discharge to local POTWs • Site Specific (Local Limits) based on capabilities each WWTP IMHO….IPP All Comes Down to This

• 40 CFR 403.5(a)(1) • General prohibitions. A User may not introduce into a POTW any pollutant(s) which cause Pass Through or Interference. • These general prohibitions and the specific prohibitions in paragraph (b) of this section apply to each User introducing pollutants into a POTW whether or not the User is subject to other National Pretreatment Standards or any national, State, or local Pretreatment Requirements. Classifications of Users

• Domestic user (Residential) • Non-Domestic User (Offices, Restaurants, Industries) • Significant Industrial Users • Discharge more than 25K Gallons of water per day • Discharge more than 5% of the POTW’s hydraulic or treatment capacity • Discharges water from a registered Categorical Process • Any other user that the CA feels needs to be regulated. • Categorical Users • A specific type of SIU that discharges non-standard pollutants Tools of the Trade Industrial User’s Surveys Site Inspections Baseline Monitoring Reports Discharge Permits Lab Testing and Flow Meters Pretreatment Devices Oil/Water separators Grease traps Inspection Manholes pH Adjustment Screens Periodic Reporting Sewer Cameras Enforcement Response Plans Finding Problems Before they Start Industrial User’s Surveys: - Identifies SIUs - Identifies Non-Significant Industrial Users - Identifies Users with the potential to disrupt the treatment works. Always ask yourself “What can go wrong?” Know what’s going on in your town. - What businesses are coming to town - What businesses are leaving Build relationships with business owners - Don’t be Walter Peck - Most people want to do the right thing - Engage with them and be a resource - Customer Service is part of our job Dealing With Grease Education is the first and most important step Any food with a fat content, is a potential grease source Not having fryers doesn’t mean that you don’t have grease Grease dumpsters are not the same as grease traps All grease devices need servicing occasionally Drain Cleaners/caustic chemicals and hot water do not make a grease problem go away. It just makes it show up somewhere else. Grease Traps Traps can be under the sink, in the floor, in the basement, plastic, or metal, but they all need cleaning. Grease Interceptors Case Study: FOG On October 28th, 2011 the Sewer Maintenance crew called me with a report of high grease in the sewer. Grease had accumulated at a low spot, where flow slows down. I began at the low spot and worked my way upstream, checking manholes for signs of grease. Case Study: FOG

I pulled inspection manholes, so that I could observe the flow from each building. Case Study: FOG

¾ of a mile away, near the end of that stretch of line, I found this one. Case Study: FOG The establishment was a former Chinese restaurant turned sports bar, with an interceptor….that had never been serviced.

An NOV was issued and the interceptor is now pumped on a regular schedule. Case Study: Rags

Received a call from the sewer maintenance crew, asking us to investigate the cause of frequent callouts to a major lift station. Rags, wash cloths and clothing were being pulled from the pumps. One of the clothing items was labeled with a name, whom we were able to track down as being a resident in a local nursing home. Staff and/or confused residents of the facilities were flushing these materials instead of putting them in the laundry NOVs issued When problems persisted, CA required the installation of pretreatment screens Pop Quiz Pop Quiz: Thank You

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