Please use this site to submit your comments regarding the proposed sewer use ordinance.
Thank You,
Decatur Utilities
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For Industrial users who currently discharge without an SID that will fall into category 2I, consider removal of the monthly self-monitoring requirements. Discharges in this category may be infrequent and monthly samples may not be obtainable placing a burden on industry to analyze or demonstrate there was no discharge to sample. Also, the analytical for monthly sampling can potentially cost more then collection and transport to other wwt facilities.
An analysis and approval prior to discharge and at most, annual certification should be sufficient for this category of discharge.
The proposed ordinance may result in many users electing new types of pretreatment to avoid the new surcharges. These new pretreatments will need to be approved by DU but many times the initial reviews for process changes do not identify all impacts that a process change can create. These changes could have a negative impact for DU. Has this been considered?
I offer the following comments on behalf of BPA, Inc.
The proposed surcharges on pH are highly unusual and not justified. High pH values are common at metal finishing facilities to achieve effective precipitation of metal hydroxides. It is not uncommon for some metal finishers to operate at pH values from 9.0 to 10.5. Such high pH discharges will likely be beneficial to the sewer system. If the wastewater in a sanitary sewer can be maintained at about 8.5, hydrogen sulfide generation will be minimized. Moreover, it is widely recognized that municipal wastewater has significant buffering capacity. Therefore, we respectfully request that the proposed surcharges on pH be eliminated.
We feel strongly that the only appropriate surcharge on organic strength is BOD5. The oxygen demand at the wastewater treatment plant is primarily dependent on the amount of biodegradable organics and ammonia-N loading in the raw wastewater. Using COD as the surcharge parameter is inappropriate because COD includes biodegradable and nonbiodegradable organics. Nonbiodegradable organics should not exert an oxygen demand on the wastewater treatment plant (WWTP). Some of these nonbiodegradable organics may be removed during treatment by adsorption into the biomass, setting, etc. However, the impact on oxygen requirements in the process should be negligible. In other words, the nonbiodegradable fraction of the COD should not impact WWTP operating costs. In addition, the Dry Creek WWTP has no requirements for COD removal. Therefore, we respectfully request that the surcharges proposed on COD be eliminated.
We feel that the increase in the BOD surcharge rate from $.02/lb above 250 mg/L to as high as $0.25/lb above 3,000 mg/L will pose an unfair financial burden on some small industries with low flow but high BOD concentrations. Industries such as dairies, food processors, soft drink bottling plants, meat processors, and others will be facing an extreme increase in their BOD surcharges. For industries with BOD5 levels above 3,000 mg/L, this is a 1150% increase in rates. Based on the size of the Dry Creek WWTP, we respectfully request that the surcharge rate on BOD5 be $.05/lb for concentrations exceeding 250 mg/L. In other words, the step 2 and step 3 surcharge rates should be eliminated. The $0.05/lb rate amounts to a 150% increase in rates and would be more feasible for industries that will be adversely impacted by the proposed rates.
We respectfully request that the maximum allowable concentrations for TKN and ammonia-N be eliminated. The Dry Creek WWTP has no limits on TKN or ammonia-N at the present time. If the city is having problems with an industry that discharges TKN and/or ammonia-N, DU can work with ADEM to establish an appropriate mass limit (lb/day) in that discharger’s pretreatment permit. If the city decides to impose upper limits on TKN and ammonia-N, we suggest that the maximum allowable concentrations be 2000 mg/L (TKN) and 1000 mg/L (ammonia-N).
We feel that the current limit on sulfate of 500 mg/L is adequate to protect DU’s sewer system and WWTP. The spring upset at the Dry Creek WWTP may have been exacerbated by slightly elevated sulfate levels. Nevertheless, if the primary clarifiers had not held the raw wastewater so long and if the aeration system delivered the amount of oxygen it was designed to deliver, the low dissolved oxygen levels and sulfide odor problems at the aeration basins likely would not have occurred. Thus, we feel that the proposed base allowance level on sulfate of 250 mg/L is too stringent.
The proposed surcharge rates on sulfate are especially high. Most cities do not surcharge its industrial customers for high sulfate concentrations. Sulfates should not add to the cost of the WWTP as long as the wastewater is kept aerobic. If DU restores the aeration capacity to its design level and provides appropriate detention times in the primary clarifiers, sulfates should have minimal impact on the cost of operating the Dry Creek WWTP. We respectfully request that the Step 2 and Step 3 surcharge rates on sulfate be eliminated. If the city implements a surcharge on sulfate, the rate should be $0.02/lb for concentrations above 500 mg/L.
We feel that the surcharges on chlorides are inappropriate. The literature indicates that activated sludge biomass can become acclimated to chloride concentrations as high as 50,000 mg/L and still produce excellent effluent quality. Moreover, we are not aware of any problems caused by chloride at the Dry Creek WWTP. Chloride also does not add to the cost of operating the WWTP, and the WWTP has no effluent limits on chloride. Therefore, we respectfully request that the proposed surcharges on chloride be eliminated. We also respectfully request that the maximum allowable concentration of 10,000 mg/L be eliminated. If an industry discharges excessive loadings of chloride, then DU in conjunction with ADEM can establish an appropriate mass chloride limit in that industry’s pretreatment permit. In other words, chloride should be addressed on a case-by-case basis.
We respectfully request that the limit on chlorine demand and the surcharge on chlorine demand be eliminated. High strength organic wastewaters would be expected to have a high chlorine demand. However, most of the organic matter entering the WWTP will be removed during the biological treatment process. The chlorine demand test is best applied at the influent to the chlorine contact basin. If an industry is contributing constituents that pass through the activated sludge process and exert a significant chlorine demand, DU and ADEM should establish an appropriate mass limit on those particular constituents.
We appreciate the opportunity to make these comments and trust that DU will give serious consideration to them as it seeks to finalize the revised Sewer Use Ordinance and the revised surcharge rates.
To the Municipal Utilities Board of the City of Decatur:
The following comments are submitted on behalf of United Launch Alliance (ULA), LLC – Decatur Operations:
Part III Section B “Charges and Fees”(1, 2, and 3) – The application of fees for reimbursement of operating costs, monitoring, inspections, surveillance procedures, and reviewing procedures seems inappropriate. It is anticipated that the functions listed in items 1, 2, and 3 are current roles performed during day to day operations of the DU municipal wastewater program and would be expected to by captured by existing budgets.
ULA formerly requests that these specific fees be removed from consideration.
Part IV Section E “Compliance Tracking” (3) – There is no defined requirement for compliance sampling inspections. The requirement for a CSI should be driven by some type of indicator, such as a non-compliant discharge on a category 3 discharger’s monthly DMR or a questionable parameter. The existing language in this section does not define when a CSI would be imposed. Also, the text does not indicate the type of sample (i.e. grab / composite) that would be required from a category 3 discharger. When being placed on a CSI, it is the feeling of ULA that three samples a month is excessive. Also, the further sampling description for being placed on the compliance tracking program seems very excessive. A sampling program as described will be an unnecessary burden for dischargers who immediately know why and how a contaminant was released. If the discharger can prove that a quick, compliant response together with effective corrective actions was successful to ensure future compliant discharges, then the excessive sampling would simply be a waste of physical and budgetary resources for the discharger.
ULA formerly requests that the requirements for CSIs be guided by the existing, monthly SID DMR requirement for category 3 dischargers. Also, ULA requests that the maximum number of monthly samples be set at two and not three. The defined requirement, together with the type of sample, should be reflected in section E paragraph 3. ULA further requests that consideration be given to the discharger’s understanding of the suspect discharge and the effectiveness of any associated corrective actions prior to being placed on a CSI.
Part V Section C “Special Charges and Contracts” – The base allowances for several parameters seem inappropriate. Regarding parameters for pH, the 5–9 su base allowance will be burdensome for dischargers; specifically smaller volume dischargers who may engage in metals finishing operations. The 10.5 maximum allows much more flexibility while producing discharge waters that typically are not considered detrimental to the treatment process. The proposed sulfate base allowance of 250 mg/l is very stringent. Currently, waste treatment operations observe the 500 mg/l limit and treatment within this parameter has proved successful. There has been information stated that there may have been issues surrounding the treatment process involving the clarifiers and the aeration system. This being the case, then there seems to be no justified reason to lower the sulfate base allowance to 250 mg/l. Domestic water provided to the ULA facility reflects a consistent sulfate reading between 30 – 40 mg/l on a daily basis; this being the fact, then we already start out with a sulfate discharge deficit when simply discharging rinse waters. Also, data compiled on other industrial cities in the southeast and east coast reflect, without exception, a 500 mg/l sulfate base allowance. The proposed molybdenum base allowance of 1 mg/l is very low and will place a heavy burden on smaller dischargers. Landfill treatment sludge limits have been set by the US EPA at 75 mg/l; the suggested limit of 1 mg/l for wastewaters is excessively low and compliant landfill sludge could be achieved with base allowances upwards of 20 mg/l for molybdenum. Also, please consider the numerous sources from non-industrial customers that could be elevating molybdenum levels such as car washes, maintenance shops, local garages, etc. Unmonitored businesses such as these could provide heavy molybdenum contamination with the contaminate burden going unduly to the industrial customer.
ULA respectfully requests that the pH parameter base allowance be set at 10.5 su; the sulfate parameter base allowance be set no lower that 500 mg/l; and the molybdenum base allowance be raised to a more appropriate limit for industrial customers.
Non-Domestic Sewer Fee Schedule – Surcharge Rates – ULA realizes the necessity of surcharge rates to properly administer a successful wastewater treatment program. However, as stated previously, the pH base allowances of 5-9 su is unusual and a surcharge fee on waters between 9-10.5 su seems unjustified. Also, it does seem inconsistent that a customer could discharge waters with a pH of less than 5 su and not incur a surcharge. ULA requests that the surcharge for wastewater between 9-10.5 su be eliminated.
Other parameters such as BOD, Sulfates, Oil & Grease, and Molybdenum reflect surcharges that could be a heavy financial burden to industrial customers. As indicated in the initial draft ordnance meeting, small to mid-range dischargers will struggle to meet the surcharge fees as currently defined. Also, large wastewater dischargers may be forced to incorporate additional waste treatment technologies that will require planning and budget to meet the updated ordnance. Treatment modifications will require the proper time to implement and improperly defined ordnance will physically and financially burden even large dischargers.
ULA respectfully requests that the proposed surcharges for BOD, Sulfates, Oil & Grease, and Molybdenum be significantly lowered to reflect more manageable fees for business owners and corporate industry.
Milk Products of Alabama offers the following comments on the proposed sewer use ordinance.
1. pH — a tiered pH limit is unusual and unnecessary if the pH is acceptable in a range from 5-10.5 then that should be the ordinance range. A surcharge for pH above 9 and up to 10.5 is very unnusual. Does the utility experience additional cost when wastewater is dischard at pH’s between 9 and 10.5? If there is no additional treatment cost then no surcharge is necessary. Also, U.S.E.P.A. pretreatment general prohibitions only addresses pH below 5.0. How was the upper limit determined?
2. Why is the temperature prohibition at the introduction to the wastewater collection system and not at the headworks of the wastewater treatment plant as U.S.E.P.A regulations allow.
3. We request the chlorine demand limit be removed since chlorine demand measures organic strength which is already being measured by BOD and COD.
4. Surcharge Structure
We request that the step method of surcharging be eliminated in favor on a more widely recognized method of surcharging for high strength wastes. Either the quantity/quality method when all BOD, TSS etc is paid for at the same rate starting with pound one or the more widely use method where the domestic concentration is substracted from the average concentration of the various parameters and the excess pounds are calculated and the same rate then applies to all pounds in excess.
Since the treatment plant does not recognize a pound of BOD at 3000 mg/l differently than a pound of BOD at 250 mg/l the rate should reflect what it costs to remove a pound of BOD. A pound of BOD (or any other parameter) is a pound of BOD and the cost to remove it doesn’t change with concentration.
Also having a step surcharge discourages water conservation projects since by conserving water you may go up a step in surcharge cost if it concentrates BOD, TSS, etc. Step surcharge systems encourages water use.
5. Lastly, many of the surcharge parameters are also listed as limits. We request that language be added that clearly states that exceeding the base concentration is not a violation of the permit, contract or ordinance.
We thank you for the opportunity to comment on this draft sewer use ordinance.
Recommend you Define Accident Discharge.
Definition of Cool Water doesn’t include Cooling Tower water with additives.
Part II.A. 2 – Most POTWs prefer to receive pH up to 10
Part II A. 10 – Suggest revising sentence to state “Any regulated pollutants”. Comment: It would be extremely difficult for regulated dischargers to proactively monitor their compliance with this condition short of installing continuous monitoring for all regulated pollutants. From our understanding this is not practical for many pollutant such as metals. Not enough data to know when we are exceeding in the absence of continuous monitoring.
Part II A. 13 – What is the process for obtaining approval? Example storm water (from air compressor condensate, HVAC condensate, containment basins, dikes, et. that is not allowed to discharge to river but within POTW limits.
Part II E. 1 – Where is this temp measured? Should this section be left to prohibitions IIA9. Comment: Exceedance of these parameters in section II, are they considered contract violations or are they just permitted levels subject to extra wastewater surcharges.
Part II E. 7 – Should this section be left to prohibitions in IIA3.
Part II E. 9 – 250 mg/l – Isn’t this low for sanitary waste.
Part II E. 11 – Should this section be left to prohibitions in IIA10.
Part II E. 16 & 17 – Should this section be combined with E2.
Part II I. – Recommend last sentence read “In case of an accidental discharge of a prohibited material or regulated pollutant outside of acceptable range established under Part II E., it is the responsibility of the User to ..”
Part II I. 2 –Recommend read “Within five (d) business days.” include 24-hour telephone number.
Part II I. 3 – Who to call – Does that mean site EHS Leader from site to make call or employee to call DU directly? Recommend Leadership of site make call to DU.
Part IV A 3 – This is considerable additional expense for those who don’t have SID permits. Additional costs up to 52K in just monitoring.
Part IV E 1 – For potential 2I discharges monthly will add significant costs, especially when many parameters are well below the allowable concentrations. Recommendation: Change to once a year, every six months or a maximum of quarterly. Recommendation: In contracts for those with out SID permits, that some parameters be removed from self-monitoring based on historical data.
• Though the intention of the draft DU Surcharge Rate Schedule from July 2007 may be to distribute treatment costs, Wayne Farms views the suggested surcharge schedule as punitive to current industrial dischargers with long-established constituent concentration and loading levels. For example, the proposed BOD5 schedule for Surcharge Step 1 applies a $0.05/lb fee for monthly average concentrations greater than 250 mg/l – 2.5 times the current rate of $0.02/lb! We suggest keeping the current cost of $0.02/lb for BOD5 greater than 250 mg/l, with an increase to $0.05/lb for monthly average BOD5 concentrations greater than 500 mg/l.
• The new COD and chlorine demand monitoring requirements will multiply the costs for the same organic loading currently monitored by BOD5 testing many times – not only with multiple constituent surcharges, but also through increased monitoring and treatment costs.
• We share the same view as a prior commenter, that the step-surcharge system discourages water conservation and reuse initiatives. Any concentration of Surcharge Constituents, as expected through conservation measures, is counterintuitive to the best interests of the Discharger under the proposed Surcharge Rate Schedule, and ultimately the optimal operation of the city’s Wastewater Treatment System.
• With all due respect, the requirement for all category 2FS and 3 dischargers to monitor for Molybdenum and Total Toxic Organics is excessive and unnecessary. The July 2007 Draft Sewer Use Ordinance makes provisions for non-compliant dischargers in Section Part II A.7…”A user may not discharge to the BOARD’s wastewater collection and treatment facilities…any substance which will cause the BOARD’s wastewater facilities to violate its NPDES and/or State Disposal System Permit or the receiving water quality standards.” In addition Section E makes provisions for suspending the service of a discharger which “…causes interference to the BOARD’s Wastewater Collection and Treatment System or causes the BOARD to violate any condition of its NPDES Permit.”
Wayne Farms understands the intent of the BOARD is to protect the city’s Wastewater Treatment System, but to require continual monitoring for suspected toxics from all categorical dischargers is not justified. We ask you to consider the specific source of toxic inhibitors to the operation of the Wastewater Treatment System and to address those dischargers on an “as-needed” basis.
I think I speak for the entire industrial community when I say that we all feel like DU is not listening to us. When good supportive data is presented in support of a suggested change to the draft ordnance it is simply discounted. It is the opinion of a great majority of the Decatur industrial community that the DU meetings have simply been a waste of time. Where applicable, Decatur industry should explore an NPDES surface discharge permit.
December 11, 2007 at 2:05 pm
For Industrial users who currently discharge without an SID that will fall into category 2I, consider removal of the monthly self-monitoring requirements. Discharges in this category may be infrequent and monthly samples may not be obtainable placing a burden on industry to analyze or demonstrate there was no discharge to sample. Also, the analytical for monthly sampling can potentially cost more then collection and transport to other wwt facilities.
An analysis and approval prior to discharge and at most, annual certification should be sufficient for this category of discharge.
December 11, 2007 at 2:06 pm
The proposed ordinance may result in many users electing new types of pretreatment to avoid the new surcharges. These new pretreatments will need to be approved by DU but many times the initial reviews for process changes do not identify all impacts that a process change can create. These changes could have a negative impact for DU. Has this been considered?
December 11, 2007 at 2:07 pm
I offer the following comments on behalf of BPA, Inc.
The proposed surcharges on pH are highly unusual and not justified. High pH values are common at metal finishing facilities to achieve effective precipitation of metal hydroxides. It is not uncommon for some metal finishers to operate at pH values from 9.0 to 10.5. Such high pH discharges will likely be beneficial to the sewer system. If the wastewater in a sanitary sewer can be maintained at about 8.5, hydrogen sulfide generation will be minimized. Moreover, it is widely recognized that municipal wastewater has significant buffering capacity. Therefore, we respectfully request that the proposed surcharges on pH be eliminated.
We feel strongly that the only appropriate surcharge on organic strength is BOD5. The oxygen demand at the wastewater treatment plant is primarily dependent on the amount of biodegradable organics and ammonia-N loading in the raw wastewater. Using COD as the surcharge parameter is inappropriate because COD includes biodegradable and nonbiodegradable organics. Nonbiodegradable organics should not exert an oxygen demand on the wastewater treatment plant (WWTP). Some of these nonbiodegradable organics may be removed during treatment by adsorption into the biomass, setting, etc. However, the impact on oxygen requirements in the process should be negligible. In other words, the nonbiodegradable fraction of the COD should not impact WWTP operating costs. In addition, the Dry Creek WWTP has no requirements for COD removal. Therefore, we respectfully request that the surcharges proposed on COD be eliminated.
We feel that the increase in the BOD surcharge rate from $.02/lb above 250 mg/L to as high as $0.25/lb above 3,000 mg/L will pose an unfair financial burden on some small industries with low flow but high BOD concentrations. Industries such as dairies, food processors, soft drink bottling plants, meat processors, and others will be facing an extreme increase in their BOD surcharges. For industries with BOD5 levels above 3,000 mg/L, this is a 1150% increase in rates. Based on the size of the Dry Creek WWTP, we respectfully request that the surcharge rate on BOD5 be $.05/lb for concentrations exceeding 250 mg/L. In other words, the step 2 and step 3 surcharge rates should be eliminated. The $0.05/lb rate amounts to a 150% increase in rates and would be more feasible for industries that will be adversely impacted by the proposed rates.
We respectfully request that the maximum allowable concentrations for TKN and ammonia-N be eliminated. The Dry Creek WWTP has no limits on TKN or ammonia-N at the present time. If the city is having problems with an industry that discharges TKN and/or ammonia-N, DU can work with ADEM to establish an appropriate mass limit (lb/day) in that discharger’s pretreatment permit. If the city decides to impose upper limits on TKN and ammonia-N, we suggest that the maximum allowable concentrations be 2000 mg/L (TKN) and 1000 mg/L (ammonia-N).
We feel that the current limit on sulfate of 500 mg/L is adequate to protect DU’s sewer system and WWTP. The spring upset at the Dry Creek WWTP may have been exacerbated by slightly elevated sulfate levels. Nevertheless, if the primary clarifiers had not held the raw wastewater so long and if the aeration system delivered the amount of oxygen it was designed to deliver, the low dissolved oxygen levels and sulfide odor problems at the aeration basins likely would not have occurred. Thus, we feel that the proposed base allowance level on sulfate of 250 mg/L is too stringent.
The proposed surcharge rates on sulfate are especially high. Most cities do not surcharge its industrial customers for high sulfate concentrations. Sulfates should not add to the cost of the WWTP as long as the wastewater is kept aerobic. If DU restores the aeration capacity to its design level and provides appropriate detention times in the primary clarifiers, sulfates should have minimal impact on the cost of operating the Dry Creek WWTP. We respectfully request that the Step 2 and Step 3 surcharge rates on sulfate be eliminated. If the city implements a surcharge on sulfate, the rate should be $0.02/lb for concentrations above 500 mg/L.
We feel that the surcharges on chlorides are inappropriate. The literature indicates that activated sludge biomass can become acclimated to chloride concentrations as high as 50,000 mg/L and still produce excellent effluent quality. Moreover, we are not aware of any problems caused by chloride at the Dry Creek WWTP. Chloride also does not add to the cost of operating the WWTP, and the WWTP has no effluent limits on chloride. Therefore, we respectfully request that the proposed surcharges on chloride be eliminated. We also respectfully request that the maximum allowable concentration of 10,000 mg/L be eliminated. If an industry discharges excessive loadings of chloride, then DU in conjunction with ADEM can establish an appropriate mass chloride limit in that industry’s pretreatment permit. In other words, chloride should be addressed on a case-by-case basis.
We respectfully request that the limit on chlorine demand and the surcharge on chlorine demand be eliminated. High strength organic wastewaters would be expected to have a high chlorine demand. However, most of the organic matter entering the WWTP will be removed during the biological treatment process. The chlorine demand test is best applied at the influent to the chlorine contact basin. If an industry is contributing constituents that pass through the activated sludge process and exert a significant chlorine demand, DU and ADEM should establish an appropriate mass limit on those particular constituents.
We appreciate the opportunity to make these comments and trust that DU will give serious consideration to them as it seeks to finalize the revised Sewer Use Ordinance and the revised surcharge rates.
December 11, 2007 at 2:08 pm
Is there any update from Decatur Utilities on progress of the draft or if and when there will be another meeting? Please update.
December 11, 2007 at 2:09 pm
To the Municipal Utilities Board of the City of Decatur:
The following comments are submitted on behalf of United Launch Alliance (ULA), LLC – Decatur Operations:
Part III Section B “Charges and Fees”(1, 2, and 3) – The application of fees for reimbursement of operating costs, monitoring, inspections, surveillance procedures, and reviewing procedures seems inappropriate. It is anticipated that the functions listed in items 1, 2, and 3 are current roles performed during day to day operations of the DU municipal wastewater program and would be expected to by captured by existing budgets.
ULA formerly requests that these specific fees be removed from consideration.
Part IV Section E “Compliance Tracking” (3) – There is no defined requirement for compliance sampling inspections. The requirement for a CSI should be driven by some type of indicator, such as a non-compliant discharge on a category 3 discharger’s monthly DMR or a questionable parameter. The existing language in this section does not define when a CSI would be imposed. Also, the text does not indicate the type of sample (i.e. grab / composite) that would be required from a category 3 discharger. When being placed on a CSI, it is the feeling of ULA that three samples a month is excessive. Also, the further sampling description for being placed on the compliance tracking program seems very excessive. A sampling program as described will be an unnecessary burden for dischargers who immediately know why and how a contaminant was released. If the discharger can prove that a quick, compliant response together with effective corrective actions was successful to ensure future compliant discharges, then the excessive sampling would simply be a waste of physical and budgetary resources for the discharger.
ULA formerly requests that the requirements for CSIs be guided by the existing, monthly SID DMR requirement for category 3 dischargers. Also, ULA requests that the maximum number of monthly samples be set at two and not three. The defined requirement, together with the type of sample, should be reflected in section E paragraph 3. ULA further requests that consideration be given to the discharger’s understanding of the suspect discharge and the effectiveness of any associated corrective actions prior to being placed on a CSI.
Part V Section C “Special Charges and Contracts” – The base allowances for several parameters seem inappropriate. Regarding parameters for pH, the 5–9 su base allowance will be burdensome for dischargers; specifically smaller volume dischargers who may engage in metals finishing operations. The 10.5 maximum allows much more flexibility while producing discharge waters that typically are not considered detrimental to the treatment process. The proposed sulfate base allowance of 250 mg/l is very stringent. Currently, waste treatment operations observe the 500 mg/l limit and treatment within this parameter has proved successful. There has been information stated that there may have been issues surrounding the treatment process involving the clarifiers and the aeration system. This being the case, then there seems to be no justified reason to lower the sulfate base allowance to 250 mg/l. Domestic water provided to the ULA facility reflects a consistent sulfate reading between 30 – 40 mg/l on a daily basis; this being the fact, then we already start out with a sulfate discharge deficit when simply discharging rinse waters. Also, data compiled on other industrial cities in the southeast and east coast reflect, without exception, a 500 mg/l sulfate base allowance. The proposed molybdenum base allowance of 1 mg/l is very low and will place a heavy burden on smaller dischargers. Landfill treatment sludge limits have been set by the US EPA at 75 mg/l; the suggested limit of 1 mg/l for wastewaters is excessively low and compliant landfill sludge could be achieved with base allowances upwards of 20 mg/l for molybdenum. Also, please consider the numerous sources from non-industrial customers that could be elevating molybdenum levels such as car washes, maintenance shops, local garages, etc. Unmonitored businesses such as these could provide heavy molybdenum contamination with the contaminate burden going unduly to the industrial customer.
ULA respectfully requests that the pH parameter base allowance be set at 10.5 su; the sulfate parameter base allowance be set no lower that 500 mg/l; and the molybdenum base allowance be raised to a more appropriate limit for industrial customers.
Non-Domestic Sewer Fee Schedule – Surcharge Rates – ULA realizes the necessity of surcharge rates to properly administer a successful wastewater treatment program. However, as stated previously, the pH base allowances of 5-9 su is unusual and a surcharge fee on waters between 9-10.5 su seems unjustified. Also, it does seem inconsistent that a customer could discharge waters with a pH of less than 5 su and not incur a surcharge. ULA requests that the surcharge for wastewater between 9-10.5 su be eliminated.
Other parameters such as BOD, Sulfates, Oil & Grease, and Molybdenum reflect surcharges that could be a heavy financial burden to industrial customers. As indicated in the initial draft ordnance meeting, small to mid-range dischargers will struggle to meet the surcharge fees as currently defined. Also, large wastewater dischargers may be forced to incorporate additional waste treatment technologies that will require planning and budget to meet the updated ordnance. Treatment modifications will require the proper time to implement and improperly defined ordnance will physically and financially burden even large dischargers.
ULA respectfully requests that the proposed surcharges for BOD, Sulfates, Oil & Grease, and Molybdenum be significantly lowered to reflect more manageable fees for business owners and corporate industry.
December 11, 2007 at 2:10 pm
Milk Products of Alabama offers the following comments on the proposed sewer use ordinance.
1. pH — a tiered pH limit is unusual and unnecessary if the pH is acceptable in a range from 5-10.5 then that should be the ordinance range. A surcharge for pH above 9 and up to 10.5 is very unnusual. Does the utility experience additional cost when wastewater is dischard at pH’s between 9 and 10.5? If there is no additional treatment cost then no surcharge is necessary. Also, U.S.E.P.A. pretreatment general prohibitions only addresses pH below 5.0. How was the upper limit determined?
2. Why is the temperature prohibition at the introduction to the wastewater collection system and not at the headworks of the wastewater treatment plant as U.S.E.P.A regulations allow.
3. We request the chlorine demand limit be removed since chlorine demand measures organic strength which is already being measured by BOD and COD.
4. Surcharge Structure
We request that the step method of surcharging be eliminated in favor on a more widely recognized method of surcharging for high strength wastes. Either the quantity/quality method when all BOD, TSS etc is paid for at the same rate starting with pound one or the more widely use method where the domestic concentration is substracted from the average concentration of the various parameters and the excess pounds are calculated and the same rate then applies to all pounds in excess.
Since the treatment plant does not recognize a pound of BOD at 3000 mg/l differently than a pound of BOD at 250 mg/l the rate should reflect what it costs to remove a pound of BOD. A pound of BOD (or any other parameter) is a pound of BOD and the cost to remove it doesn’t change with concentration.
Also having a step surcharge discourages water conservation projects since by conserving water you may go up a step in surcharge cost if it concentrates BOD, TSS, etc. Step surcharge systems encourages water use.
5. Lastly, many of the surcharge parameters are also listed as limits. We request that language be added that clearly states that exceeding the base concentration is not a violation of the permit, contract or ordinance.
We thank you for the opportunity to comment on this draft sewer use ordinance.
December 11, 2007 at 2:10 pm
Recommend you Define Accident Discharge.
Definition of Cool Water doesn’t include Cooling Tower water with additives.
Part II.A. 2 – Most POTWs prefer to receive pH up to 10
Part II A. 10 – Suggest revising sentence to state “Any regulated pollutants”. Comment: It would be extremely difficult for regulated dischargers to proactively monitor their compliance with this condition short of installing continuous monitoring for all regulated pollutants. From our understanding this is not practical for many pollutant such as metals. Not enough data to know when we are exceeding in the absence of continuous monitoring.
Part II A. 13 – What is the process for obtaining approval? Example storm water (from air compressor condensate, HVAC condensate, containment basins, dikes, et. that is not allowed to discharge to river but within POTW limits.
Part II E. 1 – Where is this temp measured? Should this section be left to prohibitions IIA9. Comment: Exceedance of these parameters in section II, are they considered contract violations or are they just permitted levels subject to extra wastewater surcharges.
Part II E. 7 – Should this section be left to prohibitions in IIA3.
Part II E. 9 – 250 mg/l – Isn’t this low for sanitary waste.
Part II E. 11 – Should this section be left to prohibitions in IIA10.
Part II E. 16 & 17 – Should this section be combined with E2.
Part II I. – Recommend last sentence read “In case of an accidental discharge of a prohibited material or regulated pollutant outside of acceptable range established under Part II E., it is the responsibility of the User to ..”
Part II I. 2 –Recommend read “Within five (d) business days.” include 24-hour telephone number.
Part II I. 3 – Who to call – Does that mean site EHS Leader from site to make call or employee to call DU directly? Recommend Leadership of site make call to DU.
Part IV A 3 – This is considerable additional expense for those who don’t have SID permits. Additional costs up to 52K in just monitoring.
Part IV E 1 – For potential 2I discharges monthly will add significant costs, especially when many parameters are well below the allowable concentrations. Recommendation: Change to once a year, every six months or a maximum of quarterly. Recommendation: In contracts for those with out SID permits, that some parameters be removed from self-monitoring based on historical data.
December 11, 2007 at 2:12 pm
• Though the intention of the draft DU Surcharge Rate Schedule from July 2007 may be to distribute treatment costs, Wayne Farms views the suggested surcharge schedule as punitive to current industrial dischargers with long-established constituent concentration and loading levels. For example, the proposed BOD5 schedule for Surcharge Step 1 applies a $0.05/lb fee for monthly average concentrations greater than 250 mg/l – 2.5 times the current rate of $0.02/lb! We suggest keeping the current cost of $0.02/lb for BOD5 greater than 250 mg/l, with an increase to $0.05/lb for monthly average BOD5 concentrations greater than 500 mg/l.
• The new COD and chlorine demand monitoring requirements will multiply the costs for the same organic loading currently monitored by BOD5 testing many times – not only with multiple constituent surcharges, but also through increased monitoring and treatment costs.
• We share the same view as a prior commenter, that the step-surcharge system discourages water conservation and reuse initiatives. Any concentration of Surcharge Constituents, as expected through conservation measures, is counterintuitive to the best interests of the Discharger under the proposed Surcharge Rate Schedule, and ultimately the optimal operation of the city’s Wastewater Treatment System.
• With all due respect, the requirement for all category 2FS and 3 dischargers to monitor for Molybdenum and Total Toxic Organics is excessive and unnecessary. The July 2007 Draft Sewer Use Ordinance makes provisions for non-compliant dischargers in Section Part II A.7…”A user may not discharge to the BOARD’s wastewater collection and treatment facilities…any substance which will cause the BOARD’s wastewater facilities to violate its NPDES and/or State Disposal System Permit or the receiving water quality standards.” In addition Section E makes provisions for suspending the service of a discharger which “…causes interference to the BOARD’s Wastewater Collection and Treatment System or causes the BOARD to violate any condition of its NPDES Permit.”
Wayne Farms understands the intent of the BOARD is to protect the city’s Wastewater Treatment System, but to require continual monitoring for suspected toxics from all categorical dischargers is not justified. We ask you to consider the specific source of toxic inhibitors to the operation of the Wastewater Treatment System and to address those dischargers on an “as-needed” basis.
December 11, 2007 at 2:13 pm
I think I speak for the entire industrial community when I say that we all feel like DU is not listening to us. When good supportive data is presented in support of a suggested change to the draft ordnance it is simply discounted. It is the opinion of a great majority of the Decatur industrial community that the DU meetings have simply been a waste of time. Where applicable, Decatur industry should explore an NPDES surface discharge permit.