Tracking the Source of interference at a POTW

1. Tracking the Source of interference at a POTW Jeffrey Uhler

2. Introduction • Mr. Jeffrey Uhler • Pretreatment Coordinator for the City of Portland, Tennessee • Discuss the steps I took to identify and stop the source of interference with the proper operation of our WWTP

3. Job Description • Our job description in pretreatment is to protect the POTW from discharges that may adversely effect the system or be a threat to the health and safety of human beings or the environment and to ensure compliance with all federal, state and local pretreatment regulations

4. Topics of Discussion • Interference • The term Interference means a Discharge which, alone or in conjunction with a discharge or discharges from other sources, both: • (1) Inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal; and • (2) Therefore is a cause of a violation of any requirement of the POTW's NPDES permit (including an increase in the magnitude or duration of a violation) or of the prevention of sewage sludge use or disposal in compliance with the statutory provisions and regulations or permits issued thereunder (or more stringent State or local regulations).

5. Identify the Problem • Feedback from operators of the WWTP • Verify the problem area • Hydraulic • Mechanical • Operational • Eliminate in house possibilities

6. Identify the Problem • Increasingly higher dosage of CL2 needed to achieve disinfection at the WWTP • Caused e-coli violations of NPDES permit • Identify and solve the problem ASAP!

7. Sources of the Problem • Some tools to determine the possible source of interference • IU files, permit applications, past inspection findings, MSDS, etc. • The internet - search engines • Past experiences at the WWTP

8. The Investigation • Visual inspections of lift stations and gravity system feeding each station • Set up automatic samplers to determine the quality of the wastewater at the WWTP headworks, lift stations, manholes, etc.

9. The Investigation • Visit possible IU sources unannounced • Collect samples and conduct inspections • Conduct the investigation keeping in mind your findings could be questioned

10. The Investigation • DOCUMENT everything! • Dates, times, flow rates, observations, people present, conversations, sample locations, COC, etc.

11. Helpful Tools • A fellow employee • two sets of eyes are better than one • A camera • a picture is worth a thousand words • Log book • Electronic documentation • Microsoft Outlook

12. Findings • Discovered an upset condition at a ham processing plant • Observed two employees of the facility watching the event without correcting, diverting or reporting the condition • Results from samples collected confirmed discharge was a slug load

13. Action steps • Set up composite sampler • Took pictures of the events • Documented everything • Continued to sample

18. Facts • During the investigation two more upset conditions were observed • The IU suspended processing and discharging one day that week and the following weekend • The CL2 demand at the WWTP returned to normal during that day and the weekend • When the IU process discharge resumed the CL2 demand at the WWTP increased again

19. Conclusions • The ham processing facility was the cause of interference at the WWTP • An Administrative Order with fines was issued • Total fine amount was $91,000.00

20. Outcome • The IU appealed the amount of the fines • None of the results or findings were appealed by the IU, only the fine amount • Final fine amount was $60,000

21. Outcome • $30,000 fine • $15,000 used for employee training • $15,000 used for treatment facility improvements