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Got Capacity? A Case for Special Allocation Limits

This presentation discusses how Special Allocation Limits (SALs) can effectively enhance the recovery of costs associated with treating extra-strength industrial waste. With traditional methods resulting in untapped capacity and potential revenue loss, SALs offer a flexible solution by allowing tailored limits for industrial users while improving overall asset utilization. By using methodologies based on USEPA software, utilities can accurately update rates and better adapt to local needs. Implementing SALs promotes economic development by attracting new industries and increases surcharge revenues, all while ensuring compliance with regulatory standards.

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Got Capacity? A Case for Special Allocation Limits

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  1. Got Capacity?A Case for Special Allocation Limits Jerald O. Thaler, P.E.

  2. Previously • Surcharge Rate Updates/A 21st Century Approach (MWEA Administrators Conference, January 2010) • Surcharges recover cost of treating extra-strength industrial waste • Rates should be regularly updated to current costs • New methodology based on USEPA software • More accurate O&M cost breakdown • Straightforward calibration • Efficient annual updates For copy of presentation, please e-mail jothaler@ftch.com

  3. Program • Objective Discuss advantages of combining SALs with extra-strength surcharge program • Agenda • The Available Capacity Conundrum • SALs as a Solution • USEPA/MDEQ Position • Implementation • Potential Revenue Impact

  4. IPP Local Limits • Widely successful protecting WWTPs against detrimental effects of industrial wastes • www.michigan.gov/deq

  5. The Available Capacity Conundrum • Many wastewater utilities currently experiencing lower flows and loadings • Magnified by local limits, which are often: • Uniform not-to-exceed concentrations • Applied to all nondomestic users • Difficult to adapt to special needs • Result is available capacity that cannot be accessed and loss of potential revenue

  6. A Solution • Why not more flexible local limits? • Could use available capacity to assist industrial users, thereby promoting local economy • Great match for surchargeable compatibles • Treatable via existing system • Improve asset utilization • Enhance surcharge revenues

  7. Special Allocation Limits • Extension of traditional local limits, with option to assign alternate user-specific limits • Provide the ultimate in flexibility • Rapidly gaining acceptance across MI • Ann Arbor • Bay City • Flint • Genesee County • Lansing • Wyoming

  8. SALs to the Rescue • Dairy-based industry considered locating new facility in community • Requested applicable local limits • Assessed need/cost of pretreatment system • Ended up selecting alternate site in Indiana • Community has available WWTP capacity and interest in increasing surcharge revenues • To improve economic development opportunities in future, now implementing SALs

  9. SALs to the Rescue • Existing landfill facility considering expansion in community • Involved major capital investment • Ongoing issue with ammonia local limits required pretreatment system upgrade • Community has available WWTP capacity and interest in increasing surcharge revenues • To enable treatment to be “subcontracted” to WWTP, now implementing SALs

  10. Traditional Local Limits • MAHL = not-to-exceed mass to protect WWTP • MAIL = portion of MAHL available to SIUs • Uniform allocation of MAIL over total SIU flow

  11. SAL-based Local Limits • Portion of MAIL set aside as reserve • Uniform allocation of MAIL, less reserve, over total SIU flow

  12. USEPA Position on SALs • May select any allocation method producing enforceable local limits which: • Prevent pass-through and interference • Comply with prohibitions in Federal regulations • Subject to review by approval authority

  13. MDEQ Position on SALs • Legal authority in Sewer Use Ordinance • Constraints • Total influent mass cannot exceed MAHL • Total allocated mass, including any septage, cannot exceed MAIL • Assigned limit cannot exceed any applicable collection system limitation • Approvable written procedures

  14. Step 1 – Classify SIUs

  15. Step 2 – Check MAHL/MAIL Status

  16. Step 3 – Select Appropriate SAL

  17. Potential Revenue Impact • As condition of agreement, can use SAL as basis for calculating surcharge

  18. Perspective Got capacity? • Combining SALs with your extra-strength surcharge program can: • Increase asset utilization • Enhance surcharge revenue • Promote local economy

  19. Acronyms • IPP – Industrial Pretreatment Program • MAHL – Maximum Allowable Headworks Loading • MAIL – Maximum Allowable Industrial Loading • MDEQ – Michigan Department of Environmental Quality • O&M – Operating and Maintenance • SAL – Special Allocation Limit • SIU – Significant Industrial User • USEPA – U.S. Environmental Protection Agency • WWTP – Wastewater Treatment Plant

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