1. Water Quality Division Texas Commission on Environmental Quality
Source Control Planning for Municipal Wastewater System Permit Compliance
Water Quality Seminar
Austin, TX.
May 3, 2016
David James
Water Quality Division
Texas Commission on Environmental Quality

2. Source Control Approach
picture of a side view of an activated sludge treatment tank that is overflowing with white foam. What caused this condition?

3. Source Control Planning
1. Identify pollutant(s) of concern
2. Find sources of pollutant(s)
3. Determine control strategies
4. Set realistic reduction goals
5. Implement strategies
6. Monitor progress
7. Reassess and make adjustments
8. Communicate results
1. Identify pollutant(s) of concern
2. Find sources of pollutant(s)
3. Determine control strategies
4. Set realistic reduction goals
5. Implement strategies
6. Monitor progress
7. Reassess and make adjustments
8. Communicate results

4. 1. Identify Pollutant(s) of Concern
What is the concern?
Prohibited discharges into publicly owned treatment works (POTW)?
Excessive wastewater treatment plant (WWTP) loading?
WWTP pass-through & interference?
Texas Surface Water Quality Criteria?
Whole Effluent Toxicity Failures
Toxicity Identification and Reduction Evaluations
Sludge limits
TPDES permit limit violations?
Prohibited discharges into publicly owned treatment works (POTW)?
Excessive wastewater treatment plant (WWTP) loading?
WWTP pass-through & interference?
Texas Surface Water Quality Criteria?
TPDES permit limit violations?
Whole Effluent Toxicity Failures
Toxicity Identification and Reduction Evaluations
Sludge limits

5. Prohibited Discharges to POTWs [40 CFR §403.5(b)]
Pollutants which create a Fire or Explosion Hazard
Pollutants which will cause corrosive damage & not below pH 5.0
Solid or viscous pollutants in amounts which will cause flow obstructions
Any pollutants discharged at a flow rate and/or concentration that will cause interference
Pollutants which create a Fire or Explosion Hazard
Pollutants which will cause corrosive damage & not below pH 5.0
Solid or viscous pollutants in amounts which will cause flow obstructions
Any pollutants discharged at a flow rate and/or concentration that will cause interference

6. Prohibited Discharges to POTWs [40 CFR §403.5(b)]
Heat in amounts which will inhibit biological activities
Oil, non-biodegradable cutting oil, or products of mineral oil origin in amounts which will cause interference or pass through
Pollutants that cause toxic gases, vapors or fumes within the POTW
Any trucked or hauled pollutants, except at discharge points designated by the POTW
Heat in amounts which will inhibit biological activities
Oil, non-biodegradable cutting oil, or products of mineral oil origin in amounts which will cause interference or pass through
Pollutants that cause toxic gases, vapors or fumes within the POTW
Any trucked or hauled pollutants, except at discharge points designated by the POTW

7. 1. Identify Pollutant(s) of Concern
Pollutant Sources
WWTP
Industrial
Commercial
Domestic
Hauled Waste
Other Sources?
Pollutant Sources
WWTP
Industrial
Commercial
Domestic
Hauled Waste
Other Sources?

8. 1. Identify Pollutant(s) of Concern (cont.)
Why might these pollutants and types of facilities be a concern?
Fats, oil, & grease (FOG)
Mercury
Phosphorus
Total Dissolved Solids (TDS)
Breweries
Food Processors
Metal Finishers
Soap & Detergent Mfg.
Why might these pollutants be a concern?
Fats, oil, & grease (FOG)
Mercury
Phosphorus
Total Dissolved Solids (TDS)
Why might these types of facilities be a concern?
Breweries
Food Processors
Metal Finishers
Soap & Detergent Mfg.

9. 1. Identify Pollutant(s) of Concern (cont.)
“Look for diamonds in your backyard”
Chemicals added to the collection system or WWTP
Hauled waste accepted at the WWTP (grease or grit waste, septic, RCRA, CERCLA)
Illegal dumping
Water or wastewater sludge discharged into the collection system
“Look for diamonds in your backyard”
Chemicals added to the collection system or WWTP
Hauled waste accepted at the WWTP (grease or grit waste, septic, RCRA, CERCLA)
Illegal dumping
Water or wastewater sludge discharged into the collection system

10. 2. Find Sources of Pollutant
Identify sewer sub-basins in your collection system
Sample at locations that capture each sub-basin
Identify sub-basins with high pollutant contributions
Sewer Collection System Sub-Basin Map City of Folsom, CA
Identify sewer sub-basins in your collection system
Sample at locations that capture each sub-basin
Identify sub-basins with high pollutant contributions

11. 2. Find Sources of Pollutant (cont.)
Further subdivide identified sub-basins
Identify areas or facilities that are potential contributors of the pollutant(s)
Note types of business, industry, residential area, etc.
Identify potential sources of a pollutant of concern. These may be single facilities (industries, hospitals) or areas with high concentration of similar facilities (restaurants, car washes, laundromats).
Further subdivide identified sub-basins
Identify areas or facilities that are potential contributors of the pollutant(s)
Note types of business, industry, residential area, etc.

12. 3. Determine Prevention and Control Strategies
Further subdivide identified sub-basins
Identify areas or facilities that are potential contributors of the pollutant(s)
Note types of business, industry, residential area, etc.
Further subdivide identified sub-basins
Identify areas or facilities that are potential contributors of the pollutant(s)
Note types of business, industry, residential area, etc.

13. 3. Determine Prevention and Control Strategies (cont.)
Public Education?
Suitable for multiple sources difficult to control (domestic)
Requires dedicated outreach
Sensible to public perception
Continuous effort to maintain desired behavior change
Public Education?
Suitable for multiple sources difficult to control (domestic)
Requires dedicated outreach
Sensible to public perception
Continuous effort to maintain desired behavior change

14. 3. Determine Prevention and Control Strategies (cont.)
Voluntary Reduction?
Suitable for sector-specific identified sources
Best Management Practices (BMPs)
Requires meetings, education, and negotiations
High start-up effort, verification BMPs implemented
Voluntary Reduction?
Suitable for sector-specific identified sources
Best Management Practices (BMPs)
Requires meetings, education, and negotiations
High start-up effort, verification BMPs implemented

15. 3. Determine Prevention and Control Strategies (cont.)
Implement a Partial Pretreatment Program?
Suitable for contributing industrial sources
Requires legal authority (ordinance) and enforcement
See Texas Water Code §26.176
High start-up efforts to develop and implement
May include requirements: permits & effluent limits, BMPs, and fees
Compliance monitoring & inspections
Implement a Partial Pretreatment Program?
Suitable for contributing industrial sources
Requires legal authority (ordinance) and enforcement
See Texas Water Code § (see texas below)
High start-up efforts to develop and implement
May include requirements: permits & effluent limits, BMPs, and fees
Compliance monitoring & inspections
Sec DISPOSAL SYSTEM RULES. (a) Every local government which owns or operates a disposal system is empowered to and shall, except as authorized in Subsection (c) of this section, enact and enforce rules, ordinances, orders, or resolutions, referred to in this section as rules, to control and regulate the type, character, and quality of waste which may be discharged to the disposal system and, where necessary, to require pretreatment of waste to be discharged to the system, so as to protect the health and safety of personnel maintaining and operating the disposal system and to prevent unreasonable adverse effects on the disposal system.

16. 3. Determine Prevention and Control Strategies (cont.)
Gather flow and concentration data from identified areas and/or facilities
Calculate loading contributions and rank them from highest to lowest
DEFINE PRIORITIES!
Calculate Pollutant Loading from Sources
𝐿= 𝐶 ∗𝑄
Where,
L = Pollutant loading (mass/time)
[C] = Concentration (mass/volume)
Q = Wastewater flow (volume/time)
Calculate Pollutant Loading from Sources
Gather flow and concentration data from identified areas and/or facilities
Calculate loading contributions and rank them from highest to lowest
DEFINE PRIORITIES!
𝐿= 𝐶 ∗𝑄
Where,
L = Pollutant loading (mass/time)
[C] = Concentration (mass/volume)
Q = Wastewater flow (volume/time)

17. 3. Determine Prevention and Control Strategies (cont.)
Calculate and rank contributions of total loading from identified sources
Calculate and rank contributions of total loading from identified sources

18. 4. Set Reduction Goals 𝑅𝐸= [𝐶] 𝑖𝑐 −[ 𝐶] 𝑒𝑐 [𝐶] 𝑖𝑐
Determine the WWTP removal efficiency for “conservative” pollutants
Design removal efficiency
Calculate actual (measured) removal efficiency
𝑅𝐸= [𝐶] 𝑖𝑐 −[ 𝐶] 𝑒𝑐 [𝐶] 𝑖𝑐
Where,
RE = Removal efficiency
[C] = Concentration (mass/volume)
ic = measured at the influent
ec = measured at the effluent
Determine the WWTP removal efficiency for “conservative” pollutants
Design removal efficiency
Calculate actual (measured) removal efficiency
𝑅𝐸= [𝐶] 𝑖𝑐 −[ 𝐶] 𝑒𝑐 [𝐶] 𝑖𝑐
Where,
RE = Removal efficiency
[C] = Concentration (mass/volume)
ic = measured at the influent
ec = measured at the effluent
Conservative Pollutant
A pollutant found in wastewater that is not changed while passing through the treatment processes in a conventional wastewater treatment plant. This type of pollutant may be removed by the treatment processes and retained in the plant's sludges or it may leave in the plant effluent. Heavy metals such as cadmium and lead are conservative pollutants

19. 4. Set Reduction Goals (cont.)
𝐿 𝑖𝑛= 𝐶 𝑒𝑓𝑓 ∗𝑄 1−𝑅𝐸
Determine how much the WWTP can treat
Determine effluent concentration goal (permit limit, water quality standard)
Calculate allowable influent concentration based on effluent limit
Where, [L]in = Allowable influent loading (mass) [C]eff = Effluent limit concentration (mass/volume) Q = Wastewater flow (volume/time) RE = Removal efficiency (design or measured )
Determine how much the WWTP can treat
Determine effluent concentration goal (permit limit, water quality standard)
Calculate allowable influent concentration based on effluent limit
𝐿 𝑖𝑛= 𝐶 𝑒𝑓𝑓 ∗𝑄 1−𝑅𝐸
Where,
[L]in = Allowable influent loading (mass)
[C]eff = Effluent limit concentration (mass/volume)
Q = Wastewater flow
(volume/time)
RE = Removal efficiency
(design or measured )

20. 4. Set Reduction Goals (cont.)
Determine WWTP inhibition threshold concentration
Is the influent concentration causing inhibition?
Values from literature or studies
EPA Local Limits Development Guidance (July 2004), Appendix G
Determine WWTP inhibition threshold concentration
Is the influent concentration causing inhibition?
Values from literature or studies
EPA Local Limits Development Guidance (July 2004), Appendix G

21. 4. Set Reduction Goals (cont.)
Compare loading from sources to allowable influent loading to set reduction goal
Does the loading from the identified contributing sources exceed allowable influent (headworks) loading or inhibition limit?
What reduction is needed at the headworks and from each source or group of sources?
Set realistic reduction goal(s)
Consider a safety factor
Compare loading from sources to allowable influent loading to set reduction goal
Does the loading from the identified contributing sources exceed allowable influent (headworks) loading or inhibition limit?
What reduction is needed at the headworks and from each source or group of sources?
Set realistic reduction goal(s)
Consider a safety factor

22. 5. Implement Strategy (cont.)
Select the control strategies to be implemented
Consider how progress will be measured
How will you know if your actions are successful?
Multiple strategies can be used (more than one for each type of source)
Consider implementation period, resource needs, costs, and benefits
Select the control strategies to be implemented
Consider how progress will be measured
How will you know if your actions are successful?
Multiple strategies can be used (more than one for each type of source)
Consider implementation period, resource needs, costs, and benefits

23. 5. Implement Strategy (cont.)
Planning and Implementing
Education and outreach activities
Meetings and negotiations
Pretreatment program development
Monitoring and evaluating
Communicating results
Cost/benefits
Buy-in
Funding
Budget
Planning & Implementing
Education and outreach activities
Meetings and negotiations
Pretreatment program development
Monitoring and evaluating
Communicating results
Considerations
Cost/benefits
Buy-in
Funding
Budget

24. 6. Monitor Progress
Continue sampling
Collection system sub-basins
WWTP influent and effluent
Contributing facilities
Track compliance or progress toward goal
Graph data to visualize trends and evaluate and monitor progress
Continue sampling
Collection system sub-basins
WWTP influent and effluent
Contributing facilities
Track compliance or progress toward goal
Graph data to visualize trends and evaluate and monitor progress

25. 7. Reassess & Adjust
Are the implemented strategies achieving the goal (consistently)?
If not, why not?
Look for additional sources that can be prevented or controlled
Have new sources moved into town and not identified?
Have facilities added new sources?
Continuously update the list of potential sources
Are the implemented strategies achieving the goal (consistently)?
If not, why not?
Look for additional sources that can be prevented or controlled
Have new sources moved into town and not identified?
Have facilities added new sources?
Continuously update the list of potential sources

26. 8. Communicate Results Management Public Facilities Management Public
WIFM = What’s In it For Me?

27. Source Control Case Studies

28. Case Study: WCWD Vehicle Service Facility Pollution Prevention Program
West County Wastewater District
Established a voluntary pollution prevention (P2) program
46 vehicle service facilities
24 discharge wastewater (not permitted, but must comply with local limits in ordinance)
22 facilities are “zero” discharge
West County Wastewater District
Established a voluntary pollution prevention (P2) program
46 vehicle service facilities
24 discharge wastewater (not permitted, but must comply with local limits in ordinance)
22 facilities are “zero” discharge

29. Case Study: WCWD Vehicle Service Facility P2 Program
West County Wastewater District
Each facility gets BMP information
Required annual sampling of
Cu, Hg, Pb, and Zn
(at WCWD expense)
Implement BMPs to get free annual sampling.....or.....
Resampling done at customer expense when exceeding local limit if BMPs not implemented
West County Wastewater District
Each facility gets BMP information
Required annual sampling of Cu, Hg, Pb, and Zn (at WCWD expense)
Implement BMPs to get free annual sampling.....or.....
Resampling done at customer expense when exceeding local limit if BMPs not implemented

30. Case Study: WCWD Vehicle Service Facility P2 Program
Vehicle Service Monitoring Results for Zn, Pb, Cu, & Hg
( )
Numerical results in mg/L
Zinc
Lead
Copper
Mercury
Vehicle Service Monitoring Results for Zn, Pb, Cu, & Hg
( )

31. Case Study: 1994 City of Cleburne
April 1994 – POTW failed first chronic WET tests
Water flea (Ceriodaphnia dubia)
100% mortality at every dilution
May 1994 – retest results also showed mortality
Begin conducting a Toxicity Reduction Evaluation (TRE)
April 1994 – POTW failed first chronic WET tests
Water flea (Ceriodaphnia dubia)
100% mortality at every dilution
May 1994 – retest results also showed mortality
Begin conducting a Toxicity Reduction Evaluation (TRE

32. Case Study: 1994 City of Cleburne (cont.)
POTW was operating great – why the WET test failures?
Conducted extensive studies:
Influent and effluent sampling
Manholes
Industries up the collection system
POTW was operating great – why the WET test failures?
Conducted extensive studies:
Influent and effluent sampling
Manholes
Industries up the collection system

33. Case Study: 1994 City of Cleburne (cont.)
TRE results traced the toxicity to a semiconductor manufacturer
Tetra methyl ammonium chloride (TMACl) was identified as the toxicant
WET effluent limit in TPDES permit?
TRE results traced the toxicity to a semiconductor manufacturer
Tetra methyl ammonium chloride (TMACl) was identified as the toxicant
WET effluent limit in TPDES permit?

34. Case Study: 1994 City of Cleburne (cont.)
The City did NOT want a WET limit in permit
Determined that the POTW could receive 80 mg/L at the influent without failing biomonitoring
Alternative was reached to include an influent limit for TMACl
Additional safety factors were implemented
Semiconductor also received an effluent limit
The City did NOT want a WET limit in permit
Determined that the POTW could receive 80 mg/L at the influent without failing biomonitoring
Alternative was reached to include an influent limit for TMACl
Additional safety factors were implemented
Semiconductor also received an effluent limit

35. Case Study: 2013 City of Cleburne
Feb POTW failed sublethal WET tests (Water Flea - Ceriodaphnia dubia)
Began investigating potential sources in the industrial park
Sampled sewer system
Found high selenium levels downstream from an industry, power plant, and the POTW, but no known sources ???
Feb POTW failed sublethal WET tests (Water Flea - Ceriodaphnia dubia)
Began investigating potential sources in the industrial park
Sampled sewer system
Found high selenium levels downstream from an industry, power plant, and the POTW, but no known sources ???

36. Case Study: 2013 City of Cleburne (cont.)
Further investigation revealed false-positive results for selenium due to bromide interference
Lab started using inductively coupled plasma mass spectrometry (ICP-MS) & helium collision cell
Found industry started discharging a wastestream containing bromide
25% of POTW effluent reused at power plant so may also elevate bromide levels in influent
Further investigation revealed false-positive results for selenium due to bromide interference
Lab started using inductively coupled plasma mass spectrometry (ICP-MS) & helium collision cell
Found industry started discharging a wastestream containing bromide
25% of POTW effluent reused at power plant so may also elevate bromide levels in influent

37. Case Study: 2013 City of Cleburne (cont.)
The City did NOT want a WET limit in permit
Conducted study to demonstrate WET failures due to bromide
TPDES permit and City required industry to not discharge wastestream containing bromide
The City did NOT want a WET limit in permit
Conducted study to demonstrate WET failures due to bromide
TPDES permit and City required industry to not discharge wastestream containing bromide

38. Food Processor Case Study
Pretreatment review of the TPDES discharge permit renewal application for “City A” revealed some high loadings to both WWTPs
WWTP 1
Design Flow: MGD
Average Flow: MGD
Industrial Flow: MGD
Hydraulic loading: 11 %
(% design flow)
Hydraulic loading: 17 %
(% actual flow)
WWTP 2
Design Flow: MGD
Average Flow: MGD
Industrial Flow: MGD
Hydraulic loading: %
(% design flow)
Hydraulic loading: %
(% actual flow)
Pretreatment review of the TPDES discharge permit renewal application for “City A” revealed some high loadings to both WWTPs
WWTP 1
Design Flow: MGD
Average Flow: MGD
Industrial Flow: MGD
Hydraulic loading: 11 %
(% design flow)
Hydraulic loading: 17 %
(% actual flow)
WWTP 2
Design Flow: MGD
Average Flow: MGD
Industrial Flow: MGD
Hydraulic loading: %
Hydraulic loading: %

39. Food Processor Case Study (cont.)
Obtained additional details regarding the industries and types of pretreatment units.
WWTP 1
Dairy Products Manufacturer
Clarifier
WWTP 2
Cheese and Salsa Manufacturer
Oil &Grease Separator
Pet food Manufacturer
Dairy Industry
Clarifier
Obtained additional details regarding the industries and types of pretreatment units.
WWTP 1
Dairy Products Manufacturer
Clarifier
WWTP 2
Cheese and Salsa Manufacturer
Oil &Grease Separator
Pet food Manufacturer
Dairy Industry

40. Food Processor Case Study (cont.)
Summary of maximum and minimum concentrations of the industrial discharges (after pretreatment) to WWTP 2
Parameter
Max Conc. (mg/L)
Min Conc. (mg/L)
Cheese and Salsa Manufacturer
CBOD5
21,480
985
TSS
6,690
648
NH3
64.0
3.47
Pet foods Manufacturer
1,381
287
436
192
14.2
1.82
Dairy Industry
268
2.54
338
8.00
9.64
1.05
Summary of maximum and minimum concentrations of the industrial discharges (after pretreatment) to WWTP 2
Concentration (Conc.) results in mg/L
Parameter Max Conc. Min Conc.
Cheese and Salsa Manufacturer CBOD5 21,
TSS 6, NH
Pet foods Manufacturer CBOD5 1,
TSS NH
Dairy Industry CBOD
TSS NH

41. Food Processor Case Study (cont.)
Summary of Organic (BOD5) Loading from the Industries to WWTP 2
Organic loading (treatment) capacity: lbs/day
Total industrial organic loading: ~1,000 lbs/day
WWTP 2
Organic (BOD5) Loading (lbs/day)
Max
Min
Average
Cheese and Salsa Manufacturer
985 30
662
Pet food Manufacturer
288
200
253
Dairy Industry
495
4.4 83
Total
998
Summary of Organic (BOD5) Loading from the Industries to WWTP 2
Organic loading (treatment) capacity: lbs/day
Total industrial organic loading: ~1,000 lbs/day
WWTP 2
Organic (BOD5) Loading (lbs/day)
Max Min Average
Cheese and Salsa Manufacturer
Pet food Manufacturer
Dairy Industry
Total

42. Food Processor Case Study Summary of Findings
No exceedances of TPDES permit limits at the WWTPs
Discussed the situation with the City
Cheese and Salsa Manufacturer and Pet Foods Manufacturer periodically contributed high organic loading to the WWTP (greater than the treatment capacity)
Hydraulic loading from industrial contribution 94% at WWTP 2
No exceedances of TPDES permit limits at the WWTPs
Discussed the situation with the City
Cheese and Salsa Manufacturer and Pet Foods Manufacturer periodically contributed high organic loading to the WWTP (greater than the treatment capacity)
Hydraulic loading from industrial contribution 94% at WWTP 2

43. Food Processor Case Study Outcome
Issued TPDES permit that required implementation of a partial pretreatment program
Conduct an industrial waste survey
Update ordinance
Develop and adopt technically-based local limits for conventional pollutants
Develop enforcement response plan and procedures
Issued TPDES permit that required implementation of a partial pretreatment program
Conduct an industrial waste survey
Update ordinance
Develop and adopt technically-based local limits for conventional pollutants
Develop enforcement response plan and procedures

44. Brewery Case Study
City requested assistance from TCEQ’s Small Business and Local Government Assistance Program (SBLGA)
Excessive TSS discharge from brewery was allegedly causing pass through and interference
Recurring TSS violations and enforcement action
City’s Industrial Waste Ordinance had a limit for BOD5 but not for TSS
Brewery installed anaerobic biological treatment:
BOD5 <300 mg/L
TSS measured downstream of discharge
~ 2,000 mg/L
City requested assistance from TCEQ’s Small Business and Local Government Assistance Program (SBLGA)
Excessive TSS discharge from brewery was allegedly causing pass through and interference
Recurring TSS violations and enforcement action
City’s Industrial Waste Ordinance had a limit for BOD5 but not for TSS
Brewery installed anaerobic biological treatment:
BOD5 <300 mg/L
TSS measured downstream of discharge
~ 2,000 mg/L

45. Brewery Case Study (cont.)
TPDES permit was expiring and the renewal application was submitted
Storm Water & Pretreatment Team worked with the City and SBLGA to address the situation.
WWTP
Design Flow: MGD
Average Flow: MGD
Industrial Flow: MGD
Hydraulic loading: %
(% design flow)
Hydraulic loading: %
(% actual flow)
TPDES permit was expiring and the renewal application was submitted
Storm Water & Pretreatment Team worked with the City and Small Business and Local Government Assistance (SBLGA) to address the situation.
WWTP
Design Flow: MGD
Average Flow: MGD
Industrial Flow: MGD
Hydraulic loading: %
(% design flow)
Hydraulic loading: %
(% actual flow)

46. Brewery Case Study Outcome
Issued TPDES permit that required implementation of a partial pretreatment program
Conduct industrial waste survey
Update ordinance
Develop and adopt technically-based local limits for conventional pollutants and metals
Develop enforcement response plan and procedures
Issued TPDES permit that required implementation of a partial pretreatment program
Conduct industrial waste survey
Update ordinance
Develop and adopt technically-based local limits for conventional pollutants and metals
Develop enforcement response plan and procedures

47. SOME SECTOR-SPECIFIC RESOURCES FOR:
Food Processing
Mercury
Breweries
Phosphorus

48. Food Processing Source Control Resources
EPA Multimedia Environmental Compliance Guided for Food Processors (EPA 305-B )
Minnesota Technical Assistance Program

49. Food Processing Source Control Resources
Waste Reduction in Food Processing
Wastewater Reduction and Recycling in Food Processing Operations
Meat, Food, and Dairy Processing Industry-Waste Streams & PollutionPrevention

50. Mercury Reduction Resources
Mercury-Added Products Found at Drinking Water & Wastewater Treatment Facilities
The Northeast Waste Management Officials’ Association (NEWMOA)
EPA Dental Amalgam

51. Mercury Source Control Resources
Blueprint for Mercury Reduction Guidance for WWTPs
Western Lake Superior Sanitation District

52. Mercury Source Control Resources
EPA Recommended Management and Disposal Options for Mercury-Containing Products
Consumer products: home items
Medical pharmaceutical products
Consumer products: automotive parts
Commercial products
Alternatives to Mercury-Containing Products

53. Brewery Source Control Resources
Examples of EPA Brewery Inspections

54. Phosphorus Source Control Resources
Phosphorus Management Plan Guide (Minnesota Pollution Control Agency, 2006)
Six Municipalities, One Watershed: A Collaborative Approach to Remove Phosphorus in the Assabet River Watershed (EPA 820-R , 2015)

55. Summary Look for trends If not making progress, ask “why not?”
Know your service area and contributors
Identify known and potential sources of pollutants of concern
Be familiar with your TPDES permit requirements
Influent, effluent, and sludge limits for current and draft permits
Look for trends (anticipate limits)
Set goals, monitor and evaluate progress, and reassess strategies
Look for trends
If not making progress, ask “why not?”
Know your service area and contributors
Identify known and potential sources of pollutants of concern
Be familiar with your TPDES permit requirements
Influent, effluent, and sludge limits for current and draft permits
Look for trends (anticipate limits)
Set goals, monitor and evaluate progress, and reassess strategies
Look for trends
If not making progress, ask “why not?”

56. Summary
Keep management, public, & facility sources informed of activities and progress
Acknowledge past and current efforts
Justify future efforts
Share your knowledge
What was done and how
Dealing with barriers
Lessons learned
Keep management, public, & facility sources informed of activities and progress
Acknowledge past and current efforts
Justify future efforts
Share your knowledge
What was done and how
Dealing with barriers
Lessons learned

57. Questions?