Category: Process

The Need for Industrial Pretreatment Programs (IPP)

picture of bewery vats

Whether it’s a brewery, paper mill, food or chemical plant in your community, these businesses almost always produce industrial wastewater. As such, there is a need for wastewater management generated from these, and many other, industrial activities discharging to a Publicly Owned Treatment Works (POTW). Managing industrial wastewater can be accomplished through a well-run Industrial Pretreatment Program (IPP). In addition, with the emergence of new contaminants that might not be compatible with POTWs, an IPP facilitates the regulatory framework to determine the origins of such contaminants.

National IPP: Setting the Standards

In 1972, US Congress passed the Federal Water Pollution Control Act, known as the Clean Water Act (CWA), to restore and maintain the nation’s water quality. The Act’s goals were to eliminate the introduction of pollutants into the nation’s navigable waters to achieve “fishable and swimmable” water quality levels. The CWA’s National Pollutant Discharge Elimination System (NPDES) Permit Program is one key component established to accomplish these goals. The NPDES Permit Program generally requires that direct dischargers to a waterbody obtain an NPDES Permit.

In addition to addressing direct discharges to the nation’s waterways, the National Pretreatment Program is a regulatory program for pollutants that are discharged into a POTW, otherwise known as indirect discharges. This program requires industrial and commercial facilities to obtain permits (or use other control measures) to discharge their wastewater to a POTW. Certain discharges by these users may pass through or interfere with the operations of a POTW, leading to a direct discharge of untreated wastewater into rivers, lakes, and other water bodies.

The goals of the National Pretreatment Program as stated in 40 Code of Federal Regulations (CFR) Part 403.2 are as follows:

  • To prevent the introduction of pollutants into a POTW that will interfere with the operation of the POTW, including interference with its use or disposal of sludge
  • To prevent the introduction of pollutants into a POTW that will pass through the treatment works otherwise be incompatible with such works
  • To improve opportunities to recycle municipal and industrial wastewater and sludges

To accomplish these goals, the National Pretreatment Program requires all large POTWs (those with design flows greater than 5 million gallons per day) and small POTWs that accept wastewater from industrial users that could affect POTWs to establish a local pretreatment program. Local pretreatment programs must enforce national pretreatment standards and requirements, as well as more stringent local requirements necessary to protect the site-specific conditions of the POTW. For example, industrial discharges from a large brewery with organic loadings much greater than typical domestic loadings may not negatively impact a large POTW but might cause major interference or pass-through at a very small POTW not designed to properly treat such organic loads.

Identifying and understanding a POTW’s Significant Industrial User’s (SIU’s) wastewater discharges is an important component of an IPP since SIUs have the ability to adversely affect the POTW.

Implementing IPP on the Local Level

Once the determination has been made that a POTW needs a local pretreatment program, six minimum elements must be included in a pretreatment program submission for review and approval by the USEPA, the state or both, depending on state statute.

  1. Legal Authority – A POTW must have the legal authority which authorizes the POTW to apply and enforce any pretreatment requirement. This authority is derived from state law.
  2. Procedures – A POTW must develop and implement procedures to ensure compliance with pretreatment requirements which include:
    • Identifying all Industrial Users (IUs) subject to the pretreatment program
    • Identify the characteristic of pollutants contributed by IUs
    • Notify users of applicable pretreatment standards and requirements
    • Receive and analyze reports from IUs
    • Sample and analyze IU discharges
    • Evaluate the need for an IU slug control plan
    • Investigate instances of IU non-compliance
    • Comply with public participation requirements
  3. Funding – A POTW must have sufficient resources and qualified personnel to carry out the procedures included in the approved pretreatment program.
  4. Local Limits – A POTW must develop local limits developed for pollutants that could cause interference, pass through or sludge contamination or worker health and safety problems.
  5. Enforcement Response Plan (ERP) – A POTW must develop and implement an ERP containing detailed procedures indicating how the POTW will investigate and respond to IU non-compliance instances.
  6. List of SIUs – A POTW must prepare, update and submit to the approval authority a list of all SIUs.

These elements are important for managing a well-run local pretreatment program and developing good working relationships with IUs. As new contaminants continue to emerge that are not compatible with POTWs, pretreatment programs will be useful to identify sources of new contaminants that may potentially cause issues with POTW effluent water quality or sludge disposal practices. A pretreatment program must be adaptable, and any necessary modifications to local pretreatment programs to address new contaminants must be conducted expeditiously.

Our Experience with IPP & Water Treatment

Hoyle, Tanner’s Northeast Municipal Engineering Services Group employs 20 engineers whose primary focus is water quality engineering – wastewater, stormwater and drinking water. industrial inspections, writing annual reports or providing technical expertise relative to enforcement actions. Our team has the experience to provide pretreatment program resources and immediate expertise.

Our depth and breadth of pretreatment program experience includes: identifying IUs to be included in an IPP, writing industrial user permits, evaluating the need for updating technically-based local limits, and updating Sewer User Ordinances and ERPs.

For more information, please visit our website at: www.hoyletanner.com or contact Senior Engineers Paula Boyle or Heidi Marshall.

All About LPA: A Valuable Funding Source for Maine Transportation Projects

We’re excited to have another professional get LPA certified in Maine! Sean James, PE, Senior Vice President, joins our growing number of LPA certified project managers, engineers and technicians who can coordinate on these specific projects. Sean has worked on dozens of LPA projects in the state of New Hampshire and is looking forward to bringing his tenured experience to LPA projects in Maine.

What is an LPA Project?

The Local Project Administration (LPA) program leverages local dollars with state or federal dollars through the Maine Department of Transportation (DOT) on a wide variety of projects statewide. These projects can include resurfacing and rebuilding of roads, intersection improvements and non-vehicular transportation alternatives such as sidewalk and shared-use paths, pier and float installations and bridge and culvert replacement.

 
Who is Eligible & for How Much?

An LPA project can be administered by a variety of organizations including municipalities, regional transportation agencies, education institutions and tribal governments. The selection of projects is competitive and includes a variety of programs including Transportation Alternative, Low-Use Redundant Bridge Program, Small Harbor Improvement Program and the Hazard Elimination Program. Funding reimbursement varies from 50 to 80 percent of the project’s eligible costs.

Is there Certification Required?

LPA program certification is required for all projects that include federal funding; however, the training is beneficial for non-federally funded programs as well. The certification program covers the financial aspects of projects, hiring consultants, project design including environmental review, utility coordination, Right-of-Way and construction administration. Hoyle, Tanner’s team includes LPA certified professionals who understand the program and assist our clients in meeting their project goals.

The Role of Consultants

Engineering consultants act as an extension of the owner’s organization and bring specialized technical and funding program experience to the project. The consultant’s role is to understand the purpose and need of the owner, to study and provide alternatives for consideration, turn the project vision into a final design and permit the project and finally provide assistance with bidding and construction administration and oversight as well as final project closeout for reimbursement. 

The LPA program provides opportunity to improve our communities while minimizing the cost to local budgets. Our bridge, transportation and environmental teams have a wide variety of design and construction experience with LPA projects including bridges (vehicle and pedestrian), sidewalks, roadway improvement and safety and intersection improvements. For more information on how to get started and how we can assist in meeting your project goals, please contact Sean.

The New Great Bay Total Nitrogen General Permit

Pink and purple sunset image over water with tree skyline of Great Bay Estuary

What is the Great Bay Total Nitrogen General Permit & why does it matter?

The US Environmental Protection Agency (EPA) issued the final Great Bay Total Nitrogen General Permit (GBTNGP) on November 24, 2020. The GBTNGP is aimed at reducing the overall nitrogen loading into Great Bay, a unique coastal marine estuary. The GBTNGP covers discharges of nitrogen from the 13 communities that own/operate wastewater treatment facilities in the watershed: Dover, Durham, Epping, Exeter, Milton, Newfields, Newington, Newmarket, Pease Tradeport, Portsmouth, Rochester, Rollinsford and Somersworth. The permit allows for an adaptive management approach to monitoring and reducing nitrogen discharges. Each community has the option of being included for coverage under the GBTNGP or not (opt in or opt out). If a community decides to be included for coverage under the permit it must file a Notice of Intent with the EPA, Region 1, by April 2, 2021. The alternative to opting in to the GBTNGP will be that the community will receive a new/revised individual NPDES permit to govern its WWTF discharge. Key dates for actions to be taken pursuant to the GBTNGP are as follows:

  • February 1, 2021 – Effective date of the Great Bay Total Nitrogen General Permit.
  • March 31, 2021 – Deadline for finalizing an Intermunicipal Agreement to develop the Adaptive Management Plan.
  • April 2, 2021 – Deadline for sending EPA the Notice of Intent to Opt-In to the TN General Permit.
  • July 31, 2021 – Deadline for submittal to EPA of the Part 3 Adaptive Management Plan.

How can an Adaptive Management Approach help?

The GBTNGP allows for an adaptive management approach to be taken for monitoring and controlling nitrogen discharges and allows for the communities to develop the Adaptive Management Plan. Adaptive management is a key aspect of watershed management and restoration. Elements of adaptive management included in GBTNGP involve ambient monitoring, pollution tracking, reduction planning, and review. Adaptive Management is, by definition, a structured iterative process of robust decision making in the face of uncertainty, with an aim to reducing uncertainty over time via ongoing system monitoring. In this way, decision making simultaneously meets one or more resource management objectives and, either passively or actively, accrues information needed to improve future management and decision-making. Adaptive management is a tool which can be used not only to change a system, but also to learn about the system (Holling 1978). Because adaptive management is based on a learning process, it improves long-term management outcomes. The challenge in using the adaptive management approach lies in finding the correct balance between gaining knowledge to improve management in the future and achieving the best short-term outcomes based on current knowledge (Allan & Stankey 2009).

A holistic & cost-effective approach.

The objective of an adaptive management approach is to take a broad holistic and more cost-effective approach to implementing water quality restoration and management measures that will achieve better overall results in improving water quality goals in less time and at less cost than the traditional regulate-react approach by applying limited resources where they will have the greatest effect. In fact, the GBTNGP encourages sharing of resources and costs among the participating communities. The adaptive management approach allows for planning, implementation, monitoring and refinement in order to maximize the results with limited resources (resource optimization). The idea behind an adaptive management approach is for communities to become proactive rather than reactive in restoring water quality within the watershed. A successful adaptive management approach will require extensive collaboration and cooperation between municipalities, regulators, agencies, volunteer groups and other watershed stakeholders.

Our experience.

Hoyle, Tanner’s Northeast Municipal Engineering services Group (NEME) employs 20 engineers whose primary focus is water quality engineering – wastewater, stormwater and drinking water. Our depth and breadth of experience includes working with communities to assist them with compliance with permits such as NPDES (wastewater and stormwater), MS4 (stormwater and non-point) and a host of other regulatory and environmental permits. We have been working with communities under regulatory constraints to monitor and reduce the amount of total nitrogen discharged to local water bodies and helping them to achieve water quality goals. Jennie Auster, one of our wastewater process engineers, has been working with communities affected by the Long Island Sound Total Maximum Daily Load (TMDL) for Nitrogen for over six years including completing biological nutrient removal analysis for several facilities. Jennie completed nitrogen removal optimization plans for six communities and has presented at the Green Mountain Water Environment Association Technical Sessions on her experience with low-cost nitrogen optimization plans (presentation available upon request). We are assisting several communities on compliance with the 2017 MS4 permit which includes nutrient reduction in stormwater and non-point sources. We are also working with many communities on asset management for their wastewater, stormwater and drinking water systems, the goal of which is resource optimization to improve decision-making and maximize the life of the infrastructure.

Let us help!

Our team has a history of developing creative and innovative solutions to help clients achieve their goals in cost-effective ways while optimizing the use of limited resources. For more information please visit our website at: www.hoyletanner.com or contact Michael Trainque or Joseph Ducharme.

I am a Senior Environmental Engineer and Vice President at Hoyle, Tanner, and chairman of the Board of Directors of the Southeast Watershed Alliance (SWA). The SWA is a non-profit watershed organization for which enabling legislation was enacted by the NH State Legislature in 2009 encompassing the 42 communities in the NH coastal watershed. I have been following the development of this permit on behalf of clients.

Right-of-Way Acquisition in 7 Steps

Right-of-Way Process Graphic with arrows

Right-of-Way acquisitions in civil engineering encompass a lot of detail. According to Betsy Bosiak, land acquisition specialist at Hoyle, Tanner, it can take a little under five years to learn everything there is to know about Right-of-Way.

Betsy has shared her knowledge to answer common questions about the acquisition process. For those who may not know what Right-of-Way is, it’s the act of acquiring land or easements to complete a project. It could be anything from a homeowner’s land that needs drainage services near a road to getting new land to build a medical office. Each state has to follow certain federal guidelines, but the individual states do have specific criteria for Right-of-Way processes.

Betsy has shared about the acquisition process in New Hampshire (one she tried not to get into too much detail about because of its sheer power to overwhelm). In 7 steps, here’s a breakdown of she shared:

Before Final Design:

  1. Know the basics. First and foremost, Right-of-Way acquisition is considered a part of the final design process, depending on the size of the project. Yet it’s also important to realize that many items occur concurrent with plan development. The types of Right-of-Way are Easement and Fee. Easement acquisition is when the property owner gives easements to allow the use of land. Today, however, the most popular acquisition is fee-based; land is purchased for the project to be completed.Types of Right-of-Way
  2. Determine what’s already there. It’s vital to determine the existing Right-of-Way by checking existing plans, historic documents, property surveys, deeds, and existing ground conditions.
  3. Make a plan & be specific. To actually acquire land for project use, there needs to be a project scope, preliminary design, final design, and recording all plans.
  4. Determine the type of acquisition: Fee Taking (buying the land), Temporary Easement (using it for the time of construction), or Permanent Easement (the land is yours forever, but the State or Municipality has easement rights).
  5. Explain the impacts. You actually need to explain to the landowner the intended impacts to the property. Public meetings, meetings with officials, and meetings with landowners are a critical part of the process. As Betsy suggests, keep records of what everyone says so that there’s no confusion later in the process.

During Final Design:

  1. Determine appraisals. Even after the landowner meetings, the land is still not ready to be built upon. In fact, the next step in the detailed acquisition process is Land Value Appraisals. Once that’s complete, a written offer is made to the landowner. If the landowner does not agree, it’s back to the negotiation table.Right-of-Way Appraisal Graphic with 4 types
  2. Acquire the needed property rights. The property owner has agreed to the written compensation. It’s time to prepare the deed or easement document, and with a notary, sign the document. Save all written records and notes and make copies of each. The land is officially available for project construction.

The Right-of-Way acquisition process is no simple matter (though it was explained in layman’s terms here); and it can take anywhere from 1-6 months depending on acquisition complexity. Betsy recommends documenting files for each landowner and making multiple copies of these documents for reference.

Have Right-of-Way questions? Talk to the specialist: Betsy Bosiak.

From Groundbreaking to Ribbon Cutting: An Internship with Hoyle, Tanner

Over the past three months, I have had the pleasure of being part of the Hoyle, Tanner team, primarily in the Bridges & Structures group. I have gotten to see and experience a variety of different projects at all stages, and I am grateful for this opportunity and everything I learned along the way.

Projects in Derry

The first half of my internship experience was spent in Derry, New Hampshire replacing a bridge with structurally deficient culverts on this box culvert project. Here I performed Resident Project Representative (RPR) services and observed construction from start to finish – when the excavator broke ground to when the bridge was reopened to traffic. It was very rewarding to see the full project life-cycle and be there to walk the bridge. Every day in the field there was a new step and process for me to learn and see for the first time. Being on site opened my eyes to how many people are involved in the entirety of a project. Now I better understand the client, contractor, and engineer’s roles in making a project successful. For example, Hoyle, Tanner, the contractor, and the Town worked together to make field changes as needed.

Working on this project also introduced me to new engineering computer programs such as Bluebeam, MicroStation, and Mathcad that allowed me to edit drawings, review check sets and create other engineering documents. User efficiency greatly improved from the first days of using a program compared to after a couple of months.

Projects in Bedford

The last half of my internship has been spent in Bedford, New Hampshire where I took on day-to-day inspections of a gas main project. My duty there was to make sure the trench is properly backfilled and compacted and make sure everything goes according to plan. This role was rewarding because it allowed me to work more independently. I frequently communicated with the client on day-to-day progress and was the bridge of communication to the site.

At Hoyle, Tanner I was welcomed with open arms (virtually) and felt like I belonged. I am thankful my supervisor emphasized spending as much time in the field as I could because the experience taught me valuable lessons. I enjoyed the team environment and how my questions were encouraged by everyone. This opportunity brought me new experience and knowledge, and has increased my interest in field work. I’d like to personally thank Matthew Low, PE for providing me with this opportunity, Josif Bicja, PE for showing me what it takes to be a great engineer, and Katie Welch, EIT for guiding me along the way.

Derry, NH Box Culvert Replacement Project

MS4 Timeline: The Second Annual Report & What’s Next

MS4 timeline with relevant dates

September 2020 marks another year for MS4 permitting in New Hampshire. Since MS4 rules were updated in 2017, we have continued to help communities regulate their stormwater discharges to meet these new requirements. This month on the MS4 timeline, communities should be aware that Second Annual Reports are due.

First, let’s back-track and recall that MS4 permitting refers to regulations in place to manage stormwater in a community. Stormwater outfalls from an MS4 area must be located, mapped, and assigned a unique identification number. Then, inspections and condition assessments must be completed for each outfall based on priority ranking. We have a detailed post about what happens if you observe flow during dry weather and different outfall rankings based on testing samples. We also identified a timeline  following the initial mapping, focusing on what happens after the first annual report. With September’s deadline quickly approaching, here is what communities can expect with the next steps.

The Second Annual Report

Communities should be submitting their second annual reports to EPA by September 28, 2020.

EPA has provided a partially filled-in report template to permitees; EPA has provided a partially filled-in report template to permitees; however, the New Hampshire stormwater coalitions have modified the template to be more user-friendly. The updated template can be found as part of the Coalition blog site here: NH Stormwater Coalition Annual Report for Year 2 Template.

We have worked with a half dozen small communities in New Hampshire to prepare them for their annual reports. In some communities, this means we mapped, visited, and screened their outfalls, and provided training. For others, we helped coordinate stormwater team meetings and activities, or just provided reassurance. After working with several communities, we’ve found that the same hurdles present themselves and have gathered a few tips to help the process move smoothly:

  • Do not omit information. When filling out the second annual report, be sure to take credit for everything that had progress between July 1, 2019 and June 30, 2020.
  • Take time now to review the requirements for the next report. Some required activities or tasks are more easily performed during specific times of the year; now is a good time to plan how to keep up with your Stormwater Management Program activities.
  • Be conscious of the timeframe.  Any efforts begun, but not completed in the Year 2 timeframe, cannot be marked complete. Any progress should be mentioned in the comments section.

What Next?

The most important thing to keep in mind is that as each year of the permit term passes, the stringency of the requirements increases. There is no time for rest or relaxation – pull out that Stormwater Management Program and see what elements (written program updates, outfall screenings, training, regulatory review and updates, stormwater management device Inspection, etc.) are required to be completed when the complete outfall ranking (based on dry-weather samplings) is due – June 30, 2021. Reviewing the required elements ahead of time will help with early coordination of next year’s report.

Not every MS4 community will encounter the same challenges. Meeting these deadlines and documenting all stormwater sources can be time consuming and difficult. Our stormwater experts are here to help and are fully prepared to help with unique challenges and stormwater setbacks. Reach out to our experts Heidi Marshall, PE or Michael Trainque, PE with stormwater inquiries!

*This post was co-written by Catie Hall, marketing coordinator. MS4 Expert Michael Trainque, PE also contributed to this post.

At-The-Ready Consultant Services: A Streamlined Approach to Starting Your Project

If your community was awarded a grant through the Vermont Agency of Transportation (VTrans) Municipal Assistance Bureau (MAB), you can take advantage of a streamlined approach to procuring your project consultant through the At-The-Ready (ATR) process. With this choice, municipalities have an alternative option to the standard RFQ/RFP process; an option that can speed up your proposed project schedule using prequalified and reputable experts in their field with success in delivering projects in accordance with VTrans MAB standards. VTrans maintains ATR consultants from a qualified roster, ready for qualifications-based-selection (QBS) when a project arises.

This accelerated procurement method can be applied to three categories of work:

  1. Design (including Scoping)
  2. Municipal Project Management
  3. Construction Inspection

If the ATR process is something your community would like to consider, VTrans has set up a simple Guide and Flowchart that can be followed and coordinated with your VTrans Project Supervisor. Begin by defining a selection committee (minimum of two members); along with the Municipal Representative in Responsible Charge (typical members could include the Municipal Project Manager, Public Works Engineer, Road Foreman or other municipal representatives). The committee then reviews a minimum of three consultant qualifications packages and selects the firm that best meets the needs of the municipality for the particular project. Once the committee chooses a firm, they can work through the cost proposal process with the VTrans Project Supervisor and the consultant.

For a municipality, the ATR process is beneficial for more than just accelerating the procurement of consultant services. Utilizing ATR also ensures you will be selecting from qualified firms that are experts in completing MAB funded projects. Instead of preparing a laborious Request for Qualifications package and then reviewing multiple submissions, the QBS selection is made easier, giving the option of only a minimum of three to pick from, while maintaining full state and federal grant/funding eligibility.

Hoyle, Tanner has had a working relationship with the VTrans MAB group for over 20 years and has been an ATR Consultant under the Design Category since the program began in 2017. We are a prequalified Design Consultant and are At-the-Ready whenever a municipality needs.

If you have any questions about the ATR process, contact Jon Olin, PE, our Vice President and Regional Business Manager of our Vermont office.

What you May not Have Considered about Solar Energy in New England

Hoyle, Tanner is currently providing professional engineering design services for the development of solar energy in New England. We are working for several solar companies as the solar industry has not only taken off in the flatlands of our Midwest United States, but solar energy development is also happening in our New England backyards.

There are many reasons why this industry has recently become so popular. Solar energy has become a viable option because of the sun’s power – but also because of its cost. As the technology of solar energy has become more efficient, the option for purchasing solar power has become a reality to an average energy user.

In order to consider solar options, permitting and procurement need to be considered.

Permitting

Public utilities commissions and state regulators have recently developed and revised rules and regulations for the advancement of solar energy. Hoyle, Tanner has stayed up-to-date with the development of these guidelines so that we can keep our clients educated and able to make sound decisions and reliable investments — not only based on costs, but also permitting success. The probability of getting a project permitted is a major milestone in the progression of a project, and can in many cases can determine if the project ever gets started.

There are many factors that contribute to the permitting and design of a solar array. Following is a list of some major factors that can affect development:

  • What is the size and shape of the property?
  • Is the property located in a properly zoned area or can it be rezoned?
  • Are the soils adequate to develop for this use? Are there significant wetlands? Are they well drained soils?
  • Is the topography adequate for solar development? Is the orientation of the property favorable for solar development?
  • Are there abutting structures on neighboring property that would prevent sunlight from reaching the site?
  • Is there adequate access to the property?
  • Is there access to an existing power source to transmit the power?
  • Are there natural resource protection areas within the site (vernal pools, deer wintering areas, or historic preservation areas)?
  • Does the developer have adequate title to the property?

Hoyle, Tanner has developed several solar array sites being cognizant of all the factors pertaining to a successfully designed and permitted project, while keeping versed of the regulatory processes. With our experience, we can save the client time and money while helping them realize a successful project.

Procurement

In many state governments, there is a procurement process for renewable energy projects (that are part of energy packages). These packages contain guidelines for the development of a limited amount of energy. What we are finding in some states is the need to increase the development limits as demand increases. Hoyle, Tanner is working with state agencies to make sure we are aware of these opportunities so that we may share them with our clients.

In some states there is a procurement process, raising the net metering cap, allowing arrays of up to 5MW — 5,000 KW — to sell or store excess energy. 

Raising the cap is what makes renewable energy development viable for investors, developers, and municipalities. These opportunities to create renewable energy not only lower the states’ dependence on fossil fuels to generate electricity but are also expected to create new jobs in the coming years as the number of projects increase.

Many states look to increase their renewable energy portfolio standard — the amount of renewable electricity created as opposed to that created by fossil fuels — from lows currently at 10% or less to 40% or 80% by 2030 and some even at 100% by 2050.

Helping Developers

We understand the importance of this type of development and the need for development of renewable resources. Our design experience helps the developers understand the limitations of development and of course the permitting process.

Hoyle, Tanner’s experts are here to help. If you have any solar development questions, contact Andy Sturgeon, Vice President and Regional Business Manager.