Tag: Environmental Protection

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.

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.

Celebrating National Endangered Species Day with Awareness of the Canada Lynx

Canada lynx in the snow

The Endangered Species Act (ESA) was created in 1973 to protect at-risk species and the habitat those species use to complete their life cycles. This important piece of legislation came out of a growing recognition that the impacts from growth and development were having negative effects on the environment. It was issued shortly after the Clean Water Act was passed in 1972, and together these two Acts provide the legal foundation for much of the environmental protection regulations that work to ensure that the many varied ecosystems within the United States remain, or strive to become, healthy, sustainable and well-balanced. 

Together these two Acts provide the legal foundation for much of the environmental protection regulations that work to ensure that the many varied ecosystems within the United States remain, or strive to become, healthy, sustainable and well-balanced. 

Species that are protected under the ESA are either classified as endangered or threatened. Endangered means a species is in danger of extinction throughout all or a significant portion of its range. Threatened means a species is likely to become endangered within the foreseeable future. All species of plants and animals, except pest insects, are eligible for listing as endangered or threatened.

The ESA is administered by the US Fish and Wildlife Service (USFWS) for terrestrial and freshwater species, and the National Marine Fisheries Service (NMFS) for marine species. More information on the ESA, including the list of species currently being protected, as well as “candidate” species, which are those proposed for protection, can be found at: https://www.fws.gov/endangered/species/us-species.html.

Our work on a wide variety of projects across six states and a range of habitats requires us to consult with USFWS and NMFS during project planning to ensure that we adhere to the requirements for species protection where necessary.

To determine potential impacts to environmental resources (including several parameters such as water, air quality, and noise) when we begin planning for a project, we review the project site using USFWS and NMFS online mapping. Online mapping helps to determine if there is habitat for a listed species. Each species that is listed under the ESA has a defined land range that is developed from data regarding current habitat needs for that species and species surveys; the result is that not only are locations where the species currently exist protected, but there is also protection offered in areas where the species could survive if their population numbers were to increase.

The result is that not only are locations where the species currently exist protected, but there is also protection offered in areas where the species could survive if their population numbers were to increase.

Projects in northern Vermont, New Hampshire, and Maine have the potential to be located within the range of the federally-threatened Canada lynx (Lynx canadensis). Canada lynx is a medium-sized cat with long legs, large, well-furred paws, long tufts on the ears, and a short, black-tipped tail. Their long legs and large feet are highly adapted for hunting snowshoe hares (Lepus americana) – their primary prey species – in deep snow conditions. The distribution of lynx in New England is associated with northern forests that are a mix of spruce and balsam fir, among other pine species, some hardwoods such as birch and aspen, and hardwood and softwood trees, such as pine. Lynx are more likely to inhabit landscapes that provide suitable habitat for snowshoe hare populations in regenerating forest environments rather than landscapes with very recent clearcut or partial tree harvests. There are a number of scenarios that may unfold when a project is located within Canada lynx habitat – depending on the size and amount of the project, and how much habitat alteration may occur.

Prior to project inception, we coordinate with USFWS to describe the project and provide details regarding any potential change that may occur to the existing habitat (including tree removal or land clearing and soil excavation). Depending on the amount of potential habitat alteration, we may develop a Biological Assessment to provide to the USFWS. This assessment includes an in-depth analysis of the potential use and value of the habitat within the project area, and helps make a determination of the effect on Canada lynx, both as individuals and as a regional population. Sometimes surveying for lynx within the project area may need to be completed by a wildlife biologist in order to determine if lynx are actively using the land.

If potential habitat exists in the project area but there is a low likelihood of lynx using that habitat, the project may be required to modify the design such that tree removal is limited to the smallest area possible. There may be requirements to complete this clearing at a time when the impact to any potential lynx using the habitat would be the least harmful, such as during seasons when females will not be giving birth. If it is identified that lynx are actively using the project area, then additional coordination with USFWS is necessary to ensure the project will not directly affect those individuals.

We recently completed a Biological Assessment for Canada lynx at the Sugarloaf Regional Airport in Carrabassett Valley, Maine where tree removal within potential lynx habitat was proposed.

We recently completed a Biological Assessment for Canada lynx at the Sugarloaf Regional Airport in Carrabassett Valley, Maine where tree removal within potential lynx habitat was proposed. We worked with USFWS biologists to reduce the potential impacts to this habitat, and any lynx that may be using the area, by strictly limiting the area of tree removal to only that which is necessary to complete this important safety project, to ensure the result will increase the safety of the public using this airport, while also minimizing the risk to Canada lynx.

If you would like to learn more about Canada lynx, or the other species listed under the Endangered Species Act and the steps you can do celebrate Endangered Species Day, check out the USFWS website. Our environmental experts are here to answer your questions and help guide you through the project process while avoiding or minimizing impacts to listed species. Reach out to me and our environmental team will be happy to help.


Landslides: Prevention & Repair Through Slope Stabilization

Slope failure photo with blog title

In New England, March marks the last weeks of winter and the start of spring rains and snow melt.  Paying attention to erosion control during this time of year is always on the minds of municipal public works staff, state agencies, construction companies, and even homeowners, especially those fortunate enough (or perhaps not) to have water frontage. 

A 2018 study conducted by the USDA found that precipitation is increasing in the northeast more than any other region in the United States. The frequency of consecutive wet days is generally increasing in the northeast and precipitation extremes have also become more frequent. Given these trends, it is no surprise that peak flows in rivers and streams are also increasing and occurring earlier in the year which can result in a greater risk of flooding.

While it is difficult to prevent major erosion of stream and river banks due to extreme precipitation events, damage can be mitigated by inspections of at-risk areas combined with prioritization of these areas for repair. It is important to address slope failures quickly because bank degradation can cause significant damage including loss of property and infrastructure, sedimentation of the waterbody, water quality issues and damage to critical riparian buffer areas. As civil engineers, we can provide assistance with erosion control issues that range from preventative design practices, culvert replacements and stabilization of failed embankments.

Below is a list of some stabilization practices along with before and after photos of our recent embankment stabilization projects.

One such embankment failure occurred in Lancaster, New Hampshire, when high flow conditions in the Connecticut River resulted in severe washouts along an 800 foot long embankment causing loss of land and unstable soil conditions. Hoyle, Tanner designed and permitted solutions to repair and stabilize the slope using native riparian vegetation and rip rap armament. Live willow and dogwood stakes were planted in soil between the rip rap stones.

Terms to know:

  • Live willow & dogwood stakes: Living shrub cuttings that take root quickly in bank environments – provides natural habitat and additional erosion control
  • Rip rap: Large stones used for protection and dissipation of energy from high water flows
Washout along the Connecticut River in Lancaster
Lancaster Embankment after Stabilization

Hoyle, Tanner also designed and permitted repairs to a steep slope in Rochester, Vermont, when intense rainfall events undermined the toe of the bank, causing the slope and roadway above to fail and slide into Brandon Brook 90 feet below.  The repair solutions included installation of a blast rock toe detail and stone facing with grubbing material along the hillside to restore the slope. The roadway was reconstructed and a mid-slope underdrain was installed to intercept groundwater seepage. Debris from the slope failure was removed from Brandon Brook and the streambed was restored.

Terms to know:

  • Stone facing with grubbings: Combination of stone and native material to promote vegetation growth
  • Blast rock toe: Large rocks placed at the toe of the re-stabilized slope to combat undermining
Rochester Slope Failure at Brandon Brook
Brandon Brook Stabilized Slope Repair

Improving safety and combatting damage from growing peak flows and extreme storm events is an important part of our job. Hoyle, Tanner is excited to offer solutions to slope stability issues and challenging site conditions. For more information on how we can be of assistance, please contact me.

Presidential Power Sways Environmental Perception

Who would you say was one of the most significant environmental Presidents? Would it surprise you if I told you I think it is Richard Nixon? Yes, the only US President to resign from office, and who commonly made such un-eco-friendly statements as comparing environmentalists to a bunch of animals, was also the President who signed into creation the National Environmental Policy Act (NEPA) in 1969. This was one of the first laws that established the legislative framework for protecting the environment, outlined national environmental policies and goals, and developed the Presidential Council on Environment (now known as the Council on Environmental Quality (CEQ)) within the executive office. NEPA requires federal agencies to integrate our national environmental values into their decision making processes by considering the environmental, human and social impacts of their proposed actions as well as the reasonable alternatives to those actions.

In 1970, President Nixon also created the Environmental Protection Agency (EPA). Before the agency was created, our nation had no central authority overseeing the protection of the environment. Shortly afterwards, he signed into effect the Clean Air Act Extension. This is one of the most significant air pollution control bills in American history. It required the newly formed EPA to create and enforce regulations to protect people from airborne pollution known to be hazardous to human health, specifically targeting sulfur dioxide, nitrogen dioxide, particulate matter, carbon monoxide, ozone and lead.

President Nixon also signed into effect the Endangered Species Act (1973) creating the concept of preserving species and their habitats listed as threatened and endangered; this act has been called “the Magna Carta of the environmental movement.”

Finally, in the midst of his impeachment concerns, Nixon also proposed and lobbied through Congress the Safe Drinking Water Act that was ultimately signed by President Gerald Ford in 1974. This act initiated national efforts to protect the nation’s lakes, streams, rivers, wetlands and other bodies of water. It is fundamental in protecting aquatic resources including public drinking water supplies.

It comes as no surprise that during such an important environmental awareness period the first Earth Day was celebrated on April 22, 1970. Earth Day founder Gaylord Nelson, then a U.S. Senator from Wisconsin, proposed the idea of a “national teach-in on the environment” to the national media and ultimately gathered a national staff of 85 to promote events across the country. On that first Earth Day over 20 million Americans took to the streets, parks, and auditoriums to demonstrate for a healthy, sustainable environment in many wonderfully creative ways.

In the 45 years since the origin of NEPA and these other ground-breaking legislations, environmental protection and regulation has become extensive and complex. In my role as Environmental Coordinator, I work hard to ensure our clients and projects comply with the applicable laws and regulations that govern our projects. I work to guide projects from preliminary design through construction and operation while successfully acquiring the relevant federal and state environmental permits, including NEPA compliance for impacts to streams, rivers, floodplains, wetlands, and state- and federally-listed species, among others.

Earth Day 2015 will celebrate the 45th anniversary of the event that raised environmental issues awareness to unprecedented heights and brought the concept of working towards a cleaner and safer nation from a wild “hippie” idea to mainstream citizens. For more information on how you can participate in Earth Day celebrations and events visit Earth Day Network.