PFAS Compounds – Per- and polyflorioalkyl substances (PFAS)
On March 17, 2021, the New Jersey Department of Environmental Protection, Division of Water Quality required all industrial holders of a NJPDES Category B or L permit to submit responses to a survey to determine the potential for these discharges to contain PFAS.
The RVRSA is a Delegated Local Authority and as such writes Industrial Permits, when necessary, for users within its Service Area. The RVRSA prepared and distributed PFAS Survey’s to its industrial permittees. In addition, the RVRSA is currently testing its Influent and Effluent to determine if PFAS Compounds are present and to what extent. As test results are processed, the RVRSA will test areas of its Service Area to locate potential sources of PFAS to reduce or eliminate from the wastestream into the Treatment Plant.
On January 17, 2023, State of New Jersey, Department of Environmental Protection Commissioner, Shawn M. LaTourette, signed Administrative Order No. 2023-01, directing the following:
1. For purposes of this order, PFAS is defined as those substances identified in the draft
EPA Method 1633.
2. Where a Treatment Entity or DLA provides PFAS data from its system to the Department in the form
and manner prescribed by the Department to assist in the collective effort to identify, reduce or
eliminate sources of PFAS discharged into the wastewater systems operated by Treatment Entities or
DLAs, the Department shall:
a. Deem such data as disclosed to the Department as part of the NJPDES permit application and
compliance process under N.J.A.C. 7:14A; and
b. Consider such PFAS data to have been within the reasonable contemplation of the Department as
part of the Treatment Entity’s or DLA’s NJPDES permit application process; and,
c. Consider the Treatment Entity’s or DLA’s discharge of PFAS protected by the permit shield
afforded pursuant to 33 USC § 1342(k) unless it is required by the Department to be reported in
their Discharge Monitoring Report.
3. Based on the foregoing findings, the Department will not take an enforcement action for an
unpermitted discharge against any Treatment Entity or DLA based upon PFAS data submitted to the
Department solely pursuant to this Order.
4. This Order shall take effect immediately and shall be retroactive to January 1, 2021. Any PFAS
data previously submitted by a Treatment Entity or DLA consistent with the terms of this Order
shall be treated in the same manner and with the same protection as data submitted after the
effective date of this Order.
5. This Order shall not apply to any PFAS data submitted pursuant to a current or future
requirement in a Treatment Entity’s or DLA’s NJPDES permit.
INFILTRATION AND INFLOW
Historically and in recent years (2012 to 2023), the RVRSA has observed a steep rise in flows during rain storms through its metering stations and into the wastewater treatment plant. Increases in flow during rain events is attributable to Infiltration and Inflow.
Infiltration is defined as ground water that seeps into a sewer line through holes, breaks and joint failures in both the main gravity sewer as well as house connections to sewer mains. Age of the connection, tree roots and damage to sewer laterals all contribute to infiltration of ground water into sewer systems.
Inflow is defined as gound water that is misdirected into the sewer system. Sources of inflow are sump pumps, roof drains, and cross connected storm drains.
I & I into the sewer system has a costly impact to all. Municipalities and customers within the RVRSA Service Area are billed annually based on flow and the RVRSA budget. Added flow from I&I increases the annual flow for the municipality which then impacts the cost to the municipality. Municipalities then may increase the cost of sewer treatment to its individual rate payers. In addition to the increased costs associated with I&I, I&I also increases the potential of overflows from sanitary manholes and at other locations in the sewer system during heavy rain events.
Homeowners can do their part to reduce I&I by:
1. Check that outside gutters and outside drains are not connected to the sanitary sewer.
2. Avoid planting trees and shrubs over sanitary sewer laterals.
3. Inspect sewer cleanout caps at least annually to ensure they are present, closed and not broken by lawn mowers or other yard equipment.
4. Inspect house basement sump pumps and drains to ensure they are not connected into the sanitary sewer.
5. Repair house connection (lateral) if it is cracked, broken or has tree roots growing into it.
6. Notify the town or water company of any water leaks you may notice. Water leaks not only are a waste of water, but this water often finds its way into the sanitary sewer system.
Making these repairs will not only reduce infiltration, but will also reduce the potential of blockages in the future.
Connections to RVRSA
Prior to any new connection to the sanitary sewer system in RVRSA’s sewer service area, a connection permit must be issued. This permit must first be endorsed by the town to ensure that the town is aware of the connection and all town regulations are followed.
Once a permit is issued by the RVRSA, the RVRSA will perform an inspection of the work. The RVRSA requires a pressure test to be performed and witnessed by RVRSA on all new pipes connecting to the sanitary sewer system to ensure that the pressure within the pipe does not drop excessively over time. A pressure drop would indicate a leak and a potential source of infiltration.
Finally, the RVRSA inspects its Interceptor System on a regular basis and performs as needed maintenace and mainline pipe replacements as necessary. Manhole inserts are installed in manholes located in areas where they are subject to being submerged due to flooding. Any manholes that are observed to be missing or improperly seated should be reported to the town immediately.
ENERGY – (Reliability and Cost)
The operation of the wastewater treatment facility requires reliable sources of energy to operate pumps and other equipment without interruption. In cases of power outages it is essential that backup power is supplied using electrical generators. To ensure reliable power, RVRSA equipment is inspected and serviced on a quarterly, semi-annual and annual basis.
To address the increasing cost of energy, the RVRSA is a member of an Energy Aggregate with other Municipalities and Authorities in New Jersey where bulk pricing provides for lower prices.
Workers in the wastewater industry, including RVRSA employees are stewards of the environment. Operators are required to be licensed by the State of New Jersey and are also required to obtain continuing education hours to maintain issued by the State.
The RVRSA also employs other professionals who work in Administration, Finance, Human Resources, Engineering, Industrial Pre-Treatment and Laboratory Science.
A career in the wastewater industry can be very rewarding, but is often overlooked by people entering the workforce. The RVRSA is looking to the future by succession planning and promoting public education and awareness of the career opportunities in the wastewater industry thru its affiliation with various organizations including the AEA and the NJWEA.
FOG – (Fats, Oils & Grease)
Fats, oils and grease enter into sewer systems from homes and businesses through washing and rinsing dishes, pot and pans. Once the hot liquid FOG enters the sewer system it quickly cools, hardens and lines pipes. Overtime the pipe will become blocked and will require cleaning.
Homeowners can prevent expensive cleaning costs by collecting FOG (use a soup or other small can) and when the FOG is cool, dispose of the FOG in the regular trash.
Businesses can prevent expensive sewer cleaning by having properly sized grease traps and inspecting and cleaning them frequently.
As municipalities in the RVRSA’s Service Area expand in response to their Master Plans, additional demands are placed on the RVRSA Interceptor System and Treatment Facility. The RVRSA monitors the quality and quantity of the influent and effluent of the Treatment Facility through its NJ Certified Wastewater Laboratory and reports test results to the NJ DEP via monthly, semi-annual and annual Discharge Monitoring Reports.
The Morris County Office of Planning and Preservation along with the Highlands Commission are responsible for the generation of RVRSA’s Service Area Wastewater Management Plan (WMP). Future flows are estimated by each municipality by reviewing its Master Plan and Zoning Ordinances and reporting current and future estimated flows to Morris County.