tmdls and phosphorus compliance -...
TRANSCRIPT
Reconnaissance, Creative Solutions and Partnerships
TMDLs and Phosphorus Compliance:
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Agenda
• Overview of TMDLs & Phosphorus Regulations
• Compliance Options • Take away
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Phosphorus Standards• Est. in 2011
– NR 102– WQ Standards for Phosphorus– NR 217– Implementation of phosphorus standards in WPDES
permits– NR 151– Agricultural performance standards for phosphorus.
• All WPDES permits issued after December 2010 – Compliance schedule = up to 7 to 9 years
• Limits based on one of the following – TBL (Technology Based Limits) – WQBEL (Water Quality Based Effluent Limits)
• limits based on the receiving water– TMDL – watershed based
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Adjusting Phosphorus Limits• TMDL-derived limits• Site-specific criteria:
– less stringent phosphorus limits where water quality goals are being attained despite elevated phosphorus levels
• Variance waters: – surface waters not capable of meeting the
fishable or swimmable goals – some streams have too little flow to support a
healthy fish community
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Total Maximum Daily Load• Required for impaired waters under CWA• Amount of pollutant that the watershed can
receive and still meet water quality standardsload allocations (nonpoint sources)
+ waste load allocations (point sources)+ margin of safety
TMDL
• Included in WPDES permits • Municipal Wastewater Dischargers• Industrial Wastewater Dischargers (cheese factories, breweries)• Municipal Separate Storm Sewer System (MS4/TMDL)• Non-contact cooling water • Concentrated Animal Feeding Operations (CAFO)
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Status of TMDLs
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http://dnrmaps.wi.gov/SL/?Viewer=Watershed%20Restoration%20Viewer&layerTheme=statewide%20tmdl
Compliance Options • Variances
– Individual Variance– Multi-discharger Variance
• Adaptive Management• Water Quality Trading• On-site evaluations
– Modeling of existing BMPs– Facility Upgrades (Wastewater dischargers)– New treatment BMPs (MS4/TMDLs)– Consumptive Use
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http://dnr.wi.gov/news/mediakits/mk_phosphorus.asp
Variances • Process & submittal
requirements in s. 283, Stats. & NR 200 & 217, Wis. Adm. Code
• Individual Economic Hardship Variance – Site specific analysis– Will it “cause substantial and widespread adverse social and
economic impacts in the area where the permittee is located” – Only for specific permit term (5 yrs)– State standards loosely based on EPA guidance – The application for the variance can occur during either the first or
the second permit term.– Have to do pollution prevention projects
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Multi-Discharger variance • Must be approved by EPA
– final package mailed to EPA on March 30, 2016.• DNR/DOA = economic analysis for state• Table to identify the type of permittee that may
be eligible. – Still need to apply and conduct facility/municipal specific
analysis to determine final eligibility
• NOT a free pass– Interim limits- progressively more restrictive – Also must do one of the following –
• Pay $ to county - $50/lb/year over target value• Adaptive Management projects• 3rd party to reduce phosphorus discharge
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Multi-Discharger Variance• More streamlined approach
– simplifies the application and review process.– EPA = discretionary review over individual
requests• Watershed improvements
– spelled out for entire state– rather than being site-specific.
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http://tony-wilson.com.au/blog/trust-in-teams-pt-ii-the-physiology-of-higher-performance/
Comparisons
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EPA’s Water Quality Trading Toolkithttps://www3.epa.gov/npdes/pubs/wqtradingtoolkit.pdf
Adaptive Management • Watershed efforts to reduce phosphorus
– Partnerships to implement BMPs “upstream”• Typically Agricultural Landowners
– In-stream monitoring to show BMPs are working • If not working at the end of 15 yrs, will need to look at
WQ trading or treatment BMPs– Good option if waterbody is close to achieving water
quality standard for phosphorus– More flexible implementation than WQ trading
• Permit compliance timeline extended (15yrs) to identifying and implementing measures
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Adaptive Management
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http://dnr.wi.gov/topic/SurfaceWater/documents/AdaptiveManagementHandbooksigned.pdf
Examples
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http://www.nrcs.usda.gov/wps/portal/nrcs/detail/ia/home/?cid=nrcs142p2_008566
Water Quality Trading • Compliance with discharge limit• Point source (PS) pays someone to achieve
less costly pollutant reduction in watershed. – PS or Non-PS (ag., municipalities)– Limited circumstances a non-PS can buy from
another non-PS• Can be “upstream” or “downstream”• Trade ratios to quantify reductions• Long-term if practice/activity is maintained
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Water Quality Trading• Practices must be in place prior to credit use• Not as flexible as adaptive management.
– Agreement to buy credits and practices used to generate credits must be established up front.
– Compliance schedule typically 5 years or less. – Practices must have quantifiable reductions
• May not be a viable compliance option for some due to – Costs– No credit generators in their watershed
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Examples• Baker Cheese
– New wastewater treatment facility• Previously trucked waste to WWTP• Had phosphorus limit of 0.075 mg/L & 0.16 lb/d
– New discharge = must achieve P-standards on day 1• Chemical treatment in the facility = discharge at 0.2-0.4
mg/L – Purchased nearby farm fields with phosphorus runoff and
restored the fields to native prairie– Permanent credits generated to help facility meet
discharge limits– Credits placed in annual bank for use
• Use/withdraw credits from bank as needed
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John Clancy, Godfrey & Kahn- CSWEA 2016 Government Afffairs Seminarhttp://www.cswea.org/File_Catalog/WISCONSIN/2016_Government_Affairs/5_B_John_Clancy_1035_Baker_Cheese_Example.pdf
Examples• Red Cedar River Nutrient Trading Pilot Program
– City of Cumberland• Paying farmers in the watershed to install BMPs
– Nutrient management planning & no-tillage• More than 60 BMPs purchased• Required to purchase 4,400 pounds of phosphorus credits
per year• Farmers may receive payment for a BMP for 3 years
– Barron Co. LCD = 3rd party facilitator to est. Ks– Trade ratio of 2:1– City has paid $58,000 to remove 31, 500 lbs of P
https://www3.epa.gov/npdes/pubs/wqtradingtoolkit_appendices.pdf
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Out of state example• City of Princeton WWTP, Minnesota
– Previously discharge infiltrated into groundwater• Groundwater contamination & high groundwater
– New discharge to Rum River (ORW in MN)• Phosphorus limits strict because of anti-degradation
requirements – To meet the phosphorus limits
• Facility upgrade• Water Quality trading with non-point sources
– Shoreland restoration projects
MS4/TMDL PERMIT OVERVIEW
IMPAIRED WATERBODY EXAMPLE – MASON CREEK
MS4/TMDL ROCK RIVER BASIN MAJOR SUB-BASINS IMPAIRED WATERBODIES
MS4/TMDL PERMITS
• ROCK RIVER BASIN• TOWN OF OCONOMOWOC• TOWN OF MERTON• VILLAGE OF MERTON• CITY OF DELAFIELD• VILLAGE OF SUMMIT
SEH COMMUNITIES WITHIN THE ROCK RIVER BASIN
MS4/TMDL PERMIT OVERVIEW• SECTION 1: APPLICABILITY CRITERIA
MS4/TMDL PERMIT OVERVIEW• SECTION 1: APPLICABILITY CRITERIA
TMDL Required for Impaired waterbodies (Sec. 303d) identified by WDNR & EPA
TMDL generated for all pollutants violating water quality standards for each impaired waterbody
TMDL = ∑WLA + ∑LA + MOS
• WLA = Waste Load Allocation (point sources such as WWTFs, MS4/TMDLs, and general permits)
• LA = Load Allocation (nonpoint sources such as agriculture, forest/wetland, non-permitted urban)
• MOS = Margin of Safety
Total Suspended Solids (TSS) and Total Phosphorus (TP) for MS4/TMDLs has its own WLA, as defined by the TMDL, for each Reachshed of an impaired waterbody
• WATER QUALITY MONITORING
• WATERSHEDS EVALUATED FOR TSS AND TP LOADING USING WINSLAMM
• WATERSHED DELINEATED BASED ON DRAINAGE AREA FOR OUTFALLS AND/OR TREATMENT PRACTICES
• TREATMENT PRACTICES – GRASS SWALES, INFILTRATION AND WET PONDS, FILTER STRIPS, CATCH BASINS AND STREET SWEEPING (ONLY STREETS WITH CURB & GUTTER ARE ELIGIBLE
• WATERSHED CAN BE EXCLUDED FROM MODELING IF:• AREA DOES NOT DRAIN THROUGH MS4/TMDL
• AGRICULTURAL LAND USE
• UNDEVELOPED PARCEL LARGER THAN 5 ACRES
• STATE OR INTERSTATE TRANSPORTATION
• OUTSIDE THE URBANIZED AREA FROM DECENNIAL CENSUS
MS4/TMDL PERMIT COMPLIANCE
Reachsheds
Urbanized Area
Modeled Area
Unmodeled Area
MS4/TMDL PERMIT COMPLIANCE
• TMDL COMPLIANCE• UPDATED WINSLAMM FILES USED FOR INITIAL WATER QUALITY
STANDARDS REQUIREMENTS (20% TSS REDUCTION)
• INITIALLY MODELED EACH WATERSHED IN WINSLAMM WITH NO CONTROLS
• MODELED EACH WATERSHED WITH CONTROLS
• INCORPORATED ANY BMP’S• SWALES & FILTER STRIPS
• WET PONDS, BIOFILTERS AND CATCH BASINS
• USED WDNR TABLE 2: DESIGN INFILTRATION RATES FOR SOIL TEXTURES RECEIVING STORMWATER – BASED ON RAWLS, 1998
• OUTPUT RESULTS FOR NO CONTROLS & EXISTING CONDITIONS
MS4/TMDL PERMIT COMPLIANCE
Reachshed Municipalities within Reachshed
Required TSS % Reduction
Required TP % Reduction
23 Town of Merton 47% 36%
25Oconomowoc
Merton (Town & Village) 59% 74%
55 Merton (Town & Village) 66% 77%
• TMDL % REDUCTION REQUIREMENTS
• BASED ON TMDL WATER QUALITY POLLUTANT LOAD ALLOCATIONS
MS4/TMDL PERMIT COMPLIANCE
ReachshedTSS % Reductions TP % Reductions
Required Ocono. T. Merton V. Merton Required Ocono. T. Merton V. MertonID/Fox River - 87.7% 69.6% 58.8% - 86.2% 69.3% 55.3%
23 47% - 63.1% - 36% - 58.0% -25 59% 52.5% 43.5% 83.6% 74% 49.1% 39.6% 75.7%55 66% - 44.3% 66.8% 77% - 39.6% 61.6%
CONSERVATIVE VALUES!
NOTE: ID = INTERNALLY DRAINED
MS4/TMDL PERMIT COMPLIANCE
• TMDL ANALYSIS CONTINUED: INFILTROMETER TESTING TOWNS OF OCONO. & MERTON• MAP CREATED WITH RECOMMENDED TEST LOCATIONS, SUBMITTED TO AND APPROVED BY WDNR
• FIELD TESTING CONDUCTED TO GET REAL INFILTRATION RATES
• ALLOWS FOR MORE ACCURATE WINSLAMM MODELING OF TSS & TP REDUCTION
Test Location
Infiltration Rate
Modeled Area
Unmodeled Area
LOW HIGH
MS4/TMDL PERMIT COMPLIANCE
Delafield Public Works Bio-Filter
Double-Ring Infiltrometer
INFILTROMETER TESTING OVERVIEWMS4/TMDL PERMIT COMPLIANCE
TMDL COMPLIANCE - CONTINUED REMODELED EACH WATERSHED IN WINSLAMM W/ FIELD TESTED
INFILTRATION RATES FOR BMPs THAT UTILIZE INFILTRATION FOR EVERY REACHSHED TSS & TP % REDUCTION RESULTS
WERE MUCH BETTER – BUT NOT ALL MET REDUCTION REQUIREMENTS
MS4/TMDL PERMIT COMPLIANCE
• TOWN OF OCONOMOWOC – STORM WATER MODELING SPREADSHEET
MS4/TMDL PERMIT COMPLIANCE
Town of Oconomowoc
ReachshedTSS % Reductions TP % Reductions
Required Unmeasured Infiltration
Measured Infiltration Required Unmeasured
InfiltrationMeasured Infiltration
ID/Fox River - 87.7% 90.6% - 86.2% 89.2%23 47% - - 36% - -25 59% 52.5% 82.3% 74% 49.1% 81.4%55 66% - - 77% - -
Town of Merton
Reachshed
TSS % Reductions TP % Reductions
Required Unmeasured Infiltration
Measured Infiltration Required Unmeasured
InfiltrationMeasured Infiltration
ID/Fox River - 69.6% 81.6% - 69.3% 81.2%23 47% 63.1% 79.3% 36% 58.0% 78.0%25 59% 43.5% 75.3% 74% 39.6% 72.9%55 66% 44.3% 78.5% 77% 39.6% 75.9%
NOTE: ID = INTERNALLY DRAINED
TMDL MODELING – TOWNS OF MERTON & OCONO. MODELED SEPARATELYMS4/TMDL PERMIT COMPLIANCE
THE PHOSPHOROUS REMOVAL REQUIREMENT IS NON-COMPLIANT, BUT THE MARGIN WAS DRASTICALLY REDUCED. MINIMAL ADDITIONAL CONTROLS WOULD BE REQUIRED OR THERE IS A POSSIBILITY FOR TRADING TO REACH COMPLIANCE
Reachsheds
Urbanized Area
Modeled Area
Unmodeled Area
• POTENTIAL STORM WATER IMPROVEMENT LOCATION – TOWN MERTON
Infiltration Basin
MS4/TMDL PERMIT COMPLIANCE
Infiltration Basin
• POTENTIAL STORM WATER IMPROVEMENT LOCATION – TOWN MERTON
MS4/TMDL PERMIT COMPLIANCE
• BMP EXAMPLES TOWN OF MERTON AREA
TOWN OF OCONOMOWOC AREA
MS4/TMDL PERMIT COMPLIANCE
MS4/TMDL BMP OVERVIEWBMP OPTIONS GRASSED SWALES WET DETENTION BASINS INFILTRATION BASINS BIO-FILTRATION BASINS FILTER STRIPS CATCH BASINS PROPRIETARY STORMWATER
DEVICES (I.E. STORMCEPTORS,ETC.)
PERVIOUS PAVEMENT STREET CLEANING & LEAF
SWEEPING
MS4/TMDL BMP’SGRASSED SWALES % REDUCTION VARIES WITH
SLOPE, SHAPE, LENGTH & INFILTRATION RATE (SOILS)
% REDUCTIONS OF TSS AND P IN THE 10-95% RANGE
HIGHLY RECOMMEND INFILTROMETER TESTING TO INCREASE WDNR TABLE VALUES FOR INFILTRATION RATES
LONGITUDINAL SLOPES MUST BE < 4%
PRE-TREATMENT NOT REQUIRED
MS4/TMDL BMP’SWET DETENTION BASINS % REDUCTION VARIES WITH SIZE
OF BASIN TO DRAINAGE AREA AND OUTLET DESIGN
% REDUCTIONS OF TSS AND P IN THE 50-90% RANGE
BUILD TO WDNR TECH STD. 1001 MUST HAVE 2 FT. CLAY LINERS
AND SAFETY SHELVES MUST BE IN PUBLIC DRAINAGE
EASEMENTS WITH MAINTENANCE AGREEMENTS
MS4/TMDL BMP’SINFILTRATION BASINS % REDUCTION VARIES WITH SIZE
OF BASIN TO DRAINAGE AREA AND SOILS
% REDUCTIONS OF TSS AND P IN THE 60-100% RANGE
BUILT TO WDNR TECH STD. 1003 MUST HAVE 3 FT. SEPARATION
TO SEASONAL HIGH GROUNDWATER
MUST BE IN PUBLIC DRAINAGE EASEMENTS WITH MAINTENANCE AGREEMENTS
PRE-TREATMENT REQUIRED
MS4/TMDL BMP’SBIO-FILTRATION BASINS % REDUCTION VARIES WITH SIZE
OF BASIN TO DRAINAGE AREA AND SOILS
GENERALLY SMALLER WATERSHEDS (<2 AC.)
% REDUCTIONS OF TSS AND P IN THE 60-100% RANGE
BUILT TO WDNR TECH STD. 1004 TYPICALLY HAS UNDERDRAIN MUST BE IN PUBLIC DRAINAGE
EASEMENTS WITH MAINTENANCE AGREEMENTS
PRE-TREATMENT GENERALLY REQUIRED
MS4/TMDL BMP’SCATCH BASINS & PROPRIETARY DEVICES % REDUCTION VARIES WITH
DRAINAGE AREA. FOLLOW WDNR TECH STD. 1006 GENERALLY SMALLER
WATERSHEDS (<2 AC.) % REDUCTIONS OF TSS AND P
IN THE 8% RANGE FOR CATCH BASINS
% REDUCTIONS IN THE 40-50% RANGE FOR PROPERLY SIZED PROPRIETARY DEVICES
CAN BE ADDED TO ROAD RE-CONSTRUCTION PROJECTS TO IMPROVE REDUCTIONS
REQUIRE YEARLY CLEANING
MS4/TMDL BMP’SFILTER STRIPS % REDUCTION VARIES WITH
SLOPE & SLOPE LENGTH GENERALLY SMALLER
WATERSHEDS MUST BE GREATER THAN 10 FT.
IN LENGTH FOR WinSLAMM MODELING
PARKING LOT RUNOFF OR FILL SECTIONS OF RURAL ROADS
% REDUCTIONS OF TSS AND P IN THE 50-100% RANGE
MS4/TMDL BMP’SSTREET CLEANING -LEAF SWEEPING % REDUCTION VARIES WITH
SWEEPER AND FREQUENCY OF SWEEPING
GENERALLY NEED A VACUUM SWEEPER, ONCE A WEEK FOR AN EFFECTIVE % REDUCTION
% REDUCTIONS OF TSS IN THE 1-9% RANGE, PER RECENT WDNR STUDY IN MADISON
% REDUCTIONS IN THE 10-20% RANGE MAY BE POSSIBLE WITH AGGRESSIVE SWEEPING WITH MODERN VACUUM SWEEPERS
MS4/TMDL BMP’SPERMEABLE PAVEMENT USE WDNR TECH STD. 1008 GENERALLY SMALLER
WATERSHEDS PAVERS, CONCRETE, ASPHALT
& PROPRIETARY SYSTEMS (SPANCRETE, PAVE-DRAIN, ETC.)
PARKING LOT RUNOFF, OR EDGE OF ROADWAYS
POTENTIAL FOR ROAD RECONSTRUCTION PROJECTS
% REDUCTIONS OF TSS AND P IN THE 65-35% RANGE, RESPECTIVELY
MAINTENANCE REQUIRED (VACUUM)
MS4/TMDL PERMIT SUMMARY• TMDL’S DO HAVE A SIGNIFICANT IMPACT ON AN MS4 AND
HOW IT IS EVALUATED• MAKE SURE TO TAKE CREDIT FOR ALL EXISTING BMP’S IN A
WATERSHED• LOOK FOR ANY PRIVATE BMP’S AND DISCUSS EASEMENTS WITH
THE OWNERS• MAKE SURE TO COMPLETE INFILTROMETER TESTING TO
INCREASE INFILTRATION RATES OF SWALES AND BASINS• LOOK FOR WAYS TO INCREASE INFILTRATION OPPORTUNITIES
WITH GRASSED SWALES AND FILTER STRIPS
WWTP Facility Upgrades • Analysis of existing operations
– Facilities with tertiary treatment• Pilot testing shows they can typically get close
– Optimization of processes & increased use of chemicals
– Facilities with no tertiary treatment• May need upgrades at significant cost if on impaired
waterway• Consider requesting a revised 7Q10 flow from USGS
if stream is below criteria to gain maximum dilution factor possible
Consumptive Use• Consumptive use
– potential users of water that may be able to use treated wastewater as a substitute water source.
– Water = “consumed” by evaporation, or incorporation into a product or discharge to somewhere other than the waterway ≠ phosphorus standards.
– Site specific – Examples
• Wash water for Frac sand• Irrigation • Concrete products (watch chloride content)
What we’re hearing• Adaptive management
– If the stream doesn’t meet criteria, must look at other options
• Legacy Phosphorus? -Dane County LCD http://www.cswea.org/File_Catalog/WISCONSIN/2016_Government_Affairs/3_John_Reimer_940_Implications_of_Legacy_Phosphorus_in_Sediment.pdf
• Can’t control other land use practices upstream
• Adaptive management & water quality trading– Long-term management & oversite