MWEA NPDES Permit Compliance Seminar December 2, 2009 1 Patrick Bradley LimnoTech MWEA Government Affairs Committee NPDES Compliance Seminar December 2, 2009 Bath, MI POTWs ◦ Capacity issue Additional treatment facilities Bypass/blending Collection system ◦ CSOs ◦ Capacity issue SSOs MS4 ◦ Flood control ◦ Erosion control ◦ Watershed enhancement
10
Embed
Patrick Bradley LimnoTech - Michigan Water Environment ... Weather Permitting_Bradley.pdf · Patrick Bradley LimnoTech MWEA Government Affairs Committee NPDES Compliance Seminar December
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
MWEA NPDES Permit Compliance Seminar December 2, 2009
MWEA NPDES Permit Compliance Seminar December 2, 2009
2
� MS4◦ Urban runoff
� MEP
� CSOs ◦ NMC
◦ LTCP
� Construction◦ Erosion control
� Post-construction/Development
� Industrial activities
� Agriculture
� Forestry
MWEA NPDES Permit Compliance Seminar December 2, 2009
3
� What are the “real issues”??
� Where would the watershed spend the dollars?
� The discharge from the WWTF is probably not a major problem during wet weather events
� The major issues originate in the “non-point sources” or the point sources that act like non-point – wet weather sources
MWEA NPDES Permit Compliance Seminar December 2, 2009
4
� CSOs
� Storm water
� SSOs
� Peak Flows (Blending)
Water Quality Standards-to-
Permits Process
� Designated uses
� Criteria to protect the uses
◦Numeric
◦Narrative
� Anti-degradation Policy
MWEA NPDES Permit Compliance Seminar December 2, 2009
5
� Water Quality Standards
◦Generally, WQ standards do not
specifically address wet weather
◦WQ standards apply in the water, not
end of pipe – unless specifically stated in
the standard
◦Without data, regulatory agencies will
make conservative assumptions
� Wet Weather Permitting Challenges
◦ CSOs – NMCs, LTCPs (Presumption versus
Demonstration), Post Phase II???
◦ Municipal Storm water – MEP is the requirement for
control
◦ SSOs – Are point sources, so cannot discharge
without a permit
◦ Peak Flows (a.k.a. “Blending”) – Supposedly these are
bypasses, but they are not
MWEA NPDES Permit Compliance Seminar December 2, 2009
6
� Focus on the permit and how to determine if the discharge will meet permit requirements
� Assure that Effluent Limitations are Appropriate (and Achievable)
◦ NMC, LTCP, post-LTCP
� Watch out for broad, poorly defined limits
� At all times the discharge shall not cause receiving waters to contain substances, materials, floating debris, oil or scum:◦ That will settle to form putrescent or otherwise
objectionable deposits;
◦ That are in amounts sufficient to be unsightly or
deleterious;
◦ Yada, yada, yada
� Permittees should question permit language if they can’t clearly demonstrate compliance
MWEA NPDES Permit Compliance Seminar December 2, 2009
7
� Advantages
◦ Applicable for WQBELs
◦ Opportunity to address discharges on a system-wide
basis
◦ Gain some economy of scale
◦ More efficiently use resources
� Disadvantages
◦ Permit writers lack experience and resources
� CSOs
◦ NMC meets TBEL
◦ Regulations require permit writers to calculate numeric
limits; options exist
◦ Make sure the permit reflects your LTCP
� Storm water (how does MEP fit in?)
� SSOs (TBEL is challenge)
� Peak Flows (combination)
MWEA NPDES Permit Compliance Seminar December 2, 2009
8
� Provides a framework for evaluating water quality related issues in a comprehensive, prioritized manner
� Convergence of regulatory frameworks◦ CSO vs. SSO� 3-4/yr vs. “0”
◦ WWTF vs. MS4� Tech-based vs. BMP
◦ Grey vs. Green� Concrete & steel vs. plants
� Stormwater, CSO and SSOs are all controlled via BMP limits (or can be)
� Why not have a single “Wet Weather” BMP control system?
MWEA NPDES Permit Compliance Seminar December 2, 2009
9
� Tension between objectives
◦ Enhancement of riparian corridors
� Increase in wildlife populations
◦ Reduction in bacteria levels
� Integrated Water Resources Management
� “Water is Water”
� Prioritization
� Comprehensive, Innovative Solutions
MWEA NPDES Permit Compliance Seminar December 2, 2009
10
Patrick BradleyPatrick BradleySenior ScientistLimnoTech1705 DeSales Street, NW, Suite 600Washington, D.C. 20036Tel. [email protected]
� NPDES Permit Program: www.epa.gov/npdes
� Overview of the Water Quality Standards-to-Permits Process: cfpub.epa.gov/npdes/wqbasedpermitting/wqoverview.cfm
� EPA. 2007. Watershed-Based National Pollutant Discharge Elimination System (NPDES) Permitting Technical Guidance. www.epa.gov/npdes/pubs/watershed_techguidance.pdf