National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit Program Factsheet

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1 National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Permit Program Factsheet Permittee: City of Princeton Facility Name: Princeton WWTF Permit Number: MN nd Street North 100 Pond Road Princeton, MN Princeton, MN Current Permit Expiration: November 30, 2014 Public Comment Period Begins: April 22, 2015 Period Ends: May 22, 2015 Receiving Water: Rum River (Class 2B, 3C, 4A, 4B, 5, 6 Water) Proposed Action: Permit Reissuance Permitting Contact Robin L. Novotny Minnesota Pollution Control Agency Baxter, MN Phone: Fax:

2 Table of Contents Purpose and Participation Applicable Statutes... 3 Purpose... 3 Public Participation Facility Description Background Information Facility Location... 4 Outfall Location... 4 Map of Permitted Facility... 5 Components and Treatment Technology Current Information... 6 Flow Schematic... 7 Changes to Facility or Operation... 8 Significant Industrial Users... 8 Recent Compliance History... 8 Recent Monitoring History... 9 Receiving Water Use Classification Impairments Total Maximum Daily Load Studies Existing Permit Effluent Limits Technology Based Effluent Limits Water Quality Based Effluent Limits State Discharge Restriction Limits Existing Permit Effluent Limits Proposed Permit Effluent Limits Technology Based Effluent Limits Water Quality Based Effluent Limits State Discharge Restriction Limits Proposed Permit Effluent Limits Phosphorus Management Chronic Whole Effluent Toxicity Monitoring Annual Testing Additional Requirements Pollutant Minimization Plans Additional Monitoring Requirements Industrial Stormwater Biosolids Total Facility Requirements Nondegredation and Anti backsliding

3 Purpose and Participation Applicable Statutes This factsheet has been prepared according to the Title 40 Federal Code of Regulations (CFR) and and Minn R , subp. 3 in regards to a draft National Pollutant Discharge Elimination System (NPDES)/State Disposal System (SDS) permit to construct and/or operate wastewater treatment facilities and to discharge into waters of the state of Minnesota. Purpose This factsheet outlines the principal issues related to the preparation of this draft permit and documents the decisions that were made in the determination of the effluent limitations and conditions of this permit. Public Participation You may submit written comments on the terms of the draft permit or on the Commissioner s preliminary determination. Your written comments must include the following: 1. A statement of your interest in the permit application or the draft permit. 2. A statement of the action you wish the Minnesota Pollution Control Agency (MPCA) to take, including specific references to sections of the draft permit that you believe should be changed. 3. The reasons supporting your position, stated with sufficient specificity as to allow the Commissioner to investigate the merits of your position. You may also request that the MPCA Commissioner hold a public informational meeting. A public informational meeting is an informal meeting which the MPCA may hold to help clarify and resolve issues. In accordance with Minn. R and Minn. R , your petition requesting a public informational meeting must identify the matter of concern and must include the following: items 1 through 3 identified above; a statement of the reasons the MPCA should hold the meeting; and the issues you would like the MPCA to address at the meeting. In addition, you may submit a petition for a contested case hearing. A contested case hearing is a formal hearing before an administrative law judge. Your petition requesting a contested case hearing must include a statement of reasons or proposed findings supporting the MPCA decision to hold a contested case hearing pursuant to the criteria identified in Minn. R , subp. 1 and a statement of the issues proposed to be addressed by a contested case hearing and the specific relief requested. To the extent known, your petition should include a proposed list of witnesses to be presented at the hearing, a proposed list of publications, references or studies to be introduced at the hearing, and an estimate of time required for you to present the matter at hearing. You must submit all comments, requests, and petitions during the public comment period identified on page 1 of this notice. All written comments, requests, and petitions received during the public comment period will be considered in the final decisions regarding the permit. If the MPCA does not receive any written comments, requests, or petitions during the public comment period, the Commissioner or other MPCA staff as authorized by the Commissioner will make the final decision concerning the draft permit. During the public comment period, however, you may request that the draft permit be presented to the 3

4 MPCA s Citizens Board (Board) for final decision. You may participate in the activities of the Board as provided in Minn. R Comments, petitions, and/or requests must be submitted by the last day of the public comment period to: Robin L. Novotny Minnesota Pollution Control Agency 7678 College Road, Suite 105 Baxter, MN The permit will be reissued if the MPCA determines that the proposed Permittee or Permittees will, with respect to the facility or activity to be permitted, comply or undertake a schedule to achieve compliance with all applicable state and federal pollution control statutes and rules administered by the MPCA and the conditions of the permit and that all applicable requirements of Minn. Stat. ch. 116D and the rules promulgated thereunder have been fulfilled. More detail on all requirements placed on the facility may be found in the permit document. Facility Description Background Information Facility Location The Princeton Wastewater Treatment Facility (Facility) is located at NW ¼ of SW ¼, Section 3, and NE ¼ of SE ¼, Section 4, Township 35 North, Range 26 West, Baldwin Township, Sherburne County, Minnesota as shown in Figure 1. Outfall Location The Facility has a continuous discharge (SD001) to the Rum River (Class 2B, 3C, 4A, 4B, 5, and 6 Water). SD001 is located in SW ¼ of NW ¼ of SE ¼, Section 3, Township 35 North, Range 26 West, Baldwin Township, Sherburne County, Minnesota as shown in Figure 1. 4

5 Map of Permitted Facility Figure 1. Facility and Outfall Location 5

6 Components and Treatment Technology Current Information The existing Class A Facility is designed to treat an average wet weather (AWW) flow of million gallons per day (mgd), an average annual flow of mgd, a peak hourly wet weather flow of mgd and a five day carbonaceous biochemical oxygen demand (CBOD 5 ) strength of 241 milligrams per Liter based on the AWW design flow. The Facility is an activated sludge plant designed for operation in an extended aeration mode. The main lift station is preceded by a manual bar screen and also has a standby generator with automatic transfer capabilities. The Facility receives influent from two lines each consisting of 4,500 feet of 12 inch polyvinyl chloride (PVC) force main from the main lift station. This main lift station is fed by five other small lift stations throughout the town. The Facility consists of influent flow metering, four static fine screens with screen element washer and heat system and also two screening compactors, three anaerobic selector tanks with mixing, four oxidation ditches modified for biological phosphorus removal, chemical phosphorus removal, four final clarifiers with modifications for biological phosphorus removal, two tertiary disc cloth filter units, ultraviolet (UV) disinfection, post aeration tank, effluent pumping capabilities if needed, effluent flow meter, with discharge to the Rum River. The solids treatment system consists of two aerated sludge holding tanks, sludge load out stand, sodium hypochlorite chemical feed system and 12 sludge drying reed beds with a filtrate pump station. Biosolids are land applied. The Facility has a stationary engine generator for backup power. There are no designed bypass points in the system. The Facility is further described in several sets of plans and specifications on file with the MPCA. 6

7 Flow Schematic Figure 2. Flow Schematic of Facility 7

8 Changes to Facility or Operation There are no planned changes to the Facility or its operation during this permit cycle. Significant Industrial Users (SIUs) There is one SIU that contributes process wastewater to the Facility. United States Distilled Products (USDP) contributes between 6,000 and 7,000 gallons per day of processed wastewater to the Facility. The Permittee is currently working on an SIU agreement with USDP. Recent Compliance History The most recent MPCA inspection of the Facility occurred on May 20, The Compliance Evaluation Inspection (CEI) consisted of a visual inspection of the Facility and a review of the monthly Discharge Monitoring Reports (DMRs) for the time period from January 2013 through April Several violations of the terms and conditions set forth in the NPDES/SDS permit were noted. The 2012 and 2013 Pretreatment Annual reports had not been submitted. The Permittee had also not submitted to the MPCA an annual certificate of compliance under a Phosphorus Trade Agreement with the Metropolitan Council Environmental Services. All three annual reports were submitted within 30 days of the inspection. 8

9 Table 1. Recent Monitoring History Februay 2014 January 2015 Receiving Water Use Classification The receiving water is a Class 2B, 3C, 4A, 4B, 5, 6, Water, Restricted Outstanding Resource Value Water (ORVW R). Minn. R , Water Use Classifications for Waters of the State. Subp. 3. Class 2 waters, aquatic life and recreation. Aquatic life and recreation includes all waters of the state that support or may support fish, other aquatic life, bathing, boating, or other recreational purposes and for which quality control is or may be necessary to protect aquatic or terrestrial life or their habitats or the public health, safety, or welfare. 9

10 Subp. 4. Class 3 waters, industrial consumption. Industrial consumption includes all waters of the state that are or may be used as a source of supply for industrial process or cooling water, or any other industrial or commercial purposes, and for which quality control is or may be necessary to protect the public health, safety, or welfare. Subp. 5. Class 4 waters, agriculture and wildlife. Agriculture and wildlife includes all waters of the state that are or may be used for any agricultural purposes, including stock watering and irrigation, or by waterfowl or other wildlife and for which quality control is or may be necessary to protect terrestrial life and its habitat or the public health, safety, or welfare. Subp. 6 Class 5 waters, aesthetic enjoyment and navigation. Aesthetic enjoyment and navigation includes all waters of the state that are or may be used for any form of water transportation or navigation or fire prevention and for which quality control is or may be necessary to protect the public health, safety, or welfare. Subp. 7 Class 6 waters, other uses and protection of border waters. Other uses includes all waters of the state that serve or may serve the uses in subparts 2 to 6 or any other beneficial uses not listed in this part, including without limitation any such uses in this or any other state, province, or nation of any waters flowing through or originating in this state, and for which quality control is or may be necessary for the declared purposes in this part, to conform with the requirements of the legally constituted state or national agencies having jurisdiction over such waters, or for any other considerations the agency may deem proper. Table 2. Impairments AUID Reach Name Reach Description Approved Rum River West Brand Rum River Mercury to Stanchfield Creek Rum River Stanchfield Creek to Mercury Seelye Brook Rum River Seelye Creek to Cedar Mercury Creek Rum River Cedar Creek to Trott Mercury Brook Rum River Trott Brook to Anoka Dam Mercury Rum River Anoka Dam to Mercury Madison/Rice St in Anoka Rum River Madison/Rice St in Anoka Mercury to Mississippi River Mississippi River Rum River to Elm Creek Mercury, PCBF Mississippi River Elm Creek to Coon Rapids Dam Mississippi River Coon Rapids Dam to Coon Creek Mississippi River Coon Creek to Upper St. Anthony Falls Mercury, PCBF Mercury, PCBF Mercury, PCBF, Fecal Coliform 10

11 AUID Reach Name Reach Description Approved Mississippi River Upper St. Anthony Falls to Mercury, PCBF Lower St. Anthony Falls Mississippi River Lower St. Anthony Falls to Mercury, Fecal Coliform L & D #1 (RM to RM847.6) Mississippi River L & D #1 to Minnesota Mercury, PCBF River Mississippi River Minnesota River to Metro WWTF (RM 844 to 835) Mercury, Fecal Coliform, PCBF, TSS Mississippi River Metro WWTF to Rock Mercury, PCBF, TSS Island RR bridge (RM 835 to 830) Mississippi River Rock Island RR bridge to L & D #2 (RM 830 to 811.3) Mercury, PCBF, PFOS, TSS Mississippi River L & D #2 to St. Croix River Mercury, PCBF, TSS (RM to 811.3) Mississippi River St. Croix River to Mercury, PCBF, TSS Chippewa River Mississippi River Chippewa River (WI) to L Mercury, PCBF & D # Mississippi River L & D #6 to Root River Mercury, PCBF Mississippi River Root River to MN/IA border Mercury, PCBF Total Maximum Daily Load (TMDL) Studies. Statewide Mercury TMDL The statewide mercury TMDL was approved March 27, 2007, with the implementation plan approved in For more information on the mercury TMDL and implementation plan, refer to wwprm1 16. pdf. Upper Mississippi River TMDL These listings have been removed from the impaired waters inventory. New analysis of the data shows that the reaches are in attainment for bacteria. Minnesota Polychlorinated Biphenyls (PCB) TMDL No PCB TMDLS are in development at this time. South Metro Mississippi River Total Suspended Solids (TSS) TMDL The waste load allocation for the Princeton WWTF: TSS = 72 kilograms per day and 26,280 kilograms per year. These allocations are equivalent to the permit s current TSS effluent limitations. Perfluorooctane Sulfonate (PFOs) No PFOs TMDLs are in development at this time. Ammonia (Un ionized) This listing has been removed from the impaired waters inventory. New analysis of the data shows that the reach is in attainment for ammonia. Pepin Lake The Facility s discharge to the Rum River is considered a new discharge upstream of an impaired water. The Draft Lake Pepin Excess Nutrient Total Maximum Daily Load (TMDL) has not been completed and a total phosphorus Waste Load Allocation (WLA) has not been established for the 11

12 Facility. The Permittee's discharge shall not cause a net increase in the total phosphorus permitted mass load within the Lake Pepin Basin. For additional information, see the trade in the proposed limits and monitoring section. Existing Permit Effluent Limits The limits and monitoring requirements in the current permit are presented in Table 3 and list water quality based effluent limits, technology based limits and state discharge restriction limits. Technology Based Effluent Limits (TBELs) The ph and percent removal are technology based limits developed for achieving secondary treatment standards. These limits are specified in 40 CFR and Minn. R and Minn. R Water Quality Based Effluent Limits (WQBELs) The CBOD 5, TSS, ammonia, mercury, and phosphorus are water quality based effluent limits. These limits are based on the designated use classification of the receiving water. State Discharge Restriction Limits (SDRs) The 1 milligram per Liter total phosphorus (TP) and fecal coliform bacteria limits are state discharge restriction limits. 12

13 Table 3. Existing Permit Effluent Limits 13

14 Proposed Permit Effluent Limits The limits and monitoring requirements for Station SD001 for draft reissued Permit MN are presented in Table 4. This table lists water quality based effluent limits, technology based limits and state discharge restriction limits. Technology Based Effluent Limits The ph and percent removal are technology based limits developed for achieving secondary treatment standards. These limits are specified in 40 CFR and Minn. R and Minn. R Water Quality Based Limits The CBOD 5, TSS, ammonia, mercury, and phosphorus are water quality based effluent limits. These limits are based on the designated use classification of the receiving water. State Discharge Restriction Limits (SDRs) The 1 milligram per Liter TP and fecal coliform bacteria limits are state discharge limits. Table 4. Proposed Permit Effluent Limits 14

15 Table 4. Proposed Permit Effluent Limits cont. Phosphorus Management Until a WLA is established for this discharge, the mass of phosphorus discharged from the Facility may be offset by removal of an equivalent mass of phosphorus from nonpoint source restoration projects within the Lake Pepin Basin and the Rum River watershed, resulting in no net increase in phosphorus to Lake Pepin. An actual reduction of phosphorus to the water body will be achieved when the trade ratio is applied. For each trade, buyers are required to purchase phosphorus in excess of the exact amount needed to discharge, called trade ratios. Both the nonpoint source reductions and the discharger must discharge upstream of the identified impaired water. The MPCA will not approve trades that will make worse the violation of a water quality standard. All trades are reviewed by the MPCA on a case by case basis and in accordance with Minn. Stat , subd. 10. The MPCA requires that the permitted phosphorus mass of 1,862 kg/year from this discharge be offset through a pre TMDL phosphorus trade. The Permittee has requested to offset the phosphorus load by a 15

16 point to nonpoint source trade. A trade ratio of 2.6 to 1 has been applied to the permitted mass so that a total of 4,841 kg/year in nonpoint source reduction offset is required. The Permittee has completed five nonpoint source restoration projects, which are located within the Rum River watershed. The nonpoint source restoration projects have resulted in a reduction of 4,568 kg/year of phosphorus being discharged to the Rum River, as listed below: Location Site Name Trade Value Phase 1, Site 1 Trunk Highway kg/year Phase 1, Site 2 Princeton Middle School 1,167 kg/year Phase 1, Site 3 Princeton Golf Course 374 kg/year Phase 2, Site 1 ISD # kg/year Phase 2, Site 2 Abney Recycling 1,692 kg/year Total 4,568 kg/year At this time, the city of Princeton has implemented nonpoint source best management practices (BMPs) sufficient to achieve phosphorus reductions of 4,568 kg/year. After applying the 2.6 to 1 trade ratio, the Permittee is allowed to discharge up to 1,757 kg/year. The value of the five restoration projects leaves the Permittee 273 kg/year short of the total needed. From October 2012 through November 2014, the actual discharge from this Facility was 151 kg/year. At this time, further nonpoint reductions are not necessary. See section 1.6 below for information regarding a trigger for completing additional nonpoint source reductions to account for the additional 273 kg/year. Once the Lake Pepin TMDL is complete, a WLA will be established for the Facility. At that time, the need for a point to nonpoint source trade will be re evaluated. Summary of Loads Phosphorus (kg/yr) Overall Permitted Load (sum of two seasonal limits) 1,862 Currently Allowed Discharge Amount 1,757 Currently Purchased Load 4,568 Overall Total Trade Load Ultimately Needed 4,841 The permit includes an intervention limit of 1,757 kg/year. This intervention limit is the currently allowed discharge amount. When the Facility reaches 1,317 kg/year or 75% of the allowed discharge phosphorus mass load, the Permittee must submit to the MPCA an application for a permit modification, a Pre TMDL Phosphorus Trading Application to Trade Form and the information required to do additional restoration projects. These additional projects will be completed to offset the additional mass 16

17 of 273 kg/year. The Permittee must not discharge a phosphorus load greater than 1,757 kg/year prior to MPCA approval of any additions to the nonpoint source to point source trade and modification of the permit. Chronic Whole Effluent Toxicity Monitoring The Facility has a chronic whole effluent toxicity (WET) monitoring requirement because the ratio of the Rum River low flow 7Q 10 (12.3 mgd) to the Facility s average dry weather (ADW) (2.3 mgd) is less than 20:1. Five chronic WET tests were done from March to November 2013 and one in June None of the tests were toxic to Ceriodaphia dubia or to fathead minnow. The monitoring threshold value is 8.5 toxic unit chronic (TUc). The TUc is a monitoring threshold value, not a WET limit. The TUc (8.5) has been updated with respect to the TUc (7.8) in the past permit, based on updated Rum River low flow 7Q 10. Annual Testing Testing is required one time per year. If the permit exceeds five years, there will be an additional WET test for each year that exceeds the five year permit cycle. The first set of annual chronic WET battery results are due on the last day of the first full calendar quarter following permit issuance. (For example, if the permit is issued April 28, the first test battery is due by September 30 th and each annual test battery is due by September 30 th of each of the following years for the life of the permit). If the threshold value of 8.5 TUc is exceeded for any one WET test, the Facility will perform two WET retests to determine if a Toxicity Reduction Evaluation (TRE) is needed. Additional Requirements Pollutant Minimization Plans (PMP) This permit contains requirements for mercury limits and monitoring and for a submittal of a Mercury Minimization Plan (MMP) or an updated MMP. These requirements were added in response to the U.S. Environmental Protection Agency s approval of the Minnesota statewide mercury TMDL plan. Specific mercury limits and monitoring requirements are found in the Waste Stream Station and Surface Discharge chapters of this permit. These requirements include sampling for total suspended solids via a grab sample taken at the same time as the mercury grab samples are taken. Additional Monitoring Requirements The draft permit includes influent and effluent monitoring for nitrite plus nitrate nitrogen, total Kjeldahl nitrogen, total nitrogen, ammonia nitrogen and total dissolved solids at a frequency of one time per month for the five year term of the permit. Industrial Stormwater On April 5, 2010, the Industrial Stormwater General Permit (MNR050000) was issued. This permit addresses stormwater discharges associated with industrial activity for facilities that discharge stormwater to waters of the state, including Municipal Separate Storm Sewer Systems. The General Permit also addressed stormwater discharges associated with industrial activities at facilities that provide on site infiltration of industrial stormwater discharges associated with the facility. 17

18 This Facility has applied for and obtained a Certification of No Exposure; therefore, this permit includes language regarding No Exposure exclusion. Biosolids This draft reissued permit authorizes the Facility to store and land apply domestic wastewater treatment biosolids in accordance with the provisions in this draft permit and Minn. R. ch Total Facility Requirements (TFR) All NPDES/SDS permits issued by the state of Minnesota contain certain conditions that remain the same, regardless of the size, location, or type of discharge. The standard conditions satisfy the requirements outlined in 40 CFR , Minn. R and These conditions are listed in the Total Facility Requirements chapter of the NPDES/SDS Permit. These requirements cover a wide range of areas, including recordkeeping, sampling, equipment calibration, equipment maintenance, reporting, facility upsets, bypasses, solids handling, changes in operation, facility inspections, and permit modifications and reissuance. Nondegredation and Anti Backsliding The Rum River was designated an ORVW Restricted on November 5, The design average wet weather flow of this Facility on the date of ORVW designation was 0.0 gpd. In accordance with MPCA rules regarding nondegredation for all waters (that are not Outstanding Resource Value Waters), nondegredation review is required for any new or expanded significant discharge (Minn. R ). A significant discharge is 1) a new discharge (not in existence before January 1, 1988) that is greater than 200,000 gallons per day or 2) an expanded discharge that expands by greater than 200,000 gallons per day that discharges to any non ORVW water other than a Class 7 water or 3) a new or expanded discharge containing any toxic pollutant at a mass loading rate likely to increase the concentration of the toxicant in the receiving water by greater than one percent over the baseline quality. This permit also complies with Minn. R regarding anti backsliding. Any point source discharger of sewage, industrial, or other wastes for which a national pollutant discharge elimination system permit has been issued by the agency that contains effluent limits more stringent than those that would be established by parts to shall continue to meet the effluent limits established by the permit, unless the Permittee establishes that less stringent effluent limits are allowable pursuant to federal law, under section 402(o) of the Clean Water Act, United States Code, title 33, section