Todd Miller Scott Mansell Raj Kapur June 1, 2017

Transcription

1 Todd Miller Scott Mansell Raj Kapur June 1, 2017

2 Introduction Update previous ACWA Temperature Management Plan Manual (2000) Working group philosophy: Reorganize to emphasize tools/info most needed now Update guidance related to the new standard, TMDLs, BMPs, and water quality trading Focus the manual to be the go to desktop resource for ACWA members Demonstrate Example City application of tools and info Keep current through links and ease of updating

3 Overview: Table of Contents Section 1: Purpose And Use Of The Temperature Compliance Guidance Manual Section 2: Determining Applicable Temperature Criteria and Associated Permit Limits Section 3: Data Collection, Data Handling, and Calculations Section 4: Compliance Strategies BMPs & Mitigations Section 5: Developing a Compliance Plan Section 6: References and Links Section 7: Examples and Case Studies Section 8: Manual Change Management Record Appendix A: Temperature Formulas Appendix B: BMP Fact Sheets Appendix C: Celsius to Fahrenheit Conversion Table Appendix D: Historic Timeline of the Oregon Temperature Standard Appendix E: Triple Bottom Line Methods

4 How to Use the Manual Five Steps: 1. Determine applicable criteria 2. Determine listing status of the receiving stream 3. Conduct reasonable potential analysis 4. Determine permit limits 5. Develop a compliance plan

5 The Example City Arbitrary location in the middle of Oregon (Upper John Day watershed) Example location carried through the manual to demonstrate application of tools and analysis Can follow step-by-step (builds on information developed) but stands alone for each demonstration

6 Walk Through: The 5 Steps Steps 1 & 2: determine your status (Scott Mansell) Steps 3 & 4: determine your limits (Raj Kapur) Step 5: identify a compliance strategy (Todd Miller)

7 Step 1 Step 1: Determine applicable criteria What is the temperature standard that my permit limits will be based on? Understanding Oregon's temperature standard history 2.1 Using Fish Use Maps to Determine Designated Uses Determine Numeric and Narrative Criteria Based on Designated Uses 2.2.2

8 Why is a temperature standard needed? Many aquatic species very sensitive to water temperature e.g., Salmonids Require temperatures < 9-20 C (48-68 F) depending on species & life stage Many salmonid-bearing waters in Oregon do not meet the standard CWA to protect aquatic life of_colu.html

9 History of Oregon s temperature standard EQC significantly revises temperature criteria In response to NWEA lawsuit, EPA disapproves the NCC, NWEA files suit to invalidate all TMDLs using the NCC Limbo. TMDLs will be redone, but not clear when. Not clear if WLAs apply or not Mid 1970 s EQC adopts statewide temperature criteria by river basin After NWEA lawsuit, EQC revises criteria, includes Natural Conditions Criterion (NCC) NMFS issues BO that says 20 degree migration corridor standard is appropriate if cold-water refugia protected. ODEQ, EPA, and NMFS set forth a three-year plan to map coldwater refugia

10 Timeline: Oregon Temperature Standard 1996: Oregon revises temperature standard July 1999: EPA disapproves portions of temperature standard 2001: NWEA lawsuit against EPA 2003: Judge Haggerty issues decision in NEA I case 2003: EPA s Regional Temperature Guidance February 2012: NCC approval arbitrary and capricious; additional consultation with Services req d November 2012: Stipulated Order to Services re: consultation on stds April 2013: Judge Acosta s opinion re: NCC & statewide narrative standards July 2015: NMFS draft jeopardy determination re: 20 deg. C criterion April 2017: Temp TMDLs need to be updated but not vacated : Northwest Environmental Advocates v. EPA et al. case litigated

11 Designated Fish Uses All waterbodies assigned at least one beneficial fish use Fish maps and tables to determine applicable fish use and date ranges nistrative-rules.aspx Combination of numeric and narrative criteria apply depending on beneficial fish use

12 Ocean, Bay, or Natural Lake Fish and aquatic life is a designated use Known Discharge Location from Treatment Plant Type of receiving water Flowing Freshwater and Reservoir Locate waterbody on fish use maps or tables (See Section 2.2.1) Borax Lake Chub? Yes Borax Lake Chub is a designated use No No Use designated use of first downstream waterbody Waterbody located on maps? Yes Select ALL applicable designated uses from maps and note applicable spawning periods Select the temperature criteria and applicable time period from Table 2-1 Continue to Step 2: Determine listing status (Section 2.3)

13 Fish Use Maps-A

14 Fish Use Maps-B-Spawning Periods

15 Designated Use Tables

16 Fish Use Tables

17 Example 1 Using Fish Use Maps Plant Discharge Location

18 Example 1 Using Fish Use Maps Plant Discharge Location

19 Example 1 Using Fish Use Maps So, receiving water body has the following fish uses: Salmon and trout rearing and migration Salmon and steelhead spawning (January 1-May 15)

20 Example 2 Using Fish Use Maps Plant Discharge Location

21 Example 2 Using Fish Use Maps Plant Discharge Location

22 Example 2 Using Fish Use Maps So, receiving water body has the following fish uses: Core Cold-Water Habitat Salmon and steelhead spawning (September 1-June 15)

23 Numeric and Narrative Criteria Each Designated use has Numeric and Narrative Criteria Associated with it Numeric = temperature not to be exceeded Narrative = criteria to be calculated to determine allowable anthropogenic effects relative to temperature from numeric criteria Use Table 2-1 Not all narrative criteria necessarily apply

24 Common Narrative Criteria Human Use Allowance Point source may not cause the waterbody to exceed numeric standard by more than 0.3 C Before a TMDL edge of mixing zone of 25% of 7Q10 flow After a TMDL point sources cumulatively cannot exceed 0.3 C with 100% of 7Q10 flow (WLA applies) Cold-Water Protection Narrative, Summer Waterbody may not be heated by more than 0.3 C above the ambient temperature cumulatively by point sources during summer Cold-Water Protection Narrative, Spawning Waterbody may not be heated by more than a certain threshold (depends on ambient temp) during spawning period, cumulatively by point sources

25 Common Narrative Criteria, cont d Thermal Plume Narrative Plume from a point source (mixing zone) may not Impair active salmonid spawning area (9 C bull trout, 13 C salmon) Expose fish to >32 C for more than 2 seconds Expose fish to >25 C for more than 5% of the cross section at 7Q10 Expose fish to >21 C for more than 25% of the cross section at 7Q10 Cold-Water Refugia Narrative If a waterbody has a Migration Corridor designated fish use, must maintain cold-water refugia sufficiently distributed to allow salmon and steelhead to migrate without adverse effects from temperature Cool-Water Narrative A waterbody cannot be warmed by more than 0.3 C unless it is shown that a greater increase would not harm sensitive aquatic life (when salmonids not present)

26 Examples 1 and 2 Example 1 & 2, Fish use 2 Example 2, Fish use 1 Example 1, Fish use 1

27 Examples 1 and 2 Criteria Example 1 Example 2 Numeric Criteria: 18 C - year round 13 C - spawning period (Jan 1-May 15) Narrative Criteria: Human Use Allowance Cold-Water Protection Narrative, summer Cold-water Protection Narrative, spawning Thermal Plume Narrative Numeric Criteria: 16 C - year round 13 C - spawning period (Sept 1-June 15) Narrative Criteria: Human Use Allowance Cold-Water Protection Narrative, summer Cold-water Protection Narrative, spawning Thermal Plume Narrative

28 Step 2 Step 2: Determine Listing Status Is the receiving waterbody listed for temperature or is there a TMDL? Determine if the receiving waterbody has a valid TMDL Determine if the waterbody is impaired for temperature and which narrative criteria apply 2.3

29 After Step 1: Determining applicable temperature criteria (Section 2.2) Does a valid* TMDL exist for the Waterbody (Section 2.3.1) Yes No Set the Permit Limits Equal to the WLA and Conduct Any Other Needed Analyses (Section 2.5.6) Select all applicable narrative criteria that apply to waterbodies that meet numeric criteria (Section 2.3.4) Is the waterbody listed for temperature in the latest approved** 303(d) list? (Section 2.3.2) No Yes Select all applicable narrative criteria that apply to waterbodies that DO NOT meet numeric criteria (Section 2.3.4) Continue to Step 5: Develop a Compliance Strategy (Section 4 and 5) Continue to Step 3: Reasonable Potential Analyses (Section 2.4)

30 Narrative Criteria Based on Listing Status Narrative Criteria that apply ONLY for waterbodies that DO NOT meeting numeric criteria: Human Use Allowance Narrative Criteria that apply ONLY for waterbodies that DO meeting numeric criteria: Cold-Water Protection Narrative, summer Cold-Water Protection Narrative, spawning Narrative Criteria that apply regardless of listing status Thermal Plume Narrative

31 Results in the following standards: Human Use Allowance applied to Salmonid and Steelhead Spawning Criterion: The point source must not cause more than a 0.3 ºC increase above 13.0 ºC at edge of mixing zone or 25% of the 7Q10, whichever is more restrictive Applies January 1 through May 15 Human Use Allowance applied to Salmon and Trout Rearing and Migration Criterion: The point source must not cause more than a 0.3 ºC increase above 18.0 ºC at edge of mixing zone or 25% of the 7Q10, whichever is more restrictive Applies year round Thermal Plume Narrative The plume may not cause any active salmonid spawning area to exceed 13 ºC The plume may not cause any fish to experience temperatures > 32 ºC for more than 2 seconds The plume may not cause a temperature > 25 ºC in more than 5% of the cross sectional area The plume may not cause a temperature > 21 ºC in more than 25% of the cross sectional area Example 1 Criteria Waterbody IS 303(d) listed, no valid TMDL, so Human Use Allowance applies Cold Water Protection Narratives do NOT apply Thermal Plume Narrative applies

32 Example 2 Criteria Waterbody is NOT 303(d) listed, waterbody is currently meeting the standards, so Human Use Allowance does NOT apply Cold Water Protection Narratives (both spawning and summer) apply Thermal Plume Narrative applies Results in the following standards: Cold Water Protection Narrative (spawning) applied to Salmonid and Steelhead Spawning Criterion: (Assume 60-DAM is 11 ºC) Point sources cumulatively cannot increase temperature above 11.5 ºC Applies September 1 through June 15 Cold Water Protection Narrative (summer) applied to Core Cold Water Habitat Criterion The point sources cumulatively cannot increase temperature above ambient temperature by more than 0.3 ºC Applies during summer (June 1 through September 30) If there was any gap between spawning period and summer applicable periods, then the Numeric Criterion for Core Cold Water Habitat would apply during the gap Thermal Plume Narrative The plume may not cause any active salmonid spawning area to exceed 13 ºC The plume may not cause any fish to experience temperatures > 32 ºC for more than 2 seconds The plume may not cause a temperature > 25 ºC in more than 5% of the cross sectional area The plume may not cause a temperature > 21 ºC in more than 25% of the cross sectional area

33 Step 3 Step 3: Conduct Reasonable Potential Analysis Determine which RPAs to conduct and conduct all applicable RPAs 2.4 If the data are not available to conduct the RPAs, collect the necessary data 3

34 Step 3: Reasonable Potential Analysis Scenario: Pre-TMDL Inputs MZ dilution 7Q10 stream flow Temperature criteria (rearing/migration, spawning, etc.) Effluent characteristics (flow & temperature) HUA Determine reasonable potential (RP) If RP, thermal load limits

35 Step 3: Example Scenario: Pre-TMDL DEQ Temperature Spreadsheet Inputs MZ dilution: 5 7Q10 stream flow: 100 cfs Temperature criteria (18 deg c; 13 deg C) Effluent characteristics (5 mgd; 23 deg C; 20 deg C) HUA: 0.3 deg C Reasonable potential (RP)? If RP, thermal load limits

36 Step 3: Reasonable Potential Analysis Scenario: Thermal Plume Criteria Mixing zone provisions Thermal Plume Criteria Active salmonid spawning area Acute impairment (32 deg C/2 secs) Thermal shock (25 deg C/5% of stream) Thermal blockage (21 deg C/25% of stream) Inputs Stream flow (7Q10) Temperature criteria/ambient temperature Effluent characteristics (flow & temperature) Statistics

37 Step 3: Example Scenario: Thermal Plume Criteria DEQ Temperature Spreadsheet Inputs 7Q10 stream flow: 100 cfs Ambient temperature (20 deg C) Effluent characteristics (5 mgd; 24 deg C max; 23 7DADM)) Reasonable potential? If RP, temperature limits

38 Step 4 Step 4: Determine Permit Limits Determine Permit Limits based on applicable RPAs If the data are not available to determine permit limits, collect the necessary data 2.5 3

39 Step 4: Permit Limits Permitting approach Use of appropriate data (effluent, stream & mixing) If RP, effluent limits will be established Permit limits (source) TMDL WLAs: thermal load Pre- TMDL HUA: thermal load Thermal plume criteria: temperature limits Permit limits (type) Excess thermal load (ETL) Temperature limits

40 Step 4: Permit Limits TMDLs still in effect; WLAs still apply More stringent of TMDL WLAs or pre- TMDL HUA Formula (Pre-TMDL scenario) EEE = EEEEEEEE ffff DD HHH 2,446,665 Units (kcal/day)

41 Step 4: Data Needs Temp data: continuous recording device/hourly data Statistics (daily max, 7DADM) Initial information: Effluent flow & temperature Receiving stream flow (7Q10) & temperature Mixing zone dilutions (scenarios) Compliance strategies Influent temperature Unit processes Collection system/industrial user data

42 Step 5 Step 5: Develop a Compliance Plan Evaluate the various management practices and compliance alternatives 4 Select those management practices and compliance strategies that are best for your facility 5.1 Develop a compliance plan 5.2

43 BMP Reference Table Strategy Category (in order of typical priority) 1. Typical NPDES Permit Strategies (Section 4.2) 2. Pre-Treatment Reductions (Section 4.3) 3. Water Quality Trading (Section 4.4) 4. Treatment Process Modifications (Section 4.5) 5. Discharge Alternatives (Section 4.6) 6. Natural Treatment (Section 4.7) 7. Recycled Water Use (Section 4.8) 8. Lower-Energy Temperature Reduction Technologies (Section 4.9) 9. Alternative NPDES Permit Strategies (Section 4.10) 10. Higher-Energy Temperature Reduction Technologies (Section 4.11) Strategy Description Ensure the permit considers all applicable factors to avoid unnecessarily restrictive temperature requirements, and explore permitting options to help attain compliance. Reduce the overall heat load entering the treatment plant by either reducing the temperature or reducing the flow. Trading provides an often cost-effective and environmentally beneficial solution to temperature compliance by reducing thermal loading elsewhere in the watershed. May be necessary if it is found from in-plant monitoring that certain treatment processes increase the waste stream temperature significantly. These management practices would not make changes to the actual temperature of the wastewater, but would eliminate or modify the discharge to reduce the impact on the receiving water. As opposed to indirect discharge or watershed restoration, natural treatment provides physical cooling of the effluent prior to discharge. Diverting effluent to recycled water uses reduces the total flow and therefore the total thermal load on the receiving waterbody. Reduce the temperature of the wastewater effluent prior to discharge. These may be very expensive and may be cost prohibitive. If any of the above compliance strategies will not work, it may be possible to meet compliance using alternative permitting strategies, but these are often difficult to obtain. Tend to be highly energy-intensive and expensive. Should only be used as a last resort. If these are the only option available options, it may be possible to obtain an alternative compliance mechanism rather than build one of these. BMP / Application Mixing zone analysis Bubble permits / alliances Pretreatment of identified heat loads Public awareness/education Limiting discharge to the collection system Riparian shading Flow augmentation Channel restoration Point-to-point trades Credit banking Covering basins Disinfection alternatives evaluation Recycling and/or eliminating cooling water discharge Energy conservation Outfall/discharge relocation Diffuser Alterations Reservoir detention/seasonal storage Indirect discharge/infiltration Tree farms Wetlands Treatment ponds Hyporheic injection/blending WPCF reuse Community reuse Cooling ponds Spray ponds Waste heat recovery Site-specific criteria Use attainability analysis Variances Cooling towers Chillers

44 Compliance Strategies Domestic Pretreatment Industrial Reuse Education/ outreach Process enhancement/ New Technology Commercial Influent Wastewater WQ Trading Outfall mod./reevaluate mixing zone Use Attainability Analysis Site Specific Criteria Variances 44

45 Recommended Approach DO evaluate what you can do to reduce temperature in influent or effluent DO consider multiple benefit solutions Recycled water use Wetland treatment Consider the big picture: what is the environmental problem we are trying to solve? Assess the triple bottom line

46 Example: basin cover and discharge wetland

47 The Environmental Problem 86%

48 The Triple Bottom Line & SWOT Economic Benefits and Capital Costs Water Resource Benefits and Environmental Impacts Community Benefits and Human Impacts

49 TBL Example: MWMC

50 Result: Portfolio Approach Co-generation engine jacket cooling water: recycle to boiler? Dissipate? [ start at home ] Optimize recycled water use to irrigate tree farm [permittee multiple benefits] Partner with watershed protection interests to restore riparian shade [community multiple benefits] Demonstrate/pilot small scale recycled water uses may be important asset in the future [innovate]

51 Other Sections References and links Case studies/examples Change record resource to track updates and ensure most up-to-date manual information is on hand Appendices Temperature Formulas BMP Fact Sheets Celsius to Fahrenheit Conversion Table Historic Timeline of the Oregon Temperature Standard Triple Bottom Line Methods

52 Next Steps Continue to revise and improve final draft Get feedback from ACWA members Please do look at the current working draft (Version 3) and give us general thoughts (not typos and formatting!) DEQ review of next version Did we get it right? New ideas? Fall 2017 permit workshop: final version

53 Discussion Thanks for attending!