Patrick Bradley LimnoTech MWEA Government Affairs Committee NPDES Compliance Seminar December 2, 2009 Bath, MI

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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 1

2 MS4 Urban runoff MEP CSOs NMC LTCP Construction Erosion control Post-construction/Development Industrial activities Agriculture Forestry 2

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 3

4 CSOs Storm water SSOs Water Quality Standards-to- Permits Process Peak Flows (Blending) Designated uses Criteria to protect the uses Numeric Narrative Anti-degradation Policy 4

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 5

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 6

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) 7

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? 8

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 9

10 Patrick Bradley Senior Scientist LimnoTech 1705 DeSales Street, NW, Suite 600 Washington, D.C Tel NPDES Permit Program: Overview of the Water Quality Standards-to-Permits Process: cfpub.epa.gov/npdes/wqbasedpermitting/wqoverview.cfm EPA Watershed-Based National Pollutant Discharge Elimination System (NPDES) Permitting Technical Guidance. 10