Phil Argiroff, Chief, Permits Section Water Resources Division, MDEQ October 20, 2016

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1 Phil Argiroff, Chief, Permits Section Water Resources Division, MDEQ October 20, 2016

2 Protect and Monitor 4 Great Lakes 3,288 miles of Great Lakes shoreline 11,000 inland lakes 36,000 river miles 6.5 million acres of wetlands 70,000 acres of critical dunes For swimming, fishing, drinking water, and aquatic ecosystems.

3 21 st Century Infrastructure Commission Assess current condition Benchmark other states and nations Comprehensive vision and how do we get there Water Strategy Invest in Water Infrastructure

4 Asset Management SAW grants Capacity Management, Operations and Maintenance (CMOM) Plans Fiscal Sustainability Plans (FSP) 4

5 Current Efforts Construction Permits (Part 41) NPDES Permits (Part 31), Asset Management Plans New Efforts CMOM

6 Construction permits for any alterations that serve the public Ten States Standards provides design guidance Redundancy required Flow capacity and ability to treat Handle the 25-yr/24-hr storm without bypass Meet NPDES effluent limits Correct SSOs/CSOs, prevent backups Require facilities be properly operated and maintained

7 Part 41 Rule 55(1) Sewerage systems shall be operated and maintained at all times as efficiently as possible in a manner which minimizes discharges of excessive pollutants. NPDES Permits Part II.D.3, Facilities Operation The permittee shall, at all times, operate and maintain all treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit DEQ - Asset Management 7

8 Governor s 2011 Infrastructure Message - sustainability and AM for sewer and water DEQ is supportive of AM for sewer (and water) DEQ has started a NPDES regulatory initiative for WWTPs/collection systems, and has a state grant program for AM with the potential for a grant (SAW) Assistance for AM program development

9 Started in 2013, adding AM program requirements to all reissued major municipal WWTP permits; now in 70 permits First requirement was Detroit WWTP - 33% of treated municipal discharge in MI, history of poor equipment maintenance. Appropriate to be first with AM requirements Summary of core requirements current state, level of service, critical assets, minimum life cycle costs, and long term funding Will add AM requirements to minor permits that receive AM grants

10 Five Core Questions of Asset Management 1. What is the current state of my assets? 2. What is my required "sustainable" level of service? 3. Which assets are critical to sustained performance? 4. What are my minimum life-cycle costs? 5. What is my best long-term funding strategy?

11 Permit Language Requires AM Plan to Develop Program which addresses: Maintenance Staffing Mapping Collection System Inventory and Assessment/Criticality of Fixed Assets Budget and Rate Sufficiency Annual Report DEQ - Asset Management 11

12 Great Lakes Water Quality Bond 2002 P.A. 562 of 2012 authorized money for Stormwater, Asset Management, Wetland Mitigation or SAW program $450M allocated to provide grants and loans for SAW $97M available for FY 2014, 15 and 16 Grants available up to $2M per municipality Applications accepted starting Dec 2, 2013 on a first come first served basis On December 2, applications totaling $541M were received

13 Capacity, Management, Operation & Maintenance Capacity Evaluation (testing, inspection, flow monitoring) Management (org structure, training, customer service, legal authority) Operation (budget, emergency response, mapping, construction) Maintenance (budget, maintenance, cleaning schedules, parts and equipment inventory) Rehabilitation (SSO elimination, I/I reduction)

14 Ensure that collection systems have adequate collection system capacity and maintenance (consistent with Part 41 Rules 41 and 55) No SSOs or basement backups Non-excessive Infiltration/Inflow To help protect public health and the environment

15 Part 41 looks at capacity; but not throughout system State law and SSO Policy prohibit SSOs NPDES permits require proper O&M NPDES Asset Management Programs look at collection systems mapping Enforcement Orders include I/I correction programs when SSOs have occurred

16 U.S. Environmental Protection Agency 10/24/

17 U.S. Environmental Protection Agency 10/24/

18 Approximately 970 collection systems About 540 are covered under NPDES permits; WWTP, or CSOs/CSO treatment facilities Leaves 430 collection systems that are not covered by NPDES permits These discharge to regional WWTPs; for example Detroit WWTP serves 77 communities U.S. Environmental Protection Agency 10/24/

19 MI: includes AM in all major NPDES permits; Considering CMOM Requirements in Permits IL: includes AM for collection systems only as a subset of CMOM in all major NPDES permits, or in minor NPDES permits that have SSO problems; WI: no AM requirements, but CMOM included in all permits U.S. Environmental Protection Agency 10/24/

20 IN; OH; MN: No AM routinely required in NPDES Permits; CMOM included only for permittees that have SSO problems.

21 1. Strong CMOM Program Requirements 2. All Permittees POTW (Individual NPDES Permit Satellite Sewer Communities (via SSO General Permit ) 3. Strong CMOM Training Program (regional) 4. Jack Saltes, WDNR Engineer U.S. Environmental Protection Agency 10/24/

22 We will use a stakeholder process, with help from MWEA and others Some preliminary ideas Include CMOM conditions for management, operations, maintenance, capacity evaluation Prohibit SSOs Include Asset Management program requirements; if received SAW grant

23 May include opportunities to streamline Part 41 permitting for routine gravity sewer extensions Require approval of standard detail sheets for Part 41 permits List system capacity restrictions and programs to correct After stakeholder input hope to issue a General Permit for use starting in FY 2018

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