MUNICIPAL ENVIRONMENTAL GROUP – WASTEWATER DIVISION VANESSA D. WISHART STAFFORD ROSENBAUM LLP 222 WEST WASHINGTON AVENUE, SUITE 900 P.O. BOX 1784 MADISON, WI 53701-1784 VWISHART@STAFFORDLAW.COM SPEAKER’S TASK FORCE ON WATER QUALITY PUBLIC HEARING – JULY 11, 2019
WHO WE ARE • MEMBERSHIP ORGANIZATION OF APPROXIMATELY 100 SMALL AND MEDIUM SIZED WASTEWATER TREATMENT FACILITIES • LOCATED THROUGHOUT WISCONSIN • ESTABLISHED OVER 31 YEARS AGO • WE ADVOCATE FOR MUNICIPALITIES IN THE DNR RULEMAKING PROCESS AND AT THE LEGISLATURE • OUR MEMBERS SERVE KEY FUNCTIONS: • ENGAGE IN THE CRITICAL PUBLIC FUNCTION OF WATER RECLAMATION • ACCEPT AND TREAT SEPTAGE FROM PRIVATE WASTEWATER SYSTEMS • PARTNER WITH NONPOINT SOURCES SUCH AS AGRICULTURAL OPERATIONS TO REDUCE POLLUTION • EDUCATE AND REGULATE COMMUNITIES TO REDUCE OR ELIMINATE PROBLEM WASTE STREAMS
WHO WE ARE • MEG WAS INTEGRAL TO A NUMBER OF KEY RECENT DEVELOPMENTS: • CREATION OF THE MULTI-DISCHARGE VARIANCE FOR PHOSPHORUS • IMPROVEMENTS TO THE CLEAN WATER FUND INTEREST PROGRAM
WISCONSIN WASTEWATER TREATMENT PLANTS • THERE ARE 641 MUNICIPAL TREATMENT PLANTS IN WISCONSIN WIDELY RANGING IN SIZE
MARSHFIELD PLANT
FOND DU LAC PLANT
CITY OF RACINE PLANT
WASTEWATER TREATMENT SYSTEMS • FRONT LINE IN PROTECTING WATER QUALITY • MUNICIPAL WASTEWATER SYSTEMS CONSIST OF TWO MAIN PARTS: • COLLECTION SYSTEMS – THE PIPES THAT CARRY WASTE FROM INDIVIDUAL CONNECTIONS • TREATMENT PLANTS – TREAT THE WASTE AND DISCHARGE CLEAN WATER
WASTEWATER TREATMENT PLANTS • THE TREATMENT PROCESS INVOLVES SEVERAL STEPS: • PRIMARY AND SECONDARY TREATMENT • EMPLOYS SETTLING AND BIOLOGICAL PROCESSES TO BREAK DOWN WASTE • DISINFECTION • IN MANY CASES, TERTIARY TREATMENT OR FILTERS • FURTHER REDUCES SOLIDS, NUTRIENTS, AND OTHER CONSTITUENTS • THE TREATMENT PROCESS GENERATES SOLIDS RICH IN NUTRIENTS THAT ARE TYPICALLY LAND APPLIED
WASTEWATER TREATMENT PLANTS • MUNICIPAL TREATMENT PLANTS TREAT A VARIETY OF WASTES: • HOUSEHOLD SANITARY WASTE • COMMERCIAL AND INDUSTRIAL WASTE • HAULED WASTE FROM PRIVATE SEPTAGE SYSTEMS
WASTEWATER TREATMENT PLANTS • MUNICIPAL TREATMENT PLANTS ARE REQUIRED TO HOLD WPDES PERMITS ISSUED BY DNR • INCLUDE NUMERIC LIMITS FOR CONSTITUENTS DISCHARGED IN WASTEWATER • LIMITS ARE DESIGNED TO PROTECT WATER QUALITY, PUBLIC HEALTH, FISH AND WILDLIFE • MUNICIPALITIES MUST TEST THE WATER BEING DISCHARGED DAILY IN CERTIFIED LABS AND REPORT THE RESULTS TO DNR
WASTEWATER TREATMENT PLANTS • SEPARATE SEWER SYSTEMS • ALL MUNICIPALITIES EXCEPT FOR MILWAUKEE AND SUPERIOR NOW HAVE SEPARATE STORM SEWERS AND SANITARY SEWERS
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: THINKING OUTSIDE THE FENCE • TREATMENT PLANTS WERE DESIGNED TO REMOVE CERTAIN CONSTITUENTS • SOLIDS, NUTRIENTS, AND BACTERIA • TREATMENT PLANTS ARE NOT DESIGNED TO REMOVE CHEMICALS • CERTAIN CHEMICALS, SUCH AS MERCURY AND CHLORIDES, CANNOT BE TREATED THROUGH CONVENTIONAL TREATMENT METHODS
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: THINKING OUTSIDE THE FENCE • RELIANCE ON REDUCING SOURCES OF POLLUTANTS • MERCURY: MUNICIPALITIES WORK WITH DENTAL OFFICES TO LIMIT USE OF MERCURY AND REDUCE MERCURY CONTAINING WASTE BEING PLACED INTO THE SEWER SYSTEM • CHLORIDES: MUNICIPALITIES WORK WITH COMMUNITIES TO REDUCE SOURCES OF SALT FROM WATER SOFTENERS AND ROAD SALT • AS NEW CONTAMINANTS EMERGE, THESE TYPES OF SOURCE REDUCTION AND POLLUTANT MINIMIZATION PROGRAMS WILL BECOME MORE CRITICAL
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: MANAGING STORMWATER • SOME SANITARY SEWER SYSTEMS STILL EXPERIENCE “OVERFLOWS” IN MAJOR STORM EVENTS • TYPICALLY CAUSED BY INFILTRATION AND INFLOW OF STORMWATER INTO THE SANITARY SYSTEM • SOMETIMES FROM CRACKS IN SEWER PIPES AND JOINTS OR MANHOLES • DNR REQUIRES ALL MUNICIPALITIES TO INSTITUTE PROGRAMS TO LIMIT INFILTRATION AND INFLOW
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: MANAGING STORMWATER • CONTINUED CONCERNS WITH INFILTRATION AND INFLOW • INFILTRATION FROM SEWER LATERALS THAT ARE ON INDIVIDUAL PROPERTY AND OUTSIDE OF THE CONTROL OF THE MUNICIPALITY • INTENSITY AND FREQUENCY OF STORM EVENTS • SEWERS ARE DESIGNED AT CAPACITY ACCOUNTING FOR CERTAIN AMOUNTS OF INFILTRATION • AS INTENSITY AND FREQUENCY OF SIGNIFICANT STORM EVENTS HAS INCREASED, ISSUES ASSOCIATED WITH INFILTRATION HAVE ALSO INCREASED
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: POINT VS. NON-POINT POLLUTION CONTROL • DIRECT DISCHARGES SUCH AS MUNICIPAL TREATMENT PLANTS ARE “POINT SOURCES” • REQUIRE WPDES PERMITS • NUMERIC LIMITS ARE EASIER TO REGULATE THESE SOURCES • DIFFUSE SOURCES OF POLLUTION ARE “NONPOINT SOURCES” • GENERALLY NOT SUBJECT TO PERMITS OR NUMERIC LIMITS • EXCEPTIONS INCLUDE STORMWATER DISCHARGES FROM LARGE COMMUNITIES AND DISCHARGES FROM CONCENTRATED ANIMAL FEEDING OPERATIONS (CAFOS)
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: POINT VS. NON-POINT POLLUTION CONTROL • WATER QUALITY IMPROVEMENTS FROM POINT SOURCES HAVE BEEN SIGNIFICANT • MUNICIPAL TREATMENT SYSTEMS HAVE BEEN REQUIRED TO REDUCE PHOSPHORUS SINCE 1991 • HAVE REDUCED DISCHARGES BY OVER 90% • MOST OF REMAINING SURFACE WATER IMPAIRMENT DUE TO PHOSPHORUS COMES FROM RUNOFF
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: COST OF MAINTAINING INFRASTRUCTURE • MOST CITIES IN WISCONSIN HAVE HAD SEWER TREATMENT PLANTS FOR 100 YEARS OR MORE • THIS AGING INFRASTRUCTURE NEEDS TO BE REPLACED • COSTS CONTINUE TO MOUNT • POPULATION AND INDUSTRY DEMAND REQUIRE LARGER SYSTEMS AND INCREASED CAPACITY • INCREASED REGULATORY DEMANDS REQUIRE NEW TREATMENT, NEW TESTING AND REPORTING, AND NEW PROGRAMS
CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: COST OF MAINTAINING INFRASTRUCTURE • UPGRADING OR EXPANDING INFRASTRUCTURE IS EXPENSIVE AND COMPLEX • PIPES ARE UNDERGROUND AND OUT OF SITE - DIFFICULT TO DIAGNOSE AND REPAIR/REPLACE • BUDGETING IS CHALLENGING, ESPECIALLY IN SMALL TO MEDIUM SIZED COMMUNITIES • MANY COMMUNITIES LACK THE POPULATION OR TAX BASE TO AFFORD UPGRADES • THE CLEAN WATER FUND • FOR SMALL COMMUNITIES, USUALLY DOES NOT PROVIDE SUFFICIENT SUPPORT
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