RMWEA Industrial Wastewater/Pretreatment Committee Nutrient Regulations: What’s Next? July 8 | 2015
Nutrient Regulations: Cliff Notes RMWEA Industrial Wastewater/Pretreatment Committee
REG. 85 & REG. 31 Nutrients Phase I and II 8 TECHNOLOGY-BASED approach 5 8 MANDATED FOR THE 44 LARGEST POTWS 58 “DELAYED IMPLEMENTATION” for POTWs 2.0 MGD and most industry 5 8 No effluent limits for POTWs 1 MGD and most industry 5 WATER QUALITY STANDARDS upstream of POTWs (TP and Chl-a now, TN 3 5/31/17) 1 3 WQS downstream starting 5/31/22 (Phase II) 1 3
Reg 85 Limits Notes: 1. Median of all samples taken in most recent 12 calendar months. 2. The 95th Percentile of all samples taken in the most recent 12 calendar months. 3. Delayed until 5/31/2022 for dischargers subject to existing control regulations 71-74, have design capacity ≤ 2 MGD, or who discharge in low priority hydrologic units code watersheds (Purgatoire, Upper Arkansas-John Martin Reservoir, Upper San Juan, Upper Arkansas-Lake Meredith, Upper White, San Luis, Chico, Kiowa, Middle South Platte –Sterling, San Miguel, Alamosa- Trinchera, McElmo, Lower Gunnison, Arkansas Headwaters, Upper Yampa, Upper Gunnison, and Uncompahgre). 4. Dischargers who submit a complete request for preliminary effluent limits to the Division on or after May 31, 2012. Brown and Caldwell 4
Reg 85 - Industrial Dischargers Existing Discharges (prior to 5/31/13) • Delayed implementation for the low priority 8- • digit hydrologic codes Except for effluent concentrations TN > 53 mg/L • and TP > 6 mg/L Reg 85 Limits apply to • Industry in SIC Code 20 • Others that the WQCD determines may discharge • more than the applicable Reg 85 limits Based on when discharge began or PEL requested • 5
Reg 85 - Industrial Dischargers Exceptions • Where there is no “RP” for Reg 31 Limits • Noncontact cooling water where nutrients • originate in source water or from chemicals shown to be necessary for proper operation Groundwater from construction dewatering sites • or building sumps where no P or N is added Reg 31 values could be added in place of Reg 85, if • the limitations would be higher (less stringent) based on dilution potential 6
Reg 85 - Industrial Dischargers Other Options • Variance • If there is no reasonable relationship to • economic, environmental or energy impacts Propose alternate limits that represent the • highest degree of nutrient removal Nutrient trading • Where it will result in equal or better WQ • Point to non-point – minimum 2:1 ratio • Point to point on 1:1 ratio • 7
Monitoring Requirements Cooling towers Flow, TN, TP, and TIN at outfall and intake (11/12 – 10/14) Others with required Flow, TN, TP, and TIN at outfall, limits upstream, and downstream Minor’s – every 2 months Major’s - monthly 8
Reg 31 Interim Limits Notes: 1. Annual median; 1-in-5 year exceedence frequency. For protection of aquatic life use. 2. July 1 – Sept 30 average in mixed layer (median of multiple depths); 1-in-5 year exceedence frequency. For lakes and reservoirs >25 acres. 3. July 1 – Sept 30 maximum attached algae, not to exceed. For protection of recreational use. 4. March 1 – Nov 30 average chlorophyll in the mixed layer (median of multiple depths); 1-in-5 year exceedence frequency. Brown and Caldwell 9
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Nutrient Regulations: What’s Next?
Purposes • To evaluate the effectiveness of Reg. 85 • To determine sources and loads Monitoring (§ 85.6(1)) • To implement appropriate and necessary source controls ? What about non-point sources of nutrients? 13
• EPA approval or disapproval Other • New ammonia criteria for Factors mussels/clams • TMDLs ? Will the numbers go lower? How can I be certain? 14
And what • Protect the recreational use about (not aquatic life or water supply protection) chlorophyll • Value is 150 mg chl a a ? (to measure abundance of attached algae) ? • This is a “nuisance” threshold (based on public perception) • Implemented as a summertime maximum (with allowable exceedance of once in 5 yrs.) 15
16 Issues to consider for both Regulations Reg. 85 monitoring does not take Currently, there is no consideration into account non-point source of biological endpoints, e.g., TP nutrient loads & MS4 data and TN are independently submittal is retrospective only, applicable based on existing data REG. 85 & REG. 31 What is “background” for TN, e.g., TP recovery likely will be needed atmospheric deposition of NOx
What’s Next – Hearing Schedule Additionally: 2014/19/24 Colorado Reg 85 reviews scheduled for 2015, 2018 and 2021. 2018/23 2015/20/25 WQCC will determine Arkansas South Platte if any changes are Rio Grande needed moving forward. 2015 is planned to be solely an informative hearing with no proposed changes 2017/22 2016/21/26 from the WQCD San Juan Basic Gunnision Standards Brown and Caldwell 17
Challenges 2016 303(d) Listing However, EPA has discretion hearing will not include to object to permit limits listing against the that are not protective of narrative nutrient existing narrative standards standards Reg. 85 data collection A segment does not have to be included on the 303(d) may have unintended List for wasteload allocations consequences to be developed 18
Opportunities If non-point source loads can be determined, This is not an state regulatory controls could option under be included in Reg. 85 the federal Act Modeling will be Need to characterize nutrient “near field” and needed for nitrogen “far field” effects within each watershed 19
Nutrient Regulations: What Can We Do?
What’s Next – What Can We Do? 2014/19/24 Participate in the Colorado WQCC hearings Collect and share information 2018/23 2015/20/25 Arkansas South Platte Build partnerships Rio Grande Obtain site-specific information Modeling of specific stream reaches 2017/22 2016/21/26 San Juan Basic Gunnision Standards Brown and Caldwell 21
What Can We Do? Brown and Caldwell 22
The Colorado Monitoring Framework (CMF) is a statewide nonprofit organization formed with the objective of creating a collaborative process to comply with water quality regulations adopted by the Colorado Water Quality Control Commission.
CMF Specifics • Kickoff Fall 2012 • Organized Under SP CURE • Steering Committee w/ Co-Chairs • DSN as Data Repository 2 24 4
CMF Specifics Membership • Kickoff Fall 2012 • Utilities • Organized Under • Industries SP CURE • Watershed Groups • Steering Committee w/ • Agriculture Co-Chairs • Individuals • DSN as Data Repository 2 25 5
CMF Members • AF CURE • L/E WWTP • Battlement Mesa Metro • Longmont District • Louisville • Brighton • Metro WRD • Boulder • NFRWQPA • Centennial W&S • MillerCoors • Co Ag Producers • South Adams County W&S • Fort Collins • Suncor • FRICO • Wastewater Utility Council • Greeley • Lafayette • UCCWA 26
CMF Specifics Membership Task Forces • Kickoff Fall 2012 • Utilities • Ag • Organized Under • Industries • DSV SP CURE • Watershed • Nutrients • Steering Groups • Temperature Committee w/ Co- • Agriculture Chairs • Individuals • DSN as Data Repository 2 27 7
What Can We Do? Brown and Caldwell 28
What Can We Do? Brown and Caldwell 29
WERF Pilot Study • Process to develop site- specific standards • Approvable models • ID/resolve issues • Address questions to make viable • Holistic view of watershed • ID periphyton sampling procedures 30
Challenges Regulations are becoming more There are limited complex, creating resources and unintended competing priorities consequences Changes need to be We have one water sustainable 31
Questions/Discussion
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