Wieberg, Chris, Sappington, Amanda, MDNR, Operating Permits Section Update, at Missouri Water...
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Transcript of Wieberg, Chris, Sappington, Amanda, MDNR, Operating Permits Section Update, at Missouri Water...
Celebrating 40 years of taking care of Missouri’s natural resources.
Chris Wieberg and Amanda Sappington
Operating Permits Section
Operating Permits Section Update
Celebrating 40 years of taking care of Missouri’s natural resources.
Master General PermitsIssuedMOGD – Non-POTWs discharging ≤50,000 gpd; Effective 07/01/2014MOG14 – Oil/Water Separators; Effective 07/01/2014MOG76 – Swimming pool discharges; Effective 08/01/2014MOR22A – Lumber and Wood (primary); 09/01/2014MOR203 – Fab. Metal, Light Industrial; 09/01/2014MOR80H – Solid Waste Transfer; 09/01/2014
ModifiedMOR22C – Lumber and Wood (secondary); 08/08/2014
Celebrating 40 years of taking care of Missouri’s natural resources.
Master General Permits
Pending ModificationMOG64 – WTP Settling Basins; 10/01/2014 Draft PhaseMOG84 – Clay PitsMOR22B – Wood TreatersMOR241 – Agrichemical FacilitiesMOR23A – Chemical Manufacturing
Celebrating 40 years of taking care of Missouri’s natural resources.
Average Process Days Permits Issued Application for New Permit
General Permit Covered Facility 48 Non-NPDES - Construction for Ag Chem Storage Facilities 1 Non-NPDES - Construction for Sewer Extension 85 Non-NPDES - Construction for Wastewater Treatment 55 Site Specific 17
206
Average Process Days Permits Issued Modification
General Permit Covered Facility 7 Site Specific 32
39
Average Process Days Permits Issued Ownership Transfer
Site Specific 25
25
Average Process Days Permits Issued Renewal
Site Specific 415
415
Average Process Days Permits Issued Termination
Site Specific 20
20
Celebrating 40 years of taking care of Missouri’s natural resources.
401 Certifications
39 Individual 401 Certifications for the Corps Nationwide and Individual permits since January 1, 2014
Celebrating 40 years of taking care of Missouri’s natural resources.
Permit Quality Review (PQR)
Review conducted in March 2014 by EPA Region 7 staff.
Celebrating 40 years of taking care of Missouri’s natural resources.
Findings• Priority Pollutant Scans
– 40 CFR 122.21 requires 3 for majors POTWs at renewal
Form B2 has been revised
Celebrating 40 years of taking care of Missouri’s natural resources.
Findings• Reasonable Potential
– EPA found that permit writers where not including data from the permit application in reasonable potential analysis.
Celebrating 40 years of taking care of Missouri’s natural resources.
Findings• Backsliding
– EPA found that permits renewed with less stringent requirements lack sufficient factsheet language providing justification as to why the backsliding requirement met the provisions of 40 CFR 122.44
• Permit Writers have been directed to provide detailed justification in factsheet regarding each requirement less stringent from the previous permit decision
Celebrating 40 years of taking care of Missouri’s natural resources.
Findings• EPA suggests that the Department review
the general permit for pesticide applicators as to it’s applicability in “Outstanding Natural Resource Waters” and impaired waters.
– The Department intends to review this upon the renewal of the MGP
Celebrating 40 years of taking care of Missouri’s natural resources.
Findings• EPA found several issues regarding how
pretreatment programs are addressed in permits.– Identified 7 POTWs that were missing
pretreatment implementation requirements in the permit.
– Identified the lack of requirements in permits that address the re-evaluation of local limits per 40 CFR 122.44
Celebrating 40 years of taking care of Missouri’s natural resources.
Pretreatment Findings Cont.• EPA suggests that the department should
insure factsheets for POTW permits without pretreatment programs should be explicit to the fact that a pretreatment program is not required in addition to listing any discharging industries that discharge to the POTW.
Celebrating 40 years of taking care of Missouri’s natural resources.
Pretreatment Findings Cont.• EPA suggest that the Department should
follow-up with categorical industrial users outside of the pretreatment program to ensure they are complying with reporting requirments.
Celebrating 40 years of taking care of Missouri’s natural resources.
Findings• EPA identified several concerns regarding
the Departments CAFO permitting program– EPA identified that Missouri definition of process
wastewater was less stringent than 40 CFR 122.23 in that the definition must include water “indirectly” used in the operation of a CAFO
Celebrating 40 years of taking care of Missouri’s natural resources.
CAFO Findings cont.• EPA pointed out that some site specific
CAFO permits did not adequately address how process wastewater and stormwater in contact with materials are disposed of.
– The department is currently reviewing this comment and will likely address in permits at the next renewal.
Celebrating 40 years of taking care of Missouri’s natural resources.
CAFO Findings cont.• EPA identified applications that they felt
were incomplete.
– The department is reviewing this comment
Celebrating 40 years of taking care of Missouri’s natural resources.
CAFO Findings cont• EPA identified concerns with the
departments Wet Weather Management Guide and it’s interaction with the CAFO permits.
– The department is currently reviewing the guide and will likely change some of the wording to clarify.
Celebrating 40 years of taking care of Missouri’s natural resources.
Improvements • WET
– EPA noted the WET program saw significant improvements such as movement toward toxic units
• Sludge– EPA noted the department provides good
examples regarding 503 in it’s reporting forms which has been helpful to permittees
Celebrating 40 years of taking care of Missouri’s natural resources.
Other EPA Comments• EPA urges the department to take a robust
approach to setting BPJ-based technology limits, and in the consideration of water quality based limits for WTP discharges.
• EPA points out that the department needs to build the capacity for assessing 316(a) variances and notes there are several facilities in MO where variances will be needed.
Celebrating 40 years of taking care of Missouri’s natural resources.
Form Changes• Form B and B2
– Process Flow Diagram or Schematic• Wet Weather Design Flow
– Priority Pollutant Scan– Downstream Landowner– Other small changes– Financial Questionnaire– Small Domestic General Permit = Form B not E– Always Print the new form from the web
Celebrating 40 years of taking care of Missouri’s natural resources.
AffordabilityChange is coming
• Comments from Stakeholders• Comments from Environmental
Improvement and Energy Resources Authority (EIERA)
• Legislative inquiries• Recent Legislation
Celebrating 40 years of taking care of Missouri’s natural resources.
Affordability• The Nature of Affordability (Cost
Analysis for Compliance) • Consistent with Section 644.145, RSMo (revised in 2012
and 2014) • Any new requirements within the permit • The cost analysis will influence derivation of the schedule
of compliance • The cost analysis does not determine whether or not an
upgrade will be required • The cost analysis does not take place of a Factor 6 UAA
Celebrating 40 years of taking care of Missouri’s natural resources.
Senate Bill NO. 642 (2014)• Department is working on changes to the
analysis. • New treatment options • Addition of a new criteria - Inclusion of ongoing
costs of operating and maintaining the existing wastewater collection and treatment system, including payments on outstanding debts for wastewater collection and treatment systems when calculating projected rates (also in SB 664)
Celebrating 40 years of taking care of Missouri’s natural resources.
New Treatment Options • Land Application – could be appropriate for
communities up to 150,000 gallons per day
• Has the potential to be a more affordable option
• The best option for THE BIG PICTURE!
Celebrating 40 years of taking care of Missouri’s natural resources.
New Treatment Options
• Extended Aeration Package Plants – Facilities up to 50,000 gallons per day
• More Practical Treatment Option for smaller communities
• May still result in a high burden for very small communities
Celebrating 40 years of taking care of Missouri’s natural resources.
Addition of a new criteria
• Drafting a “Financial Questionnaire Form” • Will be available on the website with the
applications • An application without the supplemental
form will be deemed as incomplete
Celebrating 40 years of taking care of Missouri’s natural resources.
Financial Questionnaire Form
Celebrating 40 years of taking care of Missouri’s natural resources.
Financial Questionnaire Form • Includes the how, when and where to find
information to complete the form • Affordability Assessment Tool for Federal
Water Mandates was used as the reference Prepared for: the US Conference of Mayors, American Water Works Association, and Water Environment Federation
• By: Stratus Consulting
Celebrating 40 years of taking care of Missouri’s natural resources.
Senate Bill NO. 642 (2014) Annual Report – Total number of findings of affordability meeting
the definition of affordable
– Not meeting the definition of affordable – Those implemented as a Federal Mandate – Average increase in projected sewer rates in
various forms and percentages
• Also in SB 664
Celebrating 40 years of taking care of Missouri’s natural resources.
Senate Bill NO. 664 (2014) • "Affordability", with respect to payment of a
utility bill, a measure of whether an individual customer or household with an income equal to the lower of the median household income for their community or the state of Missouri can pay the bill without undue hardship or unreasonable sacrifice in the essential lifestyle or spending patterns of the individual or household…
Celebrating 40 years of taking care of Missouri’s natural resources.
State MHI• $47,333 as stated in the 2012 ACS median
household income (dollars) • Inflation factor updated once per month • Using the state MHI helps to mitigate some
of the burden on distressed populations that can exist in a municipality with a high MHI.
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean….
• No more range of estimated costs associated with mechanical treatment
• The addition of socioeconomic indicators into the Financial Capability Table – % Households in Poverty – % Households relying on Food Stamps
Celebrating 40 years of taking care of Missouri’s natural resources.
No more ranges
• Most practical treatment option • Most appropriate technology for design flow • So we can get the most accurate depiction
of what the financial situation could look like
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean….• Schedules of Compliance will look different
Longer schedules to include education, assistance, integrated planning?
• Department Community Services Initiative • Integrated Planning is Important Other
environmental obligations and requirements (Drinking water, MS4, I&I, etc…)
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean….• Schedule of Compliance timelines:
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean….
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean….• Schedule of Compliance timelines: All years
include Inflow and Infiltration maintenance
1.Seek Community Assistance from MDNR
2.Complete Education Assistance Program
3.Hire an Engineer
4.Evaluation of Rate Structure and Treatment Plant
5.Raise user costs to appropriate level, MDNR will reassess analysis at renewal
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean….• Schedule of Compliance timelines: All years
include Inflow and Infiltration maintenance 6. Evaluate Flow and Treatment Options
7. Evaluate Flow and Treatment Options
8. Public meetings and hearings
9. Bond Election, Apply for permit renewal
10. Permit Renewal, Apply for SRF Funding, Submit Facility Plan and Antidegradation Review, MDNR will reassess analysis at renewal
11. Apply for Construction and Operating Permit Modification
12. Construction
13. Construction
14. Complete Construction
Celebrating 40 years of taking care of Missouri’s natural resources.
What the changes mean…. • Community Services Initiative Hannah
Humphrey • Communities serving 500 to 5,000 people
– Regional Office Staff – NERO – Denise Haberl – KCRO – Stephen Krabbe – SLRO – Tracy Haag – SERO – Travis Abernathy – SWRO – Not yet named
Celebrating 40 years of taking care of Missouri’s natural resources.
Integrated Planning • Communities facing multiple environmental requirements
with conflicting deadlines and limited resources should request approval of an integrated plan.
• The plan does not have legal authority to change compliance deadlines, additional actions must be taken.
• MDNR would like an integrated plan, to consider all environmental requirements (example: solid waste or air pollution)
Celebrating 40 years of taking care of Missouri’s natural resources.
New Regulations• 10 CSR 20-7.015(9)(L)4.C.• A Toxic Unit (TU) Water Quality Based
Effluent Limit shall be established in the permit where the department finds reasonable potential to cause or contribute to an excursion from the narrative water quality criteria
• WET is now a numeric limit like all other parameters, violations treated accordingly
Celebrating 40 years of taking care of Missouri’s natural resources.
Permit Language• Monitoring only until reasonable potential is
established – Identify a problem and address it before it becomes a violation– Reopener clause included
• When reviewing monitoring data, look for exceedances of TUa = 1 and TUc = 1.6
• Trigger language only included when a facility gets limits
• Permit manual updates are on Web
Celebrating 40 years of taking care of Missouri’s natural resources.
What hasn’t changed• Test methods• Test applicability
– except the use of chronic for major POTWs• Method for calculating AEC
– Acute AEC% = ((design flow + ZID7Q10) / design flow)-1] x 100 = ##%
– AEC is no longer the compliance point
Celebrating 40 years of taking care of Missouri’s natural resources.
Permit Manual• http://www.dnr.mo.gov/env/wpp/permits/manual/5_0.htm
Celebrating 40 years of taking care of Missouri’s natural resources.
• Can be done by eDMR – Upload all related documents
• New Forms sent out with permit– Please be sure everything is complete
• New Forms should be sent to appropriate Regional Office with DMR
• Old Forms still come to Jefferson City
Reporting