DO TMDL Subcommittee Meeting June 19 2012 A Bit of History 20082009 SummerFall 2008 BAP discussion begins Study Proposal formulated SummerFall 2009 Quality Assurance Project Plan developed ID: 527505
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Slide1
BAP Update
DO TMDL Subcommittee Meeting
June 19, 2012Slide2
A Bit of History (2008-2009)
Summer-Fall 2008
BAP discussion begins
Study Proposal formulated
Summer-Fall 2009
Quality Assurance Project Plan developed
Spokane Regional Wastewater
Phosphorus
Bio-Availability Study Initiated
Samples collected summer 2009-spring 2010Slide3
A Bit of History (2010)
September 2010
Draft Report submitted to Ecology and EPA for peer review and comments provided
Ecology review/comment/decision on incorporation into engineering plan and 2
nd
cycle of permits scheduled for 2
nd
Quarter 2012
November 2010, ECY states:
The
model is
the
basis for quantifying credits
The model will be adjusted on factors that increase allocation (i.e., BAP) at the 10 year assessment
December 2010, first “Final Report” completed
Formal comments provided by Ecology (1/20/2011)Slide4
A Bit of History (2011)
February 2011
Second “Final Report” completed
Response to comments received from UW (2/11/2011)
Formal comments provided by EPA (2/25/2011)
Response to comments received from UW (2/28/2011)
Formal response provided by EPA (3/01/2011)
Discussions
Not enough data to integrate BAP into permits
“Next steps” subcommittee formed
Dischargers concerned about “certainty”
Ecology and EPA acknowledge need for regulatory decisionSlide5
A Bit of History (2011)
April 2011
Discussions about
IEP studies and BAP research
“2-bucket” vs. “3-bucket” phosphorus models
Ecology’s commitment to use of the “2-bucket” TMDL model
IEP as the “poster child” for a modified permit limit
Ecology made another request for IEP’s orthophosphate
data
June 2011 – Washington NPDES permits issuedSlide6
Conclusion
“no matter who decides to pursue BAP, modeling with modified BAP inputs has to be consistent with the TMDL model and cannot negatively affect
Avista’s
DO responsibility found in Table 7 of the TMDL.”Slide7
2012
March - April
Bioavailable Phosphorus Workshop
Request from SRSP to Ecology to fund additional
studies
Proposed Scope of Work submitted to Ecology
Outstanding questions
Did original study meet the goals of the QAPP?
Were the comments submitted by Ecology and EPA adequately addressed?
Have Ecology’s requests for data been met?Slide8
Status
Reviews to be completed by June 30, 2012
Line by line evaluation of comments submitted by Ecology and EPA to UW and responses
2010
2011
Review of study for adequacy with the QAPP
Review of Ecology requests from DO TMDL meeting notes
Evaluation of the proposed Scope of Work with respect to EPA and Ecology expectations.