Domestic Sewage Treatment Lagoons General Permit - PowerPoint Presentation

Slide1

Domestic Sewage Treatment Lagoons General Permit2013 – GP Overview

Christine Weaver

Montana Department of Environmental Quality (DEQ)

Water Protection BureauSlide2

Domestic Sewage Treatment Lagoons General Permit (GP)Slide3

Unlawful to discharge to state waters without a current wastewater discharge permitSurface water discharge permits (MPDES

)

Individual

or

General

Permit

Renew

every five (5) years

.

Ground water discharge permit (MGWPCS)

Renew every five (5) years.Slide4

Domestic Sewage Treatment Lagoons GP (MTG580000)Twenty-four (24) facilities covered under the renewed GP, which was issued as final September 27, 2012, effective January 1, 2013.Slide5

ApplicabilityAny facultative or aerated (including partial mix) domestic sewage treatment lagoon in Montana, except for those within Indian Reservations, that meet all of the following:

< 1.0

million gallons per day (mgd

)

design

average flow;

No significant

industrial contributors or indirect

dischargers

(ARM 17.30 Subchapter 14)

;

Does not discharge either to Outstanding Resource Waters or to waterbodies classified as A-1 or

A-Closed;

and

Is not a “

new or increased source

” that discharges to “high quality waters

.”Slide6

Ephemeral streams are not high quality waters.New sources can only be covered by this GP if discharge to ephemeral waterbody.

Ephemeral stream

…

a stream or part of a stream which flows only in direct response to precipitation in the immediate watershed or in response to the melting of a cover of snow and ice and whose channel bottom is always above the local water table

[

ARM 17.30.602(12

)].Slide7

Ephemeral StreamSlide8

So, you can be covered under the GP….Then What?Slide9

Consider cost$ is major factor –savings of about $4,000/5-yr in fees, vs. possible increase in monitoring costs if covered under GP rather than under an Individual MPDES permit.

5-Year

Renewal

Fee

Minimum

Annual Fee

Total Cost

Five Years

GP

800

$

850

$

5,050

$

Individual MPDES Permit

POTW

1,500

$

1,500

$

9,000

$

(or greater)

Private

3,000

$

1,500

$

10,500

$

(or greater)

General Permit (GP)Slide10

Application ProcessAny facility that has not been covered previously under this GP must pay $800 (if switching from another permit) or $1,200 (if it is a new facility to ephemeral drainage).

Owner/operator must submit a complete Notice of Intent (NOI)

package.

Submittal

of a complete NOI package constitutes immediate coverage -- but DEQ reserves the right to deem an NOI incomplete or a facility

ineligible. Slide11

Confirmation LetterDEQ will issue a facility-specific confirmation letter to all eligible facilities. Slide12

Confirmation LetterThe confirmation letter will include the requirement to keep both the confirmation letter and a copy of the GP available at all times. Electronic access is acceptable.Slide13

Effluent Limits The limits for each facility are comprised of:Appropriate Technology-based Effluent Limits (TBELs) [40 CFR 133]; andWater Quality-based Effluent Limits (WQBELs). Slide14

TBELs include:pH between 6.0 – 9.0 s.u.Biochemical Oxygen Demand (BOD5) & Total Suspended Solids (TSS):Concentration-based effluent limits (i.e. mg/L)Mass-based effluent limits (i.e. lb/day)Percent removalSlide15

Equation 1: Mass-based, or Load Limit (lb/day) =

Concentration (mg/L) x Effluent Flow Rate (

mgd

) x (8.34)

Facility Limit

: based on

average daily

design

flow

provided in NOI.

DMR reporting

: u

se daily flow for the day in which the samples are collected.

8.34Slide16

Percent removal =

[

Influent Concentration

] - [

Effluent Concentration

]

x 100%

%

Removal

= [

Influent Concentration

]

Where:

Influent Concentration

= Corresponding 30-Day average influent concentration based on the analytical results of the reporting period.

Effluent Concentration

= Corresponding 30-Day average effluent concentration based on the analytical results of the reporting period.

EXAMPLE

100 mg/L

10 mg/L

Sludge

(100 – 10)

100

= 0.90 x 100%

= 90%Slide17

BOD5 Limits (All facilities)Footnotes:

(2) CBOD

5

limits contained in 40 CFR 133.102(a)(4)

may replace BOD

5

limits for the term of the permit if requested by the permittee during the renewal application process and approved by DEQ.Slide18

TSS LimitsEach facility needs to request, and will be assigned, TSS effluent limits based on:TBEL Group A – National Secondary Standards (NSS) = DEFAULT, or upon demonstration:TBEL Group B –Treatment Equivalent to Secondary (TES)TBEL Group C –Alternate State Requirements (ASR)Slide19

TBEL Group A – National Secondary Standards (NSS)Slide20

TBEL Group B –Treatment Equivalent to Secondary (TES) Slide21

TBEL Group C –Alternate State Requirements (ASR) Slide22

Demonstration of TSS eligibilityNotice of Intent (NOI) Question #E.6.:95th percentile TSS effluent quality for 2 years [i.e., excel formula ‘=percentile(cell#:cell#,0.95)’]PLUS justification that Operation & Maintenance (O&M) conducted appropriately.Slide23

WQBELs

Total Residual Chlorine (TRC) limit effective immediately.



Escherichia

coli

(

E. coli

) bacteria

limit effective 2017.Slide24

Future WQBELs…Next 5-year GP renewal:AmmoniaNitrogen & PhosphorusOther?Slide25

?? On Effluent Limits ??Slide26

MonitoringSlide27

General Monitoring RequirementsMust monitor at the last point of control before the discharge enters the receiving water. Analysis must meet any Required Reporting Values (RRVs) listed in the most recent Circular DEQ-7Samples shall be collected, preserved and analyzed in accordance with procedures listed in 40 CFR 136, and must be representative of the volume and quality of the effluent.

By January 1, 2017, all facilities must ensure effluent

flow

monitoring is representative.Slide28

General Monitoring RequirementsReporting to DEQ on DMRs by 28th of following month.Slide29

Monitoring Tables # 6 - #8Self-monitoring frequency based on designed discharge frequency & size. The types are: Continuous dischargers are facilities designed to discharge on a continuous basis, or discharge 270 continuous days or greater per calendar year, based on design average flow rate: Small Continuous:

less than 0.1 mgd

.

Large Continuous

:

between 0.1 – 1.0 mgd

.

B.

Batch dischargers

are facilities that are designed to operate with periodic, controlled, or seasonal discharges. This includes non-discharging facilities. Slide30

Table 8: Self-

Monitoring Requirements for

Batch

Dischargers

(1)

Parameter

Units

Monitoring Location

Sample Frequency

(2)

Sample Type

Flow/TBELs

Flow

mgd

Effluent

1/Day

(3)

days

Effluent

1/Day

Calculated

5-Day Biochemical Oxygen Demand (BOD

5

)

(or CBOD

5

if appropriate)

(7)

mg/L

Influent

1/Month

(4)

Composite

mg/L

Effluent

1/Week

(5)

Composite

(6)

% removal

Effluent

1/Month

(4)

Calculated

lb/day

Effluent

1/Month

Calculated

Total Suspended Solids (TSS)

mg/L

Influent

1/Month

(4)

Composite

mg/L

Effluent

1/Week

(5)

Composite

(6)

% removal

Effluent

1/Month

(4)

Calculated

lb/day

Effluent

1/Month

Calculated

pH

s.u.

Effluent

1/Week

(5)

Instantaneous

WQBEL

Oil and Grease

(8)

mg/L

Effluent

1/Year

Grab

E. coli

Bacteria

cfu/100 mL

Effluent

1/Week

(5)

Grab

Total Residual Chlorine (TRC)

mg/L

Effluent

5/Week

(9)

Grab

Ammonia as N

mg/L

Effluent

2/Month

Composite

(6)

Nitrate + Nitrite as N (NO

3

+ NO

2

)

mg/L

Effluent

1/Month

(10)

Composite

(6)

Total Kjeldahl Nitrogen (TKN)

mg/L

Effluent

1/Month

(10)

Composite

(6)

Total Nitrogen as N (TN)

(11)

mg/L

Effluent

1/Month

(10)

Calculated

lb/day

Effluent

1/Month

(10)

Calculated

Total Phosphorus as P (TP)

mg/L

Effluent

1/Month

(10)

Composite

(6)

lb/day

Effluent

1/Month

(10)

CalculatedSlide31

Footnotes:See Definition section at end of permit for explanation of terms.Monitoring only required during periods of discharge. Frequency is based on calendar week, calendar month, etc.

By no later than

January 1, 2017

, all facilities under the 2012-issued GP must ensure flow monitoring is representative of the nature and volume of the discharge.

Beginning on

January 1, 2017

, facilities will be required to monitor influent BOD

5

and TSS composite samples for reporting %removal. Influent monitoring is required only if a discharge occurs during that reporting period.

The last weekly sample for these parameters must be taken on the last day of discharge.

Effluent composite samples are 24-hour composite samples, using a minimum of four grab samples. However, a minimum of one grab sample may be taken for effluents from holding ponds or other impoundments with a retention period greater than 24 hours. This will be specified in the confirmation letter.

CBOD

5

limits and monitoring may replace BOD

5

for the term of the permit if requested by the permittee during the renewal application process and approved by DEQ.

Use EPA Method 1664, Revision A: N- HEM or equivalent.

TRC monitoring only required if chlorine is used to disinfect during the reporting period. If not, report “NA” on the DMR. The approved sampling method must be performed whenever chlorine is utilized for disinfection. Analytical results less than 0.1 mg/L will be considered in compliance with the chlorine limit.

Monitoring of nutrients, including NO

3

+ NO

2

, is required monthly for the six warmer months of May through October.

TN is calculated as the sum of Nitrate + Nitrite as N and TKN concentrations.Slide32

Upstream MonitoringBeginning 2014 (or first calendar year after coverage), each facility shall monitor for the following parameters in the receiving water upstream from their discharge point quarterly (monthly for pH and temperature) for three years

(the second, third, and fourth year of coverage):

Nitrate + Nitrite, as N

Ammonia, as N

Total Kjeldahl Nitrogen (TKN)

Total Nitrogen, as N (TN)

Total Phosphorus, as P (TP)

pH (monthly)

Temperature (monthly)

This data will be used for the NEXT GP renewal.Slide33

Compliance ScheduleBy no later than January 1, 2017, each facility shall comply with the E. coli bacteria effluent limits or have applied for coverage under an individual permit.Slide34

Special Conditions1. By no later than January 1, 2017, each facility shall begin monitoring to demonstrate compliance with the % removal monitoring requirements (both BOD5 and TSS) or have applied for coverage under an individual permit.2. By no later than

January 1, 2017

, all facilities must ensure that the facility is capable of effluent flow monitoring such that the measured flow is representative of the nature and volume of the actual flow. DEQ recommends the use of a weir, flume, and/or meter with an effluent recording device, or

totalizer

. Slide35

Until January 1, 2017…Each facility must submit an annual report summarizing their progress, post-marked no later than January 28th of each year. The report must include actions taken in the previous year and planned actions for the upcoming year, including identification of potential options, design, and installation of the selected option.Slide36

Lagoon O&M RequirementsEach facility covered under the GP is required to:Maintain an up-to-date O&M manual for the domestic sewage treatment lagoon system;Follow the procedures in the O&M manual;Conduct inspections at least monthly to ensure the O&M procedures are being followed and are working; andMaintain records of the routine inspections and any follow-up.Slide37

Seasonal Land Application of Treated Effluent O&M procedures for an irrigation system is included as part of the plan and specification approval by DEQ [Circular DEQ-2], and shall be incorporated into the treatment system’s final O&M manual.Slide38

Inflow/InfiltrationAll facilities with design average discharge rates at or above 0.1 mgd are required to evaluate the influences from infiltration/inflow (I/I) to the treatment works by January 1, 2017. The evaluation shall provide an estimate of the amount and sources of I/I into the collection system and a summary of work accomplished and additional work planned. Slide39

Christine WeaverMT DEQ Water Protection Bureau(406) 444-3927cweaver@mt.gov