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Domestic Sewage Treatment Lagoons General Permit 2013 – GP Overview

Domestic Sewage Treatment Lagoons General Permit 2013 – GP Overview. Christine Weaver Montana Department of Environmental Quality (DEQ) Water Protection Bureau. Domestic Sewage Treatment Lagoons General Permit (GP).

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Domestic Sewage Treatment Lagoons General Permit 2013 – GP Overview

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  1. Domestic Sewage Treatment Lagoons General Permit2013 – GP Overview Christine Weaver Montana Department of Environmental Quality (DEQ) Water Protection Bureau

  2. Domestic Sewage Treatment Lagoons General Permit (GP)

  3. Unlawful to discharge to state waters without a current wastewater discharge permit • Surface water discharge permits (MPDES) • Individual orGeneral Permit • Renew every five (5) years. • Ground water discharge permit (MGWPCS) • Renew every five (5) years.

  4. 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.

  5. Applicability Any facultativeoraerated (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.”

  6. Ephemeral streams are nothigh 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)].

  7. Ephemeral Stream

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

  9. 5-Year Renewal Minimum Total Cost Fee Annual Fee 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) 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. General Permit (GP)

  10. Application Process • Any 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.

  11. Confirmation Letter DEQ will issue a facility-specific confirmation letter to all eligible facilities.

  12. Confirmation Letter The 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.

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

  14. 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 removal

  15. 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 flowprovided in NOI. • DMR reporting: use daily flow for the day in which the samples are collected. 8.34

  16. 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. (100 – 10) 100 100 mg/L = 0.90 x 100% = 90% 10 mg/L EXAMPLE Sludge

  17. BOD5 Limits (All facilities) Footnotes: • (2) CBOD5 limits contained in 40 CFR 133.102(a)(4)may replace BOD5 limits for the term of the permit if requested by the permittee during the renewal application process and approved by DEQ.

  18. TSS Limits • Each 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)

  19. TBEL Group A – National Secondary Standards (NSS)

  20. TBEL Group B –Treatment Equivalent to Secondary (TES)

  21. TBEL Group C –Alternate State Requirements (ASR)

  22. Demonstration of TSS eligibility • Notice 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.

  23. WQBELs •  Escherichia coli (E. coli) bacteria limit effective 2017. •  Total Residual Chlorine (TRC) limit effective immediately.

  24. Future WQBELs… • Next 5-year GP renewal: • Ammonia • Nitrogen & Phosphorus • Other?

  25. ?? On Effluent Limits ??

  26. Monitoring

  27. General Monitoring Requirements • Must 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-7 • Samples 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.

  28. General Monitoring Requirements • Reporting to DEQ on DMRs by 28th of following month.

  29. Monitoring Tables # 6 - #8 • Self-monitoring frequency based on designed discharge frequency & size. The types are: • Continuous dischargersare 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 dischargersare facilities that are designed to operate with periodic, controlled, or seasonal discharges. This includes non-discharging facilities.

  30. Upstream Monitoring • Beginning 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.

  31. Compliance Schedule • By 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.

  32. Special Conditions 1. 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.

  33. 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.

  34. Lagoon O&M Requirements • Each 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; and • Maintain records of the routine inspections and any follow-up.

  35. 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.

  36. Inflow/Infiltration • All 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.

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

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