Municipal Sources of Phosphorus. Elizabeth A. Wick, P.E. Manager Division of Surface Water Northwest District Office

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1 Municipal Sources of Phosphorus Elizabeth A. Wick, P.E. Manager Division of Surface Water Northwest District Office

2 Division of Surface Water Regulate wastewater treatment plants Publically owned treatment plants (POTWs) Schools, campgrounds, churches, carry outs On site systems at businesses

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5 Division of Surface Water Industries that discharge to waters of the state Wetlands Storm water

6 Division of Surface Water Non regulatory programs Sampling Lake Erie, Grand Lake St. Marys, other inland lakes

7 Division of Surface Water Non regulatory programs Sampling ambient stations Sampling POTWs Maumee Area of Concern Compliance assistance

8 Ohio s Legal Authority Ohio Revised Code (ORC) gives the director of Ohio EPA his authority. Chapter 6111 Ohio Administrative Code (OAC) contains regulations Section 3745 National Pollutant Discharge Elimination System (NPDES) permits

9 ORC 6111 Definitions Wetland rules Powers of the director Coal mining general permits Water Pollution Control Loan Fund Class B sludge requirements Permit to Install requirements Civil and criminal penalties

10 OAC 3745 Regulations for program areas Mirrors or more stringent than federal rules OAC Water Quality Standards OAC NPDES rules (40CFR122) OAC Operator Certification OAC Storm water OAC Sludge rules

11 Nutrient Standards Narrative nutrient standards in OAC In 1999, target P and N concentrations developed to protect aquatic life New nutrient standards being worked on for past 10 years Recent events show that we need to: Develop new solutions Improve effectiveness and efficiency of existing strategies to reduce nutrients

12 Narrative Water Quality Standards Criteria applicable to all waters The free froms that result from human activity Free from substances that settle and form deposits Free from floating debris, oil and scum Free from color, odor, or other conditions that create a nuisance Free from substances that are toxic Free from nutrients in concentrations that create nuisance growths of algae and aquatic weeds Free from public health nuisances associated with raw or poorly treated sewage

13 Technical Advisory Group Started in 2013 Advising the Agency as we develop State surface water quality standards for nutrients Draft rules expected in 2015 Phased approach to implementation

14 Wastewater Treatment Plants All discharges to waters of the state require a permit National Pollutant Discharge Elimination System (NPDES) Permit Renewed every 5 years Contain effluent limits, monitoring requirements, compliance schedules, standard conditions

15 Wastewater Treatment Plants 5,600 individual NPDES permits statewide Approx. 1,200 in NWDO View list of permits by county:

16 Wastewater Treatment Plants P limits in Lake Erie basin since mid 1980s All POTWs 1 MGD or greater have effluent P limits 1.0 mg/l monthly average 1.5 mg/l weekly average POTWs 100,000 gpd or greater: monitoring data evaluated and limits added if necessary All POTWs over 10,000 gpd monitor for P

17 Wastewater Treatment Plants Biological nutrient removal Chemical addition TMDLS may recommend lower permit limits Compliance schedules added to permits if new limits Typically 3 5 years to meet limits Cost of treatment and increased solids

18 Wastewater Treatment Plants Phosphorus optimization language Added to NPDES permits in Lake Erie basin Operational changes at the plant Economical way to reduce P Submit plan on how to optimize Report with renewal application what was done and cost

19 Wastewater Treatment Plants Water Quality Trading Watershed specific Permittee uses pollutant reductions from another source to obtain nutrient credits that may be applied to permit to meet specific nutrient requirements Trading program requirements in OAC

20 Wastewater Treatment Plants Challenges Cost of treatment How low is too low for permit limits? All transfer to homeowners and businesses

21 Combined Sewer Overflows Built to carry sanitary waste in addition to storm water During rain events, volume of wastewater and storm water exceed sewer capacity Pipe overflows to nearest water body Ohio EPA CSO Control Strategy issued in 1995

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23 Combined Sewer Overflows (CSOs) Primary goals of CSO policy: No significant contribution to violations of water quality standards No use designation impairments Minimize total loading of pollutants discharged during rain events Implemented through NPDES permit conditions or enforcement actions

24 Combined Sewer Overflows (CSOs) Nine Minimum Controls Simple technologies to minimize impact of CSOs Proper operation and maintenance of collection system and overflow points Maximize use of collection system for storage Minimize the impact of nondomestic discharges Maximize the capabilities of the POTW to treat wet weather flows

25 Combined Sewer Overflows (CSOs) Nine Minimum Controls Prohibit dry weather overflows Control solid and floatable materials in the CSO discharge Conduct required inspections, monitoring and reporting Implement pollution prevention programs Implement public notification program for CSO areas

26 Combined Sewer Overflows (CSOs) Long Term Control Plan Plan for elimination of impacts of CSOs Methods to eliminate Costs Timeframes

27 Funding Ohio EPA s Water Pollution Control Loan Fund (WPCLF) $100 million available at a 0% interest rate For projects that include equipment and facilities to reduce the levels of phosphorus and other pollutants Accepting applications throughout calendar year 2015.

28 Home Sewage Treatment Systems Jurisdiction of the local health departments Unsewered areas concentrated homes in areas without central sewers In 2012, 31% of household systems were failing

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30 Narrative Water Quality Standards Free from public health nuisances associated with raw or poorly treated sewage Public health nuisance demonstrated by: Inspection by Ohio EPA or registered sanitarian documents odor, color and/or other visual manifestations of raw or poorly treated sewage AND Sample results violate numeric criteria in the rule

31 Home Sewage Treatment Systems Ohio EPA and local health department sample for e coli according to regulation If documented public health nuisance, local jurisdiction notified Ohio EPA issues Director s Final Findings and Orders Local officials address the nuisance typically by installing central sewers

32 Home Sewage Treatment Systems Some funding agencies give an area more points if Ohio EPA ordered sewers Improved living conditions for residents Costs comparable to replacing/upgrading septic tank systems Eliminate raw or partially treated sewage sources No one is happy about paying a monthly sewer bill

33 Home Sewage Treatment Systems $1 million provided to the Ohio Department of Health To be used to help counties, communities and individuals address home sewage treatment system problems, particularly those in the Lake Erie basin.

34 Monitoring programs Inland lakes 1 or 2 lakes in TMDL study area assessed Sample monthly May through September

35 Monitoring programs Stream ambient stations Sampled quarterly until recently Monthly sampling USGS monitoring locations Background data

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37 Monitoring programs Lake Erie Sampled every other week From ice out until late September

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39 Future Continue to monitor point sources Reduce effluent limits as TMDLs dictate Enforcement action as necessary Continue to monitor ambient stations Continue to monitor Lake Erie Continue work to develop nutrient standards