Slide deck for Public Meeting on July 12, 2023
U.S. Environmental Protection Agency · from the EPA · 22 pages · 1.8 MB
open the file ↗ · original at the source ↗
Public Meeting National Pollutant Discharge Elimination System (NPDES) Draft Permit for the Massachusetts Water Resources Authority (MWRA) Deer Island Treatment Plant & Combined Sewer Overflows Michele Barden, EPA Region 1 July 12, 2023 Agenda • Purpose of the Meeting • NPDES Permitting in Massachusetts • Overview of MWRA Deer Island Treatment Plant Permitting History • Overview of Draft Permit • Outfall T01 – the Massachusetts Bay outfall • CSO Treatment Facilities • CSOs • Other significant changes • MassDEP Permit • Questions NOTE: This meeting will end promptly at 7:45, so we can promptly start the Public Hearing starting at 8:00. July 2023 Purpose of this Meeting • Explain the NPDES permitting process • Explain the elements of the draft permit • Following this meeting, we will be holding a public hearing. You will be able to comment orally during the public hearing. • Comments may also be submitted in writing during the extended public comment period which now closes on August 30, 2023. • Oral and written comments have equal value, and both will be addressed in EPA’s Response to Comments which will be issued along with the Final Permit. July 2023 NPDES Permitting Program in MA • EPA Region 1 issues NPDES permits in MA and NH. • EPA and MassDEP issue two separate permits: a federal NPDES Permit and a state surface water discharge permit. • MassDEP, generally, incorporates the EPA permit into the state permit and, if necessary, adds any state-only requirements. • The comment period for both permits runs simultaneously. Those wishing to comment on either or both permits should submit comments to the appropriate agency. July 2023 EPA’s NPDES Permit Process July 2023 EPA prepares Draft Permit and accompanying Fact Sheet Draft Permit goes on Public Notice for minimum of 30 days Permittees, co- permittees and members of the public submit comments by the end of the Public Notice Period EPA reviews the comments received and prepares a Response to Comments and the Final Permit Final Permit and Response to Comments are issued Appeals Petition to the Environmental Appeals Board (Within 30 days from the date the Final Permit is issued) If no appeals, the Final Permit goes into effect on the first calendar day of the month following 60 days after the issuance date of the Final Permit. MWRA Deer Island Treatment Plant Permitting History 1985 - MWRA formed by the Massachusetts’ Legislature 1991 – Sludge discharge to Boston Harbor ends 1995 - First stages of the improved primary treatment units begin operation 1997 - First of three batteries of secondary treatment started up 2000 – 2000 NPDES Permit becomes effective, and discharge is moved from Boston Harbor to the Massachusetts Bay July 2023 The 2000 MWRA DITP Permit • The 2000 Permit was developed based on effluent data from the old primary treatment plant and a pilot plant since the Deer Island Treatment Plant was still being built. • Stringent effluent limitations • Extensive monitoring of the effluent for non-limited parameters • It also focused on assuring the new discharge to Massachusetts Bay did not negatively impact Massachusetts or Cape Cod Bays. • Ambient Monitoring Plan • Contingency Plan • Outfall Monitoring Science Advisory Panel (OMSAP) • The permit also included requirements for: • a Best Management Plan • a Pollution Prevention Plan • an Industrial Pretreatment Program • Operation and Maintenance requirements • Dye Studies to confirm dilution of the diffuser July 2023 Changes between 2000 Permit and 2023 Draft Permit for Massachusetts Bay outfall (T01) – Effluent Limits & Monitoring Requirements Effluent Parameter 2000 Final Permit 2023 Draft Permit Change Reason Effluent flow, MGD 436 MGD, avg monthly 361 MGD, annual rolling avg, reported monthly ↑ 361 MGD is the annual average design flow for secondary treatment that was built CBOD & TSS, % removal No limit 85% removal, during dry weather ↑ Consistent with other NPDES permit for POTWs with CSOs pH, S.U. 6.0-9.0 6.0-8.5 ↑ Brings consistent with current state regulations Fecal Coliform Bacteria 14,000 avg. weekly, 14,000 max. daily 980 avg. weekly, 1960 max. daily ↑ Brings consistent with current state regulations Enterococcus No limit 2450 colonies/100 mL avg. monthly, 9100 colonies/100 mL max. daily ↑ Brings consistent with current state regulations Oil & Grease Narrative language Non-detect limit ↑ Reasonable potential based on effluent data PCB, Aroclors 1016, 1221, 1232, 1242, 1248, 1254, 1260 ug/L 0.000045 ug/L avg. monthly, Report max. daily No limit ↓ No limit required as PCB Aroclors never detected in effluent since 2000 Permit became effective Total Nitrogen No requirement Report calculated value from data ↔ Provides added information 40 PFAS Analytes No requirement Report ↔ Region 1 standard requirement implementing EPA Strategic Roadmap for PFAS Adsorbable Organic Fluorine No requirement Report ↔ Region 1 standard requirement implementing EPA Strategic Roadmap for PFAS July 2023 ↑ ↓ ↔ More Stringent Less Stringent Report Done; completed This table is part of a presentation. For specifics on effluent limits, monitoring requirements and other permit requirements, please review the Draft Permit. Changes between 2000 Permit and 2023 Draft Permit for Massachusetts Bay outfall (T01) – Whole Effluent Toxicity (WET) Testing Effluent Parameter 2000 Final Permit 2023 Draft Permit Change Reason Whole Effluent Toxicity LC50, % ≥50% ≥100% ↓ Frequency reduced from monthly to quarterly, limit revised to ≥100% to be consistent with MA policy. No exceedances. Whole Effluent Toxicity C-NOEC ≥1.5% ≥1.5% ↔ Frequency from monthly to quarterly, no exceedances; most permittees with dilution between 20.1-100:1 have no chronic limit but retained due to the significance volume of the discharge and its location. Salinity No requirement Report ↔ Current WET testing protocols now apply to MWRA Ammonia Nitrogen No requirement Report ↔ Current WET testing protocols now apply to MWRA Total Cadmium No requirement Report ↔ Current WET testing protocols now apply to MWRA Total Copper No requirement Report ↔ Current WET testing protocols now apply to MWRA Total Nickel No requirement Report ↔ Current WET testing protocols now apply to MWRA Total Lead No requirement Report ↔ Current WET testing protocols now apply to MWRA Total Zinc No requirement Report ↔ Current WET testing protocols now apply to MWRA Total Organic Carbon No requirement Report ↔ Current WET testing protocols now apply to MWRA July 2023 ↑ ↓ ↔ More Stringent Less Stringent Report Done; completed This table is part of a presentation. For specifics on effluent limits, monitoring requirements and other permit requirements, please review the Draft Permit. Changes between 2000 Permit and 2023 Draft Permit for Massachusetts Bay outfall (T01) – Ambient Monitoring Plan Requirement 2000 Final Permit 2023 Draft Permit Change Reason Ambient Monitoring Plan (AMP) Implement monitoring plan • Effluent Monitoring • Ambient Monitoring • Fish & Shellfish Monitoring • Benthic Monitoring Revise AMP to reflect the changes in monitoring requirements ↔ Ambient monitoring plan requirements have been revised to continue water column monitoring during the same target weeks and at the same stations, drop duplicative effluent monitoring, drop fish & shellfish and benthic monitoring as questions have been answered. Enhanced rapid response monitoring for HABs and nuisance algae to address regional changes. • Bays Eutrophication Model (BEM) Update, run and maintain BEM (at least annually) No longer required ↓ BEM is a hindcast model. Continued ambient monitoring and enhanced HABs monitoring will address the concern. • Plume tracking Implement plume track Completed Permit requirement is complete. • Food Web Model MassDEP & EPA to review scope and determined if necessary Requirement met MassDEP & EPA deemed unnecessary • Outfall Monitoring Science Advisory Panel (OMSAP) Conduct peer reviews, evaluate monitoring data and advise EPA and MassDEP; evaluate exceedances of Contingency Plan thresholds No longer a requirement In 2018, OMSAP stated ; “after 25+ years of monitoring, the data show that the MWRA outfall has not adversely affected Massachusetts Bay.” OMSAP also found that the original questions that were the basis for the AMP have been answered. They have encouraged a more regional approach with coordinated monitoring with other major dischargers. • Lobster studies Contaminant monitoring No longer required ↓ Contaminant concentrations considerably less than CP levels. • Red Tide Monitoring Stations OMSAP to investigate the need for additional Red Tide Monitoring stations 2023 Draft Permit includes monitoring and rapid response monitoring for selected HABs ↑ Enhanced rapid response monitoring for Alexandrium, Pseudo nitzschia, Dinophysis, Phaeocyctis, Karenia and Margalefidinium to address regional changes. July 2023 ↑ ↓ ↔ More Stringent Less Stringent Report Done; completed This table is part of a presentation. For specifics on effluent limits, monitoring requirements and other permit requirements, please review the Draft Permit. Changes between 2000 Permit and 2023 Draft Permit for Massachusetts Bay outfall (T01) – Plans and Conditions Plans/Conditions 2000 Final Permit 2023 Draft Permit Change Reason Contingency Plan Implement plan No longer required ↔ Outfall has been found to cause no adverse affects in MA Bay Operation and Maintenance Focus on SSOs, develop guidance for member communities, eliminate excessive I/I, develop Regional I/I Reduction Plan Updated requirements including major storm and flood evaluation & mitigation requirement ↔ Consistent with other MA POTW permits Sludge Conditions 2000 Std. Conditions Updated Std. Conditions ↔ Consistent with existing federal and state laws Development of Limitations for Industrial Users 2000 Std. Conditions Updated Std. Conditions ↔ Consistent with existing federal and state laws Industrial Pretreatment Programs 2000 Std. Conditions Updated Std. Conditions ↔ Consistent with existing federal and state laws July 2023 ↑ ↓ ↔ More Stringent Less Stringent Report Done; completed This table is part of a presentation. For specifics on effluent limits, monitoring requirements and other permit requirements, please review the Draft Permit. Changes between 2000 Permit and 2023 Draft Permit for Massachusetts Bay outfall (T01) – Plans and Conditions, continued Plans/Conditions 2000 Final Permit 2023 Draft Permit Change Reason Best Management Practices Plan Develop & implement Continue to implement ↔ Assurance of compliance with 436 MGD Flow Limit Reports on WWTP flows and water conservation Effluent Limit ↔ Consistent with other MA POTW permits Pollution Prevention Plan Develop, submit & implement Update Household Hazardous Waste booklet and school curriculum to include CECs ↔ Focuses on household hazardous waste education, industrial pretreatment program covers the industrial sources Groundwater Remediation Site Waters Review of prohibition No requirement ↔ Required under MA law July 2023 ↑ ↓ ↔ More Stringent Less Stringent Report Done; completed This table is part of a presentation. For specifics on effluent limits, monitoring requirements and other permit requirements, please review the Draft Permit. Combined Sewer Overflows (CSOs) & CSO Treatment Facilities • MWRA • 4 CSO Treatment Facilities • 6 CSOs • Boston • 27 CSOs • Cambridge • 9 CSOs • Chelsea • 3 CSOs • Somerville • 2 CSOs July 2023 Progress on CSOs Where it started - 1987 • 86 active, uncontrolled CSOs • 3.3 billion gallons of CSO estimated annually • 0% of discharge flows were treated Where are we now - 2023 • 51 CSOs remain • 414 million gallons of CSO annually (87% reduction) • 93% of remaining discharge flows are treated. July 2023 Note: Columns represent the annual volume of CSO discharge flows. Combined Sewer Overflow (CSO) Treatment Facilities: Changes between 2000 Permit and 2023 Draft Permit Effluent Parameter 2000 Final Permit 2023 Draft Permit Change Reason Effluent Flow, MGD Report Report ↔ No change Rainfall/Precipitation Report Report ↔ No change BOD Report Report ↔ No change TSS Report Report ↔ No change Total Residual Chlorine (TRC) 0.1 mg/L avg. weekly, 0.25 max. hourly Specific to each outfall ↑ Consistent with WQS E. Coli (Outfalls MWR201 and MWR205A) No limit 126 cfu/100 mL avg. monthly, 410 cfu/100 mL max. daily ↔ Bring consistent with current MA WQS Enterococcus (Outfalls MWR203, MWR205, & MWR215) No limit 35 cfu/100 mL, 130 cfu/100 mL ↔ Bring consistent with current MA WQS Fecal Coliform Bacteria Shall meet water quality standards No requirement ↔ MA WQS have changed, and indictor bacteria are now E. coli and Enterococcus Whole Effluent Toxicity Report Report ↔ Includes effluent and ambient monitoring in current WET protocols Dye Studies for the CSO Treatment Facility No requirement New requirement ↑ Provide accurate dilution information for future permitting decisions July 2023 ↑ ↓ ↔ More Stringent Less Stringent Report Done; completed This table is part of a presentation. For specifics on effluent limits, monitoring requirements and other permit requirements, please review the Draft Permit. Combined Sewer Overflows (CSOs) EPA’s CSO Control Policy requires communities: • Implement the nine minimum controls • Implement their long-term control plan • Conduct monitoring to verify that water quality standards are being met July 2023 Additional CSO requirements • CSOs hydraulically connected to the Deer Island Treatment Plant are also overseen by the Federal Court as part of the Boston Harbor case. • The Draft Permit authorizes discharges from these CSOs in accordance with the typical year discharge frequencies and volumes that are in Attachment I of the Draft Permit. • The discharges must meet federal and state WQS subject to and consistent with any water quality standards variances issued by MassDEP and approved by EPA. • MWRA and each of the CSO-responsible co-permittees must submit annual reports including information on activation frequency and volumes. July 2023 Co-permittees Co-permittees are municipalities that own or operate sanitary sewer systems that contribute to the Deer Island Treatment Plant. • There are 43 co-permittees that discharge to Deer Island including the CSO-responsible Co- permittees of Boston, Cambridge, Chelsea and Somerville. • Only four sections of the draft permit are applicable to all co-permittees: • Unauthorized Discharges (Section C) • Operation and Maintenance of the Sewer System (Section E) including a major storm and flood events plan. • Alternative Power Source (Section F) • Reporting Requirements (related to the requirements above in Section J) July 2023 Region 1 Co-permittee Background • Region 1 began routinely including co-permittees in Publicly Owned Treatment Works (POTW) permits in 2005 in MA and NH. (The first was MWRA Clinton in 2000 at MWRA’s request.) • Definition of POTW (40 CFR 122.2) includes the collection system • Purpose is to require that all portions of the POTW, including the collection systems that feed the treatment plant are properly operated and maintained. • Provides accountability and enforceability of federal and state collection system operation and maintenance requirements. • Addresses ongoing problems of: • Sewer System Overflows (SSOs) • Infiltration (groundwater) • Inflow (stormwater) • Obstructions (roots, collapses) July 2023 Massachusetts Permit Process • EPA is NPDES permitting authority in Massachusetts. • Until June 2020, EPA and MassDEP jointly issued NPDES permits, and State surface water discharge permits as one document. • Agencies now issue two separate permits. • MassDEP generally incorporates the EPA permit (by reference) into the state permit and, if necessary, adds any state-only requirements. • State draft permit and draft Water Quality Certification can be reviewed at https://www.mass.gov/info-details/massdep-permits-approvals-for- comment . • Comments on the State permit or the Water Quality Certification should be submitted to massdep.npdes@mass.gov . July 2023 presented by David Boyer, MassDEP MassDEP Surface Water Discharge (SWD) Permit Requirements • Incorporates by reference all terms and conditions of the NPDES permit • PFAS testing: • Influent • Effluent • Sludge • All Significant Industrial Users (SIUs) [different from NPDES limited listing]: • Subject to categorical pretreatment standards; OR • Discharges and average of 25,000 gpd or more process wastewater to the POTW; OR • Contributes a wastestream that makes up 5 % or more of average dry-weather hydraulic or organic capacity of the POTW; OR • Designated by the POTW as having a reasonable potential to adversely affect the POTW operation of for violating a pretreatment standard/requirement • All PFAS results (NPDES and SWD) are uploaded to MassDEP database by testing laboratory • Submittal of names and locations of all tested industries (NPDES and SWD) with updating once a year as needed July 2023 presented by David Boyer, MassDEP Contacts: EPA Contact: Michele Barden barden.michele@epa.gov or 617-918-1539 MassDEP Contact: Claire Golden Claire.Golden@mass.gov or 617-997-8874 submit comments to: massdep.npdes@mass.gov July 2023