mdfw hatchery npdes program ken simmons chief of hatcheries/trout project leader
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MDFW Hatchery NPDES ProgramKen Simmons
Chief of Hatcheries/Trout Project Leader
MDFW HATCHERIES
• Sandwich Hatchery (1912) -Trout*• Sunderland Hatchery (1913) - Trout*• Palmer Hatchery (1914) - Atlantic salmon• Montague Hatchery (1917) - Trout*• McLaughlin Hatchery (1969) - Trout*
*NPDES permit required
NPDESFour MDFW Trout Hatchery
Permits Renewed in Past Year
• Observations on the process
• Formalin
Discuss Today
Impact on Hatchery Operations
• Discharge limits were not substantially changed
• Frequency of effluent sampling was reduced
• Effluent sampling quarterly and only during major cleaning operations
continued
Impact on Hatchery Operations
• Increased use of settling pools at 3 older DFW facilities
• Reduced production at 3 older facilities
• Greatly altered operations at 3 older facilities
• Formalin use all but eliminated at 3 older facilities
Impact on Pounds of Trout Produced
Old Permit Current Permit
McLaughlin 225,000 225,000
Sunderland 115,000 90,000
Montague 90,000 80,000
Sandwich 62,000 50,000
Effluent Monitoring
• Flow• BOD• TSS• pH• Dissolved oxygen• Total ammonia
nitrogen, as N*
• Residual chlorine*• Total phosphorous*• Formaldehyde• Whole Effluent
Toxicity - chronic**• Whole Effluent
Toxicity - acute**
*Not at all facilities **New to current permit
Effluent Sampling
• Quarterly (except pH, formalin & chlorine)
• Three of the quarterly samples must be taken when conducting pool breakdown and/or settling pool or quiescent zone cleaning
• One quarterly sample must be taken during annual pool breakdown/cleaning
• Composite samples -- 1 per hour for 8 hours
Formalin Use• Discharge limit of 0.74
mg/l (formaldehyde) at all facilities
• Developed formalin use plan for each hatchery as part of B.M. P.
• Do not know if it will work except at McLaughlin Hatchery
Formalin Use Problems
• 0.74 mg/l limit effectively eliminates use at 3 of 4 facilities due to flow patterns and dilution factors
• Difficult to retain a certified lab that can analyze formaldehyde with E.P.A. methods on short notice
• W.E.T. tests - labs to conduct work on short notice
• Cost of tests
Whole Effluent Toxicity (%) Acute (invertebrates only)
AverageMonthly
Max.Daily
FrequencyMeasured
SampleType
MAC Acute LC50 > 100% * Comp.
SUND Acute LC50 > 100% * Comp.
MONT Acute LC50 > 100% * Comp.
SAND Acute LC50 > 100% * Comp.
*If formalin is used
Whole Effluent Toxicity (%) Chronic (invertebrates only)
AverageMonthly
Max.Daily
FrequencyMeasured
SampleType
MAC Chronic C-NOEC > 100% * Comp.
SUND Chronic C-NOEC > 100% * Comp.
MONT Chronic C-NOEC > 100% * Comp.
SAND Chronic C-NOEC > 100% * Comp.
*If formalin is used
My Thoughts
• Agency must play an active role in the process
• Develop & maintain a professional working relationship with the regulators
• Be honest and forthcoming with information
• Do not hesitate to ask questions or seek clarification of issues
• Exercise your right to seek change and/or clarification of pre-public draft permits
• Tremendous amount of work involved
Summary
• We do not yet know if we will be able to meet new effluent limits at all stations but have developed BMP’s with that goal
• Formalin use at 3 of 4 hatcheries is all but impossible
• Formalin use at McLaughlin Hatchery is feasible but with constraints
Thank You
FLOW (MGD)
AverageMonthly
Max.Daily
FrequencyMeasured
SampleType
MAC 7.0 8.1 Cont. Rec.
SUND 1.17 1.68 Daily Instan.
MONT 1.4 1.55 Daily Instan.
SAND 1.4 1.6 Daily Instan.
BOD (mg/l)
AverageMonthly
Max.Daily
FrequencyMeasured*
SampleType
MAC 5 10 Quart. Comp.
SUND 5 10 Quart. Comp.
MONT 5 10 Quart. Comp.
SAND 5 5 Quart. Comp.
*During cleaning operations
TSS (mg/l)
AverageMonthly
Max.Daily
FrequencyMeasured*
SampleType
MAC 10 10 Quart. Comp.
SUND 10 10 Quart. Comp.
MONT 10 10 Quart. Comp.
SAND 10 10 Quart. Comp.
*During cleaning operations
Total Phosphorous (mg/l)
AverageMonthly
Max.Daily
FrequencyMeasured*
SampleType
MAC *** 1.0 Quart. Grab
SUND *** Report Quart. Grab
MONT *** Report Quart. Grab
SAND None None None
*During cleaning operations ***No limit issued
Total Ammonia Nitrogen, as N (mg/l)
AverageMonthly
Max.Daily
FrequencyMeasured*
SampleType
MAC 4.2 *** Quart. Comp.
SUND None None None
MONT None None None
SAND 6 10 Quart. Comp.
*During cleaning operations ***No limit issued
Total Residual Chlorine (ug/l)
AverageMonthly
Max.Daily
FrequencyMeasured
SampleType
MAC None None None
SUND None None None
MONT None None None
SAND 7.5 13 If used Grab
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