the wisconsin section water environment association agenda...
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The Wisconsin Section
Central States
Water Environment Association
Agenda
Wisconsin Section CSWEA August Board Meeting
August 10, 2016
2:30 PM
Global Water Center - 6th Floor Conference Room, Milwaukee, WI
Chair Jay Kemp called the Wisconsin Section of Central States Water Environmental
Association board meeting to order at 2:30 PM on August 10, 2017 at the Global Water
Center in Milwaukee, WI
Board Members Present:
• Jay Kemp, Chair
• Troy Larson, Vice Chair
• Jon Butt, Treasurer
• Veronica Loete, Secretary
• Dan Zitomer, Trustee
• Jeremy Cramer, WWOA Liaison
Members Present:
• Dave Arnott
• Mark Van Weelden
• Mark Mittag (phone)
• Alan Grooms (phone)
• Glenn Tranowski (phone)
1. Introduction of Those Present
Attendees introduced themselves and indicated CSWEA involvement
2. Approval of Minutes of May 2017 Winter Business Meeting
Motion to approve as presented: motion passed.
3. Treasurer’s Report
Jon Butt presented the Treasurer’s report, which showed a balance in the
Section’s accounts of $10,242.84 as of 8/10/2017. Of this amount, -$135.89 was
in the checking account, $10,378.73 was in the savings account.
Motion to approve as written: Troy Larson, second: Dan Zitomer, motion passed.
Verbal report: Money is expected to come in from the Spring Biosolids
Symposium. The transition from Eric Lynne to Jon Butt as treasurer is pretty
much complete. Jon plans to explore options for different types of bank accounts
with fewer fees.
4. Trustee’s Report
Trustee Dan Zitomer provided a written report, see attached packet.
5. WWOA Liaison’s Report
WWOA Liaison Jeremy Cramer provided a written report, see attached packet.
6. Committee & Representatives Reports
a. Collection System – Wegner
Amy Post provided an email report to Jon Butt that will be added to the
meeting packet.
b. Government Affairs – Boersma
Committee Chair Paul Boersma provided a written report, see attached
packet.
Meeting attendees expressed interest in hearing more about the impacts
from the REINS Act.
c. Industrial Waste – Kemp
Committee Chair Jay Kemp provided a verbal report. Pretreatment
seminar will be held on 8/15/17. At the time of the meeting, 69 attendees
were registered included speakers and committee members. The group
may reconsider their policy of waiving seminar fees for committee
members.
d. Membership – Fisher
Committee Chair Autumn Fisher provided a written report, see attached
packet.
e. Operations – Cramer
Committee Chair Jeremy Cramer provided a written report, see attached
packet.
f. Management Seminar – Haack
Claudia Haack provided written report, see attached packet.
g. Public Education/Awareness – Yoshida
No report provided.
h. Watershed and Stormwater – Mittag
Committee Chair Mark Mittag provided written report, see attached
packet.
i. Young Professionals and Students Committees – Van Weelden
Committee Chair Mark Van Weelden provided written report, see
attached packet.
j. Spring Biosolids Symposium –Marten
Committee Chair Bill Marten provided written report, see attached
packet.
7. Old Business
a. None
8. New Business
a. Discussion of July’s CSX Meeting. At the meeting the group, brainstormed
a revised schedule for the CSWEA Annual Meeting that may be
implemented.
b. The November Annual Business meeting was scheduled for 11/14 at 2:30
PM following the Watershed and Stormwater Webinar.
Post-meeting update: The Annual Business meeting will occur on 11/9 at
2:30 PM, but the webinar remains on 11/14.
c. It was pointed out that the WI Section Policies and Procedures were
previously revised and are not posted to the CSWEA website. Veronica
Loete to investigate.
9. Upcoming Events
• Pre-Treatment Seminar – Oshkosh, WI – August 15, 2017
• WEFTEC 2017 – Chicago, IL – October 1-4, 2017
• WWOA Annual Conference – Middleton, WI – October 17-20, 2017
• Wisconsin Section Board Meeting and Stormwater Webinar – Milwaukee,
WI – November 14, 2017
• Operations Seminar – Madison, WI – October 31, 2017
10. Adjourn
There being no further new business
Motion to approve and adjourn: Jon Butt, second: Troy Larson. Motion
passed.
Meeting adjourned at 3:55 pm
Respectfully Submitted:
Veronica Loete
Secretary
Wisconsin Section - CSWEA
Board Member Assigned Committee
Chair Students and Young Professionals
Trustee Watershed Management and Government Affairs
Past Chair Membership and Public Education & Awareness
Vice-Chair Collection Systems and Industrial Wastes
WWOA Liaison Operations and Safety
The Wisconsin SectionCentral States
Water Environment Association
BALANCE ON HAND AS OF 05/24/2017 $24,527.38
Receipts :Check Income from CS Classic Registrations $560.00Check and cash income from CS Classic Registrations $1,780.00Check Income from CS Classic Registrations $40.00Creative Advertising Specialties Sales Tax reimbursement $123.05 Pending
Interest Paid on Savings $2.20
TOTAL RECEIPTS $2,505.25
Disbursements :Eric Lynne Reimbursement for CS Seminar Gift Cards (50% classic/50% northwoods) (W11) -$500.00Turner Hall Payment for 2017 CS Classic Catering (W12) -$7,849.25Creative Advertising Specialties Payment for 2017 CS Seminar Attendee Gifts (classic) (W13) -$1,789.98Creative Advertising Specialties Payment for 2017 CS Seminar Attendee Gifts (northwoods) (W13) -$745.83Showcase Awards Payment for 2017 Awards (W14) -$237.00Tom Mulcahy Marquette Student Baseball tickets (W15) -$175.00
City Press Graphic Communications Pretreatment seminar flyer (W16) -$1,534.19City Press Graphic Communications Postage (W16) -$347.55Eagles Payment for Northwoods CS seminar food (W17) -$2,587.19 PendingAaron Berry Reimbursement for student registration (W18) -$80.00 PendingWEF Reimbursement for student airfare -$943.80 Pending
TOTAL DISBURSEMENTS -$16,789.79
BALANCE ON HAND AS OF 08/10/2017
Checking Account Balance -$135.89Savings Account Balance $10,378.73
TOTAL $10,242.84
Respectfully Submitted,
Jon ButtJon Butt DateTreasurer
8/10/2017
Wisconsin Section – CSWEAMay 24, 2017 to August 10, 2017
$10,242.84
Treasurer's Report
RECONCILIATION OF STATEMENT BALANCES
The Wisconsin Section
Central States
Water Environment Association
PAGE 1
Wisconsin Section CSWEA
Committee Reports
August Board Meeting
Global Water Center, Milwaukee, WI
August 10, 2017
4) Trustee’s Report – Dan Zitomer
CSWEA held the annual CSX meeting on July 20-21 at the Kalahari Resort in Wisconsin Dells. Updates
from all state sections and CSWEA committees were presented. The major discussion pertained to
retooling of the annual meeting. The attached, draft annual meeting schedule reconfiguration was
constructed (See next page). Please provide any input regarding the draft annual meeting schedule
to Dan Zitomer.
5) WWOA Liaison’s Report – Jeremy Cramer
OPERATOR’S COMPETITION: An Operator’s Competition will be held at the 2017 WWOA Annual Conference. The Board of Directors hopes to see at least one team compete from each region. Please let Rick Mealy, Committee Chair, know if you have any questions, concerns, or ideas regarding the Operator’s Competition. [email protected] CLARIFIER: Submit articles for the Clarifier for the September issue by August 11th to [email protected]
TUITION REIMBURSEMENTS AND SCHOLARSHIPS: As a reminder, the WWOA offers six $150 tuition reimbursements annually. The tuition reimbursements are on a first-come, first-serve basis. There are also three $1000 scholarships and a $5000 scholarship available. Application information and forms are located on the WWOA website.
WWOA BOARD OF DIRECTORS MEETING: The next WWOA Board of Directors meeting will be held at the Marriot in Middleton on Monday, October 16th.
WWOA Annual Conference: The WWOA will hold its 51st Annual conference on October 17-20th 2017 at the Marriott Madison West in Middleton.
WWOA name change discussion: The Wisconsin Wastewater Operators’ Association has been discussing a possible name change for the organization. A possible name change that is more reflective of resource recovery is being discussed by the Board of Directors and the entire membership. The Board of Directors will listen to input from the membership and gauge the level of interest in making a name change.
PAGE 2
WWOA Annual Conference Technical Program: The Technical Program will again include a presentation/discussion on “Tricks of the Trade.” The presentation committee is soliciting tricks and tips from members. Members are invited to submit their tricks and tips to be included in the presentation to Troy Larson at [email protected]. The Tricks of the Trade committee will assist contributors in presenting a series of short stories illustrating lessons learned. Assistance for contributors will vary as necessary to promote the sharing of ideas and may include presenting on their behalf.
UPCOMING EVENTS:
DATE
EVENT
LOCATION
August 15, 2017 Southern Region Summer Meeting Lone Rock, WI August 17, 2017 September 14, 2017 October 17-20, 2017 October 27, 2017 December 14, 2017
Lake Michigan Summer Meeting Southeast Fall Meeting WWOA 51st Annual Conference Northwest Fall Meeting Lake Michigan Year End Meeting
New Holstein, WI Elkhart Lake, WI Middleton, WI Cumberland, WI Shawano, WI
6) Collection Systems – Amy Post, Chair
No report submitted in this packet.
Government Affairs – Paul Boersma, Chair
To: Veronica Loete - Secretary Wisconsin Section
From: Paul Boersma, Government Affairs Committee Chair
Date: August 7, 2017
Subject: Government Affairs Committee Report
The primary focus of the Government Affairs Committee (GAC) is to identify and track various
regulatory/legislative initiatives that may have a significant impact on Wisconsin Section
members, including federal initiatives that will impact Wisconsin. Following are brief summaries
prepared by individual committee members in the areas of recent interest. In addition, we have
updated the committee since the May 2017 report and the current committee is as follows:
Chair: Paul Boersma, Black & Veatch
Vice-Chair: Chris Tippery, Symbiont
Jim Kleinschmidt, Baxter & Woodman
Brent Brown, CH2M Hill
Jane Carlson, Strand Associates
Allen Williams, Donohue & Associates
Joan Hawley, Superior Engineering (Mentor)
Paul Kent, Stafford Rosenbaum
Brandon Koltz, Brandon Koltz Water & Environmental Consulting LLC
Tyler Linton, Great Lakes Environmental Center
Drew Suesse, Madison MSD
Kathy Lake, Madison MSD
PAGE 3
Regulatory and Other Initiatives Updates Committee is Tracking
General Wisconsin Legislative Updates (wide variety) - Jim Kleinschmidt/Baxter Woodman
REINS Act (Senate Bill 15-to be signed by Governor on August 9, 2017). Both the Assembly
(June 14, 2017) and Senate (May 2,2017) have passed the REINS act. Governor Walker was set
to sign the bill on August 9. This bill requires that if an economic analysis of a regulation
indicates a cost of more than $10,000,000 over a two year period it will require a specific bill to
authorize the regulation unless the agency reduces the project costs to under the $10,000,000
over a two-year period threshold. The economic analysis can be ordered either by the chairs of
the Joint Committee on Rules and Regulation or the DOA. DOA must approve of the results of
the economic analysis before promulgation may continue. If the costs are more than
$10,000,000 in two years, then there needs to be specific legislative authorization for the rule.
Also, the Dairy Business Association has filed suit against DNR alleging that DNR does not have
the authority to regulate CAFOs unless they can document pollution.
Nutrient Criteria (Designated Uses, Biocriteria, Site Specific Limit for P, Total Nitrogen)
• Jane Carlson, Strand Associates
• Tyler Linton, Great Lakes Environmental Center
• Jim Kleinschmidt, Baxter & Woodman
Wisconsin Nutrient Reduction Strategy Update. The WDNR recently published a biennial update
to the statewide Nutrient Reduction Strategy. The strategy was published in 2013 partly in
response to Gulf of Mexico hypoxia and the nationwide goals of a 45% reduction in total
nitrogen and phosphorus loadings to the Mississippi River. The biennial update can be found
here: http://dnr.wi.gov/topic/surfacewater/nutrientstrategy.html. The update indicates there
has been substantial implementation of the strategy through existing point and nonpoint
source control programs. In particular:
• 85% of WPDES permits have been reissued with phosphorus limits based on the 2010
criteria
• Adaptive management or water quality trading is being pursued by 13 permittees and
many more are considering these compliance options
• There has been an 11.4% reduction in phosphorus discharged by point sources between
2013 and 2015
• 32 percent of cropped acres have nutrient management plans
• There are 15 farmer-led watershed groups and more are being planned
• Phosphorus is still the most frequent cause of impairment in surface waters
There is still no mention of total nitrogen water quality standards for Wisconsin’s surface
waters, although groundwater nitrate is a high priority being addressed statewide.
PAGE 4
National Study of Nutrient Removal and Secondary Technologies. Last fall we reported that the
USEPA had placed on public notice a Draft Screener Questionnaire it intended to send to all
publicly owned treatment works (POTWs) to determine if the POTWs are capable of
“optimizing” their treatment processes to incorporate or improve nutrient removal. The
questionnaire appeared to be part of a USEPA initiative to incorporate nutrient reduction
requirements into the definition of secondary treatment. CSWEA and several other
organizations submitted substantial comments on the draft. The USEPA indicated it revised its
questionnaire in response to public comments. It appears this initiative is now on hold,
according to a June 2017 update here: https://www.epa.gov/eg/national-study-nutrient-
removal-and-secondary-technologies.
TMDLs - Allen Williams/Donohue and Associates & Brent Brown/CH2M
The DNR has scheduled a Upper Fox and Wolf River (Lake Winnebago) TMDL stakeholder
meeting for Wednesday, August 23, 2017 at the Winnebago County Coughlin Building in
Oshkosh, WI (625 E. County Road Y, conference rooms A & B). The meeting times have not
been established and agenda/handouts have not been provided yet. There are planned to
morning presentations on the watershed (SWAT), lake, and Lake Winnebago pool lake
modeling. It is uncertain if draft allocations will be shared. There may be afternoon meetings
that could include workgroups, and question/answer. Keith Marquardt/DNR is the DNR lead for
the TMDL.
Stormwater (Waters of the U.S, NR 151, Phase II Stormwater Rule) Paul Boersma/B&V
No report
CMOM and Wet Weather Updates - Drew Suesse/Madison MSD
The WI DNR has issued a revised form for sanitary sewage overflow (SSO) reporting. Form 3400-
184 (R 7/17) will replace the previous version (R 11/13), which will no longer be accepted after
December 1, 2017. The new form has been simplified, and incorporates data fields for ease of
entering information. DNR will continue to receive completed SSO notification reports via email
or hardcopy, but will be looking to transition to an electronic submittal in upcoming years.
CMOM overflow emergency response plans should be updated to reflect this revision.
Chloride Variance - Cathy Lake/Madison MSD
In 2014, DNR’s Recommendations for Pollutant Minimization Plans and Source Reduction
Measures for Arsenic, Chloride, Copper and Mercury Variances was approved by DNR. This
document provided guidance for the development and reporting for PMP and SRM’s and
focused the type of information to be included in the application and reports. For Variance
holders, this has meant developing PMPs and annual reports that follow the new DNR format.
On August 21, 2015, EPA adopted 40 CFR 131.14 which gave explicit authorization and
regulatory requirements for states and tribes to adopt water quality standard variances;
facilitate appropriate, consistent and effective implementation and to be transparent to both
the regulated community and the public. While Wisconsin previously had guidance on variances
(s. 283.15), many other states did not. Because the implementation of DNR’s variance
procedures predated the changes to 40 C.F.R. 131.14, there are elements of DNR’s current
PAGE 5
variance procedures that are in conflict with the new EPA regulations. DNR is in discussions
internally and with EPA regarding how DNR’s current variance procedures may or may not
change to reflect the 2015 EPA rule revisions.
Wisconsin DNR Thermal Rules Revisions (NR 102 and NR 106) - Jim Kleinschmidt/Baxter
Woodman
No report
Recreational Criteria /Other Water Quality Criteria - Brandon Koltz
No report
Air Standards - Chris Tippery/Symbiont
No report
Rule Packages 3 and 4 - Vacant
Ammonia Limits - Tyler Linton/Great Lakes Environmental Center
No Report
Great Lakes Issues - Vacant
Total Nitrogen Criteria - Jane Carlson/Strand
See above.
Anti-Degradation - Paul Kent
No Report
Multi-discharger Variance for phosphorus compliance (Wis. Stat. s. 283.16) - Jim Kleinschmidt
Multi-Discharge Variance (Kathy Lake) On February 8, 2017, the Guidance was issued on
Wisconsin’s Multi-Discharger Variance (MDV) for phosphorus. DNR developed a fact sheet that
accompanies their guidance and is available here. This is a unique variance in the state which
allows eligible facilities to pay for excess phosphorus discharge for a period of up to 20-years.
The funding transfers to Land Conservation Departments or other organizations who commit to
use it to reduce phosphorus from entering local water bodies. At the end of the MDV period,
the facility is required to meet the water quality standard.
The first Multi-Discharger Variance has been public noticed (Jim Kleinschmidt). The variance is
for Ellsworth Co-op Creamery and will use the county payment option. The economic
justification for the variance was basically a two-stage filtration process at a cost of $2,500,000
with the threshold for Dairies put at $1,500,000 which is the primary screener. There are
several other applications which have been made for the Multi-Discharger Variance. In
addition, there are also a few variance requests that have been filed for an individual economic
variance but none have been approved as of August 2, 2017.
PAGE 6
Water Infrastructure Financing - Vacant
Tracking Proposed Federal Funding Changes to EPA - Brandon Koltz
WEF Government Affairs Committee continues to track regulatory changes and proposed
budgetary issues. The letter WEF sent for regulatory changes to meet the “2 for 1” executive
order is attached. We are also watching as the USEPA budget (and USDA and USGS/Dept. of
Interior) are developed in the FY2018 budget. The proposal to cut USEPA funding significantly,
including about 1/3 staff reductions and defunding certain programs such as the Great Lakes
Restoration Initiative are still in the draft budget. WEF is closely tracking, will comment and ask
the MAs to provide additional comments as the specifics are made available. SRF would remain
funded at the FY 2017 level, but we are closely watching for any reductions in support for state
regulatory agencies. The Clean Water Rule/Waters of the United States was withdrawn, but will
be re-proposed based on the “Scalia” opinion. WEF GAC will be tracking this as it is drafted and
will engage the MAs for comment as well. Be prepared to provide a quick turnaround with
comments as these issues are advanced.
Industrial Waste – Jay Kemp, Chair
No report submitted for this packet
Membership Committee – Autumn Fisher, Chair
To: CSWEA Wisconsin Section From: Autumn Fisher, Membership Committee Chair RE: Committee Report for the Quarterly Business Meeting of the Wisconsin Section Date: August 10, 2017
The welcome letter was emailed to 13 new members during this quarter. I received no responses/inquiries from new members but this effort will continue in an attempt to engage members early in their membership and encourage their participation in their respective interest areas. The membership committees are contemplating sending a membership survey to evaluate how members rate their membership, see what they want to improve, what they like/dislike etc. It has also been suggested we may be better suited conducting interviews with a handful of selected members. Additionally, we will be evaluating how to better engage the smaller (<5 MGD) facilities and as always we are open to ideas/suggestions. At the current time, the membership committee has 3 members: Autumn Fisher, Jon Butt, and Dan Zitomer. Thank you, Autumn Fisher
Operations Committee – Jeremy Cramer, Chair
The operations committee has been active putting together the Operations Seminar that will be held on October 31st in Madison. The Seminar will have a focus on Energy/Resource Recovery.
PAGE 7
The seminar program is close to being finalized. It date is posted on both the WWOA and CSWEA websites.
Management Seminar – Claudia Haack, CSWEA Contact
Committee Information
Barb Scheiber with Donohue Associates is chair this year.
CSWEA contact – Claudia Haack – Madison MSD [email protected]
Place/Date
August 9, 2017
Hilton Garden Inn, Park Place
11600 W Park Pl, Milwaukee, WI 53224
Registration
WI section of AWWA handles the registration. Registration is still possible.
Online registration at: http://www.wiawwa.org/events/EventDetails.aspx?id=974625
Registration count as of Monday, July 31: 53
Public Education and Awareness – Hiroko Yoshida, Chair
No report submitted for this packet
Watershed and Stormwater Committee – Mark Mittag, Chair
Quarterly Teleconference Agenda – July 31, 2017 - Noon Meeting Notes are provided in italic. Attendees: Mark Mittag, Glenn Tranowski, Diane Figiel, Jim Bachhuber, Julie McMullin, Bill Hafs, Jennifer Hurlebaus, Brandon Koltz. Jane Carlson, Jon Lindert. Andrew Skog, Rusty Schroedel.
A. Review Upcoming Webinar 1. Current Status (November 14, Global Water Center, webinar hosting)
Mark Mittag provided an update on the webinar planning. UW-Milwaukee will not be providing the webinar hosting service this year. CSWEA has indicated an interest in providing the web hosting service.
2. Content – your ideas of what members would find informative and timely. The Committee reviewed potential webinar topics. Potential ideas include:
• Milwaukee MSD: green infrastructure sizing, CRPP watershed partnership to reduce
phosphorus runoff in agriculture, GI center of excellence
• Madison Yaharra WINS update with topic such as bmp performance
• NEW Water: watershed tools for adaptive management verification tools
• Yaharra WINS: Dredging sediment to remove legacy phosphorus
• Madison MSD, SEWRPC, or others: chlorides
• Waters of the US update (Clean Rivers, Clean Lake conference had presentations
from Marquette, SEWRPC, and Milwaukee River Keeper)
PAGE 8
• Watershed water quality trading
• Glenn Tranowski noted that the Wisconsin Nutrient Reduction Strategy has been
recently updated and could also be a webinar topic.
3. Sub-committee formation to work out topic details
Mark, Glenn, Brandon, Julie, Jon and Travis agreed to be part of the watershed webinar planning sub-committee. Glenn recommended getting the announcement in the CSWEA newsletter and WWOA calendar. Julie McMullin indicated that the GI tour at the annual meeting was very well received. The goal is to have similar GI tours at each annual meeting. Illinois in 2018 and Madison in 2019: Send any Illinois 2018 tour ideas to Julie. The annual meeting is scheduled to be at Drury Land and the GI tour locations should be within 30 minutes of the conference location.
B. State Watershed and Stormwater Activity Updates 1. NE Wisconsin Activities
Bill Hafs provided an update: The Silver Creek adaptive management project is in it’s 3rd year. Great process has been made year over year in cover crops with winter cover crop coverage increasing from 35 to 70 percent cover. Phosphorus total pounds removed has met expectations. TSS reduction has greatly exceeded expectations. NEW Water received a Fund for Lake Michigan grant to purchase an inter-seeder which has been donated to Brown County for use. NEW Water is progressing on a required phosphorus preliminary compliance plan. NEW Water is considering full scale adapative management. Will be considering how MS4 communities could be part of the process down the road into implementation. Jim Bachhuber reported that there is an Upper Fox TMDL meeting scheduled for August 23.
2. Madison/Rock River Activities Jane Carlson provided an update: Rock River Recovery has been processing with a focus upon working toward getting farm participation. Jon Lindert: Reported Yaharra WINS is testing out manure injection procedures. Dane County is working on implementing a hydraulic dredging for removing legacy phosphorus. Jim Bachhuber: provided an update on the WDNR leaf management phosphorus credit evaluation. The league of municipalities has an effort to fund two studies in separate cities to provide additional information to the WDNR effort. The funding to participate is $2k per city. There is still time to be part of the study. Jim will send out the city participation list to the committee to share and inform cities of the opportunity to participate. Looking for cities to commit to participating by the end of 2017 with the study implementation in 2018.
3. SE Wisconsin Activities Brandon Koltz: Southeastern Wisconsin Watersheds Trust will be providing TMDL implementation plan development for the Milwaukee watershed TMDL. Brandon is serving on a sub-committee looking into the bacteria control prioritization. MMSD is implementation a GI Center of Excellence
PAGE 9
MMSD is providing a GI presentation on the recently completed GI Design and Specification Templates.
4. Western Wisconsin Activities No specific update. Andrew Skog provided an update: Broadhead is planning on implementing a water quality trading project focused upon streambank stabilization.
5. Wisconsin River Activities Jon Lindert provided an update: Not a lot of recent information on TMDL schedule has been provided on the Wisconsin River TMDL. The project is taking longer than originally planned.
6. Other Activities Glenn Tranowski noted that the Wisconsin Nutrient Reduction Strategy has been recently updated and could also be a webinar topic.
C. Regulatory Issues Update
a. External Advisory Committee on Water Quality Standards
The site specific criteria WDNR effort is on hold. Mark will check into the latest status.
Brand Koltz mentioned the Foxconn announcement as published in recent news is reported
to include WDNR waivers for fill in waterways, wetlands, and other traditional
environmental requirements in Wisconsin. This is something to follow as it unfolds to
understand how it might apply to other future projects.
D. Other Topics of Interest 1. Identify Vice Chair by November Business Meeting. Chair and Vice Chair
responsibilities listed in link below: Please approach Mark Mittag if you have an interest in becoming the vice-chair. http://cswea.org/WISCONSIN/guidance/Committee%20Guidance%20Manual.pdf
E. Next Meeting Day and Time (tentatively Monday, October 30, 2017 at noon)
Young Professionals and Students Committee – Mark Van Wheelden, Chair
Roles for 2017/2018 Year
Chair = Mark Van Wheelden
Student Vice Chair = Kevin Berg
Young Professional Vice Chair = Allen Williams,
Committee members = Sam Austin, Dave Diehl, Ryan Holzem
Young Professional Section Updates: Recent Events: -May 30: Kenosha WWTP Tour – Very successful tour of the Kenosha WWTP with a highlight of their recent biosolids handling upgrades. We had a small social at a local tavern afterwards.
PAGE 10
-July 28: Annual YP Brewers Outing – Great turnout for the Cubs vs. Brewers game. We grilled out, played yard games, and networked with students and professionals.
Goals and Ideas for Upcoming Events:
-Brainstorm ideas for a service-oriented event for the YP’s. -Plan a small event focused on students to increase engagement (i.e. presentation/seminar) -Increase social media presence, possibly delegate this to a committee member.
-Explore opportunities to collaborate with other YP groups from other professional
organizations
-Get more YPs to join the YP committee. Look for opportunities to reach out to young
operators.
-Encourage students and YPs to investigate opportunities available in Global Water
Stewardship.
Student Section Updates -Marquette students attending the CSWEA Brewer Outing were funded by Students Committee budget. -Contact planned with local universities as school year begins. Looking to get people interested in involved in Student Design competition earlier this year. -Student design competition information expected in October/November, similar to previous years. -Continued difficulty in fully engaging student interest. Interest seems sporadic and limited to on-campus events similar to UW-Platteville’s student/professional event held last spring.
Goals and Ideas for Upcoming Events:
-Work with existing chapters to set up meetings and increase involvement -Work with interested groups to develop a chapter and get them involved -Follow up with student leadership and compile list of involved members -Establish CSWEA mentor relationship with student chapters to provide local support and continued contact. Major speedbump in this area is annual continuity between students (yearly leadership turnover), CSWEA committees (relatively high turnover), and CSWEA members (low turnover but currently low involvement).
PAGE 11
-Calling professors and asking questions (email is not working)
-Plan an event with a larger organization (i.e. ASCE, AWWA) to see if those students would be interested in CSWEA
Spring Biosolids Symposium – Bill Marten
The 36th Annual Spring Biosolids Symposium will be held on Tuesday March 20, 2018, again at the Holiday Inn Convention Center in Stevens Point. The Symposium is jointly sponsored by the Wisconsin Section and WWOA, with WDNR a contributing organization. The three organizations rotate chairs annually, and WWOA will be chairing the 2018 event.
The Symposium planning committee is planning to meet later this month to start planning next year’s event. The planning committee consists of:
• Kim Meyer/Madison MSD
• Lyle Lutz/Plover
• Don Lintner/New Holstein
• Brian Kreski/Appleton
• Karen Harter/WWOA Secretary
• Fred Hegeman/WDNR
• Alan Kaddatz/Pat’s Hauling
• Mona Johnson/Bytec Resource Management
• Glenn Tranowski/Strand
• Bill Marten/Donohue Glenn and I are the CSWEA Wisconsin Section representatives. Glenn replaces Jay Kemp, who was a long-time committee member.
7/21/17
1
5
CSWEA AM SCHEDULE
Day AM PM EVENING1 Ex Com Mtg
YP AcademyGolf Outing Plant Tour SW Tour
Meet & Greet
2 Opening Session Tech Sessions Exhibits
Tech Sessions Exhibits / Lunch Exhibitor Reception
Social
3 State Section Mtgs Tech Sessions Exhibits
Association Luncheon Tech Sessions
Awards Banquet
4 Ex Com Mtg
6
REVISED AM SCHEDULE
Day AM PM EVENING1 ExComMtg
(Combined)SpecialtyTrack(10am)
SpecialtyTracks/WorkshopsPlantTour/SWTour/GolfDiversity/YP/LeadershipTrack7SMeeting
Meet&Greet/Social
2 NoOpeningSessionTechSessions(8am)Exhibits5K/Yoga(6am)
TechSessionsExhibits(OnlyTime–1hr)AssociationLuncheon(7S)BusinessMtg
AwardsBanquet
3 StateSectionBfstTechSessionsExhibits
TechSessions+EthicsExhibitorLunchExhibits(OnlyTime–1hr)VendorShowcase
NOTHINGTravelTime
4 NOTHING NOTHING NOTHING
1
May 15, 2017
Water Docket U.S. Environmental Protection Agency Docket No. EPA-HQ-OA-2017-0190 VIA PORTAL RE: Evaluation of Existing Regulations, Docket No. EPA-HQ-OA-2017-0190
The Water Environment Federation (WEF) thanks the U.S. Environmental Protection Agency (EPA) for the opportunity to comment on the proposed Evaluation of Existing Regulations, Docket ID No. EPA-HQ-OW-2016-0353. WEF is a not-for-profit association that has provided technical education and training for the world’s water quality professionals since 1928. The Federation has over 33,000 individual members and 75 affiliated Member Associations who support its mission to preserve and enhance the global water environment. WEF is supportive of regulations that are science based, achievable, and protective of human health and the environment. Comments Summary There are opportunities to reduce, revise, or improve existing regulations and implementation thereof based on our review of the Executive Order. We have identified the following issues that EPA should take into consideration with respect to lessening the burden of implementing existing or considering future regulations. In each case, we set forth our recommendation as to how EPA should address the concerns. In addition, WEF supports the continuous focus on good science and the preservation of programs that maintain EPA’s data gathering efforts. WEF further supports an improved collaboration with stakeholders of which includes WEF, state agencies, along with the regulated communities in the rulemaking and implementation process.
SPECIFIC PROPOSED MATTERS FOR EPA CONSIDERATION National Pollutant Discharge Elimination System (NPDES): Applications and Program Updates General Permit Remand On May 18, 2016, the EPA proposed regulations that would update specific elements of the existing National Pollutant Discharge Elimination System (NPDES) regulations, targeting revisions to outdated application, permitting, monitoring and reporting requirements to eliminate inconsistencies between regulations and application forms, improve permit documentation and transparency, and clarify existing regulations.
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WEF believes that this proposed rule would create a serious inconsistency and undue burden, in particular, §122.45 allowing the calculation of NPDES effluent limitations based on other-than-design flow for publicly-owned treatment works (POTWs); and §123.44, EPA review of and objections to State permits whereby an administratively continued State permit could be designated as ‘‘proposed’’ after either a two-year or five-year period following the expiration of the initial five-year permit term, at which time the permit would be evaluated and decided upon by EPA. WEF refers the EPA to the comment letter submitted under Docket No. EPA–HQ–OW–2016–0145 on August 2, 2016. Relevant to the EPA’s thoughts expressed in the proposed modification to §123.44, and specific to §122.46, WEF wishes the EPA to consider expanding the term of the NPDES permit from 5 years to longer terms when necessary. Wastewater agencies, most of whom are NPDES permittees, face increasingly restrictive requirements that push the limits of technology and local agency budgets. The current Clean Water Act mandate to renew complex permits every five years represents a perpetual “moving target” that achieves very little in the way of water quality benefits. Given this reality, local agencies are often still in the process of constructing the upgrades necessary to comply with their prior permit when they are hit with new terms and requirements. The mandate to states to renew thousands of point source permits every five years diverts resources from addressing more pressing water quality issues, and should be extended from 5 years to a longer period to reflect current circumstances. This is a Clean Water Act requirement and would require statutory modifications, but the benefits of that approach should be considered as EPA undertakes review. Therefore, WEF requests that the EPA 1) change the term of the NPDES permit from 5 years to a longer period when necessary AND without the EPA overriding and deciding an administratively continued State permit; and 2) not change the method of NPDES effluent limitations calculations.
Draft Field-Based Methods for Developing Aquatic Life Criteria for Specific Conductivity The EPA announced the availability of Draft Field-Based Methods for Developing Aquatic Life Criteria for Specific Conductivity for public comment on December 23, 2016. WEF provided comments to the draft method under Docket ID No. EPA-HQ-OW-2016-0353 on April 24, 2017. WEF believes that the draft field-based methods document is site specific and that using specific conductivity does not consider the underlying pollutants and more importantly relative ratios of ions which may be the root cause of impairment. The proposed method does not adequately frame impairments, nor does it adequately incorporate taxonomic probability of capture on rare taxa. Also of concern is the cost impact of implementation of this proposed method in instances where the method results may not be relevant to the impairment, needlessly driving the cost up. WEF members wish the EPA to consider using an adaptive approach that allows State, regional, and local authorities the flexibility to apply the best method to their ecoregion and not implement this draft field-based method nationwide. National Emission Standards for Hazardous Air Pollutants: Publicly Owned Treatment Works On December 27, 2016, the EPA proposed an action to address the agency's residual risk and technology review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Publicly Owned
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Treatment Works (POTW). WEF commented on this proposed action under Docket No. EPA-HQ-OAR-2016-0490 on March 29, 2017. The amendments address the results of the residual risk and technology review (RTR) conducted under the Clean Air Act. The amendments propose to include pretreatment requirements to limit emissions from collection systems which would extend ultimately to regulation of stationary sources discharging into the collection system. WEF believes that this regulation creates serious inconsistency with regulatory reform initiatives and policies and expands the role of the Clean Water Act (CWA) Pretreatment Control Authority to Clean Air Act (CAA) Control Authority, beyond the framework of both acts. The rule proposes that HAP emissions from collection systems should be included in the major source determination for Group 2 sources. EPA did not adequately explain that this clarification is statutorily limited by the Clean Air Act § 112(a) definition of “Major Source.” This definition excludes collection systems that are not located in the contiguous area that includes the treatment plant. This definition also excludes collection systems when they are not under common control with the treatment plant. While the authority of a POTW under the CWA National Pretreatment program is clear and has withstood legal testing, promulgating air quality objectives through the CWA in this proposed CAA rule is both interesting and complex. WEF also disagrees with the economic analysis offered by EPA, and disagrees with the imposition of what appears to be arbitrary removal targets when EPA’s own analysis concludes no unacceptable risk is being generated. WEF asks the EPA to reconsider its approach to controlling stationary air emission sources and rather than using the CWA Pretreatment Program Control Authority the EPA can use its existing CAA Control Authority at these stationary sources to achieve its attainment objectives. Clean Water Act Methods Update Rule for the Analysis of Effluent EPA is promulgating specific changes to analytical test procedures that are used by industries and municipalities to analyze the chemical, physical, and biological components of wastewater and other environmental samples that are required by Clean Water Act regulations which was finalized and signed December 15, 2016. WEF submitted several comments under Docket ID No. EPA-HQ-OW-2014–0797 on May 20, 2015. While the EPA has posted a pre-publication version in the Federal Register and has indicated that this action has been withdrawn from the Office of the Federal Register, WEF is unclear about the legal status of the action. WEF observes that that while EPA has made needed changes to the process for determining the Method Detection Limit, it has not revised the related process for determining Minimum Levels (MLs). Revisions to the ML procedure are critically needed to ensure that test results used for determining NPDES compliance are accurate and reliable. Therefore, WEF requests that the EPA clarify the rule status. If it still considers the rule active, that it promptly re-opens the rule for public comment via the Federal Register to complete the public review process.
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WATER QUALITY ISSUES Stochastic/Statistical Permitting Water quality permits in the United States are currently deterministic. These deterministic permits give a false perception to many in the public, regulators, legislators and the environmental community that the designated use of a water body will be achieved through exacting and precise changes to water quality influencing loads such as in TMDLs. However, the water quality modeling that produce these deterministic and often conservative permits are hardly precise. The reasons for the imprecision are the uncertainty associated with the input variables such as flows and temperature, uncertainty associated with the parameters used to understand and model the water body and simplification of models necessary to simulate complex natural systems. These uncertainties and simplifications associated with these water quality parameters can be statistically determined. Therefore, a statistically varying output associated with water quality is converged to a single deterministic number in most permits. One approach is to better understand the statistical uncertainties and develop statistical limits. For example, approaches to minimize eutrophication through nutrient abatement are known but cannot be precisely quantified, yet produce deterministic permits rather than statistical permits. Similarly, many of the output loads (such as in TMDLs) for both point and non-point source controls are highly imprecise. The water quality influencing output loads of point sources controls are usually modeled or empirically determined with considerable safety factors. This conservatism is often a result of trying to comply with deterministic permits. For example, nutrient output loads from a wastewater treatment plant biological treatment process is uncertain and therefore subject to safety factors. Therefore, there is considerable uncertainty associated with attainment of designated use as well as uncertainty associated with the point and non-point source controls targeting the attainment of designated use. However, a deterministic permit in between these uncertainties increases costs of compliance. In general, statistics-based permitting can handle the fact that environmental protection has to address variability of the water quality situation and a deterministic assessment of the water quality reality may result in an overemphasis of precision associated with meeting designated use, and lead to overly protective limits, increase in costs and decrease in innovation. A comprehensive study of effluent regulations worldwide shows a large variation in approaches (Vanrolleghem, 2011)1. Statistics based limits have been approached in various ways. One can impose a no-exceedance, a time of exceedance, a number of exceedances or a percentile exceedance or acceptance (the latter two being equivalent). Other approaches include median limits and percentile attainment limits. EPA’s New TMDL Vision Program 303(d) Listing On December 5, 2013, EPA announced a new collaborative framework for implementing the Clean Water Act (CWA) Section 303(d) program with states — A Long-Term Vision for Assessment, Restoration and Protection under the Clean Water Act Section 303(d) Program. The new program vision details
1 Vanrolleghem P.A. (2011) Resolving the tensions over the treatment plant's fence: Diverse approaches around the world. Lecture held at the WEF/IWA Nutrient Recovery and Management Conference 2011. Miami, FL, USA, January 9-12 2011 (Invited lecture).
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enhancements made to the CWA 303(d) program informed by the experience gained over the past two decades in assessing and reporting on water quality and in developing tens of thousands of TMDLs. It enhances overall efficiency of the CWA 303(d) program and encourages focusing attention on priority waters and acknowledges that states have flexibility in using available tools beyond TMDLs to attain water quality restoration and protection. With the recognition that there is not a "one size fits all" approach to restoring and protecting water resources, states have been able to develop tailored strategies to implement their CWA 303(d) program responsibilities in the context of their water quality goals. While the Vision provides a new framework for implementing the CWA 303(d) program, it does not alter state and EPA responsibilities or authorities under the CWA 303(d) regulations. WEF participated in this process by facilitating states and EPA dialogue with utilities and is supportive of the adaptive management principles included in the new program vision. We again thank you for this opportunity to provide input on the Evaluation of Existing Regulations and welcome engagement with EPA on these issues. WEF invites EPA to a dialogue on several implementation issues contained in this letter as well as others WEF is still exploring. Should you have questions, you may contact me at (703) 684-2416 or at [email protected]. Sincerely,
Claudio H. Ternieden Senior Director Government Affairs and Strategic Partnerships Water Environment Federation