what is “regulatory certainty,” and how is it implemented? · 2016-07-18 · what is...
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What is “Regulatory Certainty,” and how is it implemented?
Water Communications Forum
Presenter MPCA Wastewater Staff
June 30, 2016 wq-wwprm1-27
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Regulatory Certainty
• Overview
• Legislative Effort
• Technical discussion of BNR
• Implementing into permit
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Idea from multiple sources
• Wastewater Think Tank
• Governor’s Listening Sessions
• MPCA Staff
• Legislative stakeholders and legislators
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Wastewater professionals say …
• Wastewater professionals expressedfrustration of more restrictive effluent limits
• Wastewater professionals want clean water• Wastewater professionals want to balance
treatment with economic burden on ratepayers, but they want to plan debtrepayment schedules.
• Wastewater professionals want the ability toplan for facility upgrades.
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Regulatory Certainty
qAn agreement between PCA and the owner that more restrictive effluent limits for TP and TN will not be required for a period up to 20 years, if: § the owner receives a WQBEL for TP § The owner accepts a TN effluent limit no greater
than 10 mg/L
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Benefits to the waters of the state
• Uses most effective technology to efficiently address both phosphorous and nitrogen at one time
• A more cost effective approach to nutrient
reduction for Permittees
• Provide an opportunity to show how BNR as a treatment technology will work in our climate
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Questions?
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Legislative Effort
• HF 3409, authored by: • Rep. Fabian, – R, Roseau; • Rep. Poppe, - DFL, Austin • Rep. Metsa, - DFL, Virginia
• SF 3272, authored by: • Sen. Marty, - DLF, Roseville; • Sen. Sparks, - DFL, Austin; • Sen. Senjem, - R, Rochester • Sen. Hoffman, - DFL, Champlin
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Legislative Effort
• HF 3409 and SF 3272 were identical, but SF3272 was amended in committee to include industrial permittees and to include chemical polishing for P.
• House adopted the Senate language • Senate passed SF3272 unanimously • House passed SF3272 with a 105-23 vote
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Legislative Effort
• Benefits of the bill • “Cleaner water faster” • Flexibility for municipalities • More efficient use of state funds from PFA
• Supporters
• League of Minnesota Cities • MN Municipal Utilities Association • Conservation Minnesota
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Questions?
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Regulatory Certainty
• Who is Eligible? • Municipal and Industrial Facilities that installs a
new BNR system; or • A municipality with an existing facility that
includes a treatment technology that is currently designed for TN removal.
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What is BNR?
§ Combining biological phosphorus removal with biological nitrogen removal
§ Capable of producing effluent • 5-10 mg/l total nitrogen • 0.5-2.0 mg/l total phosphorus
§ May include chemical addition • Phosphorus precipitation • Enhanced nitrogen removal
§ Many configurations capable of BNR
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What is BNR?
All Configurations have in common • Aerobic Zone sized for BOD removal and
nitrification • Protect Anoxic Zone • Release of TP in Anaerobic Zone • Luxury Uptake of TP in Aerobic Zone
– Waste TP before secondary release
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What is BNR? Modified Bardenpho
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Anaerobic Anoxic
Influ
ent
Secondary clarifier
Effluent
Waste sludge
Return activated sludge
Oxic (aeration)
NO3
Anoxic Oxic (aeration)
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What is BNR
Nitrogen Removal Key Ideas: • Nitrification is an aerobic process that requires a
long SRT and HRT
• The length of the SRT is affected by temp, DO, pH, and ammonia concentration
• Denitrification is an anoxic process that requires very low DO with a carbon source
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What is BNR
Phosphorus Removal Key Ideas:
• The correct ratio of VFA:P • Phosphorus removal requires correctly sized
anaerobic zone
• Avoid secondary release of phosphorus
• Return flows
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What is BNR
More than design • Process Control is essential to successful
biological nutrient removal • Monitoring and collecting data over time
develops control parameters • Evaluating results and understanding needed
operational changes
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Evaluation of Treatment Technology
• Influent characteristics well defined • Through out the design life • Ratios of VFA:P • Variability of flow and loading
• Biosolids handling • Secondary release • Return flows • Chemical feed points
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Evaluation of Treatment Technology
• Hydraulic consideration • Short circuiting • Back mixing • Oxygen return
• Flexibility in operation • Location and number of return lines • Swing zones
• O&M • Describing process control • Sampling location and expected results • Trouble shooting
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SRF funding for Municipal
• Work under existing programs • Apply to the PPL • Submit facility plan
• Eligible for Point Source Implementation Grant • Application period is July
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Questions?
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Regulatory Certainty
• Voluntary • Agree to meet TP WQBEL and TN effluent limit • MPCA determines whether to provide RC
based on facility design • Agreement between MPCA and Permittee • 20 year term or design life, whichever is
shorter • Sunset provisions – Dec 31 2031 or EPA
approval of nitrate toxicity WQ standard
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Regulatory Certainty – Permitting Process
• Submit Application • Must be submitted as part of an application for permit reissuance
or modification • Development of Permit Conditions:
• Development of TP WQBEL • Review of technical documentation to:
• Approve design of proposed BNR or existing treatment technology • Determine the associated TN limit • Determine design life ~ term of eligibility
• Develop and Formalize Agreement: • Length of Regulatory Certainty • TP WQBEL and TN effluent limit • Signed by both MPCA and Permittee
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Regulatory Certainty – Permitting Process
• Permit Document: • TP WQBEL and TN limits included in Limits and
Monitoring requirements • Permit Text will include:
• Language incorporating the terms of the Agreement into the Permit
• Construction schedule, if applicable
• Final Agreement - Appendix to the Permit • Factsheet and/or SOB will include basis for:
• TP WQBEL and TN effluent limit; and • Regulatory Certainty – term and conditions
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Regulatory Certainty
• Sunset • Applications will be accepted until December 31,
2031 or the day following EPA approval of MPCA adopted WQS for nitrate-nitrogen.
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Questions?
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Opportunity to participate
We are seeking volunteers to help formulate the agreement between PCA and permitee. Stakeholders: § Wastewater professionals § Consultants § Advocacy § Industry § Municipal
Limited number of meetings to conclude by August 31, 2016.
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Cleaner water faster
For questions, or if interested in advisory group, contact Joel Peck: [email protected] 651.757.2202 For permitting questions, contact Nicole Blasing [email protected] 218.316.3890 For technical questions, contact Brian Fitzpatrick [email protected] 218.316.3859
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