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Thermal Discharge - Alternative Effluent Limitations (AEL)

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Thermal Discharge - Alternative Effluent Limitations (AEL)

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Thermal Discharge - Alternative Effluent Limitations (AEL)

  1. 1. Lynn Morrison, P.E. Permitting Engineer, The Probst Group Thermal Discharge Alternative Effluent Limitations (AEL)
  2. 2. The Probst Group About Us • Completed hundreds of industrial wastewater management projects in the dairy processing industry. • Driving the industry in the advancement of efficient, sustainable, and cost-effective wastewater management solutions. • Offer a board range of services including: • Consulting • Design • Construction • Post-Construction • Operations Support • Permitting Assistance
  3. 3. Effluent Temperature Limitations Options for Flexibility • Install cooling system within terms of permit compliance schedule • Can be expensive • Can impact toxicity issues • Increased electricity use and maintenance • Larger Streams or Rivers • Monthly Low-Flow Receiving Water Data (Qs) • Mixing Zone Study/Demonstration • Real-Time Limits • Site-Specific Ambient Temperature Data • Small, Effluent Dominated Streams • Alternative Effluent Limitations • Relocate Outfall??
  4. 4. Alternative Effluent Limitations • Most useful when: • No effective mixing • Discharge is essentially stream flow • Based on EPA CWA Section 316A, there are two tracks for approval: • Causes no appreciable harm to the balanced, indigenous community or; • Assures the protection and propagation of the balanced, indigenous community of fish, shellfish, and wildlife. • Valid for term of the permit – must incorporate supporting data with each reissuance going forward AELs can be used when the proposed effluent limitation is more stringent than necessary to assure the protection and propagation of a balanced indigenous population (NR 106 Subchapter IV)
  5. 5. Alternative Effluent Limitation Steps Submit AEL request to WDNR during WPDES Application Establish point of discharge and impacted waterways Identify Sampling Stations along water reaches Establish comparative RIS with WDNR to demonstrate AEL Develop and submit study plan for WDNR and EPA Approval Implement a biological demonstration study plan 1.Establish point of discharge and impacted waterways a)Utilize the Surface Water Data Viewer (SWDV) and NR 104 to determine upstream and downstream waterbody classifications 2. Identify sampling stations along water reaches with existing data a) Review of all data collection of flow and modeling and biological monitoring studies to establish baseline of data 3. Establish comparable list of ‘Representative Important Species (RIS)’ with WDNR to demonstrate the AEL
  6. 6. Alternative Effluent Limitation Steps Submit AEL request to WDNR during WPDES Application Establish point of discharge and impacted waterways Identify Sampling Stations along water reaches Establish comparative RIS with WDNR to demonstrate AEL Develop and submit study plan for WDNR and EPA Approval Implement a biological demonstration study plan 4. Develop and submit study plan for WDNR and EPA Approval 5. Implement the biological demonstration study plan a) Collect biological data (habitat, wildlife, amphibians, macroinvertebrates, fish, etc.) to demonstrate and assure effluent thermal limitations or more stringent than necessary 6. Permittee submits AEL request to WDNR during WPDES New Outfall or Reissuance application which provides all comprehensive data to demonstrate that…
  7. 7. Alternative Effluent Limitation Steps No appreciable harm has resulted from the normal component of the discharge, or despite the occurrence of such previous harm, the AEL being requested will assure protection and propagation of a balanced indigenous community of fish, shellfish, and wildlife in and on the body of water into which the discharge is made. Application for AEL will include: • Limit requested • Description of methodology used to complete the study • Relevant data collected (biological, hydrological, meteorological) engineering models, etc. • Data and results that demonstrate that the RIS will be protected, and that will assure the protection and propagation of a balanced, indigenous community
  8. 8. Considerations & Lessons Learned (so far) Timeline: May 2016 – Decision to investigate AEL July 2016 – Submitted AEL Study Plan to WDNR for review and approval with the intent to complete the study in Summer/Fall 2016 November 2016 – Submitted revised Study Plan to WDNR for review and approval and completed macroinvertebrate sampling December 2016 – Conference Call with WDNR to discuss conceptual approval of AELs Tentative Future Timeline: February 2017 – Submit final AEL Study Plan and get approval from WDNR April 2017 – Begin fish sampling August 2017 – Complete fish sampling October 2017 – Request AEL from WDNR
  9. 9. Considerations & Lessons Learned (so far) • Utilize WDNR monitoring staff at the beginning of the project to determine available data and considerations for reference streams • Get written approval on RIS list from WDNR prior to inclusion in the Study Plan • Plan for several conference calls and on-site meetings with WDNR when preparing budget • WDNR will require 3 sampling dates: Macroinvertebrates in the Fall, Fish in the Spring for spawning and Summer for determination of balanced community • Make sure the right people are at the table for all discussions related to the study plan – including water resources and permitting staff • The Study Plan must include what you intend to do with the data you may or may not find
  10. 10. Alternative Effluent Limitations References for Managing Thermal Limits • EPA Memorandum, Implementation of Clean Water Action Section 316(a) Thermal Variances in NPDES Permits (Review of Existing Requirements) – October 2008 • WDNR Guidance for Implementation of Wisconsin’s Thermal Water Quality Standards – August 2013 • Wisconsin Administrative Code, WDNR NR 106; Procedures for Calculating Water Quality Based Effluent Limitations for Point Source Discharges to Surface Waters – August 2014 • Sub Chapter VI, Alternative Effluent Limitations for Temperature WDNR Chapter NR 102 • Technical Support Document for Wisconsin’s Thermal Water Quality Rules – Draft 2008 • Indiana Department of Environmental Management (IDEM) – Draft 2015 Guidance for Conducting a Demonstration as a Requirement of a 316(a) Alternative Thermal Effluent Limitation Request
  11. 11. Thank You

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