GROUP WASTEWATER DIVISION VANESSA D. WISHART STAFFORD ROSENBAUM - - PowerPoint PPT Presentation

MUNICIPAL ENVIRONMENTAL GROUP – WASTEWATER DIVISION

VANESSA D. WISHART STAFFORD ROSENBAUM LLP 222 WEST WASHINGTON AVENUE, SUITE 900 P.O. BOX 1784 MADISON, WI 53701-1784 VWISHART@STAFFORDLAW.COM SPEAKER’S TASK FORCE ON WATER QUALITY PUBLIC HEARING – JULY 11, 2019

WHO WE ARE

• MEMBERSHIP ORGANIZATION OF APPROXIMATELY 100 SMALL AND MEDIUM SIZED WASTEWATER

TREATMENT FACILITIES

• LOCATED THROUGHOUT WISCONSIN
• ESTABLISHED OVER 31 YEARS AGO
• WE ADVOCATE FOR MUNICIPALITIES IN THE DNR RULEMAKING PROCESS AND AT THE LEGISLATURE
• OUR MEMBERS SERVE KEY FUNCTIONS:
• ENGAGE IN THE CRITICAL PUBLIC FUNCTION OF WATER RECLAMATION
• ACCEPT AND TREAT SEPTAGE FROM PRIVATE WASTEWATER SYSTEMS
• PARTNER WITH NONPOINT SOURCES SUCH AS AGRICULTURAL OPERATIONS TO REDUCE POLLUTION
• EDUCATE AND REGULATE COMMUNITIES TO REDUCE OR ELIMINATE PROBLEM WASTE STREAMS

WHO WE ARE

• MEG WAS INTEGRAL TO A NUMBER OF KEY

RECENT DEVELOPMENTS:

• CREATION OF THE MULTI-DISCHARGE VARIANCE

FOR PHOSPHORUS

• IMPROVEMENTS TO THE CLEAN WATER FUND

INTEREST PROGRAM

WISCONSIN WASTEWATER TREATMENT PLANTS

• THERE ARE 641 MUNICIPAL TREATMENT PLANTS IN

WISCONSIN WIDELY RANGING IN SIZE

MARSHFIELD PLANT

FOND DU LAC PLANT

CITY OF RACINE PLANT

WASTEWATER TREATMENT SYSTEMS

• FRONT LINE IN PROTECTING WATER QUALITY
• MUNICIPAL WASTEWATER SYSTEMS CONSIST OF TWO MAIN PARTS:
• COLLECTION SYSTEMS – THE PIPES THAT CARRY WASTE FROM INDIVIDUAL

CONNECTIONS

• TREATMENT PLANTS – TREAT THE WASTE AND DISCHARGE CLEAN WATER

WASTEWATER TREATMENT PLANTS

• THE TREATMENT PROCESS INVOLVES SEVERAL STEPS:
• PRIMARY AND SECONDARY TREATMENT
• EMPLOYS SETTLING AND BIOLOGICAL PROCESSES TO BREAK DOWN WASTE
• DISINFECTION
• IN MANY CASES, TERTIARY TREATMENT OR FILTERS
• FURTHER REDUCES SOLIDS, NUTRIENTS, AND OTHER CONSTITUENTS
• THE TREATMENT PROCESS GENERATES SOLIDS RICH IN NUTRIENTS THAT ARE

TYPICALLY LAND APPLIED

WASTEWATER TREATMENT PLANTS

• MUNICIPAL TREATMENT PLANTS TREAT A VARIETY OF

WASTES:

• HOUSEHOLD SANITARY WASTE
• COMMERCIAL AND INDUSTRIAL WASTE
• HAULED WASTE FROM PRIVATE SEPTAGE SYSTEMS

WASTEWATER TREATMENT PLANTS

• MUNICIPAL TREATMENT PLANTS ARE REQUIRED TO HOLD WPDES

PERMITS ISSUED BY DNR

• INCLUDE NUMERIC LIMITS FOR CONSTITUENTS DISCHARGED IN

WASTEWATER

• LIMITS ARE DESIGNED TO PROTECT WATER QUALITY, PUBLIC HEALTH, FISH AND

WILDLIFE

• MUNICIPALITIES MUST TEST THE WATER BEING DISCHARGED DAILY IN

CERTIFIED LABS AND REPORT THE RESULTS TO DNR

WASTEWATER TREATMENT PLANTS

• SEPARATE SEWER SYSTEMS
• ALL MUNICIPALITIES EXCEPT FOR

MILWAUKEE AND SUPERIOR NOW HAVE SEPARATE STORM SEWERS AND SANITARY SEWERS

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

THINKING OUTSIDE THE FENCE

• TREATMENT PLANTS WERE DESIGNED TO REMOVE CERTAIN CONSTITUENTS
• SOLIDS, NUTRIENTS, AND BACTERIA
• TREATMENT PLANTS ARE NOT DESIGNED TO REMOVE CHEMICALS
• CERTAIN CHEMICALS, SUCH AS MERCURY AND CHLORIDES, CANNOT BE

TREATED THROUGH CONVENTIONAL TREATMENT METHODS

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

THINKING OUTSIDE THE FENCE

• RELIANCE ON REDUCING SOURCES OF POLLUTANTS
• MERCURY: MUNICIPALITIES WORK WITH DENTAL OFFICES TO LIMIT USE OF

MERCURY AND REDUCE MERCURY CONTAINING WASTE BEING PLACED INTO THE SEWER SYSTEM

• CHLORIDES: MUNICIPALITIES WORK WITH COMMUNITIES TO REDUCE SOURCES

OF SALT FROM WATER SOFTENERS AND ROAD SALT

• AS NEW CONTAMINANTS EMERGE, THESE TYPES OF SOURCE

REDUCTION AND POLLUTANT MINIMIZATION PROGRAMS WILL BECOME MORE CRITICAL

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

MANAGING STORMWATER

• SOME SANITARY SEWER SYSTEMS STILL EXPERIENCE “OVERFLOWS” IN

MAJOR STORM EVENTS

• TYPICALLY CAUSED BY INFILTRATION AND INFLOW OF STORMWATER INTO THE

SANITARY SYSTEM

• SOMETIMES FROM CRACKS IN SEWER PIPES AND JOINTS OR MANHOLES
• DNR REQUIRES ALL MUNICIPALITIES TO INSTITUTE PROGRAMS TO LIMIT

INFILTRATION AND INFLOW

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS: MANAGING STORMWATER

• CONTINUED CONCERNS WITH INFILTRATION AND INFLOW
• INFILTRATION FROM SEWER LATERALS THAT ARE ON INDIVIDUAL PROPERTY AND OUTSIDE OF

THE CONTROL OF THE MUNICIPALITY

• INTENSITY AND FREQUENCY OF STORM EVENTS
• SEWERS ARE DESIGNED AT CAPACITY ACCOUNTING FOR CERTAIN AMOUNTS OF

INFILTRATION

• AS INTENSITY AND FREQUENCY OF SIGNIFICANT STORM EVENTS HAS INCREASED, ISSUES

ASSOCIATED WITH INFILTRATION HAVE ALSO INCREASED

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

POINT VS. NON-POINT POLLUTION CONTROL

• DIRECT DISCHARGES SUCH AS MUNICIPAL TREATMENT PLANTS ARE “POINT

SOURCES”

• REQUIRE WPDES PERMITS
• NUMERIC LIMITS ARE EASIER TO REGULATE THESE SOURCES
• DIFFUSE SOURCES OF POLLUTION ARE “NONPOINT SOURCES”
• GENERALLY NOT SUBJECT TO PERMITS OR NUMERIC LIMITS
• EXCEPTIONS INCLUDE STORMWATER DISCHARGES FROM LARGE COMMUNITIES AND

DISCHARGES FROM CONCENTRATED ANIMAL FEEDING OPERATIONS (CAFOS)

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

POINT VS. NON-POINT POLLUTION CONTROL

• WATER QUALITY IMPROVEMENTS FROM POINT SOURCES HAVE

BEEN SIGNIFICANT

• MUNICIPAL TREATMENT SYSTEMS HAVE BEEN REQUIRED TO REDUCE

PHOSPHORUS SINCE 1991

• HAVE REDUCED DISCHARGES BY OVER 90%
• MOST OF REMAINING SURFACE WATER IMPAIRMENT DUE TO

PHOSPHORUS COMES FROM RUNOFF

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

COST OF MAINTAINING INFRASTRUCTURE

• MOST CITIES IN WISCONSIN HAVE HAD SEWER TREATMENT PLANTS FOR 100

YEARS OR MORE

• THIS AGING INFRASTRUCTURE NEEDS TO BE REPLACED
• COSTS CONTINUE TO MOUNT
• POPULATION AND INDUSTRY DEMAND REQUIRE LARGER SYSTEMS AND INCREASED

CAPACITY

• INCREASED REGULATORY DEMANDS REQUIRE NEW TREATMENT, NEW TESTING

AND REPORTING, AND NEW PROGRAMS

CHALLENGES FOR MUNICIPAL TREATMENT PLANTS:

COST OF MAINTAINING INFRASTRUCTURE

• UPGRADING OR EXPANDING INFRASTRUCTURE IS EXPENSIVE AND COMPLEX
• PIPES ARE UNDERGROUND AND OUT OF SITE - DIFFICULT TO DIAGNOSE AND

REPAIR/REPLACE

• BUDGETING IS CHALLENGING, ESPECIALLY IN SMALL TO MEDIUM SIZED COMMUNITIES
• MANY COMMUNITIES LACK THE POPULATION OR TAX BASE TO AFFORD UPGRADES
• THE CLEAN WATER FUND
• FOR SMALL COMMUNITIES, USUALLY DOES NOT PROVIDE SUFFICIENT SUPPORT

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