Today’ ’s Topics s Topics Today Introduction and Permitting Framework Introduction and Permitting Framework 1. 1. WQCD Permitting WQCD Permitting Technology Based Effluent Limits Technology Based Effluent Limits 2. 2. Process Process Water Quality Based Allocations Water Quality Based Allocations 3. 3. Water Quality Based Effluent Limits Water Quality Based Effluent Limits 4. 4. Numeric Numeric Practice Based Practice Based Colorado Water Quality Forum Colorado Water Quality Forum Procedural Items Procedural Items 5. 5. May 20, 2008 May 20, 2008 Permitting Outcome Goal Permitting Outcome Goal The Implementation Framework The Implementation Framework � Federal Basis Federal Basis � Drive Drive effective treatment and management effective treatment and management of of � Clean Water Act Clean Water Act � point source discharges point source discharges � Implementing Regulations (40 CFR) Implementing Regulations (40 CFR) � …that maintain and improve water quality that maintain and improve water quality … � State Basis State Basis � � Colorado Water Quality Control Act Colorado Water Quality Control Act …through the timely and appropriate … through the timely and appropriate � � Basic Standards: Basic Standards: Regs Regs 31 and 41 31 and 41 � implementation of implementation of � Basin and Site Specific Standards ( Basin and Site Specific Standards (Regs Regs 32 32– –38 and 42) 38 and 42) � - technology based standards, technology based standards, � Watershed Protection ( Watershed Protection (Regs Regs 71 71- -75) 75) - � � Permit Implementation ( Permit Implementation (Reg Reg 61) 61) � - water quality based standards, water quality based standards, - � Effluent Limits ( Effluent Limits (Reg Reg 62) 62) � - and other regulatory requirements. and other regulatory requirements. - � Division and WQCC Policies Division and WQCC Policies � Permit Terms Permit Terms Compliance Considerations Compliance Considerations � Individual Permits (the regular process, site Individual Permits (the regular process, site- - � The way we implement a regulation must be The way we implement a regulation must be � � specific) specific) enforceable enforceable � General Permits (streamlined process at the General Permits (streamlined process at the � How will compliance be measured How will compliance be measured � � discretion of the Division) discretion of the Division) � What level of resource does the Division have What level of resource does the Division have � � A category of point sources A category of point sources for compliance for compliance � � With the same effluent limits With the same effluent limits � � Can the terms and conditions be met Can the terms and conditions be met � � And similar monitoring conditions And similar monitoring conditions � � Compliance schedules allowed for new water quality Compliance schedules allowed for new water quality � � Major Major vs vs Minor Minor based effluent limits based effluent limits � 1
Today’ ’s Topics s Topics Technology Based Standards Today Technology Based Standards Introduction and Permitting Framework Introduction and Permitting Framework � Effluent Limitation Guidelines ( Effluent Limitation Guidelines (ELGs ELGs) ) 1. 1. � � National standards developed by EPA National standards developed by EPA � Technology Based Effluent Limits Technology Based Effluent Limits 2. 2. � Prescribe allowable levels of pollutant discharge Prescribe allowable levels of pollutant discharge � � Provides equity among dischargers within categories Provides equity among dischargers within categories � Water Quality Based Allocations Water Quality Based Allocations 3. 3. � ELG Development ELG Development � � Industries are identified based on pollutant loadings Industries are identified based on pollutant loadings Water Quality Based Effluent Limits Water Quality Based Effluent Limits � 4. 4. Numeric Numeric � Available wastewater treatment is studied Available wastewater treatment is studied � Practice Based Practice Based � Economic factors are considered Economic factors are considered � � EPA must review and update EPA must review and update ELGs ELGs on a regular basis on a regular basis � Procedural Items Procedural Items 5. 5. www.epa.gov/waterscience/guide www.epa.gov/waterscience/guide Subpart J—Copper, Lead, Zinc, Colorado Effluent Limit Regulations Colorado Effluent Limit Regulations Gold, Silver, and Molybdenum Ores � Secondary Treatment Standards Secondary Treatment Standards � Subcategory � Private Domestic and Industrial Private Domestic and Industrial � Today’ Today ’s Topics s Topics Water Quality Based Allocations Water Quality Based Allocations Introduction and Permitting Framework Introduction and Permitting Framework � Watershed Protection Regulation Load Watershed Protection Regulation Load 1. 1. � Allocations Allocations Technology Based Effluent Limits Technology Based Effluent Limits 2. 2. � Phosphours Phosphours � Water Quality Based Allocations Water Quality Based Allocations � Concentration and Loading (Annual) Concentration and Loading (Annual) 3. 3. � � Bear Creek , Cherry Creek Reservoir, Chatfield, Bear Creek , Cherry Creek Reservoir, Chatfield, � Water Quality Based Effluent Limits Water Quality Based Effluent Limits 4. 4. Dillon, Dillon, Numeric Numeric � TMDL TMDL WLAs WLAs Practice Based Practice Based � � Consistency with permit Consistency with permit WQAs WQAs � Procedural Items Procedural Items 5. 5. � TMDL expressed as pounds per day. Must TMDL expressed as pounds per day. Must � convert to mg/L or convert to mg/L or ug ug/L /L 2
Impaired Waters w/o an approved Impaired Waters w/o an approved Today’ ’s Topics s Topics Today TMDL TMDL Introduction and Permitting Framework Introduction and Permitting Framework Existing discharge: Existing discharge: 1. 1. WQS applied as WQS applied as Technology Based Effluent Limits Technology Based Effluent Limits 2. 2. discharge limit or discharge limit or permit may be re- - permit may be re Water Quality Based Allocations Water Quality Based Allocations 3. 3. issued with issued with existing “ “point point Water Quality Based Effluent Limits Water Quality Based Effluent Limits existing 4. 4. Numeric Numeric source load” source load ” Practice Based Practice Based New discharge: New discharge: Procedural Items Procedural Items 5. 5. WQS applied as WQS applied as discharge limit discharge limit Water Quality Based Standards Today’ ’s Topics s Topics Water Quality Based Standards Today Introduction and Permitting Framework Introduction and Permitting Framework � Effluent limits must be included if there is Effluent limits must be included if there is 1. 1. � “reasonable potential reasonable potential to cause or to cause or “ Technology Based Effluent Limits Technology Based Effluent Limits 2. 2. contribute to an excursion of a water contribute to an excursion of a water Water Quality Based Allocations Water Quality Based Allocations 3. 3. quality standard” quality standard ” Water Quality Based Effluent Limits Water Quality Based Effluent Limits 4. 4. � Practice based effluent limits are allowed Practice based effluent limits are allowed � Numeric Numeric Practice Based Practice Based where numeric limits are infeasible where numeric limits are infeasible Procedural Items Procedural Items � Dilution/mixing is normally allowed Dilution/mixing is normally allowed 5. 5. � Water Quality Assessment Water Quality Assessment Mixing Zone Considerations Mixing Zone Considerations � Mixing Zone Considerations Mixing Zone Considerations � Threatened and Endangered Habitat Threatened and Endangered Habitat � � � Receiving Water Characteristics Receiving Water Characteristics � Impaired Waters Impaired Waters � � � Ambient Water Quality Ambient Water Quality � Lake or Reservoir Lake or Reservoir � � � Low Flow Low Flow � � Mixing Zone Study Mixing Zone Study � � Technical Analysis Technical Analysis � � Generally rapid and complete mixing is assumed for Generally rapid and complete mixing is assumed for � � Conservative Pollutants Conservative Pollutants – – Mass Balance Mass Balance streams streams � � Site specific studies are required in some cases Site specific studies are required in some cases � Non Non- -Conservative Pollutants Conservative Pollutants � � 3
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