april 28, 2015 1:00 - 4:30 pm dakota lodge, west st. paul · chloride extravaganza . april 28, 2015...
TRANSCRIPT
Chloride Extravaganza April 28, 2015
1:00 - 4:30 pm
Dakota Lodge, West St. Paul
Purpose: Discuss the environmental impacts of chloride on the environment, the current water quality conditions in the Twin Cities Metro Area, and share the draft management plan developed to reduce
chloride at the source.
Follow the event on Twitter using #lowsaltMNwaters Tweet your questions/comments to @brookeMPCA, or
Text avidsky744 to 22333
1:00-1:10 Welcome – Gaylen Reetz, Watershed Division Director
Water Quality Impacts
1:10-1:20 Chloride Standards overview – Katrina Kessler, Water Assessment Manager
1:20-1:35 Assessment & listing process – Pam Anderson, Water Quality Monitoring Supervisor
1:35-1:50 Questions/Discussion (15 minutes)
1:50-2:05 TCMA Chloride Project – Brooke Asleson & Rachel Olmanson, Watershed Program o Project history – Brookeo Stakeholder Process - Brookeo TCMA water quality conditions – Rachelo Chloride sources – Rachel
Management Strategies, Resources & Tools
2:05-2:25 Chloride Management Strategies – Brooke Asleson, Watershed Program
2:25-2:40 Questions/Discussion (15 minutes)
2:40-2:55 Break (15 minutes)
2:55-3:10 Winter Maintenance Assessment tool – Connie Fortin, Fortin Consulting
3:10-3:20 MPCA Pollution Prevention Assistance – Rick Patraw, Community & Business Assistance Manager
3:20-3:30 Questions/Discussion (10 minutes)
TMDL and Permit Implications
3:30-3:40 TCMA Chloride TMDL overview – Brooke Asleson, Watershed Program
3:40-3:50 TMDL Modeling approach & loadings – Hans Holmberg, LimnoTech
3:50-4:00 MS4 permit requirements – Josh Stock & Mary Hammes, Stormwater Program
4:00-4:10 Wastewater & Industrial discharge permits – Marco Graziani, Wastewater Program
4:10-4:25 Questions/Discussion (15 minutes)
4:25-4:35 Closing Remarks – Marni Karnowski, Stormwater Manager
wq-iw11-06ee
What are water quality standards?
• Fundamental tool of the Clean Water Act (CWA)
• CWA objective: • “…restore and maintain the chemical, physical, and biological
integrity of the nation’s waters…” • “Fishable and swimmable” interim goal
• Address three key questions: 1. What and who are we protecting? 2. What conditions are protective? 3. How do we maintain high water quality?
2
1. Drinking water
2. Aquatic life and recreation
3. Industrial use
4. Agricultural and wildlife use
5. Aesthetics and navigation
6. Other uses
7. Limited resource value
Who/what are we protecting
3
Waters have multiple uses Key beneficial
use, protects fish, insects, mussels and plants
What conditions are protective?
• Standards identify the conditions needed to support the beneficial use
• Generally statewide or region-specific
• Can be descriptive or numeric
4
Antidegradation protects high quality waters
Different waters warrant different levels of protection
Recognize public value of exceptional waters
Only allow degradation if avoid and minimize impacts
demonstrate need for social/economic development
protect existing uses
How are high quality waters protected?
Chloride water quality standard
Based in 1988 EPA aquatic life criteria
Adopted in MN in 1990
Class 2B water quality standard – protects aquatic life
230 mg/L chronic standard (4-day)
860 mg/L acute standard (1-day)
Chloride water quality standard Research started in 2005 to re-examine chloride impacts Data indicate chloride impacts are dependent on hardness &
sulfate (2009 Iowa equation) EPA conducting ongoing toxicity tests to inform national criteria Preliminarily, acute standards may be more restrictive and chronic
standards may be less restrictive MPCA working with EPA to understand how the revised criteria may
be implemented in MN Will revise the MN standard following release of EPA’s criteria
Metro-wide Chloride Assessment Requested to fulfill the needs of the TCMA
Chloride Project Included the assessment of lakes, streams, and
wetlands for toxic levels of chloride within the 7-county metro area
Required new approaches Development of guidance on dealing with lakes and
chloride at different depths
Assessment of Chloride
Standard applies to all waters (Class 2)
Originally MPCA only assessed streams
2012 303(d) listing cycle – assessments begin for lakes
2014 303(d) listing cycle – assessments begin for wetlands
10
Application of the Standard
11
A water is considered impaired if: 2 or more exceedances of the chronic standard (230 mg/L)
occur within 3 years OR 1 or more exceedances of the maximum standard (860
mg/L)
For lakes, averaging occurs Top two meters, bottom two meters, and mid depths Each depth is compared to the standard separately for a
given day
Data Collection
Monitoring guidance was developed specific to the Metro Area Chloride Project in 2011.
Development based on agency standard operating procedures for surface water monitoring.
Changes include: Winter sampling
Increased sampling frequency when elevated level are detected.
12
Assessment Steps – Metro Chloride
Call for Data
Data prep and comparison to standard (Summer 13)
Staff review of individual waterbodies (Summer 13)
Professional Judgment Meeting (Sept 13)
Public Comment Period
Follow up meeting with stakeholders (Feb 14)
Review of decisions, response to comments (March 14)
13
Assessment – Approved Methods
Methods are selected for data analysis
Methods are not required to be CWA approved
Additional methods are acceptable if:
• reporting limits are equivalent and quality assurance data exist
MDH certified lab analysis required.
Assessments - Data Collection Data used for assessments are collected for a
variety of purposes. Composite data has limited use – do not use flow
weighted, some use of time-weighted. Flow biased data is reviewed, but for assessments, our
decisions need to be based on normal conditions. Professional judgment is part of the process to
determine what data should be use at the time of assessments.
15
Assessments – Call for Data A public call for data is made. Any data finalized in EQuIS is included MCES provides stream data as a separate export to MPCA USGS, neighboring states/tribes data is included For any data used:
Must meet methods required by system and proper lab certification.
Must be finalized data – this requires that the data provider reviews the data and indicates to the agency that it is correct.
16
Data Processing
Data summarized in a database and is compared to the applicable water quality standard
For toxic parameters, the work is done by hand – the machinery did not account for the averaging or the analysis at depth
17
Assessment Process - 2013 Review of individual data for each waterbody.
Considerations include: precipitation, flow, temperature/snowmelt, data quality, data frequency, distribution across the data record, etc.
Mistakes were found in data Requires follow up with external data providers,
corrections in the system, and reanalysis
Data was missing MCES and USGS data had to be run separately
Assessment Process - 2013 Following the PJG and the Public Comment Period
MPCA reviewed the application of the guidance for the standard considering the frequency of the data available (single values to represent a 4 day period).
Added more scrutiny to waters where impairments were based on few exceedances.
Convened internal review panel to ensure consistency and agreement on the more conservative application of the guidance.
Assessment Process - 2013
A number of draft listings were removed as a result of the reanalysis that occurred.
Most dealt with lack of sufficient data to determine that a chronic condition existed
20
Updates to Guidance
Following the public comments and reanalysis of the data, the guidance was updated to include a better look at how condition monitoring data is applied to the chronic standard.
21
Proof of Chronic Condition
Condition monitoring rarely yields multiple samples in a 4 day window
Some systems are more volatile than others – streams and hydrologically connected wetlands flush often, lakes are considerably more stable
22
Proof of Chronic Condition
Review of flow/precipitation data – if normal to low flow on a stream/wetland, or if it is a deep lake, it is possible to extrapolate a single sample as a 4 day average
Higher flow/melt conditions and shallow lakes/wetlands require more frequent sampling to determine if elevated concentrations persist
23
Conclusion Assessments resulted in 19 lakes, 14 streams, and
4 wetlands being added to the impaired waters list.
Scrutiny of the guidance resulted in better guidance and assessments of toxic parameters.
New data system will result in better transparency and ease of sharing data with partners.
24
CHLORIDE EXTRAVAGANZA
APRIL 28, 2015
Twin Cities Metro Area CHLORIDE PROJECT
Brooke Asleson and Rachel Olmanson Minnesota Pollution Control Agency
What’s the problem with salt?
• Chloride is a permanent pollutant
o Cannot be treated or filteredwith traditional BMPs
• 78% of the chloride applied in theTCMA is retained here (Stefan et al. 2008)
• Chloride concentrations in streamsin the Northern US haveapproximately doubled from 1990-2011 (Corsi et al. 2015)
• Contaminates groundwater1 tsp. of road salt pollutes
5 gallons of water
• Chloride is toxic to aquatic life
o 230 mg/L- long-term
o 860 mg/L- short-term
• Chloride can disrupt the natural mixing process in lakes
• Impacts vegetation and wildlife
• Corrodes road surfaces/bridges and damages reinforcing rods
• Human health concerns
What’s the problem with salt?
Public Safety: Road Salt
Safe roads, parking lots and sidewalks are essential
o Public expectations are difficult to meet
Currently no alternative de-icer without negative impacts to the environment
Fear of slip and fall lawsuits
365,000* tons of road salt applied each year in the TCMA (*purchasing records)
Public Concerns: Water Softening
The public desires soft water (minimal hardness levels)
Individual water softeners are used in many households
Treatment to remove chloride from wastewater effluent is costly
kirbywater.com
Feasibility Study Overview (Phase 1)
• Gain a better understanding of the extent and magnitude of chloride contamination to surface waters in the 7 county Twin Cities Metropolitan Area (TCMA)
• Included extensive data analysis, a literature review, a telephone survey, and analysis of potential strategies for further research, public education, and potential regulation
• Multi-agency team consisted of MPCA, MnDOT, MCES, BWSR, U of M SAFL, and Wenck Associates
• Completed in December of 2009
Goals & Shared Vision
Understand the public safety needs & limitations
Understand the environmental condition
Evaluate those conditions against desired water quality goals
Set realistic and
achievable goals
Develop a
collaborative
strategy to
meet those goals
TCMA Chloride Management Plan
Assist local partners to better manage the balance between the clean water and road safety
How?
Develop Chloride Management Plan for the 7-county metro: Complete Chloride TMDLs for all impaired waters
Set goals to protect the remaining surface waters
Layout implementation strategies to achieve water quality goals
This is a partnership process driven by the stakeholders
TCMA Chloride Project: Timeline
Comprehensive Stakeholder
Process
Targeted Chloride
Monitoring Evaluate Waters
Identify Sources of Chloride
Develop Protection
Goals
Complete TMDLs
Develop Implementation
Strategies
Scheduled to complete project in summer 2015
MPCA project team
Inter-Agency Advisory Team
MPCA, MnDOT, Met Council, BWSR, DNR, USGS, Dept. of
Health, U of M
Technical Advisory
Committee WMOs, WDs, Cities,
Counties, MnDOT
Outreach Group WMOs, WDs, MS4s, road salt
applicators, Citizens
Implementation Plan Committee
Winter Maintenance Professionals, Cities, Counties, MnDOT,
WMOs/WDs
Education & Outreach
Committee
MPCA, MnDOT & local education
specialists
Monitoring Sub-Group
MPCA, DNR, Met Council, USGS, local
partners
Technical Expert Group
Hands-on road salt applicators and
suppliers
Implementation Plan Committee (50)
MPCA, MnDOT, St. Paul, Minneapolis, Shoreview, Burnsville, Plymouth, Capitol Region WD, Ramsey-Washington WD, Bassett Creek WMC, Mississippi WMO, Nine Mile Creek WD, Scott County WMO, Minnehaha
Creek WD, Rice Creek WD, Dakota County, Scott County, Hennepin County, Waconia, Met Council, Three Rivers Park District, Enviro Tech Services, Prescription Landscape, Force America, East Metro Water Resource Education Program, Scott Clean Water Education Program, Freshwater Society, U of M Extension, U of M Twin
Cities, U of M Duluth, Minneapolis Park & Rec Board
Technical Advisory Committee (17)
MPCA, MnDOT, St. Paul, Minneapolis, Shoreview, Burnsville, Plymouth, Capitol Region
WD, Ramsey-Washington WD, Bassett Creek WMC, Mississippi WMO, Nine Mile Creek WD,
Scott County WMO, Minnehaha Creek WD, Rice Creek WD
Technical Expert Group (13)
MnDOT, Dakota, Scott & Hennepin Counties, St.
Paul, Minneapolis, Waconia, Three Rivers Park District, Enviro
Tech Services, Prescription Landscape,
Force America
Monitoring Sub-Group (18)
MPCA, DNR, Met Council, USGS, Capitol Region WD, Ramsey-Washington WD, Rice Creek WD, Minnehaha Creek WD, Mississippi WMO, Ramsey County, Minneapolis Park & Rec Board, Three Rivers Park
District
Inter-Agency Advisory Team (24)
MPCA, MnDOT, Met Council, BWSR, DNR, USGS, U of M, Dept. of
Health
Education & Outreach Committee
(21)
MPCA, MnDOT, East Metro Water Resource
Education Program, Scott Clean Water
Education Program, Nine Mile Creek WD, Freshwater Society,
Mississippi WMO, U of M Extension, Minnehaha
Creek WD, Ramsey-Washington Metro WD,
Dakota County
Outreach and General Communications
MPCA Road Salt and Water Quality Website
Jan. 2013 - EPA’s Stormwater Pollution Prevention Webinar
Numerous press releases, media interviews, and presentations since 2010
Road Salt Symposium annually since 2010
Local meetings & events
August 2012 - Salt Dilemma Display created
Project Monitoring
• Fall 2010 – Spring of 2013
• 74 Lakes, 27 Streams, 8 Stormsewers
• Targeted monitoring
• Lakes included surface and deep lake sample
• Involved several local partners
Chloride in Surface Waters
19 lakes, 14 streams and 4 wetlands impaired for chloride in the TCMA
41 waters determined to be “High Risk” in the TCMA
o Values ≥ 207 mg/L or at least one exceedance
Increase in chloride in Mississippi, Minnesota and St. Croix Rivers (Metropolitan Council 2014)
cityparksblog.org
en.wikipedia.org/wiki/Interstate_Park
Chloride in Groundwater
• Shallow groundwater in the TCMA is impacted by high chloride concentrations
• 30% of shallow monitoring wells in the TCMA above standard
• About one-third of wells showed increased concentrations over time
• Increasing chloride concentrations in some deep wells
• Impact on baseflow concentrations in surface waters
Land Use Chloride (mg/L)
Residential 45
Commercial/ Industrial 60
Undeveloped 15
Chloride Water Quality Trends
Long-term and seasonal trends
Relationship to winter severity
Trends within lakes
Relationships to watershed characteristics
Concentrations in stormwater
Relationships between surface
and groundwater
Visit the Road Salt & Water Quality website:
http://www.pca.state.mn.us/programs/roadsalt.html
Follow me on Twitter!! @brookeMPCA
BROOKE ASLESON M I N N E S O T A P O L L U T I O N C O N T R O L A G E N C Y
C H L O R I D E E X T R A V A G A N Z A
A P R I L 2 8 , 2 0 1 5
TCMA Chloride
Management Plan
Protection of Surface Water & Groundwater
Opportunity to prevent waters from continued degradation which may result in impairment
Prevention or protection is often more easily accomplished than restoration of an impaired waterbody
Practices for protection of groundwater are the same as those for restoring impaired surface waters
Includes all surface waters and groundwater in the TCMA
Protection goals are performance based rather than numeric (winter maintenance activities)
Prioritization – Where do I start?
Impaired watersheds - TMDLs
High Risk surface waters – near the standard
Map includes surface waters with no or limited chloride data
Relative size and impact of the source of chloride give priority to winter maintenance activities in areas of high density
of impervious surfaces
or emphasize on residential water softeners for those watersheds where the wastewater treatment facilities are identified as the major contributor of chloride
Protection – start with what is reasonable
Protection and Restoration Strategy
Prevention is the ONLY option for reducing salt
Goal is for all winter maintenance programs to perform at a level that is using minimal amount of salt
Set water quality goals for point sources to work towards
Allow flexibility in implementation
Overall Chloride Reduction Strategy
Provide high level strategies for reducing chloride
Winter Maintenance Assessment tool to allow for detailed BMP selection tailored to each program
Included some tried & true BMPs for consideration
Offer non-traditional strategies for consideration
Provide suggested training opportunities
Considerations for private applicators
Discussion on Citizens Attitudes & Practices
Includes Education & Outreach resources
Example
Implementation
Strategies
Assessment Items Goals Actions
Which organizations
have been most
successful in reducing
salt and what are the
lessons learned?
Identify outstanding
success in areas of interest
(i.e. storage buildings,
contracts that don’t bill by
the ton, using non-
traditional plow drivers to
get 24 hour coverage).
Look at Clear Roads research, SIMA
research, APWA research, AASHTO research,
attend road salt symposium and other
winter maintenance conferences to identify
the leaders. Talk to them directly.
Are lower salt use
pavements being
installed (permeable,
heated, narrower)?
Find some sort of
pavement surface that
requires 20% less salt on it.
Install permeable asphalt in parking lot near
"Smith" lake.
Is payment based on
amount of salt applied?
Have a profitable contract
without billing by the ton
which encourages overuse
of salt.
Look at Snow and Ice Management
Associations website for example contracts
that do not charge by volume.
Is concern over liability
resulting in over
applying salt?
See if other states have a
law to reduce liability for
private companies doing
winter maintenance.
Encourage legislators to look at New
Hampshire’s law that limits liability of
private contractors in winter maintenance.
• Put salt education and outreach goals in your organizations operating plans.
• Partner with MPCA to offer the “Smart Salting” winter maintenance training for
local private and public winter maintenance professionals each winter.
• Create awareness about the environmental impacts of chloride through
education, outreach, and other activities to local residents, applicators, elected
officials and businesses.
• Monitor local surface waters for chloride concentrations to track trends, track
progress and understand the movement of chloride through the watershed.
• Host yearly workshops for local winter maintenance professionals to encourage
the use of the WMAt and track progress of BMPs implemented.
• Provide a measuring cup type salt scooper to homeowners and small businesses
in order to raise awareness of the amount of salt they are using.
Example: Years 1-2
• Become educated on the salt problem and ways your constituents contribute to it.
• Understand options for reducing chloride use.
• Support the implementation of the TCMA Chloride Management Plan.
• Develop a limited liability law to protect private contractors from being sued if they are following BMPS, similar to New Hampshire. Fear of law suits often drives over application of salt.
• Create an ordinance for city that all salt and salt/sand piles must be store indoors and on an impermeable surface.
Example: Years 1-2
• Require attendance once every 5 years at MPCA Smart Salting winter maintenance training to apply salt for hire in your city.
• Those that apply salt should be educated and certified to state standards similar to the Department of Agriculture’s pesticide applicator certification program.
• Require all new construction to have irrigation water and drinking water plumbed so as to not pass through the water softener
• Require water softeners that recharge by the time of day and not by the salinity of water be banned from sale.
• Ordinance for city’s where the water is softened by the city that personal water softeners are not allowed.
Example: Years 3-5
Chloride Reduction Strategies: Winter Maintenance Practices
Shift from granular to liquids
Improved physical snow removal
Snow and ice pavement bond prevention
Training for maintenance professionals
Education for the public and elected officials
Winter Maintenance Assessment tool
A few salt saving BMPs
• Calibrate all equipment regularly
• Integrate liquids
• Develop a Winter Maintenance Policy/Plan
• Provide state of the art winter maintenance training, education and professional development
• Refine application rates charts and continually test lower rates
• Store salt indoors and on impermeable pad
• Anti-icing before events to reduce bonding of snow to pavement
• Start mechanical removal as soon as possible, and keep at it throughout the storm
• Upgrade to equipment that can deliver low application rates
Non- Traditional Winter Maintenance Practices Adopt a lower level of service
Primary challenges: public acceptance, unknown cost of longer commute times and less safe travel conditions
Benefits: technically easy to implement, immediate reduction chloride & cost savings in salt purchases
Alternative pavement types/Infrastructure changes Primary challenges: cost, and significant amount of time to implement
Benefits: no significant change in public expectations
Driver Behavior Changes Primary challenges: wide spread changes from the public, increase wear on roads
Benefits: allows for easier continued reduction in road salt use
Non-chloride deicers Primary challenges: likely increased cost for deicers, and unknown environmental
consequences
Benefits: no significant change in public expectations, easy to implement
perviouspavement.org
Case Studies
University of Minnesota, Twin Cities Made changes to winter
maintenance program 2006
purchased new equipment for ~ $10,000
saved $55,000 the first year the BMPs were implemented
Material Use (tons/yr) Use (tons/yr) Reduction
Rock Salt 775 462 40%
(1997-2005) (2006-2008)
ICE MELT 131 64 51%
(MgCl2) (1997-2005) (2006-2008)
ICE MELT 131 59 55%
(MgCl2 - CaCl2) (1997-2005) (2008-2014)
Sand 1965 20 99%
(1997-2005) (2006-2014)
City of Waconia
2010 updated “Snow and Ice Policy” to a “Winter Maintenance Policy” – proactive focus opposed to reactive
Addition of ordinances reflective of policy guidelines
Calibration and equipment changes resulted in 70% reduction in rates
Addition of pre-wet practices and material savings results in yearly $8,600 cost savings
Water Softening Options
Inform homeowners of local hardness values and recommended levels
Convert to centralized lime softening – eliminate individual water softeners
On-demand softeners have the potential to reduce salt use – if tuned appropriately, reductions from other sources may be necessary
Alternative treatment technologies – need more information
Research Needs
Chloride reductions when implementing BMPs
Environmental impacts of non-chloride de-icers
Citizen attitudes and practices around the use of chloride
Pavement Alternatives
Water softening options
Funding Opportunities
Monitoring Recommendations
Other Key Elements of CMP
Chloride Management Plan Timeline
• MPCA review of Draft TCMA chloride management plan & TMDL – Feb. 2015
• Project stakeholder review - March 2015 (thank you!)
• Expect public notice - June 2015
• Approved plan – Late Summer 2015
Implementation of plan already underway!!
Tweet your questions/comments to @brookeMPCA
#lowsaltMNwaters
Brooke Asleson
Watershed Project Manager
651/757-2205
Questions
Good Afternoon
Thank you for being here!
We have an opportunity to fine tune winter maintenance to benefit the roads & waters of our states! Let’s see what is being developed to help….
Photo: FCI
Nobody wants to be told how to reduce the
chloride entering our water…
• Therefore we developed
an assessment and
prediction tool that will
help you work with your
unique situation
• It will help you create
your own path towards
chloride reduction
• You do not have to use
this tool but it will be
available to you – FREE!
Photo: google earth
What if…
• There was a set of
questions
• That you could answer by
sitting at your computer
• And you could get a
sorted list of where you
are doing great, ok or
poor in winter
maintenance Photo: City of Beloit WI
What if…
• You took the list of your
poor practices & turned
it into an action plan?
• You took the list of your
great practices to show
your city council, to help
others that are behind in
this area, to be proud of
what you have done?
Photo: City of Grand Rapids MN
If you choose salt savings mode, you will have to fill in
data on salt usage, salt store and other topics
5000 tons salt stored
4000 tons salt/sand stored
salt/sand 30/70 mix
1000 gallons brine stored
2000 tons salt used
1500 tons salt/sand used
500 gallons brine used
$70.00 per Ton of salt
$1.00 per gallon of brine
80% salt used on low speed roads
20% salt used on high speed roads
City of Roundville salt saving potential for one year
based Winter of 2011-2012 and predicted changes
For maintenance of: high speed roads, low speed roads
2011-2012 Information
Total = 234.6 tons of salt likely to be saved
Reduction Potential = 11.7%
Prediction based on changes
Had these changes been made for the winter of 2011-2012, Roundville would have saved $16,422 in salt purchases and used only 1,765.4 tons of salt
Entry # 114
Joe Smith
8-18-2013
763-444-5555
BEFORE WINTER:
0% reduction potential
DURING WINTER:
0% reduction potential
ACCURACY DURING THE STORM:
10% Reduction Potential
*0 Ground Speed Controllers with MDSS>10 Ground speed controllers with MDSS>10% Salt Savings on salt applied salt
EFFECTIVENESS DURING THE STORM
0% reduction potential
REDUCE WASTE DURING THE STORM:
22.05% reduction potential
Bulk salt pile uncovered > Bulk salt pile indoors > Salt Savings 17% of salt in storage
Salt/sand pile uncovered> Bulk salt pile indoors > Salt Savings 17% of salt in sand pile
Receive shipments outdoor with good clean up > Receive shipments indoors > Salt savings .05% of salt ordered
Use up all salt at end of winter > give away salt at end of winter> 5% of total salt purchased
RECOVERY OF SALT:
0% reduction potential
Salt Savings Potential for One Year
City of Roundville Parks Department 6-06-2011
List of predicted changes
Legend:
- Poor Practice
- Best Practice
- Advanced Best Practice
2015 WMAt will be ready to use!
• The logic has been developed
• Programming is nearly finished
• Internal testing has started
• First group to test it will be the
technical expert team that
helped develop it
2015-2016 Level II winter
maintenance training • Audience: City, County, State, Private
maintenance leadership
• Likely to be held in a computer lab setting
I look forward to working with you on this!
Connie Fortin – Fortin Consulting Inc. [email protected]
Any Questions?
Regional Management
Assistant Division
Chloride Overview
• Where we came from?
• Where are we now?
• Where are we going?
I’LL BE
BACK!
Regional Management
Assistant Division
Chloride Overview
• Where we came from?
• Where are we now?
• Where are we going?
Where we came From
• 10 years ago - Pilot Trainings started:
– P2 Grant of $25K available to do TMDL related work
– Fortin Consulting Proposal Selected Spring 2005
– Diverse Stakeholder input
– 4 Pilot Trainings (Fall 2005-Spring 2006)
Where we came From
• Pilot findings
– Very Positive Feedback
– Training Format
• 4 hrs in length
• Ends with a test and a voluntary
commitment to implement BMP’s learned
to minimize environmental impact
Real Reductions of
985 tons
University of Minnesota
Reductions as a result of training:
1) Rock Salt – 617 tons (65%)
2) Ice Melt – 80 tons (65%)
3) Sand (w/10% salt) – 288 tons
(92%)
Savings - $55,071
Real Reductions of
50 tons/event
Dakota County
Amount used pre-training – 405 tons/event
Amount used 2 years post training – 355
tons/event
Where are we now?
• ROAD SALT:
– 4200 certified in Minnesota
– plus almost 1650 out of state
attended training
Where are we going?
– Implement Level 2 Training
(spring 2016)
– Sustainable Funding?
– Future Legislation?
CHLORIDE EXTRAVAGANZA
A P R I L 2 8 , 2 0 1 5
TCMA Chloride tmdl
overview
Tweet your questions/comments
to @brookeMPCA
#lowsaltMNwaters
Clean Water Act (1972)
Goal - Restore and maintain the chemical,
physical, and biological integrity of U.S.
waters
Section 303 of CWA 1. Develop Water Quality Standards
2. Assess State Waters - meeting water-quality standards?
3. List Impaired Waters - aka 303(d) List
4. Conduct Total Maximum Daily Load (TMDL) Studies now expanded to Watershed Restoration and Protection Strategies (WRAPS)
What is a TMDL
The TMDL is simply the maximum load (pollutant quantity per year or day) that cannot be exceeded in order to meet water quality standards.
A TMDL is a load that is determined through a scientific process
How that load is met is determined with the stakeholders and detailed in the implementation plan
Depending on the water quality of the stream and watershed conditions achieving the required loading may take several years.
The heart of a TMDL study is the pollutant load allocation
Formula–
LA(s) + WLA(s) + Margin of Safety + Reserve Capacity =
Total Maximum Daily Load
LA Load allocations from nonpoint sources
WLA Waste load allocations from point/permitted sources
Margin of Safety
To account for potential scientific error
Reserve Capacity
Set aside for future development
Reducing Chloride at the Source
Prevention is the ONLY option
Same BMPs for protection and restoration
CMP lays out overall framework and recommendations for chloride reductions
Track progress
Monitor water quality conditions
Performance Based Approach
Focus on implementation of improved winter maintenance practices
Performance-based approach doesn’t focus on specific numbers to meet, but rather on making progress with BMPs
Consistent with MS4 permit requirements
Track existing practices, goals for implementing improved practices including schedules, and reporting on progress
Winter Maintenance Assessment tool in development will assist as a planning tool for this approach
Assist winter maintenance organizations to:
Document their current practices
Chart a path towards salt reduction
Develop a strategy unique to their operation
Evaluate small areas of winter maintenance
Provide insight into current operations
Shows user recommended practices (learning tool)
Allow a flexible approach for implementing BMPs
Winter Maintenance Assessment tool
Pre-public notice Draft TMDL available
http://www.pca.state.mn.us/programs/roadsalt.html
Up Next……
* TMDL Modeling & Loadings
* MS4 Permits
* Wastewater Permits
Why model?
Environmental conditions
Water quality model
Water quality target
Allowable chloride load
Choosing the right modeling approach
Management questions
System characteristics
Available resources
Model selection
Modeling process
Jan ‘13 • Introduced modeling approaches to Technical Advisory Committee (TAC)
Mar ‘13 • Proposed modeling approach to TAC for lakes – consensus agreement
Dec ‘13
• Proposed modeling approach to TAC for streams – consensus agreement • Recommended categorical MS4 WLA
Jan ‘14 • Reviewed modeling approaches with Inter Agency Team (IAT)
Apr ‘14
• Review stream modeling approach with TAC • Received confirmation on performance based approach
Jul ‘14 • Confirmed categorical WLA approach, zero reserve capacity, and margin of safety with TAC
Sep ‘14 • Review modeling and TMDL approach with Implementation Planning Committee (IPC)
TMDL = WLA + LA + MOS + RC
LA
•Non-MS4 runoff •Background
RC MOS
WLA
• Treatment Plants
• MS4 runoff
Lakes – annual runoff load
Set target concentration (C = 230 mg/L)
Calculate annual
runoff (Qv)
Calculate allowable load
( Wrunoff = Qv * C)
Impervious area
(GIS land use)
Annual precipitation
Calculate runoff
coefficient
Streams – seasonal runoff load
Set target concentration (C = 230 mg/L)
Calculate winter runoff
(Qv)
Calculate allowable load
( Wrunoff = Qv * C)
Winter precipitation
equivalent
Set runoff coefficient =
0.98
Runoff Load
Runoff load = WLAMS4 + LA + MOS
Runoff load = WLAMS4 + LAnon-MS4 + LAbackground + MOS
MOS = 10% of Runoff Load
90% * Runoff Load = WLAMS4 + LAnon-MS4 + LAbackground
Reserve Capacity (RC) & Margin of Safety (MOS)
RC = 0
BMP’s will be implemented on newly added impervious surfaces
Runoff volume increases with new impervious surface
MOS = 10% (explicit)
Accounts for scientific uncertainty
New Hampshire chloride TMDLs use 10% (explicit)
Shingle Creek and Nine Mile Creek - implicit
Natural background load
Natural Background = 18.7 mg/L (Novotny, 2008)
8% of runoff load: 0.08 * Runoff Load
Lake/Wetland AUID Watershed
Area (ac)
TMDL and Components (all values in lbs/yr of chloride)
Loading
Capacity
(TMDL)
WLA LA
Margin of
Safety MS4 Categorical Wastewater
Sources
Non-Permitted
Aggregate
Natural
Background
Battle Creek Lake 82-0091-00 4,326 2,153,699 1,766,033 0 0 172,296 215,370
Brownie Lake 27-0038-00 391 263,812 216,326 0 0 21,105 26,381
Carver Lake 82-0166-00 2,242 1,071,123 878,321 0 0 85,690 107,112
Como Lake 62-0055-00 1,850 994,078 815,144 0 0 79,526 99,408
Diamond Lake 27-0022-00 744 486,017 398,534 0 0 38,881 48,602
Kasota Ponds North 62-0280-00 3,070 2,250,690 1,845,566 0 0 180,055 225,069
Kasota Ponds West 62-0281-00 3,070 2,250,690 1,845,566 0 0 180,055 225,069
Kohlman Lake 62-0006-00 7,533 4,839,183 3,106,733 1,050,484 0 303,096 378,870
Little Johanna Lake 62-0058-00 1,703 1,224,242 1,003,879 0 0 97,939 122,424
Loring Pond (South Bay) 27-0655-02 34 9,764 8,007 0 0 781 976
Mallard Marsh 62-0259-00 3,070 2,250,690 1,845,566 0 0 180,055 225,069
Parkers Lake 27-0107-00 1,064 1,431,262 528,161 787,163 0 51,528 64,410
Peavey Lake 27-0138-00 776 205,995 165,889 3,692 0 16,184 20,230
Pike Lake 62-0069-00 5,735 3,591,268 2,943,971 1,059 0 287,217 359,021
Powderhorn Lake 27-0014-00 332 218,588 179,242 0 0 17,487 21,859
Silver Lake 62-0083-00 655 370,011 303,409 0 0 29,601 37,001
South Long Lake 62-0067-02 114,785 26,334,624 21,534,261 4,030 56,826 2,106,448 2,633,059
Spring Lake 27-0654-00 76 44,263 36,296 0 0 3,541 4,426
Sweeney Lake 27-0035-01 2,439 1,456,271 1,194,142 0 0 116,502 145,627
Tanners Lake 82-0115-00 1,732 826,520 677,746 0 0 66,122 82,652
Thompson Lake 19-0048-00 178 134,340 110,159 0 0 10,747 13,434
Valentine Lake 62-0071-00 2,404 1,165,072 955,359 0 0 93,206 116,507
Wirth Lake 27-0037-00 426 1,095,000 897,900 0 0 87,600 109,500
Stream AUID Watershed
Area (ac)
TMDL and Components (all values in lbs/yr of chloride)
Loading
Capacity
(TMDL)
WLA LA
Margin of
Safety MS4 Categorical
Wastewater
Sources
Non-Permitted
Aggregate
Natural
Background
Bass Creek 07010206-784 5,434 1,746,399 1,432,047 0 0 139,712 174,640
Bassett Creek 07010206-538 26,738 9,825,459 7,045,777 1,233,048 0 687,393 859,241
Battle Creek 07010206-592 7,246 2,328,721 1,909,551 0 0 186,298 232,872
Elm Creek 07010206-508 66,382 21,332,410 17,386,888 0 105,688 1,706,593 2,133,241
Judicial Ditch 2 07030005-525 1,587 510,115 418,294 0 0 40,809 51,011
Minnehaha Creek 07010206-539 109,151 35,997,083 28,679,140 1,004,128 0 2,806,140 3,507,675
Raven Stream 07020012-716 42,750 15,023,193 442,771 1,284,983 10,822,561 1,099,057 1,373,821
Raven Stream, East Branch 07020012-543 14,751 6,025,349 442,093 1,284,983 3,445,007 379,229 474,037
Rush Creek, South Fork 07010206-732 13,844 4,470,069 3,646,696 21,010 1,532 355,925 444,906
Sand Creek (South) - includes 07020012-
662 07020012-513 175,578 59,480,179 4,402,547 3,056,425 41,864,932 4,513,900 5,642,375
Unnamed creek (Headwaters to
Medicine Lk) 07010206-526 6,447 2,071,959 1,699,006 0 0 165,757 207,196
Unnamed creek (Unnamed ditch to
wetland) 07010206-718 793 254,852 208,979 0 0 20,388 25,485
Unnamed Stream (Unnamed lk 62-0205-
00 to Little Lk Johanna) 07010206-909 1,627 522,817 428,710 0 0 41,825 52,282
Sand Creek TMDL = 59,480,179 lbs/yr
Treatment Plant WLA (lbs/yr),
3,056,425 MS4 Categorical
WLA (lbs/yr), 4,402,547
LA - non-MS4 runoff
(lbs/yr), 41,864,932
LA - Background (lbs/yr),
4,513,900
MOS - (lbs/yr), 5,642,375
Performance-based approach for meeting TMDL and allocations
Optional approaches for implementing TMDL:
Percent reduction
Numeric limit
Performance-based BMP approach
Linking Permits and TMDLs
40 C.F.R. 122.44(d)(vii)(B)
Limits in NPDES permits must be consistent with the assumptions and requirements of any available waste load allocation in an approved TMDL.
40 C.F.R. 130.2(h)&(i)
WLAs are to be expressed in numeric form in TMDLs.
33 U.S.C 1342(p)(3)(B)(iii); 40 C.F.R. 122.44 (k)(2)&(3)
WQBELs for NPDES-regulated storm water discharges that implement WLAs in TMDLs may be expressed in the form of best management practices (BMPs)under specified circumstances.
Permit Language Part II.D.6
6. For each applicable Waste Load Allocation (WLA) approved prior to the effective date of this permit, the applicant shall submit the following information as part of the SWPPP document:
a. TMDL project name(s)
b. Numeric WLA(s), including units
c. Type of WLA (Le., categorical or individual)
d. Pollutant(s) of concern
e. Applicable flow data specific to each applicable WLA
f. For each applicable WLA not met at the time of application, a compliance schedule is required. Compliance schedules can be developed to include multiple WLAs associated with a TMDL project and shall include:
(1) Interim milestones, expressed as BMPs or progress toward implementation of BMPs to be achieved during the term of this permit
(2) Dates for implementation of interim milestones
(3) Strategies for continued BMP implementation beyond the term of this permit
(4) Target dates the applicable WLA(s) will be achieved
g. For each applicable WLA the permittee is reasonably confident is being met at the time of application, the permittee must provide the following documentation:
(1) Implemented BMPs used to meet each applicable WLA
(2) A narrative describing the permittee's strategy for long-term continuation of meeting each applicable WLA .
Permit Language Part III.E
E. Discharges to Impaired Waters with a USEPA-Approved TMDL that Includes an Applicable WLA For each applicable WLA approved prior to the effective date of this permit, the BMPs included in the compliance schedule at application constitute a discharge requirement for the permittee. The permittee shall demonstrate continuing progress toward meeting each discharge requirement, on a form provided by the Commissioner, by submitting the following: 1. An assessment of progress toward meeting each discharge requirement, including a list of
all BMPs being applied to achieve each applicable WLA. For each structural stormwater BMP, the permittee shall provide a unique identification (ID) number and geographic coordinate. If the listed structural stormwater BMP is also inventoried as required by Part III.C.2, the same ID number shall be used.
2. A list of all BMPs the permittee submitted at the time of application in the SWPPP document compliance schedule(s) and the stage of implementation for each BMP, including any BMPs specifically identified for the small MS4 in the TMDL report that the permittee plans to implement
3. An up-dated estimate of the cumulative reductions in loading achieved for each pollutant of concern associated with each applicable WLA
4. An up-dated narrative describing any adaptive management strategies used (including projected dates) for making progress toward achieving each applicable WLA
Required Submittals
At application (all application materials are subject to public notice) List of applicable TMDL WLAs approved prior to the effective date of the
permit BMPs implemented for TMDL WLAs already met Compliance schedules for TMDL WLAs not met Long term implementation strategy Target date
Annual reports All BMPs receiving credit Cumulative reductions achieved Planned BMPs Adaptive management strategies
Note: Permit requirements for this TMDL will not be effective until the following permit term.
Questions?
Contact us: Joshua Stock 651-757-2235, [email protected] Mary Hammes 651-757-2878, [email protected]
www.pca.state.mn.us/ms4
TMDL Wasteload Allocations vs. NPDES Permit Effluent Limits
TMDL Wasteload Allocations (WLAs) are developed for all NPDES permits for discharges that contain the pollutant of concern
NPDES permit Water Quality Based Effluent Limitations (WQBELs) are developed for all pollutants that… “may be discharged at a level which will cause, have the reasonable potential to cause, or contribute to an excursion above and State water quality standard….” [40CFR 122.44(d)(1)(i)]
A discharger may be assigned a TMDL WLA but not be required to meet a permit WQBEL
NPDES Permit Limit Evaluation
Reasonable Potential (RP) is calculated using: Low flow in the receiving water
Average Wet Weather (AWW) Flow – Municipal WWTP
Maximum Flow - Industrial
Actual monitoring data:
At least 10 data points
Coefficient of Variation (CV)
Chloride effluent limits developed for permits that exhibit RP to cause or contribute to a water quality standard violation
Monitoring requirements only for permits that do not have RP
Industrial Non-Contact Cooling Water/Reverse Osmosis Reject Water
0
50
100
150
200
250
Ch
lor
ide
(m
g/L
)
Boomerang Laboratories Inc.
Chloride (mg/L) Chloride Standard (mg/L)
Industrial Non-Contact Cooling Water
0
50
100
150
200
250
Ch
lor
ide
(m
g/L
)
St. Croix Forge
Chloride (mg/L) Chloride Standard (mg/L)
Reverse Osmosis Reject Water
0
50
100
150
200
250
Ch
lor
ide
(m
g/L
)
Medivators
limit Chloride (mg/L) Chloride Standard (mg/L)
Municipal Wastewater
0.000
0.200
0.400
0.600
0.800
1.000
1.200
1.400
1.600
0
100
200
300
400
500
600
700
De
cem
ber
-11
Ja
nu
ary
-12
Feb
rua
ry-1
2
Ma
rch
-12
Ap
ril-
12
Ma
y-1
2
Ju
ne
-12
Ju
ly-1
2
Au
gu
st-1
2
Sep
tem
ber
-12
Oct
ob
er-1
2
No
ve
mb
er-1
2
De
cem
ber
-12
Ja
nu
ary
-13
Feb
rua
ry-1
3
Ma
rch
-13
Ap
ril-
13
Ma
y-1
3
Ju
ne
-13
Ju
ly-1
3
Au
gu
st-1
3
Sep
tem
ber
-13
Oct
ob
er-1
3
No
ve
mb
er-1
3
De
cem
ber
-13
Ja
nu
ary
-14
Feb
rua
ry-1
4
Ma
rch
-14
Ap
ril-
14
Ma
y-1
4
Ju
ne
-14
Ju
ly-1
4
Au
gu
st-1
4
Sep
tem
ber
-14
Oct
ob
er-1
4
No
ve
mb
er-1
4
De
cem
ber
-14
Ja
nu
ary
-15
Feb
rua
ry-1
5
Ma
rch
-15
Flo
w (
mg
d)
Ch
lor
ide
(m
g/L
)
New Prague
Chloride (mg/L) Chloride Standard (mg/L) Flow (mgd)
Municipal Wastewater
0.000
0.100
0.200
0.300
0.400
0.500
0.600
0.700
0.800
0.900
0
100
200
300
400
500
600
700
800
900
Flo
w (
mg
d)
Ch
lor
ide
(m
g/L
)
Jordan WWTP
Chloride (mg/L) Chloride Standard (mg/L) Flow (mgd)
Municipal Wastewater
0.000
0.100
0.200
0.300
0.400
0.500
0.600
0.700
0.800
0.900
1.000
0
200
400
600
800
1000
1200
No
ve
mb
er-1
2
De
cem
ber
-12
Ja
nu
ary
-13
Feb
rua
ry-1
3
Ma
rch
-13
Ap
ril-
13
Ma
y-1
3
Ju
ne
-13
Ju
ly-1
3
Au
gu
st-1
3
Sep
tem
ber
-13
Oct
ob
er-1
3
No
ve
mb
er-1
3
De
cem
ber
-13
Ja
nu
ary
-14
Feb
rua
ry-1
4
Ma
rch
-14
Ap
ril-
14
Ma
y-1
4
Ju
ne
-14
Ju
ly-1
4
Au
gu
st-1
4
Sep
tem
ber
-14
Oct
ob
er-1
4
No
ve
mb
er-1
4
De
cem
ber
-14
Ja
nu
ary
-15
Feb
rua
ry-1
5
Ma
rch
-15
Flo
w (
mg
d)
Ch
lor
ide
(m
g/L
)
Montgomery WWTP
Chloride (mg/L) Chloride Standard (mg/L) Flow (mgd)
Next Steps
Permits for discharges with sufficient chloride data will be evaluated for RP.
Permits for discharges without sufficient chloride data will include chloride monitoring requirements.
Reissued permits for discharges with RP will include chloride effluent limits.
Minimum monitoring requirements, sufficient to ensure that chloride concentrations remain low, will be included in reissued permits for discharges that that do not have RP.