understanding compliance schedules - ezview.wa.gov river clean... · 7 ppq 1 ppq washington 59-105...
TRANSCRIPT
Understanding
Compliance Schedules
Pat Hallinan
Water Quality Program
Options Considered for Issuing
Permits
Narrative Limits?
End-of-Pipe Limits?
Compliance Schedule?
No Compliance Schedule?
Compliance Monitoring
with Method 608
Compliance Monitoring
with Method 1668?
Source Reduction/
Participation in SRRTTF
Effectiveness Monitoring
with Method 1668
Options Considered for Issuing
Permits
Narrative Limits?
End-of-Pipe Limits
Compliance Schedule
No Compliance
Schedule
Compliance Monitoring
with Method 608
Compliance Monitoring
with Method 1668?
Source Reduction/
Participation in SRRTTF
Effectiveness Monitoring
with Method 1668
Options Considered for Issuing
Permits
Narrative Limits?
End-of-Pipe Limits
Compliance Schedule
No Compliance
Schedule
Compliance Monitoring
with Method 608
Compliance Monitoring
with Method 1668?
Source Reduction/
Participation in SRRTTF
Effectiveness Monitoring
with Method 1668
Options Considered for Issuing
Permits
Narrative Limits?
End-of-Pipe Limits
Compliance Schedule
No Compliance
Schedule
Compliance Monitoring
with Method 608
Compliance Monitoring
with Method 1668?
Source Reduction/
Participation in SRRTTF
Effectiveness Monitoring
with Method 1668
What is a Compliance Schedule?
• Clean Water Act, Section 502, General Definitions:
“Schedule of Compliance" means a schedule of remedial measures including an enforceable sequence of actions or operations leading to compliance with an effluent limitation, other limitation, prohibition, or standard
Compliance Schedule Principles Water Quality Based Effluent Limits
• EPA Guidance:https://www3.epa.gov/npdes/pubs/memo_
complianceschedules_may07.pdf
• Includes list of eleven (11)
principles in developing
compliance schedules to meet
water quality based effluent limits
Permitting Option
No Compliance Schedule:
• WQ based end-of-pipe limit (7 pg/L)
• Compliance testing using EPA
Method 608
• Elevated method detection level
pg/L doesn’t show non-compliance
• We considered the option of not
setting a compliance schedule
?
8 MGD5 - 160 ppq
2 MGD5-160 ppq
56 MGD5-160 ppq
8.6 MGD5-160 ppq
6.8 MGD5-160 ppq
Idaho Spokane Tribe1 ppq7 ppq
Washington
59-105
Latah Creek3500 – 8287 MGD7 - 1053 ppq
10-207
9-1356-1693 - 33
Stormwater5200 ppq
0-60,000
NOTE: values are for illustrative purposes only
?
“Quick and Defensible” = Traditional permitting approach
8 MGD5 - 160 ppq
2 MGD5-160 ppq
56 MGD5-160 ppq
8.6 MGD5-160 ppq
6.8 MGD5-160 ppq
Idaho Spokane Tribe1 ppq7 ppq
Washington
59-105
Latah Creek3500 – 8287 MGD7 - 1053 ppq
10-207
9-1356-1693 - 33
Stormwater5200 ppq
0-60,000
NOTE: values are for illustrative purposes only
Permitting Option
Compliance Schedule:
• WQ based end-of-pipe limit (7
pg/L)
• Set a compliance date to meet
end-of-pipe limit
Compliance Schedule Principles
from EPA Guidance
Ecology must make a reasonable
finding that:
1. Compliance with the limitation is
required “as soon as possible”
2. Schedule will lead to
compliance with the effluent
limitation
?
“Manage the end point” = compliance schedule
8 MGD5 - 160 ppq
2 MGD0 ppq
56 MGD5-160 ppq
8.6 MGD5-160 ppq
6.8 MGD5-160 ppq
Idaho Spokane Tribe1 ppq7 ppq
Washington
59-105
Latah Creek3500 – 8287 MGD7 - 1053 ppq
10-207
9-1356-1693 - 33
Stormwater5200 ppq
0-60,000
NOTE: values are for illustrative purposes only
Antibacksliding Issues
• The Clean Water Act prohibits the
re-issuance of permit with less
stringent limitations
–However, there are exceptions!
• Could we backslide on permit
limits/compliance schedules in future permit renewals?