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

April 28, 2015

Water Quality Standards Assessment and Listing Chloride

Katrina Kessler Pam Anderson

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

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

The Salt Dilemma

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

TCMA Chloride Project History

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

Stakeholder Collaboration

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

Stakeholder

Meeting

Notes

Minutes

Presentations

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

Sources & Water Quality

Sources of Chloride

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

www.pca.state.mn.us/programs/roadsalt.html

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

Goal of the CMP

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

Chloride Management Strategies

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

brooke.asleson@state.mn.us

Questions

Chloride Extravaganza 2015:

Winter Maintenance Assessment tool (WMAt)

Photo: FCI

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

Winter Maintenance Assessment tool

(WMAt)

As part of Minnesota’s Chloride

Management Plan

Select the modes:

BMP mode looks like this:

Will give background insight

You can offer us insight or suggestions:

Wikipedia? Looking for feedback

Generate reports:

If you choose salt savings mode, you will have to fill in

data on salt usage, salt store and other topics

The Salt Savings reports are still under development

but are expected to be similar to these….

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

joe@roundville.gov

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

Be BOLD

Help Minnesota lead the

way to lower chloride winter

maintenance!

I look forward to working with you on this!

Connie Fortin – Fortin Consulting Inc. connie@fortinconsulting.com

Any Questions?

Regional Management

Assistant Division

Chloride Overview

Rick Patraw - Manager

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?

Questions???

CHLORIDE EXTRAVAGANZA

A P R I L 2 8 , 2 0 1 5

TCMA Chloride tmdl

overview

Tweet your questions/comments

to @brookeMPCA

#lowsaltMNwaters

What is a TMDL anyways?

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

How will we meet the goals of the TMDL (and protection)?

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

Adaptive Management

Pre-public notice Draft TMDL available

http://www.pca.state.mn.us/programs/roadsalt.html

Up Next……

* TMDL Modeling & Loadings

* MS4 Permits

* Wastewater Permits

ALL METRO STAKEHOLDER CHLORIDE MEETING

A P R I L 2 8 , 2 0 1 5

Chloride TMDL

Modeling Overview

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

TMDL modeling approach for lakes

Chloride < 230 mg/L

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

Stream model

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

Treatment Plant WLAs

WLATP = Design flow * Water Quality Criterion

= Qdesign * 230 mg/L

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

South Long Lake TMDL = 26,334,624 lbs/yr

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

Bassett Creek TMDL = 9,825,459 lbs/yr

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

Discussion

Municipal Separate Storm Sewer System (MS4) Permits

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, josh.stock@state.mn.us Mary Hammes 651-757-2878, mary.hammes@state.mn.us

www.pca.state.mn.us/ms4

Wastewater Permits

Statewide Distribution of Effluent Chloride Data

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.