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8/10/2019 Nutrient Removal:Costsand Benefits,Degrees of Difficulty, andRegulatory Decision Making
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8/10/2019 Nutrient Removal:Costsand Benefits,Degrees of Difficulty, andRegulatory Decision Making
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How to Participate Today
How to participate Audio Modes
Listen using Mic&Speakers
Or, select Use Telephoneand dial the conference
Submit your text questionsusing the Questions pane
A recording will be availablefor replay shortly after thisweb seminar
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Agenda2:00-2:05 Welcome and Introduction
Amit Pramanik, WERF2:05-2:30 Finding the Sustainable Balance on Nutrient
Removal
Michael Falk, HDR, Inc.
2:30-3:10 Research on Characterization and Speciationof N and P
David Stensel, University of Washington
3:10-3:35 Managing Water Quality Translating Research
to PracticeDave Clark, HDR, Inc.
3:35-3:45 Questions and Answers
3:45 Adjourn
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Michael Falk, PhD, PE
Wastewater process engineer at HDR
Engineering
Specializes in nutrient removal and
optimization of wastewater reactors
Ph.D. from UC Davis with an emphasis onthe microbial ecology of activated sludge
This work is part of WERFs Nutrient
Challenge titled Striking a Balance
between Nutrient Removal andSustainability
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Tradeoff Between NutrientRemoval and Sustainability
Michael Falk, PhD; J.B. Neethling, PhD; Dave Reardon, BCEEHDR Engineering, Inc.
Amit Pramanik, PhD, BCEEM
Water Environment Research Foundation
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Acknowledgements
WERF:
Amit Pramanik, PhD, BCEEM
Reviewers:
Kartik Chandran, PhDMichael Stenstrom, PhD, PE, BCEEHDR:
JB Neethl ing, PhD, PE, BCEEDave Reardon, PE, BCEE
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Presentation Outline
Focus/Objectives
Background
Results & Discussion
Potential Impacts toWastewater Plants
Summary & Conclusions
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The Nutrient Storm is aNational Phenomenon
Long Island Sound
DO low in half ofsound
Water quality tradingprogramimplemented
Gulf of Mexico
Large dead zone
Importance ofphosphorus
SacramentoRegional
Concern over
ammonia/nitrateloads in Delta
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Focus/Objectives
Determine sustainability impacts of fivelevels of treatment for 10 mgd plant
Determine if there is a point of
diminishing returns for sustainabilitywith increased treatment
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What is Sustainability?
Energy
Polish YourGreen Image
Greenhouse Gas
Social
Environmental
Stewardship
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Sustainability
Sustainability is Often Described asAchieving the Triple Bottom Line
Water Quality
Greenhouse Gas
Odors/Air Quality
Economics/Life-Cycle Cost
Analysis
Waste Products Consumables
Social/Community
Impacts
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What Did We Consider for theTriple Bottom Line?
Economic Pillar:Total Project Cost
O&M Cost
Environmental Pillar: GHGs (Energy Demand, Chem
manufacturing/hauling, N2O, biosolidshauling)
Water Quality
Ancillary Benefits of IncreasedTreatmentSocial Pillar:
Discussion in WERF Report
Existing metrics (Health)
Future metrics (Social)
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Treatment Level Objectives
LevelBOD
(mg/L)TSS
(mg/L)TN
(mg N/L)TP
(mg P/L)
1 30 30 - -
2
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Level Primary Ferm.
Act Sludge
Relative
Footprint
High
Rate
Clar. Filter MF/RO
Return-
Stream
Treatment
Metal
Salt
(Chem.)
Methanol
(Chem.)
1
1X
2
2X
Optional Opt ional
3
2-2.5X
4
2-2.5X
Denit.
5
2-2.5X
Denit.
a
Treatment Unit Processes
a RO requires brine management (assumed deep well injection)
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System Inputs
(Thicken/Digest/Dewater)
Wastewater
CollectionLiquid Stream
Treatment
Discharge
Plant Boundary
Boundary for this Study
Biological Solids Treatment
GHG
EnergyProduction
GHG
Chem Mining,
Manufacturing,
& Hauling
GHG
GHG
GHGGHG
Solids
Disposal
GHG
Deep Well
Injection
(Level 5)
GHG
Biosolids
Hauling
GHGCogen
GHG
Tertiary Add-On
Disinfection
GHG
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GHG Distribution
-2,000
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
18,000 N2OEmissions (w/Data Range as Bars)
Biosolids Hauling and CH4 Emissions
DeepWell Injection
Aeration
ChemicalsPumping/
Mixing
Miscellaneous
Cogeneration
CO2 eq mt/yr
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Incremental GHG per Additional
lb N or P Removed
3
18 23
338
0.5
16
190
3,400
0
1
10
100
1,000
10,000
Level 1 to 2 Level 2 to 3 Level 3 to 4 Level 4 to 5Incremen
talGHG
Increase
perAdditionallb
NPRemoved(CO2eq
lb/N
orPlb)
Incremental GHG Increase per Change in Treatment Level for N
Incremental GHG Increase per Change in Treatment Level for P
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Potential Algae Production
0
2,500
5,000
7,500
10,000
12,500
15,000
17,500
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
Level 1 Level 2 Level 3 Level 4 Level 5
GHG
Emissions(CO2
eqmttons/yr)
Alg
aeProductionperTreatmentLevel
(lbalga
e/d)
Algae Production GHG Emiss ions
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Ancillary Benefits ofNutrient Removal
Lower BOD and TSS discharge load
Higher removal of micro-constituentsand metals
Water more conditioned for filtration,disinfection, and reuse applications
Fewer algal blooms Greater process stabil ity from the
anaerobic/anoxic zones serving as
selectors
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Whats It Going to Cost Youfor a 10 mgd Plant?
Treatment Level
Total ProjectCosts
($ Million) i
OperationsCost
($/MG) ii
Total PresentWorth
($ Million) ii i
1 (No N/P Removal) 93 250 110
2 (8 mg N/L; 1 mg P/L) 127 350 150
3 (4-8 mg N/L; 0.1-0.3 mg P/L) 144 640 180
4 (3 mg N/L N;
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Summary/Conclusions
1. GHG impacts from all levels of treatment aredominated by energy consumption
2. Levels 4 & 5 may have sustainability impacts thatoutweigh potential water quality improvements
3. Why even discharge Levels 4/5?
4. Capital and operating costs may make Level 4
and 5 treatment difficult to implement withratepayers
5. Use a more holistic approach to watershednutrient management
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Potential Impacts toDischargers
Nutrient wave is coming
Impacts on site constrained plants
(nutrient removal requires MOREspace)
More energy and chemicals Additional operators (more skilled)
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H. David Stensel, PhD, PE, BCEE
Professor of civil and environmental engineering, University
of Washington, Seattle, WA
Principal research activities: biological wastewater
treatment, biological nutrient removal, biodegradation of
micropollutants, anaerobic digestion methods, and water
reuse
ASCE Rudolf Hering Medal, twice received the WEFHarrison Prescott Eddy Medal, and the Water Environment
Bradley Gascoigne Medal for research publications
Registered professional engineer and a diplomat in the American Academy of
Environmental Engineers
B.S. degree in Civil Engineering from Union College in Schenectady, N.Y. andM.E. and Ph.D. degrees in environmental engineering from Cornell University.
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Coconuts and Bananas in BNR Effluents
Research on Characterization and Speciation
of Effluent Nitrogen and Phosphorus
WERF Research
Webinar
October 5, 2011
H. David Stensel, PhD, PE, BCEE
University of Washington
Seattle, WA
36
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WWTP Effluents are a Source ofNutrients to Surface Waters
Nitrogen (N) and Phosphorus (P) are removedfrom wastewater effluents to limit nutrientenrichment and eutrophication in surface waters
Nutrients enrich streams and lakes to promotehigher algae and plant growth
Eutrophication causes low dissolved oxygen to
harm aquatic life
Chesapeake Bay, Long Island Sound, Gulf ofMexico, many coastal estuaries and fresh water
impoundments are impaired due to nutrients 37
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WWTPs Are Point Source DischargersRegulated for Effluent N and P
Effluent permit concentrations typically based on not toexceed total nitrogen (TN) and/or total phosphorus (TP)concentration
Range of low effluent TN concentration limits
TN 3.0 mg/L common in Chesapeake and Floridacoast
TN 2.0 mg/L or 1.0 mg/L applied in a few cases
Range of low effluent TP concentration limits
0.10 to 0.20 mg/L is becoming more common
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The Dissolved Portion of TN and TP is a
Major Component at Low Effluent Limits
~ 0.01 mg/LpOrg N
DON
NH3-N
~0.81.5 mg/L
~ 0.50 mg/L
NOx-N~ 1.5 mg/L
TN~3.0 mg/L
TP~0.10 mg/L
pP
DP
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The Problem with Trying to Reduce
DON and DP Lower
Biological processes can bepushed to meet low NH4-Nand Nox
DON residual observed
DON can increase withmore aeration time
BNR effluent DON variesfor different WWTPs
Increase chemical dose candrive reactive P to lowerconcentration
But DP is not all reactive P
0
3
6
9
12
15
Primary
effluent
Anaerobic
effluent
Anoxic
effluent
Aerobic
effluent
Concentration,gN/m3
0.45-1.2 m
0.1-0.45 m
< 0.1 m
Example:
DON profile across Gdansk, Poland
BNR WWTP -
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But effluent DON
concentration varies for
different WWTPs
Meeting TN3.0 mg/L
can be possible,unreliable,
or impossible
0.0
0.5
1.0
1.5
2.0
2.5
3.0
.01 .1 1 5 10 2030 50 7080 90 95 99 99.999.99
DON Effluent Concentrations
from 33 BNR Facilities
Percent
DONConc.,mg/L
41
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Chemical Analysis
Total P
Dissolved P (DP)
Filtered
Particulate P (PP)
Reactive Dissolved P(RDP) Non-Reactive Dissolved P(nRDP)
Total Reactive P
(TRP)
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Non-reactive Dissolved P is very
significant in BNR tertiary effluents
with high chemical dose
0%
20%
40%
60%
80%
100%
NDWRFSDWRF MBR Ruidoso CUMF 1st BW 2nd BW TMF MSWTP Z2E
Pcomposition
PP
DOP
SRP
Biological Removal ACTI FiltrationBlue WaterMBR Membrane
nRDP
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C d B P l
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Coconuts and Bananas Postulate
Bo Li University of Washington
Some DON and nRDP is readily available
to algae and some is not
Reactive P (PO4-3)
Amino acids
Inorganic P
Apatite
( Ca3(PO4)2 )
AlPO4 FePO4
.
RecalcitrantsN and P in humic substances
Organic P Polyphosphate
Inositol hexakisphophate
L--phosphatidyl choline
phosphoenol pyruvate
Glycerophosphate .
Bioavailable
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Readily bioavailable
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WERF Nutrient Challenge ProgramEvaluate Bioavailability of Effluent DON and DP
Professor David Sedlak, UC Berkeley
Protocol for Algae Bioassay for effluent DON
Evaluate fraction of recalcitrant DON at BNR WWTPs
Evaluate type of constituents resistant to bioavailability Professor Michael Brett, University of Washington
Protocol for Algae Bioassay for effluent DP
Evaluate fraction recalcitrant P at BNR WWTPs and Tertiary
Treatment with Chemicals
Develop long term bioassay test
Evaluate type of constituents resistant to bioavailability
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Evaluate effect of Tertiary Treatment Processon bioavailable P fraction in effluent
Identify banana
Assess relationship between total reactive P,BAP, and total P
Find a better way to identify banana
Test Bioavailability of P speciesWhich species of banana will be more
tasty?
Or stated another way. . .
Studies Used Bioassay Methods
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Selenastrum capricornutumInitial concentration:10,000 cells/ml
Incubate for 14 days.
Culturing condition:
1.Continuous Illumination
2.Temperature: 24 2C
3. shake at 110 rpm.
Studies Used Bioassay Methods
Cell Counts or Chlorophyll a to
Measure Algae Production
Bo Li
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Highlights of Key Findings for DON
Developed method to separate coconuts and
bananas Hydrophobic DON was not bioavailable
to algae in tests
Protocol developed to minimize effect ofinorganic N in samples
20-25% of effluent DON was recalcitrant for
plants with low effluent TN (
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Hydrophobic Fractions of
WWTP Effluent DON
0.0
0.5
1.0
1.5
2.0
TMWRF KWWTP BRWRF SJWTP NDWRF SDWRF NAWTP RVWTP
Location
DON
(mg
N/L)
Whole effluent
Hydrophobic DON
Hydrophilic DON
A
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Highlights of Key Findings for DP
For tertiary treatment with chemicals the %
bioavailable (bananas) decreased with
increasing chemicals and lower effluent DP
The recalcitrant effluent DP fraction ranged
from 10 to 80% depending on the degree of
treatment
P in humic substance was not bioavailable
% Bi il bl P i Effl t TP
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% Bioavailable P in Effluent TP
Decreases as Effluent P Decreases
for Tertiary Chemical Treatment
0
20
40
60
80
100
10100100010000
BAP%&TP
Model Predicted
TP (ug/L)
BAP%
City of Spokane
pilot plant
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For Other Facilities Tested % BAP Varied
from 10-50% for TP from 0.02 to 0.20 mg/L
0
20
40
60
80
10100
Model Predicted
NDWRF
SDWRF
MBR
CUMF
1st BW
TMF
MSWTP
TP (ug/L)
BAP%
i d h bi i
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If coconut will turn to banana?
Investigate Hydrophobic Separation on
BAP and Long Term BAP Analysis
Wh i h Si ifi
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What is the Significance
of These Results?
Not all effluent N and P species from nutrient removal
WWTPs behave the same
Water quality models do not adequately consider speciation of
N and P with different bioavailability
For very low effluent TP and TN goals the fraction of P andN that is recalcitrant is more significant and more difficult
to remove
Methods are available to evaluate recalcitrant fractions of
effluent DON and DP Tool may be used to understand why some facilities have
much higher effluent DON
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QUESTIONS?
Many thanks to Professor David Sedlak, Michael Brett, Scott
Smith and April Gu and Dr. Haizhou Liu and Joonseon Jeong
and Bo Li and WERF supporters for making this possible.
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Dave Clark, P.E.
HDRs National Director of Wastewater; leads strategicefforts in understanding wastewater market issues as they
affect HDR clients
Over 25 years of experience in the wastewater industry
Works with local offices and business class technical
leads to outline technical skills needed to assist clients in
managing wastewater
Managed a broad range of wastewater projects ranging
from planning to detailed design and construction
management, to discharge permit negotiations and TMDL
Implementation Plans
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Nutrient Removal
Managing Water Quality Translating Research
to PracticeWERF Webinar
October 5, 2011
David L. ClarkHDR Engineering
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Nutrient Removal
Managing Water Quality
Translating Research to Practice Regulatory Trends
Numeric Nutrient Standards
Treatment Technology Issues Regulatory Solutions
Discharge Permitting
Key Nutrient Management
Issues
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Nutrient Removal
Regulatory TrendsNumeric Nutrient Standards
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Nutrient Removal
Acting Assistant Administrator Nancy Stoners March 16, 2011
Memorandum to EPA Regional Administrators
Working in Partnership with States to Address Phosphorus and NitrogenPollution through Use of a Framework for State Nutrient Reductions
place new emphasis on working with states to
achieve near-term reductions in nutrient loadings."
nitrogen and phosphorus pollution has the potentialto become one of the costliest and the most
challenging environmental problems we face
It has long been EPA's position that numeric nutrient
criteria targeted at different categories of water bodies
and informed by scientific understanding of the
relationship between nutrient loadings and waterquality impairment are ultimately necessary for
effective state programs.
EPA will support states that follow the framework but,
at the same time, will retain all its authorities under
the Clean Water Act
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Nutrient Removal
Challenges in Establishing Nutrient Criteria
F 150 mg/m2 Chla D 1,250 mg/m2 Chla
Scientific and Technical Basis for
Montanas Numeric Nutrient Criteria
Identifying Threshold of Harmto Beneficial Uses
Numeric Nutrient Criteria
Stressor Response
Response Variables D.O., pH
Chla, Benthic Algae
Macroinvertebrates
Fisheries
Recreation/PublicPerception
Translation of In-stream
Criteria to Effluent Discharge
Permit Limits
Typical Concentrations ThatProtect Uses Are Low MikeSuplee, MDEQTotal Phosphorus 0.05 mg/lTotal Nitrogen 0.30 mg/l
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Nutrient Removal
Treatment Technology Issues
Regulatory Solutions
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Nutrient Removal
Water Quality and
Advanced Wastewater Treatment Waterbody Numeric Nutrient Standards
Based on Natural Conditions Are Very
Low
Lower Than Treatment Technologies
Are Capable of Achieving If AppliedEnd-of-Pipe
Effectiveness of Advanced Treatment
for Nutrient Removal
Variability in Treatment Performance
Reliability Effluent Speciation
Bioavailability
Translation to Discharge Permits
303(d) Impairment Listings and TMDLs
Direct Application to Discharge Permits
Ideal Median Reliable
Neethling, JB; Stensel, H.D.; Parker, D.S.; Bott, C.B.; Murthy, S.;
Pramanik, A.; Clark, D. (2009) What is the Limit of Technology
(LOT)? A Rational and Quantitative Approach. Proceedings of the
WEF Nutrient Removal Conference, Washington DC, Water
Environment Federation, Alexandria, Virginia.
Treatment Performance Statistics
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Nutrient Removal
Regulatory Solutions Water Quality Variances,
Treatment Technology Standards, Affordability Tests
Key Areas
Permit Requirements
Below the Capabilities ofWastewater Treatment
Technology
Water Quality Variances
Treatment TechnologyLimits
Affordability Tests
Case Study Examples
Montana Senate Bill 95 andSenate Bill 367 Affordability Test (1% MHI)
Limit of Technology
Treatment Technology Std(TP 1 mg/L, TN 10 mg/L
Wisconsin Dual Legislation Numeric Nutrient Criteria
Treatment Technology Standard
Adaptive Management
Colorado New Regulation #85 Numeric Nutrient Criteria
Treatment Technology Standard
Adaptive Management
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Nutrient Removal
Wisconsin
Midwest Environmental Advocates Notice ofIntent to Sue EPA Nov 23, 2009
Failure to Perform its Non-discretionary
Duty to Promulgate Numeric Nutrient
Criteria
2010 Rulemaking
Phosphorus Criteria for Streams
Streams 0.075 mg/L
Large Rivers 0.100 mg/L
Chapter NR217 Effluent Standards and
Limitations for Phosphorus
Implementation by AdaptiveManagement
Watershed Adaptive Management Option
NPS + Stormwater
Numerical EffluentLimitations
1st Permit
TP 1 mg/L
Rolling 12 Mo. Ave
2nd Permit
TP
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Nutrient Removal
Colorado Initial Nutrient Criteria for Rivers and Streams
February 9, 2010
Selecting Numeric Nutrient Criteria That Allow
5% Decrease in Biological Condition
Multi Metric Macroinvertebrate Index
Regulation #31 Basic Standards and
Methodologies for Surface Water
New Section 31.17 Nutrient Interim Values After May 31, 2017 and Prior to May 31, 2022
Regulation #85 Nutrients Management
Control Regulation Establishes Numerical Effluent Limitations
Existing Plants
First Level BNR (3-stage)
TP 1 mg/L
TIN 10 mg/L
New Plants
Enhanced BNR (4 & 5-stage)
TP 0.7 mg/L
TIN 7 mg/L
Running Annual Median
Rivers and Streams Cold Water Warm Water
Chl a mg/m2 150 150
TP, ug/L 110 160
TIN, ug/L 400 2,000
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Nutrient Removal
Montana 150 mg Chla/m2 Considered
Nuisance Threshold by Public
Rarely Occurs in Western
Montana Reference Streams
Harm-to-Use Threshold for
Salmonid Streams Salmonid Growth Enhanced by
Productivity Up to 150 mg Chla/m2
DO Problems Begin at Higher Levels
150 mg Chla/m2 More Common
in Prairie Streams (E. MT)
2009 Senate Bill 95 Variance Temporary Nutrient
Standards
Economic Hardship
Substantial and Widespread
Targeted 1% MedianHousehold Income
Limits of Technology
2011 Senate Bill 367
MDEQ TP = 0.100 mg/L TN 5
mg/L Monthly Average
League of Cities TP = 1 mg/L
TN 10 mg/L Seasonal Average
F 150 mg/m2 Chla D 1,250 mg/m2 Chla
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Nutrient Removal
Discharge Permitting
Key Nutrient Management Issues
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Nutrient Removal
Appropriate Discharge
Permit Guidance for Nutrients Translation water quality criteria to
NPDES to permit limits
Critical interpretation of water quality
issues
Pre-formulated permit guidance
from EPA and States often focused
on toxics
Appropriate averaging periods Variability in low nutrient plant
performance
Over-specifying effluent discharge permit limits will not
provide significant additional water quality protection
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Nutrient Removal
Nutrients Differ from ToxicsNutrients
No Immediate Impact
Aside from Ammonia
Watershed Scale Impacts
Nutrient Enrichment Leads toAquatic Growth
Algal Response Over
Longer Periods
Longer Averaging Period
Appropriate for Nutrients
Seasonal or Annual Averages
Appropriate
Treatment Technology
Variability at Low Levels in the
Best Technologies
Toxics
Acute and Chronic Impacts
on Aquatic Life
Chlorine, Metals, Organics
Near-field (mixing zone) andFar-field (watershed)
Impacts
Long Term Response
Average Limits
Short Term Response
Maximum Limits Required
Treatment Technology
Available Technology to
Prevent Excursions
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Nutrient Removal
Permit Structure Long Term Seasonal
Averages, Seasonal Mass LimitsKey Areas Translation of TMDL
Requirements to Effluent
Discharge Permits
Appropriate Averaging Periodsfor Nutrient Limits
Maximum Day and Maximum
Week Dilemmas
Effluent Mixing Zones
Permit Requirements Below theCapabilities of Wastewater
Treatment Technology
Novel NPDES Permit
Approaches
Case Study Examples
Chesapeake Bay TMDL
Jim Hanlon Memo on Annual Averaging
Nitrogen and Phosphorus
Tualatin River Clean Water Services
Seasonal Median TP Concentration Las Vegas Wash City Las Vegas, CCSD,
Henderson
Seasonal Mass TP Loading Shared
Between 3 Dischargers
Spokane River DO TMDL
Seasonal Mass Loading Limits forPhosphorus, NH3N, CBOD
Coeur dAlene (Region 10 EPA)
Spokane County (Washington Ecology)
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Nutrient Removal
NPDES Permitting Regulations
40 CFR 122.45(d) requires that all permit limits be
expressed as average monthly limits and average weekly
limits for publicly owned treatment works (POTWs) and
as both average monthly limits and maximum daily limitsfor all others, unless impracticable.
Individual permit wri ters in every nutr ient limited watershed must interpret these
NPDES regulations and the definition of impracticable with limited guidance
Maximum monthly, weekly, and daily limi ts likely to be exceeded by even the best
designed and operated low nutrient treatment facil ities
Effluent N and P concentration is h ighly variable for even the best designed andoperated low nutrient treatment facili ties
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Nutrient Removal
Case Study: Chesapeake BayDaily Maximum, Weekly Average andMonthly Average Limits Not Mandatory
Guidance from EPA Headquarters
Office of Wastewater Management
Annual Permit Limits for Nitrogen
and Phosphorus for PermitsDesigned to Protect Chesapeake
Bay
permit limits expressed as an
annual limit are appropriate and
that it is reasonable in this case
to conclude that it is
impracticable to express permit
effluent limits as daily maximum,
weekly average, or monthly
average effluent limitations.
Jim Hanlon, Office of WastewaterManagement, March 3, 2004
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Nutrient Removal
Variety of Successful Permit Structures
Nationally for NutrientsLocation Total Phosphorus
LimitsComments
Clean Water Servicesof Washington
County, OR
0.100 mg/l Monthly Median, May 1to Oct 31
Watershed Permit
Las Vegas, ClarkCounty, Henderson, NV
334 lbs/day(130/174/30 lbs/day)
Mar 1 to Oct 31Cooperative Agreementto Share for Flexibi lity
Alexandria, VA 0.18 mg/l and 37 kg/day
0.27 mg/l and 55 kg/day
Monthly Average
Weekly Average
Concentration Only, Mass Only, Both Seasonal Limits
Mean or Median
Shared Capacity
Case Study Example: Spokane River Dischargers
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Nutrient Removal
(Washington Ecology, Idaho DEQ, EPA Region 10)
Dissolved Oxygen TMDL
Very Restrictive
Cumulative Anthropogenic
D.O. Depression
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Nutrient Removal
Permit Structure Effluent LimitsMass and Concentration
Long Averaging Periods
Preferred
Maximum monthly, weekly, and
daily limits likely to beexceeded by even the best
designed and operated low
nutrient treatment facilities
Individual permit writers in
every nutrient limitedwatershed must interpret these
NPDES regulations and the
definition of impracticable
with limited guidance
Mass Only
Mass Limits Provide Greater
Flexibility
Supports Effluent Reuse
Supports Trading/Water QualityOff-sets
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Nutrient Removal
Permit Structure Nutrient Speciation
and BioavailabilityKey Areas
Low N and P Effluent
Speciation
Refractory N and P Not Biodegradable
Bioavailability?
Effluent Limits Based on Total
or Inorganic N and P?
Inorganic Limits Avoid
Refractory Constituents
Case Study Examples
Onondaga Lake TMDL, Syracuse,NY
Onondaga County (NYDEC)
Spokane River DO TMDL Spokane County (Washington
Ecology)
Coeur dAlene (Region 10 EPA)
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Question & Answer Session
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please follow the instructions
on the next slide.
Q & A
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Q & A
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Closing & Follow Up
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Closing & Follow-Up
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will follow. We appreciate your feedback.
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