Phil Argiroff, Chief, Permits Section Water Resources Division, MDEQ October 20, 2016

Protect and Monitor ◦ 4 Great Lakes

◦ 3,288 miles of Great Lakes shoreline

◦ 11,000 inland lakes

◦ 36,000 river miles

◦ 6.5 million acres of wetlands

◦ 70,000 acres of critical dunes

For swimming, fishing, drinking water, and aquatic ecosystems.

21st Century Infrastructure Commission Assess current condition

Benchmark other states and nations

Comprehensive vision and how do we get there

Water Strategy – Invest in Water Infrastructure

Asset Management

SAW grants

Capacity Management, Operations and Maintenance (CMOM) Plans

Fiscal Sustainability Plans (FSP)

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Current Efforts

Construction Permits (Part 41)

NPDES Permits (Part 31), Asset Management Plans

New Efforts

CMOM

Construction permits for any alterations that serve the public

Ten States Standards provides design guidance Redundancy required Flow capacity and ability to treat ◦ Handle the 25-yr/24-hr storm without bypass ◦ Meet NPDES effluent limits

Correct SSOs/CSOs, prevent backups Require facilities be properly operated and

maintained

Part 41 – Rule 55(1) ◦ Sewerage systems shall be operated and maintained at all

times as efficiently as possible in a manner which minimizes discharges of excessive pollutants.

NPDES Permits – Part II.D.3, Facilities Operation ◦ The permittee shall, at all times, operate and maintain all

treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit…

DEQ - Asset Management 7

• Governor’s 2011 Infrastructure Message - sustainability and AM for sewer and water

• DEQ is supportive of AM for sewer (and water)

• DEQ has started a NPDES regulatory initiative for WWTPs/collection systems, and has a state grant program for AM with the potential for a grant (SAW)

• Assistance for AM program development

Started in 2013, adding AM program requirements to all reissued major municipal WWTP permits; now in 70 permits

First requirement was Detroit WWTP - 33% of treated municipal discharge in MI, history of poor equipment maintenance. Appropriate to be first with AM requirements

Summary of core requirements – current state, level of service, critical assets, minimum life cycle costs, and long term funding

Will add AM requirements to minor permits that receive AM grants

Five Core Questions of Asset Management 1. What is the current state of my assets?

2. What is my required "sustainable" level of service?

3. Which assets are critical to sustained performance?

4. What are my minimum life-cycle costs?

5. What is my best long-term funding strategy?

Permit Language Requires AM Plan to Develop Program which addresses: ◦ Maintenance Staffing

◦ Mapping Collection System

◦ Inventory and Assessment/Criticality of Fixed Assets

◦ Budget and Rate Sufficiency

◦ Annual Report

DEQ - Asset Management 11

Great Lakes Water Quality Bond 2002 P.A. 562 of 2012 authorized money for Stormwater,

Asset Management, Wetland Mitigation or SAW program

$450M allocated to provide grants and loans for SAW $97M available for FY 2014, 15 and 16

Grants available up to $2M per municipality Applications accepted starting Dec 2, 2013 on a first

come first served basis On December 2, 2013 673 applications totaling $541M

were received

Capacity, Management, Operation & Maintenance ◦ Capacity Evaluation (testing, inspection, flow monitoring)

◦ Management (org structure, training, customer service, legal authority)

◦ Operation (budget, emergency response, mapping, construction)

◦ Maintenance (budget, maintenance, cleaning schedules, parts and equipment inventory)

◦ Rehabilitation (SSO elimination, I/I reduction)

Ensure that collection systems have adequate collection system capacity and maintenance (consistent

with Part 41 Rules 41 and 55)

No SSOs or basement backups

Non-excessive Infiltration/Inflow

To help protect public health and the environment

Part 41 looks at capacity; but not throughout system

State law and SSO Policy prohibit SSOs

NPDES permits require proper O&M

NPDES Asset Management Programs look at collection systems mapping

Enforcement Orders include I/I correction programs when SSOs have occurred

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10/24/2016 U.S. Environmental Protection Agency 17

Approximately 970 collection systems

About 540 are covered under NPDES permits; WWTP, or CSOs/CSO treatment facilities

Leaves 430 collection systems that are not covered by NPDES permits

These discharge to regional WWTPs; for example Detroit WWTP serves 77 communities

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MI: includes AM in all major NPDES permits;

◦ Considering CMOM Requirements in Permits

IL: includes AM for collection systems only as a subset of CMOM in all major NPDES permits, or in minor NPDES permits that have SSO problems;

WI: no AM requirements, but CMOM included in all permits

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IN; OH; MN: No AM routinely required in NPDES Permits; CMOM included only for permittees that have SSO problems.

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1. Strong CMOM Program Requirements

2. All Permittees • POTW (Individual NPDES

Permit • Satellite Sewer Communities

(via “SSO General Permit”) 3. Strong CMOM Training Program

(regional) 4. Jack Saltes, WDNR Engineer

We will use a stakeholder process, with help from MWEA and others

Some preliminary ideas

Include CMOM conditions for management, operations, maintenance, capacity evaluation

Prohibit SSOs

Include Asset Management program requirements; if received SAW grant

May include opportunities to streamline Part 41 permitting for routine gravity sewer extensions

Require approval of standard detail sheets for Part 41 permits

List system capacity restrictions and programs to correct

After stakeholder input hope to issue a General Permit for use starting in FY 2018