MDFW Hatchery NPDES Program Ken Simmons Chief of Hatcheries/Trout Project Leader.

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MDFW Hatchery NPDES ProgramKen Simmons

Chief of Hatcheries/Trout Project Leader

MDFW HATCHERIES

• Sandwich Hatchery (1912) -Trout*• Sunderland Hatchery (1913) - Trout*• Palmer Hatchery (1914) - Atlantic salmon• Montague Hatchery (1917) - Trout*• McLaughlin Hatchery (1969) - Trout*

*NPDES permit required

NPDESFour MDFW Trout Hatchery

Permits Renewed in Past Year

• Observations on the process

• Formalin

Discuss Today

Impact on Hatchery Operations

• Discharge limits were not substantially changed

• Frequency of effluent sampling was reduced

• Effluent sampling quarterly and only during major cleaning operations

continued

Impact on Hatchery Operations

• Increased use of settling pools at 3 older DFW facilities

• Reduced production at 3 older facilities

• Greatly altered operations at 3 older facilities

• Formalin use all but eliminated at 3 older facilities

Impact on Pounds of Trout Produced

Old Permit Current Permit

McLaughlin 225,000 225,000

Sunderland 115,000 90,000

Montague 90,000 80,000

Sandwich 62,000 50,000

Effluent Monitoring

• Flow• BOD• TSS• pH• Dissolved oxygen• Total ammonia

nitrogen, as N*

• Residual chlorine*• Total phosphorous*• Formaldehyde• Whole Effluent

Toxicity - chronic**• Whole Effluent

Toxicity - acute**

*Not at all facilities **New to current permit

Effluent Sampling

• Quarterly (except pH, formalin & chlorine)

• Three of the quarterly samples must be taken when conducting pool breakdown and/or settling pool or quiescent zone cleaning

• One quarterly sample must be taken during annual pool breakdown/cleaning

• Composite samples -- 1 per hour for 8 hours

Formalin Use• Discharge limit of 0.74

mg/l (formaldehyde) at all facilities

• Developed formalin use plan for each hatchery as part of B.M. P.

• Do not know if it will work except at McLaughlin Hatchery

Formalin Use Problems

• 0.74 mg/l limit effectively eliminates use at 3 of 4 facilities due to flow patterns and dilution factors

• Difficult to retain a certified lab that can analyze formaldehyde with E.P.A. methods on short notice

• W.E.T. tests - labs to conduct work on short notice

• Cost of tests

Whole Effluent Toxicity (%) Acute (invertebrates only)

AverageMonthly

Max.Daily

FrequencyMeasured

SampleType

MAC Acute LC50 > 100% * Comp.

SUND Acute LC50 > 100% * Comp.

MONT Acute LC50 > 100% * Comp.

SAND Acute LC50 > 100% * Comp.

*If formalin is used

Whole Effluent Toxicity (%) Chronic (invertebrates only)

AverageMonthly

Max.Daily

FrequencyMeasured

SampleType

MAC Chronic C-NOEC > 100% * Comp.

SUND Chronic C-NOEC > 100% * Comp.

MONT Chronic C-NOEC > 100% * Comp.

SAND Chronic C-NOEC > 100% * Comp.

*If formalin is used

My Thoughts

• Agency must play an active role in the process

• Develop & maintain a professional working relationship with the regulators

• Be honest and forthcoming with information

• Do not hesitate to ask questions or seek clarification of issues

• Exercise your right to seek change and/or clarification of pre-public draft permits

• Tremendous amount of work involved

Summary

• We do not yet know if we will be able to meet new effluent limits at all stations but have developed BMP’s with that goal

• Formalin use at 3 of 4 hatcheries is all but impossible

• Formalin use at McLaughlin Hatchery is feasible but with constraints

Thank You

FLOW (MGD)

AverageMonthly

Max.Daily

FrequencyMeasured

SampleType

MAC 7.0 8.1 Cont. Rec.

SUND 1.17 1.68 Daily Instan.

MONT 1.4 1.55 Daily Instan.

SAND 1.4 1.6 Daily Instan.

BOD (mg/l)

AverageMonthly

Max.Daily

FrequencyMeasured*

SampleType

MAC 5 10 Quart. Comp.

SUND 5 10 Quart. Comp.

MONT 5 10 Quart. Comp.

SAND 5 5 Quart. Comp.

*During cleaning operations

TSS (mg/l)

AverageMonthly

Max.Daily

FrequencyMeasured*

SampleType

MAC 10 10 Quart. Comp.

SUND 10 10 Quart. Comp.

MONT 10 10 Quart. Comp.

SAND 10 10 Quart. Comp.

*During cleaning operations

Total Phosphorous (mg/l)

AverageMonthly

Max.Daily

FrequencyMeasured*

SampleType

MAC *** 1.0 Quart. Grab

SUND *** Report Quart. Grab

MONT *** Report Quart. Grab

SAND None None None

*During cleaning operations ***No limit issued

Total Ammonia Nitrogen, as N (mg/l)

AverageMonthly

Max.Daily

FrequencyMeasured*

SampleType

MAC 4.2 *** Quart. Comp.

SUND None None None

MONT None None None

SAND 6 10 Quart. Comp.

*During cleaning operations ***No limit issued

Total Residual Chlorine (ug/l)

AverageMonthly

Max.Daily

FrequencyMeasured

SampleType

MAC None None None

SUND None None None

MONT None None None

SAND 7.5 13 If used Grab