Green Mountain Water AssociationLegislative Lunch

February 26, 2014

Who is GMWEA?

• Established in 1994 by merger of two long-standing water treatment and wastewater organizations

• GMWEA is an association of Vermont water and wastewater professionals.

• Greater than 600 members

Who is our Membership?

• Water and Wastewater Treatment Plant Operators

• Collection and Distribution System Operators

• Engineers• Vendors• Industry Professionals• Public Works Officials• Stormwater Professionals• Vermont Department of Conservation

Employees

Boots on the Ground

“Boots on the Ground”

24 hours a day, 365 days a year -- designing, operating, maintaining, and repairing the water, wastewater and

stormwater systems in Vermont.

Primary Legislative Concerns

• Funding for infrastructure– Ongoing challenge as our infrastructure ages

• TMDL Phosphorus Load Allocation– Biggest Bang for your buck isn’t Wastewater Treatment

Facilities– Consideration for existing programs which are already

reducing Phosphorus– Innovative management of nutrients (may include offsets, trading or

varying standards in different watersheds)

• Future of Biosolids in Vermont– Rulemaking at ANR in the near future– Fact vs. Fiction – Importance of Reuse

Working for Water Quality

New England Water Environment Association &

Green Mountain Water Environment Association

Lake Champlain TMDL (Total Maximum Daily Load)

“States need room to innovate and respond to local water quality needs, so a one-size fits-all solution to nitrogen and phosphorus pollution is neither desirable nor necessary”

EPA partnership Memo March 16, 2011

Municipalities need to be afforded the same opportunity.

Phosphorus By Source

Legislation of Interest to GMWEA regarding TMDL implementations

• H.288 Clean water legacy fund with working group provisions that recommends a source of funding to support actions that improve water quality

• H.586 Water Quality Preservation with multiple provisions for all non point agricultural related program sectors. Funding mechanisms for implementation of TMDL Plans

• H.600 Establish Clean Water Legacy Fund which includes a working group for funding priorities. Also recommends a funding source to support actions that improve water quality.

• H.650 Ecosystem restoration Flow Monitoring permit compliance mechanism for MS4’s

Costs of ImprovementCONSENSUS:

• Costs presented for necessary improvements are ALL TOO LOW!

• Estimates are applied in a One-Size-Fits-All manner: Not the most cost effective approach.

• Requiring ONLY permit holders to improve does not make economic sense AND will not reach the TMDL requirements.

GMWEA and Its Members Support

• Cleaner Lakes and Rivers• A common sense approach to Water Quality Improvements.• Increased Funding for Cost Effective Infrastructure Improvements• Flexibility in Application of those Improvements

(“Biggest bang for the Buck”)• Rules and Guidance that incentivizes good behavior rather than

penalizing it by tougher permit standards on a complying sectors.• Innovative management of nutrient controls (may include

offsets, trading or varying standards in different watersheds)• Addressing the bigger sources of nutrients first• Integrated Permitting approved by EPA to allow permit holders

to prioritize improvements.

Another Piece of the Pie: Developed Lands

Another Piece of the Pie: Developed Lands

Proposed P Reductions for Developed Lands

• Enhance existing MS-4 permit

• Expand the MS-4 Program to other densely developed areas

• Retrofit 30% of all impervious areas*

• Retrofit 50% of paved roads (outside MS-4s)*

* Under a current EPA Best Management Practice Implementation Scenario

MS-4 : Muncipal Separate Sewer System

• Regulates stormwater from 9 municipalities and 3 non-traditional entities (since 2003). St. Albans City & Town and Rutland Town designated in 2012

• Requires substantial municipal investment to meet 6 minimum measures

– Public Education & Outreach– Public Involvement & Participation– Illicit Discharge & Detection– Construction Site Runoff Control– Post Construction Stormwater Management– Municipal Operations Pollution Prevention/Good Housekeeping

• 2012 MS-4 Permit included additional requirements for funding stream flow monitoring and addressing Stormwater Impairments through Flow Restoration Plans

Case Study in Urban Retrofits:Centennial Brook

• Developed land contributes P through “wash off” of nutrients but also LARGELY through the erosion of stream banks

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VT SW TMDLs: Q 0.3 (high flow) % reductions

TMDLs Submitted by VTDEC and Approved by EPA 2006-2009

• >90% watershed impervious cover retrofitted across 4 jurisdictions

• Cost of Plan = $91,485• Est. cost of implementation = $9.74 million

Not all retrofits are created equal

Water Quality Landscape in

Burlington, VT• 3 WWTPs

• 60% Combined Sewer (3 WWTPs)• 3 CSO outfalls• Wet weather events• Sewer surcharge into basements

• > 100 year old infrastructure

• 40% Separate - MS-4 permit (70+ separate SW outfalls)

• Stormwater flow based TMDLs for 3 streams – Centennial, Englesby and Potash

• Lake Champlain Phosphorus TMDL)

• Bacteria TMDL for Englesby Brook

• Vermont’s Largest “city”• 40,000+ people• 15.48 sq. miles area

What will help this important challenge?

• RECOGNIZE the investments that MS-4s are already making• FLEXIBILITY

• Municipalities should be given a lumped P reduction target that can be met through projects across a variety of sectors

• Not all lake segments or projects are created equal prioritize based on cost benefit? water quality trading?

• REALISTIC COMPLIANCE SCHEDULES• Additional funding is needed from outside the municipality• Affordability (for all permit requirements) must be a factor

in determining compliance schedules• INTEGRATED WASTEWATER/STORMWATER/AGRICULTURAL

Planning must be an option

Biosolids in Vermont

Sludge:“Sewage sludge is the solid, semi-solid, or liquid by-product generated during the treatment of wastewater at sewage treatment plants.”

Biosolids:Treated sewage sludge used in land application as class A or B is called “biosolids” by the EPA and industry.

EPA: Office of the Inspector General Status Report – Land Application of Biosolids, March 28, 2002

Biosolids in Vermont

Landfill: Leachate Concerns – solubilized to VT waters

Incinerator: Air Quality Concerns

Land Application: Constituents on the Land

Biosolids in Vermont

Clean Water Act – 1972• Primary Federal Statute addressing Water Pollution in The US• National Pollution Discharge Elimination System (NPDES)• Section 405

Biosolids in Vermont

Risk Assessment Exposure and hazard assessment

• Toxicity data for human and ecological receptors

• Constituent concentration• Constituent chemical and physical properties• Fate and transport data

Biosolids in Vermont

40 CFR Part 503 – 1993The Standard for the Use or Disposal of Sewage Sludge

• Chemicals – Numerical Pollutant limitations on 10 Metals

• Biological - Process and some Numerical Pathogen Reduction

• Vector Attraction Reduction

Biosolids in Vermont

Sludge• Unclassified – No specific pathogen reduction process – not allowed for land

application

Biosolids • Class B – Process to significantly reduce pathogens – aerobic and anaerobic

digestion at < 100 °F. Suitable for land application with constrictions

• Class A – Process to further reduce pathogens – Several technologies available, some proprietary - Most common are high temperature (< 131 °F) or high pH – composting or anaerobic digestion – suitable for land application with reduced constrictions

Biosolids in Vermont

Unclassified –

Class B –

Class A –

Google earth

Burlington Main WWTP Waterfront

Biosolids in Vermont

Unclassified –

Class B –

Class A –

Google earth

Essex Junction WWTF

Biosolids in Vermont

Unclassified –

Class B –

Class A –

Google earth

South Burlington Airport Parkway WWTP

Biosolids in Vermont

Landfill Constituents in Aquatic environments

Incinerator Air Quality

Land Application Constituents applied to the land

Biosolids in Vermont

Current Fate of Biosolids

• Dis-Investment of Federal Oversight• Micro Constituents Present

• Knowledge gaps• Disposal• No Documented Cases of Harm to Human

Health and the Environment

Questions?

Contacts:

Bob Fischer Rick KenneyGMWEA President GMWEA Gov’t Affairs Committee(802)223-9521 (802) 296-2437gmweafischer@charter.net Rkenneyvt@yahoo.com