Implementation Procedures (IPs)

Brittany LeeStandards Implementation

Team512-239-5210

Brittany.Lee@tceq.texas.gov

Functions of theStandards Implementation Team

• Technical Review of TPDES Applications• Implementation Procedures for the Texas

Surface Water Quality Standards (RG-194)• Receiving Water Assessments• 401 Water Quality Certification and

Mitigation Banks

Technical Review Process

Administrative Review

**Water Quality Standards Review**

Critical Conditions Review

Dissolved Oxygen Modeling Review

**Biomonitoring Review**

Permit Writer

TPDES Standards Review

• Assess receiving water flow status

• Assign aquatic life uses and associated criteria

• Perform nutrient and TDS screening

• Antidegradation reviews

• Endangered Species review

What are “Implementation Procedures (IPs)”

• A guidance document that explains how TCEQ applies the Texas Surface Water Quality Standards to wastewater permitting

• Example: The Standards assign a 5.0mg/L DO criterion to a segment of the Colorado River

• The IPs establish DO modeling methods to ensure the limits in a wastewater permit will maintain a 5.0 mg/L DO criterion in the river

What’s New with the IPs

• Triennial review process

• EPA approved most of the 2010 IPs on July 12, 2013

• Next water quality standards revision: 2017

• Next IPs revision also targeting 2017

EPA Objections to 2010 IPs:

• Dechlorination • Variances

• Whole Effluent

Toxicity

Dechlorination

IPs propose dechlorinationrequirements for new and expandingdomestic discharges with designflows between 0.5 and 1.0 MGD

Biomonitoring Review

• Focused on “WET”-Whole Effluent Toxicity• Exposure of an invertebrate and

vertebrate species to predict impacts to aquatic life (lethal and sublethal)

• Uses the most recent 5 years of testing, determines reasonable potential

• Formulates language, and “Toxicity limits”

Approved 2010 IPs – Highlights

Changes to Minimum Analytical Levels (MALs) -

now in effect

Nutrient Screening

▸Phytoplankton in open water▸Attached algae; floating algae▸Rooted vegetation▸Aesthetic effects on recreation▸Water supplies: THM, taste & odor▸Aquatic-life: fisheries ↑↓ habitat ↑↓

DO at night↓ diversity↓

IPs – Nutrient Narrative Criteria

30 TAC Chapter 307.4(e):

“Nutrients … shall not cause excessive growth of aquatic vegetation which impair an existing, attainable, or

designated use.”

Nutrients – Typical TP Limits

Permitted Flow (MGD) TP Limit (mg/L)

< 0.5 1.0

0.5 – 3.0 1.0 – 0.5

> 3.0 0.5

Nutrients – Nitrogen Limitations

TN limitations to prevent potential impact to sea grass communities.

Consideration of site specific conditions influencing dispersion and discharge volume in relation to the proximity of sea grasses to outfall.

In the absence of numeric criteria, nitrogen limit recommendations are based on Best Professional Judgment (BPJ) and available site specific data.

Reservoir Criteria• Criteria were

proposed for 75 reservoirs

• EPA approved about half of the criteria proposed

• How does that affect me??

Challenges Ahead

316(b)

Temperature

pH Objections

IP revisions

316(b)-Intake Structures

• EPA’s final rule for existing facilities became effective October 14, 2014

• TCEQ working with EPA and permittees on application/information requirements and implementation issues

• Court challenges still pending

Temperature

Temperature screening stakeholder group started in August 2014

TCEQ is taking initial comments and working on detailed procedures for inclusion in the IPs

Draft procedures to be presented to stakeholders in summer 2016

pH Objections Screening procedure

established with EPA concurrence for certain direct discharges to classified segments

pH Sceening conducted: for major municipal

facilities (≥1 MGD flow)

for industrial process water discharges

Any

Questions

???