Water Protection Program, Water

Pollution Control Branch, Central

Office Permitting Update

Chris Wieberg

Permitting Staffing Changes

New Unit Chiefs

– Tim Bull – Domestic Permits

– Jake Faulkner – Industrial

Permits

– Stacia Bax – MS4, MGP, LD,

401, ePermitting

Permitting Staffing Changes

New Staff

401 Coordinator - Mike Irwin

MS4 Coordinator - Mike Abbott

Industrial Permit Writer – Amberly Schulz

Domestic Permit Writer – Shawn Massey

Domestic Permit Writer – Adam Paige

Each unit as 1 vacant position currently

Permitting Totals

January 1, 2015-September 3, 2015

• Domestic Site-Specific: Non-municipal/POTW

permits - 225

• Industrial Site-Specific - 59

• ePermitting (Land Disturbance) - 720

• Priority Permits Candidates – 80%

• 401 Certifications – 43

• Subdivision Approvals - 25

CAFCOM (Affordability) 2015

• Cost Analysis For Compliance

– 30 effective permits with CAFCOM analysis

– All effective permits had a compliance

alternatives resulting in a MHI percentage

less than 2%.

– CAFCOM template has seen no changes in

2015

S.B. 642 merged with S.B. 664 2014

• created Section 644.058 RSMo

– require 66 unique environmental and

economic need studies prior to modifying

water quality standards and document these

evaluations and use them in making

individual site specific permit decision

– Also included a reporting requirement to the

Legislature on affordability

SS HB 2015

• Modified Section 644.145

– Now requires affordability analysis for water

and sewer treatment works and not just

POTWs.

– Clarified that the measurement of affordability

against the specific communities MHI or the

States MHI

Missouri Sustainability Assessment

Tool (MoSAT) • The Department contracted with Wichita State University to

complete an assessment tool that would allow for predictions on

rural Missouri community populations and future sustainability.

• A stepwise regression model was applied to 19 factors which were

determined as predictors of rural population change in Missouri.

• The weighted values for each town / village were then added

together to determine an overall decision score. The overall decision

scores were then divided into five categories

• Permit Writers reference MoSAT category when determining an

appropriate Schedule of Compliance.

Voluntary Early Nutrient Monitoring Program

for Point Sources

• According to the Nutrient Loss Reduction

Strategy

• Differs from the monitoring requirement

established for N and P in 10 CSR 20-

7.015

Nutrient Monitoring 10 CSR 20-7.015

• Discharges greater than 100,000 gallons

per day shall monitor once per quarter for

total N and P.

Voluntary Early Nutrient Monitoring

Program for Point Sources • The reduction strategy suggested slightly

different monitoring than 7.015.

– 0.1 to 1 MGD discharges to sample quarterly

for total nitrogen must included TKN, NH3,

NO3, and NO2 and Total P

– Greater than 1 MGD discharges to sample

monthly for total nitrogen must included TKN,

NH3, NO3, and NO2 and Total P

Voluntary Early Nutrient Monitoring

Program for Point Sources • The reduction strategy suggested slightly

different monitoring than 7.015.

– Additionally the strategy suggest that

receiving stream monitoring also occur at a

similar frequency for the same parameters.

– It is suggested that flow also be monitored in

order to establish loading

Voluntary Early Nutrient Monitoring

Program for Point Sources • The program procedure is currently draft

and we are accepting comments through

October 1st, 2015

• Comments and Questions can be directed

to Cameron Eisterhold at

cameron.eisterhold@dnr.mo.gov

(573) 751-7326

Electronic Discharge Monitoring

Reporting • Currently 7% of the states discharge

permittees are reporting via eDMR.

• Sign up by filling out a Facility Participation

Packet.

• eDMR training is held in Jefferson City

around 5 times a year

• eDMR is the first phase of eReporting

Compliance

Multiple-Discharger Variance • Currently working on the variance framework which is

available now at

http://dnr.mo.gov/env/wpp/cwc/docs/variance-draft-

20150715.pdf

• Applicability would include Municipal Publicly Owned

Treatment Works with a functional lagoon system

• Each municipality will need to justify that in order to meet

the water quality standards for total ammonia nitrogen

the municipality would be required to raise residential

user rates to an amount that would cause a substantial

and widespread economic and social impact.

Integrated Planning

• Can consider all environmental obligations

and requirements (Drinking water, MS4, I&I,

etc…)

• Identify highest public health and

environmental risks

• Work on highest risks first

• Formally recognize priorities

• Could support a modification of a Schedule of

Compliance

Industrial Stormwater Permitting

• Stormwater Pollution Prevention Plans

• Limits vs. Benchmarks

• BMPs

– Structural vs. Operational

• You should be letting your permit writer know what

BMPs are being implemented

Power Plant Permitting

• 316a Thermal Discharges

– BTU limits will be changed

to ̊F limits

– Schedules of Compliance will

be established where

appropriate

– Some will want to conduct a

316a variance study. Meet

with the department to

discuss work plan and QAPP

Power Plant Permitting

• 316b Intakes

– Studies are being conducted focused on

impingement and entrainment.

– Regardless of permit status you should be

working on this since the rule is effective and

self implementing.

– Information will be submitted to the

department at renewal or otherwise as

dictated by the rule.

Power Plant Permitting • Groundwater monitoring around ash ponds

– This requirement is for compliance with RSMO 644,

not the RCRA CCR rule

– Site Characterization to determine geology and

hydrology and initially indicate if discharges are

potentially occurring from the ash ponds.

– Establish well locations to monitor the discharge

condition, or lack there of

– May lead to limits in future permits if reasonable

potential exists to exceed standard

– Working to get a factsheet on this topic out by Spring

Keep an eye on the Ameren Labadie appeal.

http://168.166.15.111/Clients/MOAHC/Public/Case_Details.aspx?&EntityID=10059797

CAFO Permitting • Documents related to

permits of interest are

posted to the Departments

CAFO webpage

• Non NPDES CAFO

permits must maintain no

discharge status

regardless of weather

event

MS4 Permitting

• Mike Abbott is the new MS4 Coordinator

• General Permit will be public noticed again

• General Permit draft is currently under

MDNR General Council Review

• If you have questions please call or email

Mike Abbott at

michael.abbott@dnr.mo.gov

(573) 526-1139

POTW Permitting

• CAFCOM

• Stormwater for those over 1 MGD

• No exposure or SWPPP

• Blending

Private Domestic Permitting

• Some private sewer companies have

negotiated longer schedules of compliance

for NH3 by expressing rate payer impact

as compared to the state MHI

• Not a CAFCOM but can lengthen a SOC

where appropriate.

Questions???

Thank You