phil argiroff, chief, permits section water resources ... argiroff, chief, permits section water...
TRANSCRIPT
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)
4
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
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
10/24/2016 U.S. Environmental Protection Agency 18
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
10/24/2016 U.S. Environmental Protection Agency 19
IN; OH; MN: No AM routinely required in NPDES Permits; CMOM included only for permittees that have SSO problems.
10/24/2016 U.S. Environmental Protection Agency 21
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