1. Implementation Procedures (IPs) Brittany Lee Standards Implementation Team 512-239-5210Brittany.Lee@tceq.texas.gov

2. Functions of the Standards Implementation Team Technical Review of TPDES ApplicationsTechnical Review of TPDES Applications Implementation Procedures for the Texas Surface Water Quality Standards (RG-194)Implementation Procedures for the Texas Surface Water Quality Standards (RG-194) Receiving Water AssessmentsReceiving Water Assessments 401 Water Quality Certification and Mitigation Banks401 Water Quality Certification and Mitigation Banks

3. Technical Review Process Administrative Review **Water Quality Standards Review** Critical Conditions Review Dissolved Oxygen Modeling Review **Biomonitoring Review** Permit Writer

4. TPDES Standards Review Assess receiving water flow status Assess receiving water flow status Assign aquatic life and associated criteria Assign aquatic life uses and associated criteria Perform nutrient and TDS screening Perform nutrient and TDS screening Antidegradation reviews Antidegradation reviews Endangered Species review Endangered Species review

5. What are “Implementation Procedures (IPs)” A guidance document that explains how TCEQ applies the Texas Surface Water Quality Standards to wastewater permittingA 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 RiverExample: 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 riverThe 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

6. What’s New with the IPs Triennial review process Triennial review process EPA approved most of the 2010 IPs on July 12, 2013 EPA approved most of the 2010 IPs on July 12, 2013 Next water quality standards revision: 2017 Next water quality standards revision: 2017 Next IPs revision also targeting 2017 Next IPs revision also targeting 2017

7. EPA Objections to 2010 IPs: DechlorinationDechlorination VariancesVariances Whole Effluent ToxicityWhole Effluent Toxicity

8. Dechlorination IPs propose dechlorination requirements for new and expanding domestic discharges with design flows between 0.5 and 1.0 MGD

9. Biomonitoring Review Focused on “WET”-Whole Effluent ToxicityFocused on “WET”-Whole Effluent Toxicity Exposure of an invertebrate and vertebrate species to predict impacts to aquatic life (lethal and sublethal)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 potentialUses the most recent 5 years of testing, determines reasonable potential Formulates language, and “Toxicity limits”Formulates language, and “Toxicity limits”

10. Approved 2010 IPs – Highlights Changes to Minimum Analytical Levels (MALs) - now in effect

11. 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↓

12. 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.”

13. Nutrients – Typical TP Limits Permitted Flow (MGD) TP Limit (mg/L) < 0.5 1.0 0.5 – 3.0 1.0 – 0.5 0.5 – 3.0 1.0 – 0.5 > 3.0 0.5

14. 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.

15. Reservoir Criteria Criteria were proposed for 75 reservoirs EPA approved about half of the criteria proposed How does that affect me??

16. Challenges Ahead 316(b) Temperature pH Objections IP revisions

17. 316(b)-Intake Structures EPA’s final rule for existing facilities became effective October 14, 2014EPA’s final rule for existing facilities became effective October 14, 2014 TCEQ working with EPA and permittees on application/information requirements and implementation issuesTCEQ working with EPA and permittees on application/information requirements and implementation issues Court challenges still pendingCourt challenges still pending

18. 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

19. 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