1. Report of the NPDES Subcommittee
Paul Novak, IDEM
Report of the NPDES Subcommittee
210th Technical Committee Meeting
February 9-10, 2016

2. Committee Agenda
Subcommittee met by conference call on January 20, 2016.
5 states participated on the call.
Agenda:
Changes Made in 2015 to PCS.
New Ammonia Criteria
Implementation and Tracking Issues Associated with BCC MZ Changes
Triennial Standards Update
Mercury project and point source Hg data availability.

3. 2015 Adopted Changes to PCS
Added EPA’s aquatic life criteria for ammonia
Tables for mussels present will be default criteria; however,
mussel absent criteria tables will be included as well.
No Implementation Guidance
Mussels absent tables - may provide flexibilty permit limits small dischargers.

4. 2015 Adopted Changes to PCS
Mixing Zone Prohibition for BCCs – Eliminated Date Certain When MZs Prohibited for BCCs
“as determined by the permitting authority” … “as soon as practicable” “considering the following criteria:”
Mercury minimization measures
Concentration and duration of the discharge, bioaccumulation factors and exposure considerations

5. States reported how they will implement BCC changesWV
Unilateral Order
Evaluate Discharger Effluent Data
Any Sample > 12 ng/L
Discharges must show plan to meet 12 ng/L daily max;
Plans due by Feb 28, 2016
7 Facilities IL
If Annual Avg Hg >12ng/L
must show best degree of treatment, good house keeping measures and recovery of waste streams
Currently, no Ohio River facilities with mixing zones

6. States reported how they will implement the “as soon as practicable” mixing zone prohibition
OH & IN
Will use existing streamlined variance process
Evaluate Mercury Effluent Data
Mixing Zones Prohibited
Annual Average Limit - 12 ng/L
PMP Plan
PA – No specific policy yet developed; handle on case-by-case basis
KY – ? Was not on conference call

7. States reported how they will implement the “as soon as practicable” mixing zone prohibition
Summary:
W Va - Fully Implementing
OH & IN & IL –
Implementing Using Existing State Procedures
Ave (State Procedures) vs Max (ORSANCO) an Issue
PA – No specific policy yet developed; handle on case-by-case basis
KY – ? Was not on conference call

8. How Track Implementation by States BCC MZ Phaseout
Be ready to respond to questions regarding the implementation of ORSANCO’s BCC mixing zone prohibition
Are States Identifying Facilities with Effluent Hg Concentrations > 12 ng/L
Are States Imposing Limits/Variance Based on 12 ng/L?
If a Variance – What Included in the Variance?

9. How Track Implementation by States BCC MZ Phaseout
Be ready to respond to questions regarding the implementation of ORSANCO’s BCC mixing zone prohibition
Two-step process suggested
Staff to query all permits with limits over 12 ng/L
Some Facilities May Not Have limits/monitoring because States May Not Have Existing MZ Ban or Permit Limits Evaluation on Monthly Averages not Daily Max
Contact each state individually to review each facility and determine status
Once initial list is developed, can re-evaluate

10. Next Triennial Review Priorities
Staff presented results of the poll distributed to Commissioners and committee members to rank priority issues for the next triennial standards review
A number of issues identified for potential consideration in the next review.
Mercury, nutrients, and E. coli received the highest priority rankings.
Addressing duration and frequency of criteria was also noted as a high priority.

11. Mercury Data Availability
Discussed mercury point source data availability in light of current Commission effort to characterize mercury issue
Review DMR Data
There may be Hg point sources that do not routinely monitor for Hg
In addition to DMR results, data is collected during permit application process.
Municipal – priority pollutant scans every 5-years
Industrial – scan for pollutants based on industry category
Permit application monitoring data is available, but is not in electronic format.

12. Questions??