Loading...
HomeMy WebLinkAbout07-2021 MWMC Monthly ReportMWMC Communication Packet August 19, 2021  Regional Wastewater Program Monthly Report— July 2021  NPDES Permit Renewal Update The next meeting will be Friday, September 10, 2021 at 7:30 a.m. MWMC Meeting will be held remotely via computer or phone Photo Credit: David N. Jones M E M O R A N D U M DATE: August 17, 2021 TO: Metropolitan Wastewater Management Commission (MWMC) FROM: Todd Miller, Environmental Services Supervisor SUBJECT: NPDES Permit Renewal Update ACTION REQUESTED: Communication Packet _____________________________________________________________________ ISSUE At the July 9, 2021 MWMC meeting, staff provided an update on the National Pollutant Discharge Elimination System (NPDES) permit renewal process and status. At that time, staff expected the MWMC’s draft permit (known as the Applicant Review Draft) would be issued in July and the public review process would start in August. Staff therefore anticipated providing updates to the Commission at the September and October 2021 meetings prior to final permit issuance date in late 2021. After the July 9, 2021 meeting, staff received information from the Oregon Department of Environmental Quality (DEQ) that a new permit writer was being assigned to the MWMC’s permit and that the DEQ fully expects to issue the MWMC’s permit in calendar year 2021. The DEQ has not yet issued the Applicant Review Draft for the MWMC’s review. Therefore, the permit issuance timeline has been extended and staff will not have new information to present at the September 2021 Commission meeting. Staff will be available at the September meeting to update the Commission on the timeline. BACKGROUND Staff has been providing the Commission with periodic and more frequent updates on the NPDES permit renewal process over the past several years. As of the July 2021 meeting, staff understood that: 1) The DEQ permit writing team for the MWMC would be Geoff Rabinowitz and Jeff Navarro. A third initially identified permit writer, Steve Schnurbusch, remained close to the project as a lead subject matter expert (SME). Memo: NPDES Permit Renewal Update August 17, 2021 Page 2 of 2 -Communication Packet- 2) Having fulfilled earlier requests for additional data and providing updates to the MWMC’s Biosolids Management Plan and Recycled Water Use Plan, staff expected the DEQ’s projected Applicant Review Draft release date of July 19 to July 26, 2021, was on schedule. 3) The DEQ had provided the MWMC with preliminary Reasonable Potential Analysis (RPA) spreadsheets and anticipated permit limits but was still working out the temperature RPA. Staff expected the temperature RPA and preliminary compliance schedule for temperature compliance to be worked out with DEQ in advance of the Applicant Review Draft. 4) Staff also submitted comments to DEQ on the preliminary RPA assessment for corrections and clarifications on some of the inputs and results. Staff expected final RPA results from DEQ prior to the Applicant Review Draft. DISCUSSION On July 16, 2021, DEQ informed the MWMC that there would be a delay in drafting the MWMC’s permit. Furthermore, the DEQ has assigned a new permit writer, Vanessa Rose from the Eastern Region office, to lead up some of the permit writing, with Geoff Rabinowitz and Jeff Navarro continuing to support the permit. DEQ acknowledged receiving the MWMC’s input on the RPA results and is taking that into consideration in the final permit drafting. DEQ has not yet informed the MWMC of any results of the temperature RPA or directions on thermal load limits. While DEQ has expressed intention to finalize the MWMC permit within calendar year 2021, staff does not yet know the current adjusted timeline for the Applicant Review Draft. Given the status of some of the discussions with DEQ that staff expects in advance of the Applicant Review Draft, staff anticipates that the Applicant Review Draft will not be available for review until later in August at the earliest. Given that timeline, the public review draft is not expected to be pending until later in September or October. More recently, DEQ scheduled routine inspections of MWMC facilities in September 2021. Routine inspections are performed at DEQ’s discretion. The last MWMC inspection was in December 2016. Upcoming inspections are scheduled for September 16 (to inspect WPCF outfall, facility process train, and collection system components) and for September 22 (to perform a records review and laboratory audit). Attending on September 16 will be Steve McMillan, the MWMC’s assigned water quality compliance specialist based at the Eugene office, Vanessa Rose, the MWMC’s newly appointed permit writer, and Anna Morgan-Hayes, another permit writer/compliance specialist from DEQ’s Eastern Region. ........................................................................................................................................ 2 .................................................................................................................................... 3 ................................................................................................................... 8 .................................................................................................................................... 9 ............................................................................................................................................ 10 ........................................................................................................ 12 .................................................................................................... 13 ............................................................................................................................................... 14 • • • • • • • • • • • • • • • • • o o o o • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •