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.
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