Detroit WWTP NPDES Permit Detroit WWTP NPDES Permit Informational MeetingInformational Meeting

Michigan Department of Environmental Quality October 17, 2013

Framework for Tonight’s Public Framework for Tonight’s Public MeetingMeeting

6:30 – 8:30 PM6:30 – 8:30 PM IntroductionsIntroductions

DWSD and DEQ Presentations DWSD and DEQ Presentations

Open discussion and questionsOpen discussion and questions

DEQ Presentation DEQ Presentation

Progress addressing WWTP noise and odor Progress addressing WWTP noise and odor concerns concerns

Background and National Pollutant Discharge Elimination System (NPDES) requirements

NPDES permit compliance during 2013

Upcoming NPDES permit requirements

DWSD PresentationDWSD Presentation

Sam Smalley, P.E., Assistant DirectorSam Smalley, P.E., Assistant Director

Wastewater OperationsWastewater Operations

BackgroundBackground

After 35 years, No longer Under Federal After 35 years, No longer Under Federal Court Order as of March 2013.Court Order as of March 2013.

Under an administrative consent order Under an administrative consent order (ACO) with the DEQ for violations from (ACO) with the DEQ for violations from 2009-2011.2009-2011.

Detroit WWTP - BackgroundDetroit WWTP - Background

One of the largest WWTPs in the USOne of the largest WWTPs in the US Treats dry weather flow and significant wet Treats dry weather flow and significant wet

weather flow through secondary treatment up to weather flow through secondary treatment up to 930 million gallons per day (MGD)930 million gallons per day (MGD)

Treats wet weather flow through primary Treats wet weather flow through primary treatment up to 1700 MGDtreatment up to 1700 MGD

NPDES PermitNPDES Permit

Permit MI0022802 issued March 1, 2013; Permit MI0022802 issued March 1, 2013; effective May 1, 2013effective May 1, 2013

Expires October 1, 2017Expires October 1, 2017

www.michigan.gov/deqwww.michigan.gov/deq Click on: Water, Surface Water, NPDES PermitsClick on: Water, Surface Water, NPDES Permits Under Information click on Detroit Water and Sewerage Under Information click on Detroit Water and Sewerage

Department (DWSD) Department (DWSD)

3 Key Issues Addressed3 Key Issues Addressed

1.1. Sustained compliance with permit requirementsSustained compliance with permit requirements

2.2. Reductions in authorized total phosphorus Reductions in authorized total phosphorus loads to help address Lake Erie algae loads to help address Lake Erie algae

3.3. Adaptive Management CSO Control program; Adaptive Management CSO Control program; includes Green Infrastructure, considers Detroit includes Green Infrastructure, considers Detroit residents’ financesresidents’ finances

1. Sustained Compliance - 1. Sustained Compliance - Facility Improvement ProgramFacility Improvement Program

Includes ACO conditions that control the solids Includes ACO conditions that control the solids inventories at the WWTPinventories at the WWTP

Requires construction of new solids dewatering Requires construction of new solids dewatering equipment by 2016equipment by 2016

Requires a Long-term Solids Disposal PlanRequires a Long-term Solids Disposal Plan Requires Asset Management to address Requires Asset Management to address

operation and maintenance issuesoperation and maintenance issues Adjust effluent limits based on good operationAdjust effluent limits based on good operation

Solids Handling – Long Term Solids Handling – Long Term

Will Permanently Shut Down Incinerators Will Permanently Shut Down Incinerators in Complex C-l in Complex C-l

6 incinerators built in the 1940s6 incinerators built in the 1940s

Upgrade Incinerators in Complex C-ll Upgrade Incinerators in Complex C-ll 8 incinerators built in the 1970s8 incinerators built in the 1970s Necessary to meet more stringent Federal Necessary to meet more stringent Federal

emission standards effective March 2016emission standards effective March 2016

Biosolids DryerBiosolids Dryer

Biosolids Dryer - Future Biosolids Dryer - Future DisposalDisposal

C-II Incineration

234 28%

Drying316

37%

Landfill & Land Appl.

300 35%

Peak Day850 dtpd

C-II Incineration

78 17%

Drying305 68%

Land Application

45 10%

Landfill22 5%

Average Day450 dtpdPeak

850 dtpdAverage Day

450 dtpd

Asset Management is…Asset Management is…

The practice of managing infrastructure assets

Minimizing the total cost of owning and operating them

Delivering the desired level of service

$$$$

$$

2. Phosphorus Reduction2. Phosphorus Reduction Adjustment of Effluent Limits based on good O&MAdjustment of Effluent Limits based on good O&M Monitoring periods at wet weather outfalls changed to Monitoring periods at wet weather outfalls changed to

more quickly reflect good WWTP operation and more quickly reflect good WWTP operation and maintenancemaintenance

Effluent limits at wet weather outfalls adjusted to require Effluent limits at wet weather outfalls adjusted to require well operated WWTPwell operated WWTP

Pollutant Former Limit(30 discharge days)

Current Limit(monthly average)

TSS 100 mg/l 70 mg/l

CBOD5 100 mg/l 40 mg/l

Total Phosphorus

2.5 mg/l 1.5 mg/l

Reduction in Permitted Reduction in Permitted Phosphorus LevelsPhosphorus Levels

Beginning 2015Beginning 2015 WWTP secondary treated outfall reduced WWTP secondary treated outfall reduced

from 1.0 mg/l to 0.7 mg/l as a monthly from 1.0 mg/l to 0.7 mg/l as a monthly average average

Growing season average of 0.6 mg/l (from Growing season average of 0.6 mg/l (from April – September)April – September)

Based on levels the WWTP can achieve Based on levels the WWTP can achieve optimizing existing facilitiesoptimizing existing facilities

Outfall 049B PhosphorusOutfall 049B Phosphorus

Detroit Total Phosphorus Loads

Secondary treated outfall 049B to Detroit River – 80% of P load

Wet weather outfalls

050A

049A

3. Adaptive CSO Control 3. Adaptive CSO Control ProgramProgram

Michigan’s CSO program started in 1988Michigan’s CSO program started in 1988

Municipalities must either:Municipalities must either: eliminate the CSO or eliminate the CSO or provide adequate treatment to meet all water quality provide adequate treatment to meet all water quality

standards at times of dischargestandards at times of discharge

Detroit’s collection system consists of basically Detroit’s collection system consists of basically all combined sewers all combined sewers

1919

Wet Weather – Uncontrolled CSOsWet Weather – Uncontrolled CSOs

Typical Uncontrolled CSOTypical Uncontrolled CSO

WWTP

Storm Sewer

Sanitary Sewer

Combined Sewer

Adaptive Management ProgramAdaptive Management Program

Remaining CSOs (55)Remaining CSOs (55) 17 CSOs remain to the Rouge River17 CSOs remain to the Rouge River 38 CSOs to the Detroit River 38 CSOs to the Detroit River

An adaptive management approach for these will: An adaptive management approach for these will: Use lessons learned from previous CSO projects and Use lessons learned from previous CSO projects and

better discharge databetter discharge data Consider the financial capability of DWSD and City Consider the financial capability of DWSD and City

residentsresidents Consider reductions in stormwater flows by using an Consider reductions in stormwater flows by using an

expanded Green Infrastructure (GI) programexpanded Green Infrastructure (GI) program

CSO Correction ProgressCSO Correction Progress

0

5

10

15

20

25

1993 2019

Untreated CSO (BGY)

Green Infrastructure (GI)Green Infrastructure (GI)

What is Green Infrastructure? What is Green Infrastructure?

Low Impact Development (LID) Manual for MichiganLow Impact Development (LID) Manual for Michigan ““a network of open space, woodlands, wildlife, habitat, parks, a network of open space, woodlands, wildlife, habitat, parks, and other natural areas which sustain clean air, water, and and other natural areas which sustain clean air, water, and natural resources, and enhance quality of life”. natural resources, and enhance quality of life”.

Table Source: Value of Green Infrastructure, CNT / American RiversTable Source: Value of Green Infrastructure, CNT / American Rivers

Green Infrastructure (GI)Green Infrastructure (GI)

How does Green Infrastructure reduce runoff?

More pathways for water to:•Soaks into the ground•Taken up by plants

Hard surfaces (like pavement and roofs) remove these pathways

Too much runoff sewer overflows

Green Infrastructure (GI)Green Infrastructure (GI)Green Infrastructure Plan

Received August 1, 2013

Conditional Approval October 15, 2013Revised Plan Due - August 1, 2014

Investment - $3M per year for 5 years; $50M over 20 years (through 2029)

On our website

Detroit Future City

Areas

Upper Rouge Implementation

Near Eastside Planning

Green Infrastructure (GI)Green Infrastructure (GI)A few key aspects of the current GI Plan:

Alignment with Detroit Future City

Public Outreach and

Participation

Partnerships

Target stormwater

runoff reduction2.8 MG by 2017

Strategy

ComplianceCompliance

ACOACO Presently in compliance with all ACO Presently in compliance with all ACO

schedules or approved extensionsschedules or approved extensions

ComplianceCompliance

NPDES PermitNPDES Permit National Association of Clean Water National Association of Clean Water

Agencies (NACWA)Agencies (NACWA) DWSD Wins Silver Peak Performance DWSD Wins Silver Peak Performance

Award (2012)Award (2012) 5 or fewer NPDES Permit violations in a 5 or fewer NPDES Permit violations in a

calendar yearcalendar year

NPDES Permit Compliance Violations 2013NPDES Permit Compliance Violations 2013

Date Outfall Parameter Limit Result 

January 2013 049B TSS Min % Removal

85% 83.9% 

2/27/13 107A Fecal Coliform 1000 cts/100 ml 4394 cts/100 ml 

4/18/13 105A Fecal Coliform 1000 cts/100 ml 2064 cts/100 ml

8/31/13 109A Fecal Coliform 400 Cts/100 ml 642 cts/100 ml 

September 2013 050 Phosphorus 1.5 mg/L 1.65 mg/L

Upcoming Permit RequirementsUpcoming Permit Requirements

Residuals Management PlanResiduals Management Plan Wet Weather Operation PlanWet Weather Operation Plan Asset Management ProgramAsset Management Program Oakwood Pump Station and RTB Project Performance Oakwood Pump Station and RTB Project Performance

Certification (PPC)Certification (PPC) River Rouge Outfall 2 “Biological Survey”River Rouge Outfall 2 “Biological Survey” Green Infrastructure Annual ReportGreen Infrastructure Annual Report Pollutant Minimization Program for Total Mercury and Pollutant Minimization Program for Total Mercury and

Total PCBsTotal PCBs Collection System & CSO treatment facility Op PlanCollection System & CSO treatment facility Op Plan RRO2 Segment 2 DesignRRO2 Segment 2 Design

Residuals Management Residuals Management Program (RMP)Program (RMP)

Annual Report due October 30Annual Report due October 30 RMP approved April 22, 2008 to authorize RMP approved April 22, 2008 to authorize

land application of bulk biosolids or land application of bulk biosolids or prepare bulk biosolids for land applicationprepare bulk biosolids for land application

Must certify that current residuals Must certify that current residuals management practices are in accordance management practices are in accordance with the approved RMPwith the approved RMP

Wet Weather Operation PlanWet Weather Operation Plan

Annual report due Jan 1Annual report due Jan 1 Details necessary requirements to Details necessary requirements to

maximize wet weather treatment at the maximize wet weather treatment at the WWTP while complying with effluent limits WWTP while complying with effluent limits and all other permit conditionsand all other permit conditions

Minimize untreated combined sewage in Minimize untreated combined sewage in the tributary collection systemthe tributary collection system

Asset ManagementAsset Management

Program due January 1, 2014Program due January 1, 2014 Inventory and Assessment of Fixed AssetsInventory and Assessment of Fixed Assets Preventative Maintenance ProgramPreventative Maintenance Program Needs Assessment Needs Assessment Assessment of Criticality and Risk ManagementAssessment of Criticality and Risk Management Capital Planning ProcessCapital Planning Process Scheduled Replacement ProgramScheduled Replacement Program Budget and Rate SufficiencyBudget and Rate Sufficiency Annual ReportingAnnual Reporting

Oakwood Pump Station and Oakwood Pump Station and RTB PPC RTB PPC

The Oakwood CSO facilities (pump station The Oakwood CSO facilities (pump station and RTB) were constructed to eliminate and RTB) were constructed to eliminate discharges of raw, untreated sewage from discharges of raw, untreated sewage from Outfall 082 after June 1, 2012Outfall 082 after June 1, 2012

January 1, 2014 – End performance January 1, 2014 – End performance evaluation period evaluation period

February 1, 2014 - Submit evaluation February 1, 2014 - Submit evaluation report report

River Rouge Outfall 2 Biological River Rouge Outfall 2 Biological SurveySurvey

Assess the effect of discharges from Assess the effect of discharges from Outfall 084 (RRO2) with regard to Outfall 084 (RRO2) with regard to discharges of toxic substancesdischarges of toxic substances

June 1, 2014 – submit approvable work June 1, 2014 – submit approvable work plan for conducting a “biological survey” to plan for conducting a “biological survey” to determine whether the community of determine whether the community of aquatic, benthic biota in the Rouge River aquatic, benthic biota in the Rouge River is negatively impacted by discharges from is negatively impacted by discharges from Outfall 084 Outfall 084

Green Infrastructure Annual Green Infrastructure Annual Progress ReportProgress Report

August 1, 2013 – Plan SubmittedAugust 1, 2013 – Plan Submitted Annual report due August 1Annual report due August 1 Tributary area for Rouge River OutfallsTributary area for Rouge River Outfalls Upper Rouge and Near Eastside Areas Upper Rouge and Near Eastside Areas

Pollutant Minimization Program (PMP) for Pollutant Minimization Program (PMP) for Total Mercury and PCBsTotal Mercury and PCBs

PMP approved November 9, 1995 and PMP approved November 9, 1995 and updated October 1996updated October 1996

The goal of the PMP is to maintain the The goal of the PMP is to maintain the effluent concentration for total HG at or effluent concentration for total HG at or below 1.3 ng/Lbelow 1.3 ng/L

Implement the PMP to reach the goalImplement the PMP to reach the goal Implement reasonable cost effective Implement reasonable cost effective

control measures when sources of control measures when sources of HG/PCBs are discoveredHG/PCBs are discovered

Collection System & Treatment Facility Collection System & Treatment Facility Operation PlanOperation Plan

Annual report due October 1Annual report due October 1 Coordinated with the WWTP Wet Weather Op PlanCoordinated with the WWTP Wet Weather Op Plan Collection and treatment systems are operated to Collection and treatment systems are operated to

maximize treatmentmaximize treatment All dry weather flows are conveyed to the treatment All dry weather flows are conveyed to the treatment

facilities without bypassfacilities without bypass Max wet weather flow is conveyed to the treatment Max wet weather flow is conveyed to the treatment

facilities to minimize untreated dischargesfacilities to minimize untreated discharges Ongoing inspection of the sewer system within the City Ongoing inspection of the sewer system within the City

to reduce I/I and eliminate unauthorized connectionsto reduce I/I and eliminate unauthorized connections

RRO2 Segment 2 DesignRRO2 Segment 2 Design

December 1, 2014 submittal of Final Plans December 1, 2014 submittal of Final Plans and Specificationsand Specifications

SummarySummary

DEQ WRD and DWSD commitment to meet with DEQ WRD and DWSD commitment to meet with stakeholders to discuss WWTP issues stakeholders to discuss WWTP issues

Provided Information regarding:Provided Information regarding:

1) Noise and Odor1) Noise and Odor

2) NPDES Permit Compliance2) NPDES Permit Compliance

3) Upcoming Permit requirements3) Upcoming Permit requirements

QuestionsQuestionsDiscussionDiscussionCommentsComments

Contact: Contact:

Phil Argiroff: Phil Argiroff: argiroffp@michigan.gov

Laura Verona: Laura Verona: veronal@michigan.gov