Permitting of Waste Discharge Permit To Pennsylvania Designated Trout Stream

Caltha LLP Project Summary

Project: Waste Discharge Permit To Pennsylvania Designated Trout Stream
Client: National manufacturer
Location(s): Pennsylvania

Key Elements: Preparation of waste discharge application; Preparation of public notice and local government notification

Overview: This project was to prepare application materials and other required submittals to apply for an NDPES discharge permit for discharge of industrial wastes to a designated cold water fishery in Pennsylvania. Work included sampling and analysis of wastewater discharges and a non-stormwater discharge survey to certify the elimination of all illicit discharges. Permit was issued for discharge which maintained quality of receiving water .

For more information on Caltha LLP services, go to the Caltha Contact Page

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment. Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment

Caltha LLP Project Summary

Project: Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment
Client: Agricultural Chemical Manufacturer
Location(s): California, Illinois, Texas, Minnesota

Key Elements: Acquisition and review of state water quality monitoring data; statistical analysis of the occurrence and concentrations of herbicide in surface water, preparation and submittal of public comments to Department of Agriculture Draft Environmental Assessment

Overview: Caltha was contracted by this multinational agricultural chemical company to prepare a review and analysis of the occurrence of a specific common use herbicide, 2,4-D, in waters of the United States. Caltha first reviewed and summarized nationwide data in the US EPA STORET database and U.S Geological Survey (USGS) National Water-Quality Assessment (NAWQA) Program database. Caltha staff then contacted State agencies which implemented long-term Statewide water quality monitoring programs, including California, Texas, Illinois and Minnesota. All data were then compiled to provide a summary of 2,4-D concentrations in surface waters dating from the 1970s through 2012. Caltha then conducted a review of federal and state regulatory standards for 2,4-D in surface waters, including:

• Federal Water Quality Criteria
• State Water Quality Standards
• Federal Safe Drinking Water Act Maximum Contaminant Level
• Office of Pesticide Program Aquatic Life Benchmarks

Finally, Caltha conducted an analysis of the exceedance of applicable regulatory standards based on the comprehensive analysis of reported herbicide concentrations. All analyses were summarized in a report which was submitted to the US Department of Agriculture through its public comment process for a Draft Environmental Assessment document.

For more information on Caltha LLP services, go to the Caltha Contact Page

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment. Caltha LLP Aquatic Toxicology / WQ Standards Services Website

EPA Proposes Rule Requiring Electronic Submittal For NPDES Permit Information and Data

EPA is proposing rules that would require electronic reporting in place of the current paper-based NPDES reports. The proposed regulation would require permittees and regulators to use existing, available information technology to electronically report information and data related to the NPDES permit program in lieu of filing written reports. EPA believes the proposal will allow better allocation and use of limited program resources and enhance transparency and public accountability by providing regulatory agencies and the public with more timely, complete, accurate, and nationally-consistent sets of data about the NPDES program and potential sources of water pollution.

Given the large scope of the proposal, EPA has committed to publishing a supplemental notice should the agency receive comments on the proposed rule that require significant changes. EPA plans to publish the supplemental notice within 180 days after the public comment period for this proposed rule has closed. Comments on this proposed action must be received on or before October 28, 2013.

This proposed rule would require that reports submitted in writing now be submitted electronically by NPDES-permitted facilities to EPA through the National Environmental Information Exchange Network or to the authorized state, tribe, or territory NPDES program. This can include:

• Discharge Monitoring Reports (DMRs),
• Notices of Intent (NOI) to discharge in compliance with a general permit,
• other general permit waivers,
• certifications,
• notices of termination (NOT) of coverage,
• program reports

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

2006 NPDES Pestides Rule And Related Excemptions Removed

In response to a 2009 Sixth Circuit Court of Appeals ruling that vacated the 2006 NPDES Pesticides Rule, EPA has revised regulations to remove language added by the that rule. This language had exempted the application of pesticides from National Pollutant Discharge Elimination System (NPDES) permit requirements in two circumstances:

1. When the application of the pesticide is made directly to waters of the United States to control pests that are present in the water, and
2. when the application of the pesticide is made to control pests that are over, including near, waters of the United States.

The final rule removes this exemption and is effective on June 27, 2013.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Final Iowa Nutrient Reduction Strategy

The Iowa Department of Agriculture and Land Stewardship, Iowa Department of Natural Resources and Iowa State University have released the final Iowa Nutrient Reduction Strategy . The Iowa Department of Agriculture and Land Stewardship and Iowa Department of Natural Resources (DNR) worked with Iowa State University over a two-year period to develop a draft strategy that was released for public comment period on November 19, 2012. Over 1,700 written comments were received from November 19, 2012 to January 18, 2013.

The Iowa Nutrient Reduction Strategy is a science and technology-based approach to assess and reduce nutrients delivered to Iowa waterways and the Gulf of Mexico. The Iowa strategy was developed in response to the 2008 Gulf Hypoxia Action Plan that calls for the 12 states along the Mississippi River to develop strategies to reduce nutrient loading to the Gulf of Mexico. The strategy will be used to develop operational plans through the Water Resources Coordinating council. The strategy is designed to direct efforts to reduce nutrients in surface water from both point sources, such as wastewater treatment plants and industrial facilities, and nonpoint sources, including farm fields and urban areas, in a scientific, reasonable and cost effective manner.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

New Standard Practice For Developing Lists of Invasive Plant Species

ASTM has announced that it has begun an initiative to create a standard that 1) describes the criteria and procedures by which to develop an invasive plant list for a defined region and 2) will be useful as the foundation for creating lists of invasive plants to support building codes and related applications. Model building codes and rating systems that aim to improve the environmental performance of buildings and their sites increasingly incorporate clauses to address the ecological damage related to invasive plants in landscaping.

ASTM believes a standard is needed to provide government agencies as well as environmental, academic, and horticultural organizations a common approach to determining what plants are invasive to a specified area. Existing State and Federal noxious weed lists have generally not kept pace with the latest science in the field, and many focus predominantly on agricultural, rather than ecological, impacts. Few local governments have yet to develop their own lists. With definitions dependent on the existence of local, State, and Federal lists, ASTM has concluded that the invasive plant requirements in green building codes will have little effect.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Keokuk, Iowa Receives Grant To Address Combined Sewer Overflows

EPA Region 7 has awarded $291,000 to the City of Keokuk, Iowa, for improvements to its sewer system. The project is expected to be completed by the fall of 2014. The purpose of the project is to construct new sanitary and storm sewer systems, which will eliminate four sewer overflows. The new sewer will provide adequate capacity for both current and anticipated future flows. A long-term strategy has been developed to eliminate six combined sewer overflows in Keokuk that drain either into the Mississippi River or Soap Creek.

Keokuk is one of 10 Iowa cities that have combined sewer systems. These systems typically use one pipe that combines sanitary sewer and storm sewer to the wastewater treatment plants during normal rainfall. However, during rainfall, this system sometimes overflows into nearby streams. and private partners.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Update To Great Lakes Restoration Initiative Action Plan 2015-2019

The Great Lakes Interagency Task Force has scheduled meetings for the public to provide input to a planned update of the Great Lakes Restoration Initiative Action Plan. The updated Action Plan would direct Great Lakes restoration for fiscal years 2015-2019. The public may comment directly to the federal agencies and to the Great Lakes Advisory Board (GLAB), a panel of experts established to provide recommendations to the federal agencies.

Comments may be given at any of the following scheduled meetings:
•May 21-22 - Great Lakes Advisory Board Inaugural Meeting & Public Comment to GLAB
 •May 23 - Webinar
•May 28 - Buffalo, New York.
•May 30 - Milwaukee, Wisconsin.
•June 3 - Webinar
•June 5 - Cleveland, Ohio.

In February 2010, the Task Force released the GLRI Action Plan for FY2010-2014. The Action Plan identified goals, objectives, measurable ecological targets, and specific actions to help rehabilitate the Great Lakes. The Action Plan targets investments to reduce toxic contamination, rehabilitate fish and wildlife habitat, improve nearshore health, reduce nutrients and other land-based pollution, prevent invasive species, and promote accountability, education, and collaboration.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

PADEP List of Impaired Waters Approved For 2012

The U.S. Environmental Protection Agency has approved Pennsylvania’s 2012 final list of impaired waters. The list is part of a bi-annual monitoring and assessment report characterizing the condition of Pennsylvania’s surface waters. The 2012 list submitted by the Pennsylvania Department of Environmental Protection (PADEP) contains 7,009 impaired waters, of which 263 are newly listed including portions of Buffalo Creek and Plum Creek in the Upper Juniata watershed. The list also includes more than 650 stream miles within the Susquehanna River Basin that were added or updated in the 2012 list. The new list removes 39 water bodies that were on the previous list including over 96 miles in the Upper Susquehanna-Lackawanna basin and 27 miles of the Lehigh River.

The final report includes a change in the designation for a nearly 100-mile section of the main stem of the Susquehanna River from “unimpaired” for aquatic life and recreational uses, to having insufficient water quality data to make an impairment determination. That change from the draft to the final report reflects comments submitted to PADEP from EPA and others, as well as ongoing efforts to identify the cause of health impacts to the Susquehanna’s smallmouth bass population. PADEP initiated a special study of the fish health problem in 2012 and is continuing its data collection efforts in 2013 to further assess water quality in the Susquehanna River and its major tributaries, and identify the cause(s) for the decline in smallmouth bass. While these steps are underway, the Chesapeake Bay TMDL and accompanying Pennsylvania Watershed Implementation Plans require action to reduce nitrogen, phosphorus and sediment pollution within the Susquehanna watershed.

Caltha LLP provides expert consulting services to public and private sector clients in Pennsylvania and  nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Final 2012 Iowa Impaired Waters Listing Approved By USEPA

In an April 24, 2013 decision letter, US EPA has approved Iowa’s 2012 list of impaired waters requiring Total Maximum Daily Load (TMDL) calculations. The Iowa Department Natural Resources (IDNR) submitted its impaired waters list to EPA on April 1, 2013, for review and approval as required by the Clean Water Act.

In its decision, EPA approved the removal of 73 water bodies and the addition of 78 water bodies to the Iowa list of impaired waters. The action brings the total number of impaired waters on the state’s list to 479.

As background, a water body is placed on the impaired waters list when monitoring finds that pollutant levels prevent the lake, river, or stream from attaining its beneficial uses. A water body can be removed from the list if it meets its beneficial uses or if a pollution reduction plan (TMDL) for a water body is approved by EPA. Beneficial uses in Iowa include human recreation, water supply, and maintaining healthy aquatic life.

Caltha LLP provides expert consulting services to public and private sector clients in Iowa and nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

General Permit For Small Dredging Operations Issued By EPA Region 10

US EPA Region 10 has issued a new federal water discharge permit operate small dredge operations in Idaho. Mining for gold using small suction dredges is a popular activity in Idaho with hundreds of dredges in use, especially during the summer. Small-scale suction dredge miners ( defined as using intake nozzles of five inches in diameter or less and engines rated at 15 horsepower or less) will need to apply for coverage under the new Clean Water Act general permit. Larger suction dredges are not covered by this general permit and need to be authorized under a separate individual permit.

To legally operate small suction dredges in Idaho, miners must apply to EPA to be covered by the EPA General Permit, as well as check with the Idaho Department of Water Resources or other state or federal authority for any additional permits that may be required.

The EPA General Permit also contains:

• Special conditions
• Required best practices for dredging equipment operations
• Areas that are open to small suction dredge mining
• Monitoring and reporting requirements

If an operator does not meet the eligibility requirements to be covered under the general permit, they can apply for an individual permit from EPA.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Federal Water Quality Standards Withdrawn For New Jersey, Puerto Rico and San Francisco Bay

EPA is taking final action to amend the federal regulations to withdraw certain human health and aquatic life water quality criteria applicable to waters of New Jersey, Puerto Rico, and California's San Francisco Bay. In 1992, EPA promulgated the National Toxics Rule or NTR to establish numeric water quality criteria for 12 states and two Territories, including New Jersey, Puerto Rico and parts of California. On May 18, 2000, EPA then promulgated a final rule known as the California Toxics Rule or CTR in order to establish numeric water quality criteria for priority toxic pollutants for the State of California that were not previously in the NTR.

These two states and one territory have now adopted, and EPA has approved, water quality criteria for certain pollutants included in the NTR. Because California, New Jersey, and Puerto Rico now have water quality standards that meet the requirements of the Clean Water Act, EPA has determined that the federally promulgated criteria are no longer needed for these pollutants. Therefore EPA is proposing to amend the federal regulations to withdraw those certain criteria applicable to California, New Jersey, and Puerto Rico. The withdrawal of the federally promulgated criteria will enable New Jersey, Puerto Rico, and California to implement their EPA-approved water quality criteria. This final rule is effective on June 3, 2013.

The water quality criteria subject to this action address both freshwater and marine standards and cover a wide range of priority pollutants, including metals, volatile organic chemicals, PAHs, PCBs, pesticides and others EPA has proposed to withdraw only one federal water quality criteria for California - the saltwater aquatic life cyanide criteria for San Francisco Bay. Other criteria for cyanide for waters in California that are currently part of the NTR or CTR will remain unchanged in the federal regulations

.Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

National Rivers and Stream Assessment Report Released

U.S. Environmental Protection Agency has released the 2008-2009 National Rivers and Stream Assessment. The survey looked at the health of thousands of stream and river miles across the country, and reported that about 55% are in poor condition for aquatic life. The report findings include:

• Nitrogen and phosphorus are at excessive levels. An estimated 27% of the nation’s rivers and streams have excessive levels of nitrogen, and 40% have high levels of phosphorus.
• Streams and rivers are at an increased risk due to decreased vegetation cover and increased human disturbance. These conditions can cause streams and rivers to be more vulnerable to flooding, erosion, and pollution. Approximately 24% of the rivers and streams monitored were rated poor due to the loss of healthy vegetative cover.
• Increased bacteria levels. High bacteria levels were found in 9% of stream and river miles making those waters potentially unsafe for swimming and other recreation.
• Increased mercury levels. More than 13,000 miles of rivers have fish with mercury levels that may be unsafe for human consumption.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

EPA Adds Impaired Waters To West Virginia 303D List

The U.S. Environmental Protection Agency has responded to the West Virginia Department of Environmental Protection (WVDEP) proposed list of impaired waterways in West Virginia. The list includes 1,176 waterways previously designated as impaired by the State, and an additional 255 waterways identified by EPA, based on the State’s current water quality standards.

In its response, EPA acknowledged WVDEP’s position that it is precluded by Senate Bill No. 562 from evaluating waters for aquatic life uses pending adoption of a new methodology for evaluating waterways. EPA identified the additional waterways, representing more than 1,000 miles of rivers and streams, based on its review of readily available State data. The agency reviewed the information using substantially the same methodology that West Virginia has used to review this type of data in the past.

EPA will publish a notice of the proposed additions in the federal register on or before April 15, which will begin a 30-day public comment period. EPA will review all of the comments and make changes to the proposed list as appropriate.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Water Standards For Selenium Proposed In Kentucky

The Kentucky Division of Water has been conducting the triennial review of the state’s water quality standards since early 2012. Recently, the agency had proposed regulations address a number of changes to the water quality standards and included proposed deletion of the acute water quality criterion for selenium.

The proposal to delete the acute standard was based on the Division’s findings that the current state standard, which was derived from USEPA guidance, was not based on sound science. USEPA Region 4 commented on the proposed deletion and identified three options: (1) leave the current acute criterion in place and wait for release of any revisions to USEPA’s selenium criteria, (2) adopt the acute criterion from USEPA’s current national guidance, or (3) adopt an alternate criterion based on other scientifically defensible guidance.

In response, the Division conducted a survey of recent studies of selenium toxicity to aquatic species and determined that it was appropriate to develop state-specific water quality criteria for selenium. The agency is proposing an acute criterion for warmwater aquatic habitat of 258 ug/L, with an alternate calculation option depending on the sulfate concentration that is present. The proposed chronic criterion for warmwater aquatic habitat is 8.6 ug/g (dry weight) of whole fish tissue or 19.2 ug/g (dry weight) of fish egg/ovary tissue. The analysis of fish tissue is triggered when the water column concentration of selenium exceeds 5.0 ug/L. If the water column result is less than or equal to 5.0 ug/L, the water body is meeting is aquatic life uses. If the water column result is greater than 5.0 ug/L, then the next step is to determine whether the site is attaining the fish tissue or egg/ovary tissue criterion.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Changes Considered To Minnesota Water Quality Regulations

The Minnesota Pollution Control Agency is proposing to make some revisions to Minnesota Rules Chapters 7050, 7052 and 7053. The amendments proposed for this rulemaking are the result of the 2008 public review of Minnesota’s water quality standards. The scope of this rulemaking will address six areas of the water quality standards:

1. River Eutrophication — numeric nutrient standards for rivers, streams, the Mississippi River pools and Lake Pepin.
2. Total Suspended Solid (TSS) — replacement of the existing standard for water turbidity with more scientifically accurate, region-specific TSS standards.
3. Human Health Methods — updates to the methods used for establishing the Class 2 chronic water quality standards to protect human health.
4. Process for listing Class 2A waters as cold water communities/trout waters — refine the current basis for classifying Class 2A waters to also include biological information on the aquatic communities.
5. Class 3 Waters — update the basis for identifying Class 3 waters and remove the numeric standards.
6. Other changes to use classifications — regular review and updates to Class 1 and Class 7 Limited Resource Value Waters.

The MPCA anticipates to conduct public informational meetings in Summer 2013 and to publish proposed rules in Fall 2013. Final rules would be effective in Spring 2014

Caltha LLP provides expert consulting services to public and private sector clients in Minnesota and nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Antidegradation Requirements For Discharges To Wisconsin Impaired Waters

The Wisconsin Department of Natural Resources has released its draft guidance document “TMDL Development and Implementation Guidance: Integrating the WPDES and Impaired Waters Programs” for a 21-day public comment period. In addition to providing a framework for developing and implementing permit limits for discharges to 303d listed impaired waters, the draft guidance also addresses the WDNR approach to antidegradation requirements.

Under the draft guidance, if the new TMDL-derived limit results in an increase in an effective existing limit in a permit, then an antidegradation evaluation is needed. The initial imposition of a water quality-based effluent limit, which include TMDL-derived limits, does not require an antidegradation evaluation as long as the pollutant of concern was previously present in the discharge and the permittee is not proposing an increased load to the receiving water . According to the WDNR, possible exceptions include the initial imposition of a TMDL-derived limit for a discharge to Exceptional and Outstanding Resource Waters, for a bioaccumulative chemical of concern such as mercury when an increased discharge is proposed, and when a change in discharge location is proposed.

With a few exceptions, Wisconsin chapter NR 207 requires an antidegradation evaluation when a new or increased discharge is proposed. Therefore, an antidegradation evaluation is necessary before a TMDL-derived limit, which has been incorporated into a WPDES permit and has become effective, is increased or the TMDL-derived limit replaces a less restrictive effective effluent limit.

Caltha LLP provides expert consulting services to public and private sector clients in Wisconsin and nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Use of ASTM D7575 Method For Oil and Grease Measurement

US EPA has published its final decision on its reconsideration of the methods used by NPDES permittees to test for Oil and Grease. In the 2010 proposed Methods Update Rule (MUR), EPA discussed a new method, ASTM D7575, for oil and grease. The agency subsequently published a Notice of Data Availability (NODA) on this method that provided new data and requested comment on whether and how EPA should approve the method in Part 136 as an alternative oil and grease method.

As background, EPA establishes test procedures in 40 CFR Part 136. When EPA has promulgated a test procedure for analysis of a specific pollutant, an NPDES permittee must use an approved test procedure for the specific pollutant However, 40 CFR Part 136 also recognizes that new technologies and approaches are constantly being developed, including methods for pollutants for which EPA already has an approved test procedure. The CWA allows for use of an alternate method for a specific pollutant or parameter that is different from the approved test procedure (i.e., limited use approval). Requests for such uses, along with supporting data, are made to the applicable Regional Alternate Test Procedure (ATP) Coordinator for consideration and approval.

Unlike many parameters, oil and grease is not a unique chemical entity, but is a mixture of chemical species that varies from source to source. Common substances that may contribute to oil and grease include petroleum based compounds such as fuels, motor oil, lubricating oil, soaps, waxes, and hydraulic oil and vegetable based compounds such as cooking oil and other fats. Currently, Part 136 lists EPA Method 1664A for the measurement of oil and grease.

In 2010, EPA proposed to add new and revised EPA methods to its Part 136 test procedures. Among other methods, EPA described, but did not approve, three oil and grease methods, ASTM D7575, ASTM D7066 and Standard Methods 5520. Because EPA expressed interest in the use of solvent-free methods, EPA evaluated the ASTM D7575 method for the measurement of oil and grease and announced it was re-considering its decision not to include ASTM D7575 in 40 CFR Part 136 as an alternative to EPA Method 1664A for measuring oil and grease.

After consideration, EPA concluded that ASTM D7575 is a good stand alone method for the measurement of oil and grease. However, EPA also concluded that the case has not yet been made that ASTM D7575 should be approved for nationwide use as an alternative oil and grease method. However, EPA considered various approaches for allowing its use as an alternative to approved methods. EPA has concluded such determinations should be made on a case by case basis rather than a nationwide basis.

EPAs approach to approve ASTM D7575 as an alternative oil and grease method requires permittees to demonstrate comparability (side-by-side data) to the permitting authority. To determine comparability for a specific application, with approval of the ATP Coordinator, a permittee could use the specific side by side comparison procedures. Under this approach, a permittee would only be able to use ASTM D7575 if the recommended procedures demonstrated comparability.

EPA anticipates that requests for the use of ASTM D7575 as an alternative oil and grease method could be widespread, and wants to ensure that such requests are handled consistently. EPA recommends that applicants demonstrate comparability by conducting a side-by-side comparison using the specific procedures recommended in the guidance document that was developed when Method 1664A was promulgated. Comparability could be shown if this side by side comparison demonstrates there is no significant difference between the promulgated method and ASTM D7575. EPA notes that such requests may provide sufficient additional data to allow EPA at a later date to later make a nationwide determination on the approval of ASTM D7575 as an alternative oil and grease method.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Revision To Missouri NPDES Compliance Schedule Requirements

EPA Region 7 has approved Missouri's change to state water quality standards rules to provide greater flexibility in Missouri's National Pollutant Discharge Elimination System (NPDES) permit program.

The Missouri Department of Natural Resources submitted rule changes to EPA on Dec. 11, 2012, for review and approval. State regulations previously allowed no more than three years for a permittee to come into compliance with its NPDES permit. Due to the limits of current technology for controlling some pollutants, full compliance is not always possible within a three-year period. Therefore Missouri proposed new regulations that allow for a longer compliance period, in accordance with federal regulations.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Summary of 2011 EPCRA 313 TRI Releases To Great Lakes

Releases of EPCRA Section 313 reportable chemicals into surface waters in the Great Lakes Basin increased by 12 % from 2010 to 2011, according to the U.S. Environmental Protection Agency’s annual Toxics Release Inventory report. Nationwide, releases due to surface water discharges decreased by 3 %.

Nitrates and pesticides from municipal wastewater treatment plants and agriculture account for most of the releases from surface water discharges to the Great Lakes Basin. Nitrates were also discharged by primary metals facilities, such as iron and steel mills and smelters, and food and beverage manufacturers.

For the summary, the Great Lakes Basin consists of Lakes Superior, Michigan, Huron, Erie and Ontario; a number of other smaller lakes and waterways; and the surrounding watershed. The watershed covers parts of Illinois, Indiana, Minnesota, Michigan, New York, Ohio, Pennsylvania and Wisconsin, and parts of Ontario in Canada. Despite increases from 2010 to 2011, overall Section 313 releases in the Great Lakes Basin have decreased about 40 % since 2003 and are currently at the second-lowest level in a decade. Surface water, air and land releases in the basin increased by 12, 1 and 4 % respectively, while underground injection decreased 5 % from 2010 to 2011.

Read summary of national EPCRA TRI releases for 2011.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

EPA Comments On Draft Iowa Nutrient Reduction Strategy

U.S. EPA Region 7 has provided comments on the draft Iowa Nutrient Reduction Strategy released Nov. 19, 2012. EPA commends the Iowa Department of Natural Resources (IDNR) and Iowa Department of Agriculture and Land Stewardship (IDALS) for developing the strategy that embraces ambitious specific nutrient reduction targets. Iowa based its draft strategy on EPA’s 2011 memorandum that dealt with how states should achieve long-term reductions in nitrogen and phosphorous pollution in water bodies.

EPA states that supports states leading efforts to reduce nutrient loads from point and nonpoint sources but stresses that EPA is not mandating specific strategies or solutions. The draft strategy raised concerns about EPA’s ecoregional criteria published in 2000. Since then, EPA and some states have identified a range of options that can be appropriately used for development and implementation of numeric nutrient criteria.

In its comments, EPA does offer recommendations to strengthen the policy considerations and point and nonpoint source sections of the document. The Agency makes a number of recommendations to be addressed during implementation of Iowa’s nutrient reduction efforts.

Read a summary of the Iowa Nutrient Reduction Strategy

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Iowa Nutrient Reduction Strategy Comment Period Extended

The public comment period for the Iowa Nutrient Reduction Strategy has been extended by two weeks until January 18, 2013. The original 45-day comment period was scheduled to close on January 4.

According to IDNR, as of January 2 more than 350 comments had been received on the plan. The Iowa Nutrient Reduction Strategy is a science and technology-based approach to assess and reduce nutrients delivered to Iowa waterways and the Gulf of Mexico. The strategy outlines voluntary efforts to reduce nutrients in surface water from both point sources, such as wastewater treatment plants and industrial facilities, and nonpoint sources, including farm fields and urban areas.

The Iowa Department of Agriculture and Land Stewardship (IDALS) and Iowa Department of Natural Resources (DNR) worked with Iowa State University over a two-year period to develop the strategy. The Iowa strategy was developed in response to the 2008 Gulf Hypoxia Action Plan that calls for the 12 states along the Mississippi River to develop strategies to reduce nutrient loading to the Gulf of Mexico. The Iowa strategy follows the recommended framework provided by EPA in 2011 and is only the second state to complete a statewide nutrient reduction strategy.

More information on Iowa Nutrient Reduction Strategy

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.
Caltha LLP Aquatic Toxicology / WQ Standards Services Website