Iowa Proposes Rules To Create New General Wastewater Permits

The Iowa Department of Natural Resources (DNR) has proposed two general discharge permits to cover two types of common and generally low risk discharges. DNR plans to issue two new National Pollutant Discharge Elimination System (NPDES) general permits known as General Permit #8 (GP8) and General Permit #9 (GP9). GP8 allows for discharges of hydrostatic test water (water used to test the integrity of a pipe or tank), underground storage tank ballast water (water used to weight a tank to facilitate underground installation), and water associated with installation, repair, and replacement of potable water lines. GP9 allows for discharges from dewatering associated with construction and small residential geothermal heating and cooling systems. IDNR is proposing to include eligibility criteria and Best Management Practices. These will ensure that discharges will comply with water quality standards. Most permittees will be automatically authorized to discharge. Only a few higher-risk dischargers will need to submit a Notice of Intent. There is no fee for either permit. DNR is seeking public comment on proposed rules that will create two new general permits. DNR will hold three public hearings across the state in March:

• Wednesday, Mar. 7, 4 p.m. at the Coralville, IA Public Library
• Thursday, Mar. 8, 4 p.m. at the Harlan, IA Public Library
• Wednesday, Mar. 14, 4 p.m. at the Urbandale, IA Public Library

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Iowa Food Processing Plant Needed Water Reduction Management Plan

Caltha LLP Project Summary

Project: Water Use Reduction Audit / Water Usage Management Program
Client: International Food Processor
Location(s): Iowa


Key Elements: Water use reduction audit, Water use process control limits, Water use management plan


Overview: This large facility wished to reduce overall water usage as a corporate initiative to reduce environmental impacts of its operations and because the facility was approaching permitted limits for wastewater discharge to the local POTW. Water was used in a wide variety of processes around the facility, and water usage inside the plant was monitored by a set of water meters collecting daily total usage at various points around the water distribution system. Project elements included:

• Developing a Water Use Map for the facility,
• Review and statistically analysis of previous five years of water meter  and daily processing throughput data,
• Identification of specific processes determined to be “out-of-control”, defined as those process areas where variations in water usage were poorly correlated to production.

Once targeted processes were identified, control limits were calculated for each process so that daily water use could be quickly evaluated by facility staff to determine if immediate corrective action(s) were needed. Using this system, incremental improvements on water use reduction were realized.


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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

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

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

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

Iowa Nutrient Reduction Strategy Released

On November 19, 2012, the State of Iowa announced the release of the Iowa Nutrient Reduction Strategy for public comment. Interested parties were invited to submit comments during a 45 day comment period that will end on January 4, 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 strategy outlines voluntary efforts to reduce nutrients in surface water from both point sources and nonpoint sources. The Iowa Department of Agriculture and Land Stewardship, Iowa Department of Natural Resources (DNR) worked with Iowa State University over a two-year period to develop the strategy.

The Iowa strategy has been 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. Iowa is the second state to complete a statewide nutrient reduction strategy.

To address point source discharges, such as POTW and industrial discharge, the Iowa Department of Natural Resources will be working with major facilities throughout the state to reduce nutrient discharges from point sources to Iowa's waters with a goal of reducing total phosphorus by 16% and total nitrogen by 4 %.

Summary of proposed permitting requirements for point source discharges under nutrient reduction plan


To address nutrient transport from nonpoint sources the strategy uses a scientific assessment of conservation practices and associated costs to reduce loading of nutrients to Iowa surface waters. The strategy identifies five key categories to focus the efforts in addressing nonpoint sources and identifies multiple action items within each category. The five categories are:

• Setting Priorities;
• Documenting Progress;
• Research and Technology;
• Strengthen Outreach,
• Education,
• Collaboration; and
• Funding.

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

IDNR Proposed Changes To Use Designations For Iowa Rivers

The Iowa Department of Natural Resources (DNR) is holding public meetings across the state to gather input on proposed water quality standards designated use changes for selected rivers and streams in Iowa. These changes are intended to enhance the protection of aquatic life and recreational uses in these waters. Rivers affected include segments of the Iowa River, Cedar River, Des Moines River and several others

Meetings will be held in:

• Atlantic: Nov. 13.
• Clear Lake: Nov. 8
• Independence: Nov. 28
• Spencer: Nov. 5
• Washington: Nov. 27
• West Des Moines: Nov. 19

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 Findings On Review Of Iowa DNR CAFO NPDES Program

The US Environmental Protection Agency (EPA) has issued initial findings from an informal investigation of the Iowa Department of Natural Resources’ (IDNR) permit program for concentrated animal feeding operations (CAFOs) and has identified several correctable deficiencies. EPA’s investigation was carried out in response to a petition for withdrawal of the National Pollutant Discharge Elimination System (NPDES) program authorization from IDNR that was filed in 2007 by the Iowa Citizens for Community Improvement, Sierra Club and the Environmental Integrity Project. Federal regulations allow interested parties to file these petitions when they are concerned that a state is not meeting the minimum NPDES program requirements.

EPA’s initial findings identify deficiencies in IDNR’s NPDES program that the state agency will need to correct. Among others, EPA found that IDNR does not have an adequate program to assess whether unpermitted CAFOs need NPDES permits. The findings also note that IDNR must clarify its authority to issue NPDES permits to confinement (roofed) CAFOs that discharge. EPA also found that in a number of cases involving Clean Water Act (CWA) violations, IDNR failed to take timely and adequate enforcement actions, and assess adequate penalties.

The issuance of the initial report is the first step in the process in which EPA will work with IDNR to correct the deficiencies. EPA has asked that IDNR provide a written response to the report, within 60 days, describing the actions IDNR has taken or will take to correct the deficiencies, including a proposed plan and timeline to address the deficiencies. EPA intends to provide an opportunity for the public to comment on IDNR proposals to correct the deficiencies.


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 Proposed To Iowa Sewage Disposal Rules

The Iowa Environmental Protection Commission has approved a Notice of Intended Action for IAC567-Chapter 69, “Private Sewage Disposal Systems” and IAC567-Chapter 68, “Commercial Septic Tank Cleaners”. The proposed changes to Chapter 68 are response to the passage of Senate File 321 (2011) which amended Iowa Code 455B.172 to include language relating to the disposal of wastewater from on-farm food processing facilities. The changes to Chapter 69 result in part from the passage of House File 2437 (2010). This bill modified Iowa Code 455B.172 (11) to simplify and provide clarity to the time of transfer septic system inspection requirements. Other minor changes are also proposed including renewal of the NPDES General Permit #4 for legally discharging private sewage systems.

Written suggestions or comments on the proposed amendments are being accepted through May 1, 2012. Public hearings will be held at the several locations in Iowa on April 12-19.

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 Approves Some and Disapproves Other Proposed Changes To Iowa Designated Uses

EPA has approved the Iowa Department of Natural Resources’ (IDNR) designated use changes for 430 water bodies and disapproved proposed changes for 89 water bodies. Designated uses describe the achievable recreational activities and aquatic life uses for Iowa’s waters.

IDNR submitted these new and revised Iowa surface water quality standards to EPA for review and approval, as required by the Clean Water Act (CWA). The state based its recommendations on site-specific field data gathered by IDNR in and near streams, lakes and rivers. This submission updates the use designations to determine the highest attainable use for the individual waters. Designated recreational uses protect for activities such as swimming, fishing and canoeing; and for human consumption of aquatic life. Aquatic life uses provide for the protection and maintenance of a healthy environment for fish and other animals.

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 Impaired Waters Listing Approved By EPA

EPA has approved Iowa’s list of impaired waters, which removes 56 waters from the previous impaired waters list and adds 103 waters. The final approved 305(b) list brings the total number of impaired waters in the state to 474.

The Iowa Department of Natural Resources submitted its impaired waters list to EPA for review and approval as required by the Clean Water Act. The Act requires EPA to review the state’s list of impaired waters to determine if the state reasonably considered available water quality-related data, and identifies waters to be listed. 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. Beneficial uses in Iowa include human recreation, agricultural water supply, and maintaining healthy aquatic life.

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 DNR Water Quality Standards For Lakes

The Iowa DNR has proposed criteria for evaluating Iowa lakes used for swimming. The proposed standards measure the transparency of the water and recommend maintaining water clarity of a little more than 3 feet (1 meter) in at least 75 % of the measurements. A standard of maintaining chlorophyll-a levels not to exceed 25 ug/L in 75 % of the measurements taken is also being proposed. Both standards are based on measurements taken during the summer recreational months between Memorial Day and Labor Day.

These standards were initially proposed in January 2010 [click here for more information]

The standards will apply to 127 lakes in Iowa that have a maintained beach, appear on the list of Significant Public Owned Lakes or have a mean depth of more than 3 meters (9.9 feet).

A series of public meetings to gather input from citizens regarding proposed criteria are scheduled throughout the state between March 23 and 31. Written suggestions or comments on the proposed amendments are being accepted through May 15, 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

Quarry and Mine General Permit Revised By Iowa DNR

The Iowa Department of Natural Resources has scheduled a public meeting on November 30, 2010 to discuss proposed new rules for quarry and mine owners and operators. IDNR will explain changes in the draft permit that applies to these operations and seek comments on the rule change. The revised draft general permit will require operators to consider methods that would reduce water quality impacts. It also clarifies the duties of mine and quarry operators.

The changes are proposed for wastewater discharges from mining and processing facilities that currently need an IDNR General Permit Number 5. The updated rules will keep mines and quarries in compliance with state water quality standards.

Most currently permitted facilities are eligible to use the general permit. However, they will have to submit results from water sample tests on sulfate in the future. The DNR may require an individual permit for facilities with high sulfate levels and those with new or expanded discharges to Outstanding Iowa Waters. The proposed changes would become effective in July 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

Pesticide Application Permit Public Hearings in Iowa

The Iowa Department of Natural Resources (DNR) has scheduled a series of public hearings to solicit input on a proposed NPDES General Permit for pesticide applications. Due to a federal court decision, persons who spray or apply pesticides to areas where the pesticide residues can end up in a water body will soon have to meet the requirements of a permit issued by the DNR.

The IDNR has scheduled hearings as follows:

• September 28, 2010, Atlantic, IA.
• September 29, 2010, Clear Lake, IA.
• September 30, 2010, Storm Lake, IA.
• October 5, 2010, Manchester, IA.
• October 6, 2010, Washington, IA.
• October 7, 2010, Des Moines, IA.


Any interested person can also submit written comments on the proposed rules on or before October 13, 2010.

The DNR intends to discuss the criteria in the draft permit that determine which pesticide applicators will be required to submit a notice of intent for coverage under the permit to the DNR in addition to their current duties as pesticide applicators. DNR also intends to discuss whether more or less pesticide application types should be covered under the permit, if the operator definition is clear and reasonable, and if the permit requirements are overly burdensome or unattainable.

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

Antidegradation Implementation Procedure Training

The Iowa Department of Natural Resources (IDNR) has scheduled Antidegradation Implementation Procedure Training scheduled for Monday, June 28, 2010 in Johnston, Iowa.

Training is intended to provide a better understanding the new Antidegradation Implementation procedures. The training course will go through the new antidegradation implementation procedures, review the example alternative analysis previously released, and answer questions about how to conduct the alternative analysis.

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 Antidegradation Rule - Postponed Implementation

The revised Iowa DNR antidegradation rule was effective on February 17, 2010, but has not yet been submitted to the U.S. Environmental Protection Agency (EPA) for approval. The antidegradation rule states “all unapproved facility plans for new or expanded regulated activities…shall undergo an antidegradation review if degradation is likely in the receiving water or downstream waters following the effective date of the ‘Iowa Antidegradation Implementation Procedure.’”

However, IDNR has decided to begin implementation of the new antidegradation rule after the rule is approved by EPA. Any facility plan not approved by the date EPA approves the antidegradation rule must include an antidegradation analysis if the project would result in degradation. For activities that do not require a construction permit, a National Pollutant Discharge Elimination System (NPDES) permit application or amendment request an antidegradation analysis must be submitted if the activity would result in degradation and if the permit is not on public notice before the date EPA approves the antidegradation rule. According to IDNR, facility plans that have not been approved and NPDES permit applications or amendment requests that have not been placed on public notice will be considered to be incomplete and may be returned to the applicant for completion.

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 Terminates Nutrient Criteria Rulemaking

The Iowa Department of Natural Resources (DNR) will ask the Environmental Protection Commission to terminate the rule intended to establish nutrient water quality criteria for lakes to protect recreational uses. Public hearings and consultation with stakeholder groups indicated substantive changes needed to be made to the rule. DNR believes that the planned revisions will change the character of the rule enough to justify a new Notice of Intended Action. The changes will also require some additional research by the DNR making it impractical to amend the current notice. After conducting the research and consulting with stakeholder groups, the DNR will ask the commission to approve a new Notice of Intended Action.

The DNR has also cancelled the two remaining public hearings that were rescheduled for later in March.

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

Review of Iowa Lakes Using Proposed Water Quality Standards

The Iowa Department of Natural Resources (IDNR) has proposed a revision to the water quality standards used to assess Iowa lakes. [Read more about the proposed standards] In conjunction with this rulemaking process, IDNR has published a review of existing data sets on Iowa lakes to evaluate how well lakes in the State currently comply with the current and the proposed standards.

The report, “How Many Lakes Will Meet the New Criteria”, compares sampling data from 132 lakes with both the proposed criteria and the criteria currently used to decide whether a lake fully supports swimming. The Trophic State Index (TSI) is used to quantify whether a lake meets the narrative water quality criteria contained in Iowa’s water quality standards such as a lake must be free of nuisance aquatic life. The TSI measures water quality parameters such as nutrient concentrations, transparency and chlorophyll-a concentrations. algae blooms. These narrative criteria apply to all surface waters.

In summary, of the 132 lakes reviewed, 64% do not meet the TSI criteria. A total of 88% of these lakes do not meet the proposed criteria. Most of the lakes that do not meet the proposed criteria would not meet either the transparency or the chlorophyll-a criteria.

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