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Antidegradation and Alternatives Analysis

Antidegradation and Alternatives Analysis. Mary E. Gardner Regulatory Programs Administrator Littleton/Englewood WWTP Colorado. Littleton/Englewood. Experiences Outcomes Problems Successes. Antidegradation is the regulation that controls degradation of certain water bodies.

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Antidegradation and Alternatives Analysis

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  1. Antidegradation and Alternatives Analysis Mary E. Gardner Regulatory Programs Administrator Littleton/Englewood WWTP Colorado

  2. Littleton/Englewood • Experiences • Outcomes • Problems • Successes

  3. Antidegradation is the regulation that controls degradation of certain water bodies Alternatives Analysis is the tool used by a Permittee to address the issues associated with the regulation

  4. The Regulatory Definitions are…… • Outstanding Waters—”Outstanding Waters” is the highest level of water quality protection-- state/national waters needing to be maintained and protected at their existing quality • Use Protected—Waters that the Commission has determined do not warrant the special protection provided by the outstanding waters designation or the antidegradation review process.

  5. Segment 14 of the South Platte River Classification • Reviewable • Waters with no designation • Only insignificant degradation is allowed • Unless a review shows justification for significant degradation.

  6. Criteria to Evaluate • New activities or facilities: expansion of existing activities or facilities resulting in increased load • At time of permit renewal any increase in authorized discharge levels from permitted effluent limits

  7. Where Did this Put L/E? • 2001 permit issued with new effluent limits for Copper, Silver, Lindane • Plant expansion PELs for ammonia

  8. How to Sort it Out A determination shall be made whether the degradation is necessary to accommodate important economic or social development in the area in which the waters are located Two separate issues but one tool— Alternatives Analysis document

  9. Regulation 31 Statement of Basis and Purpose Substantial concern was expressed in comments….. additional burden placed on project…. establishing an alternatives analysis… The Commission does not intend that this requirement would constitute a major additional burden in most instances…….

  10. Necessity of Degradation • Area where the waters are located • Is the proposed regulated activity important for economic or social development?

  11. Important Economic Development Is it Economically Reasonable to: • Expect L/E to pay to treat to lower standards than the state standards? • Expect L/E customers to pay user fees that exceed other treatment plant customers within the metro area? • Expect L/E to add treatment technology which results in significantly higher treatment costs than similar existing dischargers on the same segment. Is L/E being environmentally conscientious by adding substantial energy costs over the long term?

  12. Treatment Technologies Compare the various treatment technologies that are available and the cost associated with capital investment and operations

  13. Other Alternatives Looked to the Industrial Pretreatment Program for controls and reduction of metals and Lindane. Our program had everything in place. Nothing else could be done in this area.

  14. How Did Things Go? • Division has had little experience in this area • Division requested additional information (more than once) • EPA review and Public Notice takes time • No standard format available to develop AA or for Division to make determinations • Protocols from the Division are shaky

  15. Time Frame Basically it’s taken 2-3 years to get issues resolved.

  16. Long Story Short Metals and Lindane--We met our goal. We were issued the water quality standards based on the cost of “available treatment technologies and the economic unreasonableness of them” Ammonia—another story. Did not convince the Division of the unreasonableness for ammonia treatment due to upcoming AMMTOX limits which are similar to proposed Antidegradation limits.

  17. Options for Ammonia Issue • Tiered Limits to delay due to current WLA • Try for Use Protection Classification • Go to Commission for a special hearing • Accept the Antidegradation limit

  18. Conclusions • Things are never as straight forward as the Regulations and Guidance make it sound • One size does not fit all • More Antidegradation Regulations will probably be the trend in the future

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