MDFW Hatchery NPDES Program Ken Simmons Chief of Hatcheries/Trout Project Leader

1. MDFW Hatchery NPDES ProgramKen SimmonsChief of Hatcheries/Trout Project Leader

2. MDFW HATCHERIES • Sandwich Hatchery (1912) -Trout* • Sunderland Hatchery (1913) - Trout* • Palmer Hatchery (1914) - Atlantic salmon • Montague Hatchery (1917) - Trout* • McLaughlin Hatchery (1969) - Trout* *NPDES permit required

3. NPDESFour MDFW Trout Hatchery Permits Renewed in Past Year • Observations on the process • Formalin Discuss Today

4. Impact on Hatchery Operations • Discharge limits were not substantially changed • Frequency of effluent sampling was reduced • Effluent sampling quarterly and only during major cleaning operations continued

5. Impact on Hatchery Operations • Increased use of settling pools at 3 older DFW facilities • Reduced production at 3 older facilities • Greatly altered operations at 3 older facilities • Formalin use all but eliminated at 3 older facilities

6. Impact on Pounds of Trout Produced

7. Flow BOD TSS pH Dissolved oxygen Total ammonia nitrogen, as N* Residual chlorine* Total phosphorous* Formaldehyde Whole Effluent Toxicity - chronic** Whole Effluent Toxicity - acute** Effluent Monitoring *Not at all facilities **New to current permit

8. Effluent Sampling • Quarterly (except pH, formalin & chlorine) • Three of the quarterly samples must be taken when conducting pool breakdown and/or settling pool or quiescent zone cleaning • One quarterly sample must be taken during annual pool breakdown/cleaning • Composite samples -- 1 per hour for 8 hours

9. Formalin Use • Discharge limit of 0.74 mg/l (formaldehyde) at all facilities • Developed formalin use plan for each hatchery as part of B.M. P. • Do not know if it will work except at McLaughlin Hatchery

10. Formalin Use Problems • 0.74 mg/l limit effectively eliminates use at 3 of 4 facilities due to flow patterns and dilution factors • Difficult to retain a certified lab that can analyze formaldehyde with E.P.A. methods on short notice • W.E.T. tests - labs to conduct work on short notice • Cost of tests

11. Whole Effluent Toxicity (%) Acute (invertebrates only) *If formalin is used

12. Whole Effluent Toxicity (%) Chronic (invertebrates only) *If formalin is used

13. Agency must play an active role in the process Develop & maintain a professional working relationship with the regulators Be honest and forthcoming with information Do not hesitate to ask questions or seek clarification of issues Exercise your right to seek change and/or clarification of pre-public draft permits Tremendous amount of work involved My Thoughts

14. Summary • We do not yet know if we will be able to meet new effluent limits at all stations but have developed BMP’s with that goal • Formalin use at 3 of 4 hatcheries is all but impossible • Formalin use at McLaughlin Hatchery is feasible but with constraints

16. FLOW (MGD)

17. BOD (mg/l) *During cleaning operations

18. TSS (mg/l) *During cleaning operations

19. Total Phosphorous (mg/l) *During cleaning operations ***No limit issued

20. Total Ammonia Nitrogen, as N (mg/l) *During cleaning operations ***No limit issued

21. Total Residual Chlorine (ug/l)