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Clean Water Services Watershed-based, Integrated, Municipal NPDES Permit Thinking Outside the Regulatory Box

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Clean Water Services Watershed-based, Integrated, Municipal NPDES Permit Thinking Outside the Regulatory Box

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    1. Clean Water Services Watershed-based, Integrated, Municipal NPDES Permit (Thinking Outside the Regulatory Box)

    2. Thanks to…. CWS Team Jerry Linder, Craig Dye, Mark Poling, Jan Miller, Bernie Bonn, Bruce Cordon, Tom Stow, Debra Gorman, Jan Wilson, Mark Jockers CH2M-Hill Team James Ollerenshaw, Tom Dupuis, Lisa Bacon, Dawn Sanders, Mark Bransom Schwabe - Brian King Perkins-Coie - Tom Lindley, Juge Greg USEPA Headquarters - Pat Bradley, Joel Salter DEQ – Neil Mullane, Lyle Christensen, Bob Baumgartner, Rob Burkhart, Sonja Biorn-Hansen, Pete Dalke, Mike Kortenhoff

    3. So Why a Watershed Approach? “The Planets and Stars were aligned !” 2nd (not just the 1st) TMDL Temperature, Bacteria, Phosphorus and Settleable Volatile Solids Some “tension” between parameters and management objectives All the NPDES permits expired Provided an window of opportunity Single entity & Highly Managed Stream ESA Listing Regulatory Agency willingness

    4. Evolution of Clean Water Act Implementation Technology-based Water quality-based Watershed-based

    5. Unique elements of approach Comprehensive, integrated approach “Systems” perspective of watershed Quality, Quantity, Habitat (Q2H) Water Quality Trading Assimilative Capacity basis Cost-effective Ancillary environmental benefits

    6. 4 Treatment Plants into 1 permit structure Moving away from Technology-based permit structure to a Watershed-based regulatory framework4 Treatment Plants into 1 permit structure Moving away from Technology-based permit structure to a Watershed-based regulatory framework

    7. Water Quality Trading What is it ?? What does it look like ?? WIIFM ?? How you set up a water quality credit trading program ??

    8. Facilitates both INTER-Plant Trades INTRA-Plant Trades PS to NPS Trades SELF REGULATING Facilitates both INTER-Plant Trades INTRA-Plant Trades PS to NPS Trades SELF REGULATING

    9. Water Quality Trading Simple Concept Complex Implementation

    12. Temperature So what is the issue in the Tualatin River ???

    13. Temperature - Current vs. Allocated i.e. the “System Potential” Impact of FLOW AUGMENTATION WLA for ROCK CREEK WWTP = 58 degrees RC EFFLUENT = 71-72 degrees Impact of FLOW AUGMENTATION WLA for ROCK CREEK WWTP = 58 degrees RC EFFLUENT = 71-72 degrees

    14. Temperature Reduction Options Reduce influent wastewater temperature Ban water heaters in Washington County ? Remove discharge from Tualatin Would result in greatly reduced summer flows Tualatin River is an effluent dominated stream in summer Significant WQ impacts The system is “FLOW” limited Refrigerate discharge High capital cost, $35-50 million High energy cost, $1-2 million/yr. No ancillary environmental benefits, in fact creates negative environmental impacts Just kidding!!! Significant negative environmental impact Large Economic Driver Just kidding!!! Significant negative environmental impact Large Economic Driver

    15. Thermal Load Credit Trading incorporated into watershed-based permit Thermal Load from WWTP’s Trade cooling credits of instream flow augmentation released from Hagg Lake Reservoir Trade riparian stream surface shading improvements Effluent Reuse in lieu of irrigation withdrawals Offset thermal load Mitigation thermal load Offset thermal load Mitigation thermal load

    16. The Watershed’s Viewpoint of Thermal Load Credit Trading

    17. Thermal Credit Trading Concept Effluent Thermal Load to be traded (kcal/d) – thermal load of reuse of reclaimed water Must = Thermal cooling credit from release of stored water + thermal cooling credit from stream surface area shading i.e., Heat Load Input = Cooling/Shading added Note: Shade Credits for 20 yr period

    18. Hagg Lake Reservior Clean Water Services owns rights to 15,000 acre-ft Clean Water Services voluntarily purchased rights to and voluntarily releases water in maintain a minimum summer flow. Current flow target is 150 cfs CWS releases an avg. of 30 cfs Release of stored water primarily aimed to maintain DO levels in lower portions of River

    19. Thermal Load Credit at Rock Creek WWTP (kcal/d) for release of stored water from Hagg Lake reservoir DT = 5.014{1-e Haug = Qriver x DT x 2.45x106 (Note: T expressed in oC; Q expressed in cfs)

    20. Shade Credit Calculation Potential Solar Load for a Stream Reach = WidthReach X LengthReach x 480 kcal/ft2/day Solar Load shaded = potential solar load X effective shade

    21. CWS’s Thermal Load Trading

    22. So the Bottom Line is… Excess Thermal Load from RC 759 million kcal/day (after 0.3 degree) Thermal Credit from Qaugmentation 427 million kcal/day Therefore need 332 million kcal/day shade credits At Durham, the Thermal Credit from Qaugmentation is sufficient to offset thermal load, so no shade credits needed.

    23. This Means How many stream miles ??? Based on just a couple of actual projects, the avg. effective shade is 74.3% The “average” restoration project results in a thermal credit of 9.4 million/kcal/day/mile Over the 5-yr term of permit, CWS will need to shade roughly 35 miles

    24. QUESTIONS ???

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