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Hg TMDL Approval Process

Hg TMDL Approval Process. Howard Markus, Ph.D., P.E. Research Scientist Environmental Assessment and Outcomes. Topics covered. Hg TMDL Unique features and strong science Minimum information needs Public participation EPA Approval & Record of Decision Timeline Next steps/Implementation

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Hg TMDL Approval Process

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  1. Hg TMDL Approval Process Howard Markus, Ph.D., P.E. Research Scientist Environmental Assessment and Outcomes

  2. Topics covered • Hg TMDL • Unique features and strong science • Minimum information needs • Public participation • EPA Approval & Record of Decision • Timeline • Next steps/Implementation • Northeast Regional Mercury TMDL • EPA’s 5m approach

  3. Hg TMDL Unique features and strong science: • Regional/statewide approach • Food web dynamics • 1990 as baseline • Improvements linear with pollution reductions • Use of sulfate as an implicit margin of safety

  4. Hg TMDL - continued Unique features and strong science [continued]: • Bio-P [biological phosphorus removal] • Stormwater as WLA & LA • 90% non-State [the Decision Document claims this is an implementation issue, which means they are not accepting that split or rejecting it] Bottom line – numbers have Power

  5. Hg TMDL - continued The minimum information needed to develop the Hg TMDL: • Estimate of [Total Hg] deposition • Estimate of the distribution of airborne deposition – uniform across the state or non-uniform? • Determination of the fish tissue concentrations

  6. Hg TMDL - continued The minimum information needed to develop the Hg TMDL [continued]: • Estimate of the state’s share of emissions • Determination of the presence/ absence of biological ‘hot spots’ • Determination of water point source loading concentrations and characteristics • Setting the baseline year, based on data

  7. Mercury TMDL

  8. Hg TMDL Public participation: • Many informal meetings with various partners • Formal public comment period extended from 30 to 60 to 90 days • over 900 comments received, either by letter, e-mail, petition, or e-petition • Newspaper challenges, esp. the editorial board • EPA’s Record of Decision noted numerous places where the draft Hg TMDL was modified based on comments received

  9. Hg TMDL EPA Approval & Record of Decision: • Took seven months – and actually a lot more • Very detailed review • Very thorough statements of support

  10. Timeline – high & low points • 1998 TMDL list – footnote regarding regional approach to Hg impairments • Last quarter 2003 – MPCA 4b approach • First quarter 2004 – EPA review of MPCA’s “Regional approach” • Second & third quarter 2004 – MPCA develops the draft regional/ statewide Hg TMDL • Fourth quarter 2004 - MPCA’s draft Regional/statewide Hg TMDL – placed on MPCA web page; the Air Side enters

  11. Timeline (continued) • Fourth quarter 2004 & First quarter 2005 - EPA reviews initial draft regional/ statewide Hg TMDL; MPCA responds to comments • Second quarter 2005 - Revised draft provided to US EPA • Second & third quarter 2005 - MPCA formal “90-day” public notice

  12. July 31, 2005, Front Page

  13. Timeline (continued) • Fourth quarter 2005 through second quarter 2006 - MPCA development of responses to comments • Fourth quarter 2005 Contested case -hearing request [CCHR] • Fourth quarter 2005 - Legislative hearing [a very low point]

  14. Timeline (continued) • First quarter 2006 - The CCHR was withdrawn and the Agency began developing responses to comments again • Second quarter 2006 - ‘Daily’ means ‘Daily’ court decision results in a revision to the Hg TMDL • Second quarter 2006 - Based on MPCA’s overall review of comments, a revision to the draft Hg TMDL and the assessment of impairments was developed • 511 Hg impairments covered by Hg TMDL; 801 impairments remain on the list of impaired waters

  15. Timeline (continued) • Third quarter 2006 - MPCA Citizen Board approval of final draft Hg TMDL and transmission of draft to US EPA • August 26, 2006 to March 27, 2007 - US EPA approval of Hg TMDL

  16. Implementation • Develop strategies to meet Hg TMDL goals • Air: 789 #/yr emission cap from Mn sources • Water: 24.2 #/yr water point source cap • Stakeholders will recommend comprehensive strategies and target dates • Third party will convene stakeholders and facilitate strategy development • 1-year process starting Spring 2007

  17. Implementation - continued Air emission goals • Mn final emission target: 789 #/yr • 93% reduction from 1990; 76% reduction from 2005 levels • Hg Reduction Act [2006] eliminates 1200 #/yr from power plants by 2014 • Product decreases expected because of reduced use

  18. Implementation - continued Air emission goals - continued • Taconite sources expected to increase slightly unless reduction implemented • Meeting goal will require additional reductions from all sources • All other anthropogenic sources [national & international] that deposit in Mn must also decrease by the same percentage

  19. Northeast Regional Hg TMDL Comparing Minnesota :: NER Hg TMDL • 1990 :: 1998 as the baseline • 0.2 :: 0.3 ppm criterion [except ME & CT] • 0.572 :: 1.14 ppm [Hg] in fish as baseline • 65% :: 74% Deposition reduction factor • 93% :: 98% anthropogenic emission reduction factor

  20. NER Hg TMDL - continued NER anthropogenic reduction goals @ 90th percentile [MN: 93%] This range nicely brackets fish tissue criteria

  21. EPA’s 5m approach • MPCA does not support this approach • MPCA believes this off-ramp helps US EPA out of a possible pickle without an adequate reward for the States • Near TMDL-equivalent • Yearly reporting requirements • Works against state efforts for appropriate national reductions

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