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Water-Quality Management
Services
| Frequently Asked Questions (FAQ) about Water-Quality Management Services |
Aqua Cura offers a range of services to municipal and private clients to help them protect their water resources and to comply with federal, state, and local requirements in cost-effective ways. These service include:
Clean Water Act Compliance
Most water-quality related regulatory requirements stem from the Clean Water Act and Aqua Cura can assist public and private wastewater treatment plants to understand and comply with the many requirements that affect them in any of the following ways:
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Water-Quality Trading Programs
Aqua Cura can develop water-quality trading projects or program recommendations to help clients reduce their costs for reducing pollution discharges. There are a variety of possible trading programs, including trading with wastewater treatment plants or with nonpoint sources such as farms.
Watershed Planning and Management
Aqua Cura can provide assistance or representation in the wide variety of watershed management and planning activities that may be underway at the local, state or federal level. Examples include stream restoration projects and the preparation of watershed management plans or Watershed Restoration Action Strategies.
David Sheridan, principal of AquaCura, collaborated with several other water quality professionals on a book that provides guidance to municipal wastewater treatment agencies in water-quality trading to meet environmental standards. A summary description of the book may be seen at this link. WQ trading may have particular value to wastewater treatment plants in the Susquehanna River basin in Pennsylvania, where PA DEP recently announced that extensive reductions in nitrogen and phosphorus concentrations of treated effluent will be required in NPDES permit renewals.
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MEMORANDUM
May 19, 2006
By: David Sheridan, P.E., Principal, Aqua Cura
Subject: Observations on briefing by Catherine Myers
Pennsylvania's Chesapeake Bay tributary strategy
Deputy Secretary Myers briefed a group of (mostly) land development professionals on May 18, 2006 in York, to address questions and concerns regarding the impacts of PA DEP's approach to controlling nutrients (nitrogen and phosphorus - N and P) on land development.
Background and current situation
Pennsylvania signed on to the Chesapeake Bay clean-up in 2000. Since that time, U.S. EPA developed a water-quality model with concurrence of PA, MD, and VA. This model predicted that Pennsylvania would have to remove about 35 million pounds of nitrogen and about one million pounds of phosphorus annually to meet its obligation under the 2000 agreement. Some 14 percent of N and 22 percent of P was found result from wastewater treatment plant (WWTP) discharges, the balance being generated by land use activities, particularly agricultural activities and stormwater runoff from developed areas.
PA DEP developed a plan to allocate N and P reduction requirements among the various contributors. This plan, called the tributary strategy, was an iterative process. PA DEP considered combinations of levels of treatment and flows at wastewater treatment plants and implementation of some 42 Best Management Practices (BMPs) to control nonpoint source N and P pollution carried by runoff from agricultural and existing developed areas. These combinations of controls were reviewed by U.S. EPA, and adjustments were made until the Chesapeake Bay Model predicted sufficient N and P reductions to comply with Pennsylvania's obligation under the 2000 agreement.
The tributary strategy that was eventually selected by this iterative process established the following requirements for WWTPs in the Susquehanna and Potomac watersheds:
These concentration and flow assumptions were used by PA DEP to establish an annual mass of N and P that would be allowed for each WWTP (called a “cap”). The aggregate effect of such reductions applied to the 190 +/- WWTPs in the Susquehanna and Potomac watersheds is projected to be nutrient reductions of about 14 percent. This number has a certain logical fairness: the WWTPs account for about 14 percent of the N load to the Bay.
On August 29, 2005, Maryland established water quality standards for its Chesapeake Bay shoreline. On that date, PA DEP became obligated under the federal Clean Water Act to issue National Pollutant Discharge Elimination System (NPDES) permits to WWTPs in the Susquehanna and Potomac watersheds that contribute to the meeting the water quality standards. NPDES permit renewals issued by PA DEP since that date will incorporate N and P caps. A permit renewal will generally allow up to three years for a WWTP to comply with a new or more stringent treatment requirement.
PA DEP will assign all of the N and P allowances designated for WWTPs through the NPDES permit process. The action required by each discharger will depend on many factors, which will be unique to each situation. In general, new developments for which treatment capacity had not been reserved prior to summer 2005, are likely to face a “zero net increase” condition with respect to N and P. Stated simply, new developments will likely be required to identify N and P offsets in order for their wastewater flows to be accepted by a WWTP. However, each situation will be unique, based on the situation at the WWTP and the nature of the new development.
Zero net increase
A new development may meet its zero net increase objective by a combination of actions:
Credits for the 42 BMPs identified in PA DEP's tributary strategy are defined by the Chesapeake Bay Model. For instance, the model predicts that an acre of forested riparian buffer will remove about 12 pounds of N annually. PA DEP is moving toward certifying the N and P performance of other practices, and the Department has indicated a willingness to consider site-specific actions.
There do not appear to be any PA DEP obstacles to obtaining and using N and P offsets. The Department seems to understand that developers need these offsets today. Deputy Secretary Myers stated emphatically that Pennsylvania's Chesapeake Bay strategy is not a growth control strategy. Growth and economic development are clearly local government prerogatives.
There may be obstacles - both technical and administrative - to a new development gaining access to an existing WWTP. Such obstacles, when dissected through careful discussion and analysis, may reveal actual technical constraints that will require time to overcome. Developers were accustomed to encountering such constraints, particularly in rapidly growing areas, before the Chesapeake Bay strategy. Each situation will consist of unique characteristics, which will require analysis specific to the situation to resolve.
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