Transcript Implementation of Antidegradation Policies for Indiana Waters Outline               What Are the Components of Water Quality Standards? What Are Current Antidegradation Policies for Indiana? What Are.

Implementation of
Antidegradation Policies for
Indiana Waters
Outline
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What Are the Components of Water Quality Standards?
What Are Current Antidegradation Policies for Indiana?
What Are the GLI Antidegradation Rule Components?
Proposed Approach
How Will the Default Antidegradation Effluent Limits Be
Determined?
Is There a De Minimus?
What Are the Requirements for a New/Increased
Discharge?
What Information is Required in Part 1 of the
Antidegradation Application?
When is Part 1 of the Antidegradation Application
Considered to be Complete?
What Information is Required in Part 2 of the
Antidegradation Application?
When is Part 2 of the Antidegradation Application
Considered to be Complete?
How Will the Public Be Notified About the Process?
Water Quality Project in an OSRW
Summary Flow Chart
What Are the Components of Water Quality
Standards?
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Designated Uses (40 CFR §131.10)
 fishing, recreation, drinking
Criteria (40 CFR §131.11)
 protects designated uses
 narrative or numeric
Antidegradation Policy (40 CFR §131.12)
 3 tiers
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Tier 1: maintain existing uses
 Tier 2: protection of high quality
waters (HQWs)
• Tier 2.9: Indiana Outstanding
State Resource Waters (OSRWs)
& Exceptional Use Waters
(EUWs)
• limited degradation
 Tier 3: ONRWS; no degradation
What Are Current Antidegradation Policies
for Indiana?
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1970s – IDEM adopted antidegradation policy for all
waters as part of the WQS
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1997- IDEM adopted antidegradation implementation
procedures for the Great Lakes Basin ONLY as part of
GLI initiative
What Are the GLI Antidegradation
Rule Components?
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De Minimus
Background Concentration
Total Loading Capacity
Unused Loading Capacity
Economic Review
Health Risk Review
Treatment Technology Analysis
Pollution Prevention / Alternatives Analysis
Affordability Analysis
Proposed Approach
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Applicable to all surface waters
 new/increased discharges that result in new/increased
permit limits
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Technology based
Default antidegradation effluent limits
How Will the Default Antidegradation
Effluent Limits Be Determined?
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Determined based on the most stringent of:
 Water Quality Based Effluent Limit (WQBEL)
calculated using no in-stream dilution OR
 Best Available Treatment (BAT)
 best
professional judgment of the state in
accordance with 327 IAC 5-5-2 (BPJ/BAT);
Greater protection than current regulations
Is There a De Minimus?
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High Quality Waters:
projected effluent
limit is equal to or less
than the default
antidegradation
effluent limit
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Outstanding State
Resource Waters:
projected effluent
limit is equal to
or less than the
ambient water
quality
What Are the Requirements for a
New/Increased Discharge?
1. Determine that discharge doesn’t qualify as nonsignificant lowering
2. Satisfactory completion of ‘Necessary &
Social/Economic’ tests (Antideg. Application Part 1)
3. If default antideg. limit(s) accepted, proceed to
permitting
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For OSRWs, implement water quality project/pay fee
If default antideg. limit(s) not accepted, complete
treatment alternatives analysis (Antideg. Application
Part 2)
If treatment alternatives analysis is acceptable,
permitting proceeds with alternate limits
What Information is Required in Part 1 of the
Antidegradation Application?
1. Facility Information
2. Wastewater Characterization
3. The Necessary Demonstration
4. Social/Economic Benefits Demonstration
When is Part 1 of the Antidegradation
Application Considered to be Complete?
Part 1 is complete when IDEM receives a letter
from permittee accepting default antideg.
limit(s).
What Information is Required in Part 2 of the
Antidegradation Application?
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Wastewater Treatment/Control Alternatives
Analysis
 analysis of end-of-pipe treatment methods
 compare pollutant removal/reduction
 compare cost to install and operate
 evaluation of Alternatives Analysis
When is Part 2 of the Antidegradation
Application Considered to be Complete?
Part 2 is complete when IDEM receives a letter
from permittee accepting alternate limit(s).
How Will the Public Be Notified About the
Process?
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By information on an IDEM website providing
notice of a complete antideg. application.
This information will also be available through
electronic notification.
By public noticing of a draft permit after the
applicant has successfully completed the
requirements for the Necessary and
Social/Economic tests AND either accepts
default antideg. limits OR successful completion
of treatment alternatives analysis.
Water Quality Project in an OSRW
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Applicants choosing to implement a water quality
improvement project,
 must submit the proposed project to IDEM for concurrence approval
 show adequate demonstration that project will result in an overall
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improvement to the water quality in the OSRW
demonstrate cooperation with local communities
implementation of project will be included in the permit as a
schedule of compliance
Public notice and participation
May not use a water quality improvement project that is
being planned/implemented due to other regulatory
requirements or the settlement of an enforcement action
Summary Flow Chart
Questions??