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BAP Update

BAP Update. DO TMDL Subcommittee Meeting June 19, 2012. A Bit of History (2008-2009). Summer-Fall 2008 BAP discussion begins Study Proposal formulated Summer-Fall 2009 Quality Assurance Project Plan developed Spokane Regional Wastewater Phosphorus Bio-Availability Study Initiated

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BAP Update

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  1. BAP Update DO TMDL Subcommittee Meeting June 19, 2012

  2. A Bit of History (2008-2009) • Summer-Fall 2008 • BAP discussion begins • Study Proposal formulated • Summer-Fall 2009 • Quality Assurance Project Plan developed • Spokane Regional Wastewater Phosphorus Bio-Availability Study Initiated • Samples collected summer 2009-spring 2010

  3. A Bit of History (2010) • September 2010 • Draft Report submitted to Ecology and EPA for peer review and comments provided • Ecology review/comment/decision on incorporation into engineering plan and 2nd cycle of permits scheduled for 2nd Quarter 2012 • November 2010, ECY states: • The model is the basis for quantifying credits • The model will be adjusted on factors that increase allocation (i.e., BAP) at the 10 year assessment • December 2010, first “Final Report” completed • Formal comments provided by Ecology (1/20/2011)

  4. A Bit of History (2011) • February 2011 • Second “Final Report” completed • Response to comments received from UW (2/11/2011) • Formal comments provided by EPA (2/25/2011) • Response to comments received from UW (2/28/2011) • Formal response provided by EPA (3/01/2011) • Discussions • Not enough data to integrate BAP into permits • “Next steps” subcommittee formed • Dischargers concerned about “certainty” • Ecology and EPA acknowledge need for regulatory decision

  5. A Bit of History (2011) April 2011 • Discussions about • IEP studies and BAP research • “2-bucket” vs. “3-bucket” phosphorus models • Ecology’s commitment to use of the “2-bucket” TMDL model • IEP as the “poster child” for a modified permit limit • Ecology made another request for IEP’s orthophosphate data June 2011 – Washington NPDES permits issued

  6. Conclusion “no matter who decides to pursue BAP, modeling with modified BAP inputs has to be consistent with the TMDL model and cannot negatively affect Avista’s DO responsibility found in Table 7 of the TMDL.”

  7. 2012 • March - April • Bioavailable Phosphorus Workshop • Request from SRSP to Ecology to fund additional studies • Proposed Scope of Work submitted to Ecology • Outstanding questions • Did original study meet the goals of the QAPP? • Were the comments submitted by Ecology and EPA adequately addressed? • Have Ecology’s requests for data been met?

  8. Status Reviews to be completed by June 30, 2012 • Line by line evaluation of comments submitted by Ecology and EPA to UW and responses • 2010 • 2011 • Review of study for adequacy with the QAPP • Review of Ecology requests from DO TMDL meeting notes • Evaluation of the proposed Scope of Work with respect to EPA and Ecology expectations.

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