Phosphorus

1. Phosphorus Run Away

2. How Did It Happen? April 2010 hearings began Visited State office after 1st hearing ED stands in the way (We’re not Florida, after all!)

3. Who Is Suing Who • Basically, 7 groups of “environmentalists” are threatening to sue EPA if they do not set these limits. • Clean Water Action Council of North East Wisconsin • Gulf Restoration • Milwaukee River Keepers • River Alliance of Wisconsin • Wisconsin Wildlife Federation • Midwest Environmental Advocates

4. Who Is Suing Who Since these groups were threatening to sue EPA…EPA then threatens to sue Wisconsin DNR for not setting limits low enough Where did the limits come from? Clean Water Act…1972

5. What is the Rule DNR Bureau of Watershed Management proposed new phosphorus criteria for rivers and streams into NR 102.6 Criteria is now 100 ug/L (0.1 mg/L) for listed rivers 75 ug/L (0.075 mg/L) for all other streams, unless exempted Limits for Lake Superior is 5 ug/L (0.005 mg/L) Limits for Lake Michigan is 7 ug/L (0.007 mg/L)

6. 4 Public Hearings Concerning This Rule

7. Written Comments From 411 Individuals and Organizations 217 in support 62 oppose 121 neutral positions 11 support some oppose some part of the rule

8. Support from: • Lakes and river associations • Environmental groups • Individuals who want strong rules limiting phos inputs into lakes & streams • Lakeshore property owners, small businesses municipalities that depend on tourism • Do they pay for phosphorus removal?

9. Opposition from: Over their dead bodies • Municipalities • Paper industries • Dairy farmers • Who pays for phosphorus removal?

10. Comments and Responses • Developing Criteria • Criteria does not take into account availability, phos limits don’t necessarily protect the water, phos impairment should be impaired by phos and not other things in the streams (light, other nutrients, stream gradient, etc) • According to EPS and EPA based studies…OK

11. Comments and Responses Downstream degradation can cause modification of point source phos limits…Take out this rule and go to site-specific criteria NO

12. Comments and Responses Exclude phos from water treatment (polyphos water treatment; Delete phos loadings from stormwater discharges; exclude non contact cooling water (phos used for corrosion control) NO Also OK to exclude CAFOs that do not treat manure

13. Comments and Responses Include the ability to establish a WQBEL if a plant has the potential to discharge phos OK…we will

14. Comments and Responses DNR should limit how much phos can be “traded” with farmers We’ll get to that later

15. Comments and Responses DNR should limit variances and compliance schedules because WWTPs may use this ploy to extend them having to comply with the rule No…we’ll give this one to the WWTPs

16. Comments and Responses Adaptive Management (“trading”) is not compliance because the municipal system is not an action or operation change OK…back to s----ing on the WWTPs

17. Comments and Responses Just because phos removal technology is expensive is not justification to give out a compliance schedule; it should be illegal to just exempt ponds or systems that can’t afford to further remove phos OK…we will put it on the backs of the municipalities to seek out and work with local farmers to trade phoscredits

18. Comments and Responses DNR agrees that the cost estimate was under estimated for industrial and municipal You can afford a few million $ for upgrades…can’t you??

19. Where We Are Now DNR is handing out limits right along NR guidelines If discharging to a named river, 0.1 mg/L If discharging to any other receiving stream, 0.075 mg/L 2 systems in the state have limits at 0.04 mg/L (lowest in the country?) Looks like economic hardship is a viable solution Nutrient trading and adaptive management in the mix The new variance legislation

20. Who Is Next http://cfpub.epa.gov/wqsits/nnc-development/

21. Background Municipal waste contains phosphorus anywhere from 2-20 mg/L as total phosphorus Only about 1-5 mg/L is organic phosphorus, the rest is inorganic (an organic molecule must have carbon in its makeup) Phosphorus sources include domestic, commercial, industrial and natural runoff

22. Sources Organically bound phosphorus originates from body and food waste and, upon biological decomposition of these solids, is converted to orthophosphates Detergents, used for domestic and industrial cleaning (about half) Most states have banned the sale of phosphate-containing clothes washing detergent, so phosphorus levels in household wastewater have been reduced significantly from previous levels Now automatic dishwasher detergent is the largest source

23. Business users that are likely to contribute phosphorus to your POTW can include: Additionally, industrial cleaning and sanitizing operations in any facility may result in high discharge levels of phosphorus Agricultural co-ops Car/truck washing facilities Dairies Food processing plants Meat packing plants and lockers Metal finishing facilities Nursing homes Restaurants Schools and other institutions

24. Banned Sources Wisconsin has banned the sale of fertilizer containing phosphorus Also banned phosphorus from laundry detergent in the ‘70s Recently made illegal to sell or use household dishwasher detergent with more than 0.5 percent phosphorus by weight

25. Remove Sources? Initially we should keep phosphorus out of the wastewater system Meet with businesses in town and find phosphorus containing items Bring in non phosphorus chemicals(cleaners do not have to contain phosphorus to be effective- enzymes more important)

26. Examples • Carwashes discharge large loads of phosphorus • Alternative detergent is cheaper and works better • Schools discharge quite a bit during school closings • Emulsifiers also • Dairies discharge milk and cleaning chemicals • Milk is extremely high in phosphorus

27. Examples • Metal finishing places often use phosphoric acid • Any place with a spraying booth will have large discharges of phosphorus • Metal prep, just like other metal finishers • Pre-treatment or complete haul away are best options if you cannot keep these discharges out

28. Groundwater Disposal Systems • Soil Based Treatment Systems • Slow Rate • Rapid Infiltration • Overland Flow • Aquatic Based Systems • Natural and Constructed Wetlands • Aquatic Plant Treatment Systems

29. Slow Rate System • Treatment Systems dating back to 1880 • 1972 Clean Water Act • Most Recent Developments Constructed Wetlands • Groundwater Impacts and Monitoring

30. Slow Rate System • Wastewater Treatment is Objective • Soil Permeability is Limiting • Uses Vegetation • Evaporation and Percolation • Treatment through the Soil • Low Application Rates 2 to 6 Feet of Water per Year

31. Slow Rate System • Crop Production is Objective • Crop Produced • Landscape Irrigation (Golf Course) • Groundwater Reclamation

32. Center Pivot Fixed Head

33. Canopy Evaporation Droplet Evaporation Plant Transpiration Evaporation Drift Plant Interception Runoff Deep Percolation Crop Root Zone

34. Ridge and Furrow

35. Ridge and Furrow

36. Biomass Production Hybrid willows uptake thousands of gallons of water, sequester phosphorus and uptake ALL the nitrogen Can be cropped off every 4-5 years and roots will re-sprout Crop production and management is supplied by vendor

37. Rapid Infiltration (Seepage Cell) • Seepage Cells • No Vegetation Provided • Evaporation is Low • Most of Water Percolates Through the Soil • High Application Rates 20 to 300 Feet of Water per Year • NR 207 requires 10 mg/l Total Nitrogen in Wastewater

38. Rapid Infiltration (Seepage Cell)

39. Rapid Infiltration (Seepage Cell)

40. What Happens to the Phosphorus Chemical Precipitation/Absorption • Clay Minerals • Organic Soil Fractions • P Held Very Tightly • Plants take up Little (Wetlands)

41. Water Cycle says that groundwater from a well not recharged back into the ground gets sent down river and is lost • With seepage, phosphorus is less of an issue than nitrogen (in most cases)

42. Why Not Seepage • Not all soils are suitable for seepage • Depth to groundwater • Groundwater phosphorus levels • Soil is impermeable or unusable for seepage • Soil has to have a percolation rate that allows the proper speed of absorption and will accept all of the water that is discharged • Usually several cells need to be constructed so as to allow for resting, weed control and provide enough area to accept all the discharge • To do this you need land and engineering

43. Achieving Low Level Phosphorus Removal in Lagoons Presented at the Wisconsin Rural Water 24th Annual Technical Conference March 27, 2012 Presenter: MSA Professional Services

44. Overview Pilot study conducted at O’Dell’s Bay WWTF Pilot Study Data Cost Analysis Parting Thoughts

45. O’Dell’s Bay WWTF • Small Sanitary District near Mauston, WI • Average Daily Flow – 30,000 gpd • Effluent BOD – 30 mg/L • Effluent TSS – 60 mg/L • Effluent Ammonia – 10 mg/L • Discharge to Castle Rock Lake (impaired waterway) • Currently no requirement for phosphorus removal

46. Aerial WASTEWATER TREATMENT FACILITY

47. WASTEWATER TREATMENT FACILITY Influent & Effluent Flow Metering Complete-Mix Lagoon Partial-Mix Lagoon Settling Lagoon UV Disinfection Blower Building

48. Aerial SETTLING POND PARTIAL MIX COMPLETE MIX

49. Plant

50. New Phosphorus Rule • NR 217 Water Quality Based Effluent P Limits • WQBEL could be as low as 0.03 mg/L • NR217 Criteria for stratified reservoir • Economic variance to WQBEL is possible, BUT • Eventual phosphorus removal requirement likely • Eventual WWTF optimization of P removal combined with watershed-based approach to meet 0.03 mg/L