1. The WQCD Permitting Perspective Janet Kieler Permits Section Manager

2. Overview u The Permits Section u Elements of Permitting u The Complete Application u The Water Quality Assessment u The Permit and Rationale u Compliance and Enforcement

3. Organization Chart

4. Elements of Permitting u Process u Application u Water Quality Assessment u Permit u Rationale

6. The Complete Application u Facility Map u Service Area Map u Original Signatures u Facility Upgrade Plans u Surface Water Quality Assessment u Low flow u Ambient data u Groundwater Quality Assessment u Site Conditions

7. Water Quality Assessment u Low Flows u In-stream water quality u Pollutants of Concern u WQBELs: water quality based effluent limits u ADABCs: antidegradation based average concentrations

8. Low Flows u In-stream dilution u High low flows, small design flow = greater dilution u Low low flows, large design flow = lesser dilution

9. In-Stream Water Quality u Upstream water quality concentrations u High upstream concentrations = less stringent limits u Lower upstream concentration = more stringent limits

10. Pollutants of Concern u In-stream uses and standards u Downstream uses and standards

11. Waterbody Uses and Standards u Water Supply u Arsenic u Agriculture u Aquatic Life u NH3 u WET

12. Water Quality-Based Effluent Limits (WQBELs) u Q 1 =Upstream Low Flow (1E3 or 30E3) u Q 2 = Average daily effluent flow (design capacity) u Q 3 = Downstream flow (Q 1 + Q 2 ) u M 1 = In-stream background pollutant concentration u M 2 = Calculated WQBEL u M 3 = Maximum allowable in-stream pollutant concentration (water quality standard)

13. Antidegradation u Reviewable (undesignated) waters u Baseline water quality as of September 30, 2000 u Facility contributions and permitted allocations considered if prior to September 30, 2000 u otherwise, a non-impact limit (NIL) of zero is used as permitted allocation

14. Antidegradation (cont.) u ADBACs calculated by allowing a 15% increase between baseline water quality and the standard u Facility may choose u NIL u ADBAC u complete an alternatives analysis

15. Antidegradation-Based Average Concentrations (ADBACs) u Q 1 =Upstream low flow (1E3 or 30E3) u Q 2 = Average daily effluent flow (design capacity) u Q 3 = Downstream flow (Q 1 + Q 2 ) u M 1 = In-stream background pollutant concentration u BWQ = Baseline Water Quality concentration u WQS = Water Quality Standard concentration u ADBAC = Antidegradation-based average concentration

16. The Permit u Pollutant Based Limits u WQBELs u ADABCs u Effluent Limits u Capacity Based Limits u Compliance Schedules u Studies u Funding u Design u Construction

17. The Rationale u Water Quality Assessment u Basis for Limits u Responses to Comments

18. Compliance and Enforcement u DMR data u PCS: WQBELs u Capacity based limits u Compliance Schedules u Inspections u Routine u Complaint-driven

19. It’s not supposed to be fair…. it’s supposed to be right….