HomeMy WebLinkAboutIR 7378 p1
INFORMAL REPORT TO CITY COUNCIL MEMBERS No.—7378 '
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46 To the Mayor and Members of the City Council May 2, 1989
Subject: SURFACE VATER TOXICS COKML PROGRAM
Program Requirements
Section 304(1 ) of the Clean Water Act, as amended in 1986, requires states
to identify water segments which are not expected to meet water quality
standards, after technology-based treatment requirements are met, due entirely
or substantially to point source discharges of toxic materials. Each state
is also required to develop a control strategy for every segment so designated.
The designated segments are to be identified in a published list referred to
as the 304(1 ) Short List. The proposed 304(1 ) Short List and associated control
,strategies are to be considered at a public hearing. A proposed rule in
accordance with Section 304(1 ) on the referenced subject was published by the
Environmental Protection Agency (EPA) on January 12, 1989. If wastewater
treatment plant construction is necessary to achieve compliance with toxic
material limitations in water quality standards, a 1992 deadline is imposed.
Status of Program
The Texas Water commission (TWC) has prepared a proposed 304(1 ) Short List
and associated control strategies. A hearing to receive comments on these
documents was held on April 13, 1989. Segment 0805 of the Trinity River to
which the City discharges wastewater effluent, is on this list. Segment 0805
extends from Beach Street bridge on the West Fork of the Trinity River in Fort
Worth to State Highway 31 on the Trinity River in Henderson/Navarro County.
Segment 0805 was included on the proposed 304(1 ) Short List primarily due to
cadmium (Cd) and lead (Pb). The control strategy proposed by the TWC includes
effluent biomonitoring for a one-year period, and monitoring of specific toxic
substances for the duration of one year. This strategy was recommended because,
in most cases, new effluent limits for specific toxic materials of concern
cannot be reasonably established from available information. If the Short
List and control strategy proposed by the TWC are not approved by the EPA,
a public hearing must be held by the EPA.
Problems with the Program
Several significant problems were identified with the program as proposed by
the EPA. Since these problems effect all the major dischargers in the Upper
Trinity River, the Upper Trinity River Basin Water Quality Compact; composed
of Fort Worth, Dallas, Trinity River Authority and North Texas Municipal Utility
District, contracted with a consultant to evaluate if Segment 0805 should be
on the �hort List, and the feasibility of municipal point source controls for
Cd and P Based on their study, the consultant determined the following:
1.P .
are no conclusive violations of water quality standards
for Cd and Pb in Segment 0805.
2. It cannot be conclusively determined from available data that
point source discharges will cause violations of water quality
standards.
3. The impacts of point and nonpoint source loads are not directly
comparable.
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS
2
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7378 p-
foly To the Mayor and Members of the City Council May 2p 1989
Subject: SURFACE WATER TOXICS CONTROL PROGRA14
Effect on Fort Worth
If the program proceeds as proposed, the following effects on the City wastewater
system are indicated. These are made with the assumption that the EPA will
not accept the TWC proposed control strategy of additional monitoring, and
will use permit limitations as a control strategy, as indicated in EPA program
documents.
I. If numerical permit criteria are established for Cd and/or Pb,
these limits will more stringent than requirements for drinking
water.
2. It is not known whether existing treatment technologies can
be applied to 100 MGD municipal treatment plants which would
consistently achieve the anticipated permit limits.
3. Known treatment technologies now utilized for Pb and Cd removal
on a small scale would at least double the annual costs for
operation and debt service for wastewater treatment at Village
Creek. It would be impossible to construct such facilities
before the 1992 deadline.
Recommended Action
Segment 0805 should not remain on the 304(1 ) Short List. A representative
from the City attended the TWC hearing, but did not make comments due to the
extremely short time period remaining to prepare comments after receiving the
consultant study. At subsequent hearings, the City should object to the
inclusion of Segment 0805 on the 304(1 ) Short List, and object to individual
control strategies other than additional monitoring.
Or
Douglas Harman
City Manager
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ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS