Difference between revisions of "TCMA Chloride Management Plan - Prioritizing and Implementing Restoration and Protection"

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Reducing chloride at the source is needed throughout the entire TCMA, not only to restore already impacted waters but also to protect all water resources. There are multiple sources to consider, a variety of options to reduce chloride, and a large geographical area to address. This section is intended to provide guidance, resources, and information to assist in making the important decisions of the what, how and when for managing chloride. The available data indicates that surface waters and groundwater that exceed the state’s chloride standards, as well as many lakes and streams that are considered to be at high risk for chloride impairment. Many lakes, streams, and wetlands have minimal or no data available, especially during critical times of the year, which makes it difficult to determine the current chloride status. Reductions in chloride loads not only benefit surface and groundwater quality, but may also reduce damage to infrastructure and vehicles due to corrosion, and reduce impacts to vegetation along roadways. Finally, improved winter maintenance practices that reduce salt usage also result in direct cost-savings to winter maintenance organizations and private applicators. Without making efforts to reduce chloride loads, the trend of increasing chloride concentrations in lakes, wetlands, streams, and groundwater is expected to continue and the cost-savings related to improved winter maintenance practices will be lost. Treating waters already contaminated by chloride through RO or distillation is impractical and cost-prohibitive.

Performance-based approach for reducing chloride

Deicing salt is currently the most common and preferred method for meeting the public’s winter travel expectations. There is currently not an environmentally safe and cost-effective alternative that is effective at melting ice. Therefore, the continued use of salt as the predominant deicing agent for public safety in the TCMA is expected. Setting a specific chloride load reduction target for each individual winter maintenance chloride source is challenging, as is measuring actual chloride loads entering our surface and groundwater from deicing salt and other nonpoint sources in the TCMA. Therefore, priority should be put on improving winter maintenance practices to use only a minimal amount of salt, also referred to as Smart Salting, across the entire TCMA. With these considerations in mind, the implementation approach for achieving the TMDLs and protecting all waters in the TCMA is to focus on performance of improved winter maintenance practices as well as continuing to monitor trends in local waterbodies.

A standard approach to TMDL implementation is to translate the wasteload allocation (WLA) component of the TMDL directly to a numeric permit limit, which is typical for permitted facilities with monitoring requirements. In the case of urban stormwater regulated through a Municipal Separate Storm Sewer System (MS4) Permit, the WLA may be presented in the form of a percent reduction from a baseline condition. The specified percent reduction is then included in the MS4 Permit. With a performance-based approach, the numeric WLA is translated to a performance criterion. This can include the development and implementation of winter maintenance plan which identifies a desired level of the BMP implementation and a schedule for achieving specific implementation activities. Progress made towards those goals are documented and reported, along with annual estimates of salt usage and reductions achieved through BMPs implemented.

In cases where it is not feasible to calculate a numeric effluent limit, federal regulations allow for the use of the BMPs as effluent limits (40 CFR § 122.44(k)). Such a performance-based or BMP approach to compliance with WLAs is being taken by states to address the Chesapeake Bay TMDL for nutrients. The TMDL is being implemented through state Implementation Plans. Some states are taking a performance-based approach to addressing urban stormwater sources, requiring minimum levels of the BMP implementation rather than requiring specific levels of pollutant load reductions.

A performance-based approach will be tracked through documentation of existing winter maintenance practices, goals for implementing improved practices including schedules, and reporting on progress made. Entities may choose to use the Winter Maintenance Assessment tool (WMAt), which is a winter maintenance BMP tracking tool, to assess and document practices and set goals, or another approach of their choice. Entities should track progress and document efforts, including, to the extent possible, estimates of reduced salt usage as a result of improved practices. Entities that have achieved their goals for winter maintenance will have documented their practices in a winter maintenance plan. Entities that have already made significant progress in winter maintenance activities will be able to demonstrate this through their documentation of existing practices. This plan should be reviewed annually and evaluated against the latest knowledge and technologies available for winter maintenance.

The performance-based approach doesn’t focus on specific numbers to meet, but rather on making progress through the use of BMPs. Progress is measured by degree of implementation and trends in ambient monitoring. In a traditional approach with numeric targets, progress would be measured by accounting for salt applied and comparing to the targets. The performance-based approach is intended to allow for flexibility in implementation and recognize the complexities involved with winter maintenance. Because the performance-based approach does not provide a specific numeric target, a limitation of the approach is that it is not definitive on when enough progress has been made. This can only be determined by continued ambient monitoring that demonstrates compliance with water quality standards.

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 *[[TCMA Chloride Management Plan - Prioritizing and Implementing Restoration and Protection - Success stories]]
 *[[TCMA Chloride Management Plan - Prioritizing and Implementing Restoration and Protection - Cost considerations and funding opportunities]]
-==Cost considerations and funding opportunities==
-The potential costs of reducing chloride loads and potential funding opportunities s are discussed.
-===Winter salt (applied to roads, parking lots, and sidewalks)===
-The assessment of costs and economic benefits associated with chloride uses and its impacts is complex. One thing is certain, removing chloride from impaired lakes, wetlands, and streams through RO or distillation is impractical and cost-prohibitive; therefore, prevention or source control is the logical approach.
-Application of salt in winter months is currently the most commonly used method of maintaining safe roads, parking lots, and sidewalks. The economic benefit of safe travel is hard to measure. Economic benefits also from reduced work-loss time. The various economic impacts and benefits are shown in the Cost Considerations Related to Salt Use and discussed briefly below. Though salt is one means of reducing accidents and work-loss time resulting from winter weather other means are available. Slower speed limits during snow events are one such option.
-The economic impact of salt use goes beyond the environmental and includes costs associated with damage to transportation infrastructure, vehicle corrosion, and vegetation damage (Fortin 2014).
-[[File:Cost Considerations Related to Salt Use.PNG |right|thumb|300 px|alt=This chart shows Cost Considerations Related to Salt Use|<font size=3>Cost Considerations Related to Salt Use</font size>]]
-Efficient winter maintenance practices can reduce salt use without lowering the level of service. The improved practices are intended to maintain a consistent level of service in terms of safe roads, parking lots, and sidewalks with lower salt use. Implementation of improved winter maintenance activities may come with an initial investment cost to address training, new equipment, and public outreach. However, as a result of reduced salt usage, a cost savings is expected based on information provided by several local winter maintenance organizations. A net cost-savings has been shown by many organizations who have tracked cost before and after the implementation of winter maintenance BMPs. Table 9 provides examples of tracked cost savings associated with the implementation of various salt reducing BMPs by local winter maintenance organizations. Detailed descriptions of these cost savings examples can be found in section 3.5 of the CMP. The cost estimates provided in Table 11 reflect implementation of a variety of BMPs with multiple activities applied simultaneously. The information provided in Table 9 is not intended to be a reflection of cost for any one practice but rather an overall estimate. Each organization will implement practices that are most appropriate for their individual operations and there is not a one-size-fits-all approach when it comes to winter maintenance; therefore, the costs will vary greatly across organizations.
-{{:Examples of Municipal and Private Cost Savings}}
-===Municipal waste water (primarily from water softening)===
-The cost for point source dischargers to remove chloride from their wastestream is very high and is cost prohibitive for most facilities. Below is an estimate of the cost to treat effluent from a WWTP (Henningsgaard 2012):
-An estimate for the total cost is 4-5.25 million Dollars:
-*Fine filtration - 1.5 million dollars per million gallons treated
-*RO - 1-2.25 million dollars per million gallons treated
-*Evaporation technology prior to landfill – 1.5 million dollars per million gallons treated
-Annualized cost for construction (assuming 20 year term at a market rate of 2.25%) is between 250,568 and 328,871 dollars per year.
-Annual Operation and Maintenance costs:
-•	Fine filtration – 0.01 to 0.15 dollar per 1,000 gallons treatment
-•	RO - 2,200 dollars per million gallons treatment
-•	Evaporator fuel - 10,000 to 12,000 dollars per month
-Based on specifics from each community, this cost could be considered to have “substantial and widespread economic and social impact” (40 CFR 131.10 (g) (6)) and could be justification for a variance that would not require this type of expensive treatment. There is no reasonable (environmental and economic) way to dispose of the highly concentrated sludge produced by RO treatment.
-The high cost of end-of-pipe treatment for chloride and the high cost and difficulty of final disposal of the brine makes source reduction is a critical element to wastewater treatment of chloride-containing waste streams. In most municipal situations, a major source of chloride is water softeners. The NaCl or KCl is commonly used in the softening process at the WTP and in residential or commercial softeners.
-===Funding opportunities===
-There are available sources of money to offset some of the costs of implementing practices that reduce chloride from entering surface and groundwater. Several programs, listed below, have web links to the programs and contacts for each entity. The contacts for each grant program can assist in the determination of eligibility for each program and funding requirements.
-On November 4, 2008, Minnesota voters approved the [https://www.revisor.leg.state.mn.us/laws/?key=56967 Clean Water, Land & Legacy Amendment] to the constitution to:
-*protect drinking water sources;
-*protect, enhance, and restore wetlands, prairies, forests, and fish, game, and wildlife habitat;
-*preserve arts and cultural heritage;
-*support parks and trails;
-*and protect, enhance, and restore lakes, rivers, streams, and groundwater.
-The Clean Water, Land, and Legacy Fund has several grant and loan programs that can be used for implementation of the BMPs, education and outreach, and WWTP modifications. The various programs and sponsoring agencies related to clean water funding and others are:
-*[http://www.mda.state.mn.us/agbmploans Agriculture BMP Loan Program (Minnesota Department of Agriculture)]
-*[http://www.bwsr.state.mn.us/grants/ Clean Water Fund Grants (BWSR)]
-*[https://www.pca.state.mn.us/water/clean-water-partnership-grants Clean Water Partnership (MPCA)]
-*[http://www.lccmr.leg.mn/ Environment and Natural Resources Trust Fund (Legislative-Citizen Commission on Minnesota Resources)]
-*[https://www.pca.state.mn.us/about-mpca/environmental-assistance-grants Environmental Assistance Grants Program (MPCA)]
-*[http://mn.gov/deed/government/public-facilities/funds-programs/point-source-grants.jsp Phosphorus Reduction Grant Program (Minnesota Public Facilities Authority)]
-*[https://www.pca.state.mn.us/water/financial-assistance-nonpoint-source-water-pollution-projects-clean-water-partnership-and Section 319 Grant Program (MPCA)]
-*[http://mn.gov/deed/government/public-facilities/funds-programs/smallcommunitywastewatertreatmentprogram.jsp Small Community Wastewater Treatment Construction Loans & Grants (Minnesota Public Facilities Authority)]
-*[http://www.health.state.mn.us/divs/eh/water/dwp_cwl/grants/index.html Source Water Protection Grant Program (Minnesota Department of Health)]
-*[https://www.pca.state.mn.us/water/surface-water-assessment-grants Surface Water Assessment Grants (MPCA)]
-*[http://mn.gov/deed/government/public-facilities/funds-programs/cleanwaterrevolvingfund.jsp TMDL Grant Program (Minnesota Public Facilities Authority)]
-*[https://www.pca.state.mn.us/water/wastewater-and-stormwater-financial-assistance Wastewater and storm water financial assistance (MPCA)]
-The WDs and WMOs may have individual grant opportunities for implementation of the BMPs and education and outreach activities.
-The [http://lrrb.org/ Minnesota Local Road Research Board’s] Local Operational Research Assistance (OPERA)
-Program helps develop innovations in the construction and maintenance operations of local government transportation organizations and share those ideas statewide. The OPERA program encourages maintenance employees from all cities and counties to get involved in operational or hands-on research. The program funds projects up to 10,000 dollars through an [http://www.mnltap.umn.edu/about/programs/opera/ annual request-for-proposal process].
-Implementation of the BMPs for this project can sometimes require purchasing and/or upgrading equipment, which does not necessarily fit nicely into the conventional grant and loan programs. Some work will need to be done with the funding agencies in order to make grants and loans available for equipment purchase and/or upgrades.
-The [http://www.werf.org/ Water Environment Research Foundation (WERF)] funds water quality research that is funded through a competitive process. Apply for grants for research related projects [http://www.werf.org/ here]..
-There are several grant and loan programs through the federal government for education and outreach and purchasing equipment and implementation of the BMPs. A list of federal grant programs can be found [https://www.epa.gov/learn-issues/learn-about-water here].