Watershed-Based Permitting Case Study Cache la Poudre River, Colorado Kodak Colorado Division Water Quality Monitoring Permitting Authority: Monitored Parameters: Colorado Department of Public Health and Environment (CDPHE) – Physical: Flow (where possible), Temperature, Conductance Water Quality Control Division Inorganic Nonmetallic: Dissolved Oxygen, pH, Hardness, Alkalinity Permit Writer Nutrients: Ammonia-N, Nitrate+Nitrite-N, Kjeldahl-N, Phosphorus (total) Andrew Neuhart Benthic Macroinvertebrates: Population characteristics Permits Section, Industrial Unit Microbiological: E. coli, Fecal Coliforms Water Quality Control Division, CDPHE 4300 Cherry Creek Dr. South Fish Species: Population Characteristics, Fish for flash samples Denver, CO 80246-1530 Metals: Arsenic, Cadmium, Chromium, Copper, Iron (dissolved and total ph: 303-692-3655 recoverable), Lead, Manganese, Mercury, Nickel, Selenium, Silver, Zinc [email protected] Other: Sulfate, DOC, Cyanide Permittee Environmental Engineer Baseline Monitoring Frequency, Sample Type, and Reduced Monitoring Eric Peterson Frequency Policy for Industrial and Domestic Wastewater Treatment Facilities Kodak Colorado Division Policy Document 9952 Eastman Park Drive www.cdphe.state.co.us/wq/PermitsUnit/POLICYGUIDANCEFACTSHEETS/ Windsor, CO 80551-1334 PolicyandGuidance/MonitoringReductionPolicy.pdf ph: 970-686-4014 [email protected] Permit Type: Individual NPDES permit Watershed: Cache la Poudre River, Permit Issued: CDPS permit number CO-0032158 Issued 09-25-2008, Colorado Effective 01-01-2009 Key Water Quality Concerns: (note: permits are not available online) E-coli and selenium Pollutants of Concern in the Watershed: Stakeholder Involvement Techniques: E. coli: Cache la Poudre River, Box Elder Creek to S. Platte River • Working with other local stakeholders through a Selenium: All tributaries to the Cache La Poudre River, including all regional watershed association lakes reservoirs and wetlands, from the North Fork of the Cache La Poudre River to the confluence with the South Platte River • Formation of a water quality monitoring group • Hosting stakeholder workshops and planning meetings Overview Case Study Issues of Interest Kodak Colorado Division (KCD), a film and paper manu- POTW Discharges facturing facility, became a United States Environmental ✔ Protection Agency (EPA) Performance Track member Industrial Process Wastewater Discharges ✔ in 2004. The Performance Track program recognizes Concentrated Animal Feeding Operations and drives environmental excellence, encouraging facili- Municipal Separate Storm Sewer System Discharges ties with strong environmental records to go above and beyond their legal requirements by pledging to make four Construction Site Stormwater Discharges measurable environmental achievements to improve the Industrial Facility Stormwater Discharges ✔ quality of the nation’s air, water, and land. KCD estab- Type of Point Sources of Point Type Combined Sewer Overflows lished commitments in the areas of total water use, nonhazardous-waste generation, air emissions, and total Statewide Watershed Approach non-transportation energy use. Through the program, KCD Implementation of Water Quality Standards explored monitoring flexibilities that could be incorporated Implementation of Total Maximum Daily Loads or Other into its Colorado Discharge Permit System (CDPS) permit Watershed Pollutant Reduction Goals that expired in July 2005. Permit Coordination/Synchronization KCD worked with local facilities, the Colorado Depart- Integrated Municipal Requirements ment of Public Health and Environment (CDPHE), the Point Source – Point Source Water Quality Trading North Front Range Water Quality Planning Association (NFRWQPA), and EPA Region 8 to coordinate water qual- Point Source – Nonpoint Source Water Quality Trading ity monitoring along a 45-mile stretch of the Cache la Discharger Association Highlighted Approach(es) Poudre River. This effort coincided with development of Coordinated Watershed Monitoring ✔ new CDPHE monitoring guidance, Baseline Monitoring 1 Watershed-Based Permitting Case Study Cache la Poudre River, Colorado Frequency, Sample Type, and Reduced Monitoring Frequency since 1970. In 2006, KCD began working with other local Policy for Industrial and Domestic Wastewater Treatment stakeholders through the regional watershed association, Facilities, that addresses reductions in effluent monitoring fre- NFRWQPA, to explore the possibility of forming a watershed quencies and the role of ambient water quality monitoring. As monitoring group. KCD also began considering the role its a result, KCD has been able to integrate ambient water moni- ambient monitoring could play in obtaining flexibility in its toring with its existing effluent monitoring practices. This case CDPS permit monitoring requirements. study discusses how KCD’s CDPS permit provided efficiencies and cost savings for collecting ambient water quality data in Cache la Poudre River Water Quality Monitoring Group the Cache la Poudre watershed and helped shape Colorado’s Through EPA Region 8 Performance Track staff, KCD invited monitoring policy. staff from the CDPHE, local publicly-owned treatment works, NFRWQPA, and EPA Region 8 to the KCD Windsor Background facility for a meeting and presentation on a proposed Cache Since 1969, KCD has occupied a 640 acre site along the la Poudre River monitoring group. The Cache la Poudre Cache la Poudre River in Windsor, Colorado, about 60 miles Figure 1. north of Denver. The Cache la Poudre River originates in northern Colorado near the Continental Divide. The river Cache la flows north and east out of Rocky Mountain National Park, Poudre through the Roosevelt National Forest, down the Front Watershed Range, and then southeasterly through the city of Fort Col- Map lins, and eventually into the South Platte River near Greeley, Colorado. The upper portion of the river has been designated as a National Wild and Scenic River, while the lower portion supports agricultural and industrial uses. The Cache la Pou- dre Watershed straddles the Wyoming and Colorado border and is depicted Figure 2. KCD Property Site Map in Figure 1. All industrial wastewater at KCD is treated on-site prior to discharge into the Cache la Poudre River under CDPS permit number CO-0032158, while all sanitary wastewater is treated by the Town of Windsor’s municipal wastewater treatment facility. Stormwater runoff from the plant flows south to the Cache la Poudre River, then east to the South Platt River just east of Greeley. This stretch of the Cache la Poudre River is the receiving water body for KCD industrial wastewater treatment plant effluent, storm water runoff, minimal and treated water discharges (see Fig- ure 2), as well as the Town of Windsor wastewater treatment plant effluent. Strategy Recognizing the diverse inputs to the Cache la Poudre River immediately adjacent to the KCD property, KCD had been voluntarily monitoring the river for over thirty years, contracting with Colorado State University to per- form sampling at sites along the River 2 Watershed-Based Permitting Case Study Cache la Poudre River, Colorado Water Quality Monitoring Group officially includes six signed Collins and the confluence with the South Platt River East of members committed to monitoring ambient water quality: Greeley. Eight times a year, at each of ten river assessment sampling sites, the water quality in the river is monitored KCD and recorded (see Figure 3). This water quality monitor- ing includes sampling for 46 parameters such as flow, pH, City of Fort Collins dissolved oxygen, and metals concentrations. In addition to South Fort Collins Sanitation District water quality, benthic analyses to observe and evaluate the organisms that reside in the lowest level of the water body Boxelder Sanitation District are conducted four times a year, and fish tissue studies to observe and evaluate the fish population that resides in a Town of Windsor Sanitation District section of the river are conducted annually. These types of evaluations go beyond analysis of the chemical constituents City of Greely Sanitation District present in the water to observe the aquatic life that resides The monitoring group aimed to eliminate duplicate within, and is supported by, the water column. sampling sites, reduce repetitive monitoring, and save resources while increasing the value of the water quality Figure 3. Cache la Poudre Water Quality Monitoring data its members collected. The data would help state Group Sampling Sites regulators protect the drinking water supply for both the City of Fort Collins and the City of Greely, as well as preserve the Cache la Poudre River for its designated uses of water supply, primary contact recreation, cold water aquatic life, and agriculture. In September 2004, EPA Performance Track organized a meeting with the Cache la Poudre River Water Quality Monitoring Group members and officials from EPA’s Office of Water in order to discuss both water-related issues and potential water incentives for Performance Track facilities, such as reduced monitoring frequencies. Office of Water officials emphasized the continuing need for facilities and other stakeholders to partner with EPA and state agencies to collect data. After the meeting, Performance Track staff at EPA Headquarters followed up with members who had expressed interest in implementing water incentives. KCD had expressed interest in exploring flexibility in its major NPDES permit that expired in July 2005. The