Drinking Water/ Wastewater �Regulatory Update

Mary West-Calcagno, MRWA

October 2024

Water Topics for Today

Lead and Copper Improvement Rule�

Cybersecurity (MoDNR and EPA)�

House Bill 2080, Known as the “Water Safety and Security Act”

• “Within twelve months of the effective date of this section, each community water system shall create a plan that establishes policies and procedures for identifying and mitigating cyber risk. The plan shall include risk assessments and implementation of appropriate controls to mitigate identified cyber risks.”
• DNR and EPA are checking cyber security practices at inspections for drinking water and wastewater.
• Could it happen to you?

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American Water Cyber Attack

• https://www.teiss.co.uk/news/american-water-faces-nine-class-actions-after-major-data-breach-impacting-millions-14868
• https://www.wthr.com/article/news/local/russian-hackers-claim-responsibility-for-cybersecurity-attack-on-tipton-indiana-wastewater-treatment-plant/531-7c8d5fc5-aca5-4609-8034-cb2c97c40817

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PFAS/PFOA�

Wastewater Topics for Today

Water Quality Standards Revisions�

• Ammonia is the one likely to impact most wastewater systems
• Newest revision is to protect mollusks and snails
• Discharges to Missouri and Mississippi will be in phase 2 of the rule.
• Small systems will be impacted first
• Rule still in development
• The time to impact how the rule is drafted is now
• Treatment Optimization; now is the time to clean out your lagoon, study the collection system to determine how to reduce inflow and infiltration, make sure flexibilities exist in treatment and use them to discharge the best effluent possible. Just barely getting by (or not…)? Call MRWA and ask for a site visit to help develop a plan!

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Permitting�

• Renewals
• Submit renewal application at least 6 months (180 days) before expiration of current permit.
• Backlog is real, so don’t be surprised if you don’t get your new permit before the current one expires. If you applied on time, your permit will be automatically administratively renewed.
• If you didn’t apply before the 180-day cutoff, all is not lost - if you applied before the current permit expired.
• You will need to send a letter/email cleanwaterpermits@dnr.mo.gov to DNR Permitting to request that the permit be administratively continued.
• If you didn’t apply before the current permit expired, your permit is expired.

Enforcement Initiative

• How do you end up in this bucket?
• Effluent limits not met consistently
• Inspections identify serious or ongoing significant non-compliance
• Reporting is not received (eDMRs)
• Annual reports not received
• Non-responsive to MDNR correspondence
• Schedules of Compliance are not met

SNC or Significant Non-Compliance

• EPA has an ongoing focus on non-compliance
• “This NCI is intended to ensure that all NPDES permittees-not just industrial contributors-are complying with their permits. NPDES permittees, regardless of facility size or type, will see an increase by EPA and its state and tribal partners in identifying and addressing the SNC violations using enforcement and other compliance tools.”
• “If your facility has NPDES violations, EPA recommends that you take immediate action to correct them. Smaller facilities have not often been compliance and enforcement priorities for EPA or the NPDES authorized states. However, under this NCI, more attention will be given to facilities approaching or already in significant non-compliance – no matter their size.”

PFAS/PFOA

New Regulations for Land Application

Questions/Discussion?