Winter 2009

A Quarterly Newsletter of the Instrumentation Testing Association

ITA Enews

Winter 2010

Instrumentation Testing Association  (ITA)


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In an effort to raise the profile of the Mississippi River and the Gulf of Mexico to the level of attention of the Chesapeake Bay and the Great Lakes, a coalition of environmental groups, whose action spurred Wisconsin’s recent nutrient rules, sued the US EPA for allegedly failing to set numeric nutrient criteria for the State of Florida as required by the Clean Water Act.

Currently, Florida has narrative nutrient criteria in which the regulations require that nutrient concentrations of nitrogen and phosphorus produced from municipal wastewater treatment and other sources such as runoff and emissions shall not alter a body of water so as to cause an imbalance in natural populations of aquatic flora or fauna.

Florida Watersheds (courtesy University of Florida IFAS Extension)

In Florida, the US EPA agreed to propose numeric nutrient criteria for lakes and streams to be adopted by late 2010 and agreed to propose criteria for estuaries and coastal waters by November 2011 which is to be adopted by early 2012 (Cross, B.J., US EPA’s Numeric Nutrient Criteria for Florida: A Hurricane on the Horizon?, Fall 2010). 


EPA’s proposed rules (26 January 2010) set phosphorus limits of 10-50 ppb in lakes, 107 ppb in streams in southern Florida, and 42 ppb in canals.


Florida argues that their waterways have natural phosphorus levels that are above the new proposed limits and according to the Florida Industrial and Phosphate Research Institute, commonly used laboratory measurement methods have a limit of detection of 15 ppb for phosphate and noted that “15 pbb is difficult to consistently obtain.” 


Laboratory methods take days to obtain results, thereby risking that a treatment plant can be in violation of the standard for days.

Globally other countries are adopting similar criteria.  Canada’s Ministry of the Environment (MOE) for Ontario adopted the Lake Simcoe Protection Plan in 2009 (Ontario’s largest inland lake outside of the Great Lakes) and adopted a new phosphorus reduction strategy that came into effect in June 2010. 


The Plan has put a number of policies in place to control the potential increase in the phosphorus discharge from wastewater treatment plants by 2015 and is based on aggregate loading.  Total phosphorus limits are being pushed down to 10 ppb or lower with some plants that have treatment objectives of 5 to 7 ppb in their Certificates of Approval (equivalent to the US NPDES Permit).


The US EPA’s proposed numeric nutrient criteria for the State of Florida and the methodology used to create them are widely seen as a precursor of what is to come in other states (Cross, B.J., 2010) and will impact both municipal and industrial waste dischargers. 


The coalition of environmental groups, responsible for the Wisconsin rules, separately petitioned the US EPA to set criteria similar to Florida, as well as an aggregate pollution limit, through a TMDL for the Mississippi River and the Gulf of Mexico (LUMC, Regulators Ramp-Up Plans For Nutrient Limits In Mississippi River States, March 2010).  


Systematically working up and down the Mississippi River, on a state-by-state basis, the EPA notified the coalition of environmental groups that it is working with officials in Ohio, Illinois and Iowa to craft first-time numeric water quality criteria for nutrients.

Meeting the new nutrient regulations in Florida will require upgrades of existing plants to advanced treatment using reverse osmosis (RO) with capital costs to run into the billions, and increases in operating costs that will be passed on to the consumers in the form of higher utility bills.  (Trecker, Dave; Water Standards Pit Environmentalists Against the Business Community,, November 2010). 


A study by Carollo Engineers estimates $50.7 billion in capital expenditures to upgrade Florida’s treatment plants and approximates operating costs for the upgraded facilities to run about $1.3 billion annually. Total cost to Florida consumers would result in an increase in water utility bills by an average of $700 a year.


A study conducted by XCG and Stantec (Achieving Low Effluent Total Phosphorus Concentrations) reviewed treatment technologies for total phosphorus (TP) removal capability of WWTPs in the U.S. to achieve effluent TP concentrations below 100 ppb. 


The study showed that a number of facilities were capable of removing TP below the 100 ppb level.  Half of the treatment facilities used membrane filtration and the other half used a combination of enhanced flocculation/clarification and filtration technologies to remove TP below 100 ppb.  

Lake Simcoe Watershed (courtesy of Our Lake Simcoe)

Nationally, Canadian Provinces came to a mutual agreement to harmonize Federal and Provincial regulatory frameworks to address issues of overlapping jurisdictions and inconsistent discharge limits for the treatment and discharge of wastewater which was resulting in lawsuits and disputes between municipalities and regulators. 


In 2009, the MOE endorsed a proposed framework known as the Canada-Wide Strategy for the Management of Municipal Wastewater through the Council of Ministers of the Environment (CCME).  The strategy manages discharges from more than 3,500 wastewater facilities in Canada, provides an agreed-upon path forward for achieving regulatory clarity for owners of municipal wastewater facilities and identifies performance standards to increase protection for human health and the environment on a national basis.  Implementation of the standards will be in 3, 10, 20 and 30 year timeframes based on risk analysis, available funding and financial sustainability of the community.


Performance of complying with the new Canadian strategy will be based on process optimization set by National Performance Standards for CBOD, BOD, TSS, TRC, N, P and site specific effluent discharge standards such as pathogens, metals or nutrients.  Among other objectives, the strategy plans to identify information gaps and address emerging issues through coordinated Canadian wastewater research body to achieve its goals.

Quispamsis, a town in the coastal Province of New Brunswick, faces higher performance standards above and beyond the Strategy requirements in order to protect the shell fish industry.  Quispamsis’ Utilities Manger and ITA Vice-President, Chris Vriezen stated “Meeting the objectives of the Canada-Wide Strategy will require infrastructure designed around accurate, precise, low maintenance, and cost-effective sensors and automation, with an outcome to demonstrate diligence in operation and reporting.”

Proposed Regulatory Total Phosphorus Limits (ppb)

State/Province /

Type of Body of Water

Streams / Rivers


Implementation Deadline


75 / 100

15 to 40

To be determined



10 to 50

2011 to 2012

Chesapeake Bay Watershed


Not designated

60% by 2017

100% by 2025

Lake Simcoe, Ontario


5 to 10