To: Middle Ocmulgee (MOC) Regional Water Planning Council
From: Veronica Craw, GA EPD, MOC Liaison
Paula Feldman, Freese and Nichols
Casey Porter, Freese and Nichols
Shauntelle Hamlett, Freese and Nichols
Subject: FINAL Meeting Summary
Welcome and Introductions
Middle Ocmulgee Chair, Elmo Richardson, welcomed the group and called the meeting to order at 9:30 AM. Everyone in attendance introduced themselves.
Mike Hopkins introduced the meeting facility and welcomed councilors to the top of the watershed to see all the growth in Newton County. Newton is a unique system in that the Newton County Water Authority doesn’t own the water supply, which is run by the Water Resources Division. The Authority receives treated water and delivers it to eight customers.
The County benefits from being in a watershed that doesn’t touch another state. When major industries started arriving back in 2012, the Authority had to write many letters making the case that the water supply was not at risk of Chattahoochee-style litigation and showing that Newton County will protect downstream users. The Authority has invested about $50 million in infrastructure to get large industries here. The eastern exit off I-20 was formerly very rural, despite being just 35 miles east of Atlanta. In 1998, the Newton County Commissioner worked with four other counties to develop a plan for a 1,600-acre industrial park at Stanton Springs. Improvements toward that end began with a 12-inch water main in 1998. In 2013, a pharmaceutical company came to town. Current and planned facilities include:
- Takeda - pharmaceuticals
- Bioscience Center – promoted by Governor Nathan Deal for training
- Two data centers filled with server racks (one under construction)
- Rivian, the electric truck manufacturer (planning stages)
- Planning to locate on north campus
- First request was too much W/WW capacity for the utility to provide
- The Authority wanted to aim for industrial growth as a better fit in a county where currently 75% of residents work outside the County; looking for ways to promote living and working in the same community.
- Planning for a reuse system with industrial and sanitary waste streams separated to mitigate needs.
- Council members approved the August 29, 2022 meeting minutes unanimously.
- Council members approved the November 29, 2022 meeting agenda.
Regional Water Planning Update
(Veronica Craw, GA EPD)
- Regional Planning Update
- This council is on schedule to meet the summer 2023 planning deadline.
- The Seed Grant window closed in October. There were no projects from this council, but there were about eight from other councils.
- Due to the requirement of a match from the local government or a project partner, there was not much interest in the Seed Grant program. GEFA is also hearing the same feedback due to a similar requirement.
- Asset Management for Public Water Systems
- Background – The AWIA law from 2018 required state drinking water programs to incorporate asset management into state strategies. State programs are due in December 2022 after the EPA already provided a 1-year extension to the original date.
- Georgia EPD therefore proposed rule amendments to Chapter 391-3-5-.04.
- The update is all new language with no changes to existing text.
- Requires an asset management plan for EPD’s approval for customer bases over 3,300 people, beginning in January 2024.
- The requirement is triggered for new facilities, ownership changes, permit renewals, or at the discretion of the EPD director due to compliance failures under exiting permits.
- Asset Management Plans are to be developed in accordance with Appendix C of the Minimum Standards for Public Water Systems. They should include:
- Asset inventory
- Required sustainable level of service
- Determination of critical assets (consequence of failure)
- Determination of lowest life-cycle cost options
- Long-term financing strategy (impact to rates, grants, loans, etc.)
- The Asset Management Plan should be thought of as a road map to accounting for maintenance costs.
- Appendix C to the Minimum Standards shows supporting information: who needs to submit a plan, how to prepare and implement a plan, and so on. It’s a one-stop shop to help utilities through this process.
- Please direct questions to Manny Patel: [email protected], 470-524-0585
- Discussion Followed (paraphrased for brevity)
- Tony Rojas: Is it required for utilities to implement the plan?
- Veronica Craw: Yes, it is.
- Tony Rojas: This is full-cost accounting but only for water. Any thought of doing the same thing for wastewater? It makes sense to have all those assets as part of the process if you’re going to have these tools and use them. Recommend to strongly encourage utilities to do both water and wastewater.
- Veronica Craw: I agree and will pass this feedback on to my peers.
- Tony Rojas: This is great stuff that’s going to enable economic development by putting utilities in a position to maintain assets. Suggest including the International Infrastructure Management Manual (IIMM) as another resource in Appendix C to learn about asset management.
(Chad Simmons, FNI)
- Georgia Solids
- GEFA published a study with Black & Veatch in 2021, which was a key resource for this discussion as related to Georgia information.
- Georgia is expecting a big jump in biosolids production by year 2060. The growth is population-driven.
- Compared to national practices in 2019, Georgia was using much more landfilling (63% in Georgia compared to 40% nationally). Other disposal options in Georgia included incineration (11%), Land Application (18%), and other practices (7%). The driver behind so much landfilling is cost, as it has historically been the cheapest option.
- Elmo Richardson: Note that convenience is a driver for smaller utilities and other options besides landfilling will be challenging for them.
- Chad Simmons: For smaller utilities, that’s not likely to change unless the state pushes for regional approaches.
- Drivers for Change
- Landfill capacity is diminishing, and few new landfills are currently in progress. Georgia could be out of landfill capacity by 2060 if current practices continue and no new landfills are added in the state.
- High moisture content waste rules may discourage future landfill disposal.
- Landfilling is getting more costly, making other options more financially viable.
- Part of the cost increase is regulations which were driven by slope failures caused by high moisture content waste (i.e., sludge).
- Examples were shown of other states adding regulations that drove change in biosolids management (Texas and Oklahoma).
- Per- and polyfluoroalkyl substances (PFAS) Overview
- Includes manmade chemicals which have been around since the 1940’s, with perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) being the most studied for health implications in recent years.
- Biosolids can include PFAS from wastewater and provide a pathway to drinking water through the environment.
- EPA’s roadmap lays out new enforceable limits under SDWA, as well as a future hazardous substance designation under CERCLA.
- In June 2022, EPA updated its lifetime health advisory limits to very low and in some cases undetectable levels, essentially saying “no PFAS in drinking water”.
- PFAS in Biosolids:
- Stabilization methods do not remove PFAS.
- No standard analysis has yet been approved by EPA, but some states are requiring sampling of biosolids already.
- Several studies going back to 2001 have shown levels of PFOS and PFOA in biosolids.
- An EGLE study in 2020 showed that concentrations of PFAS in biosolids were primarily coming from industry. The good news is that it can be treated at the source. Strong reductions at the source can be achieved with granular activated carbon.
- Notably, several example states saw increases in biosolids handling costs when they implemented treatment for PFAS at the water reclamation plants.
- Solids Classifications
- Unstabilized solids (sludge)
- Stabilized solids
- Class A Exceptional Quality – can be applied with minimal restrictions or marked as soil amendment or fertilizer
- Class A – can be applied with minimal restrictions
- Class B – can be land applied with access restrictions and buffer zones
- Treatment Technologies
- Stabilization can be achieved with varying technologies, but these do not break down PFAS.
- Thermal conversion usually has a high enough temperature to break the chemical bonds between carbon and fluorine that make PFAS so resilient.
- Incineration has been used for decades for municipal wastewater sludge, but this method has taken a step back since the early 2000’s due to increased cost for treatment of air emissions and public opposition.
- Gasification and Pyrolysis are emerging technologies getting a deeper look in the industry due to PFAS.
- Pyrolysis burns the material in the absence of oxygen at high temperatures, producing biochar.
- Gasification is similar to pyrolysis, but with some oxygen present and even higher temperatures, resulting in biochar and ash.
- Beneficial Reuse Markets
- Based on solids projections for Georgia, there are about 200,000 dry tons per year being produced currently.
- The potential demand in Georgia industries is nearly 10,000,000 dry tons per year. A rough, oversimplified conclusion is that only a 2% market penetration could take all the biosolids in Georgia.
- Beneficial reuse options may not make sense for small utilities, but the key point is that there is substantial demand which could be partially met by biosolids for beneficial reuse, and it is recommended that utilities take advantage if feasible.
- Agricultural / Silvicultural / Land Reclamation
- Energy Production
- Discussion Followed (paraphrased for brevity)
- Tony Rojas: Can states make changes that override EPA like Texas did?
- Chad Simmons: Texas created a biosolids classification tier between Class A and Class B, known as Class AB. What the EPA considers Class A lime stabilized biosolids is now Class AB lime stabilized biosolids in Texas and has more restrictions applied to it. Texas could do this because it’s more restrictive than EPA. They couldn’t make something less restrictive.
- Mark Wyzalek: Sewer systems will be responsible for any harms that occur under the EPA’s plan as shown in the roadmap. If a utility accepts wastewater with PFAS in it, utilities can be liable for PFAS harms due to the way CERCLA is written. Extreme care is needed in how these regulations are rolled out.
- Chad Simmons: Point taken, and it’s likely to take several years for EPA to flesh this out.
- Mark Wyzalek: EPD did well to push for monitoring this in advance in our potable water systems. Many places are monitoring for PFAS.
- Elmo Richardson: Mike Hopkins, what are your plans since you’re doing reuse on the water side?
- Mike Hopkins: Solar drying. We’re working with Covington to develop a program where we can take care of biosolids. We had a landfill with unlined cells that had a few blowouts. We have a screw press, but a lot of sludge production, and are considering multiple options.
- Elmo Richardson: Ben Copeland, does SuperSod use any biosolids on your farms?
- Ben Copeland: Absolutely not - I’m too scared of it. There are farms up in the Northwestern part of the state with tested PFAS levels coming back in the parts per million range. PFAS is a big problem in our state due to the carpet industry, and it’s throwing a light on a lot of sins from the past.
- Barry Peters: Do you have any chemical composition data on the nitrogen and phosphorous levels of biosolids?
- Chad Simmons: I can certainly get it for you.
- Tony Rojas: We put biosolids on pastureland. They like it because of the slower release of nutrients.
Management Practices Update
(Paula Feldman, FNI)
- We don’t have all the resource assessments to look at Section 3 yet, so we want to take a deep look at Management Practices to stay ahead of the planning effort. Management practices build on the gap analysis and vision/goals.
- Current Management practices are lumped into 4 buckets: Demand Management, Supply Management, Water Quality Management, and Education.
- Split Water Quality Management into Wastewater and Stormwater
- Replace Education with Administrative management practice group, to include both education and executive initiatives such as master planning
- Water Demand Management Practices
- Merge conservation practices to eliminate the distinct “non-farm” and “additional” practices.
- Relocate to the new Administrative Group the “Full Cost Accounting” practice
- Implement and Encourage Water Conservation Practices
- Suggested Enhancement: 3-tier pricing structures
- Tony Rojas: The revenue from rates includes the fixed costs of maintaining a water utility. Conservation can load the cost into lower tiers via reduced water sales if we run too fast.
- Paula Feldman: Perhaps the language can be softer… “encourage” instead of “thou shalt”
- Tony Rojas: “As circumstances demand.” If there is no water scarcity, there is no reason to create a revenue problem. The solution is for more cost to be in the base fee. 75% of most utilities’ costs are fixed. You can’t put that much in the base fee, but 50% would be nice. Whether a customer with a meter uses 1 gallon or 1,000 gallons, they have the option, and the option has costs.
- Suggested Enhancement: 3-tier pricing structures
- Water Supply Management Practices
- Relocate master planning item to new Administrative Group
- Merge existing and new reservoir storage into one comprehensive water storage practice
- Merge upgrade of existing and new water treatment plants into one plant capacity practice
- Elmo Richardson: streamlining is always better, so let’s do it.
- Investigate Impacts of Metro Atlanta Discharges
- Mark Wyzalek: some of that’s getting reviewed by GA EPD as part of Liz Booth’s modeling evaluation in Lake Jackson.
- Paula Feldman: We have recently seen higher phosphorus and chlorophyll-a levels based on the water quality assessments. Suggest keeping this in here.
- Evaluate New and Existing Surface Water Reservoir Storage
- Enhancement: evaluate abandoned quarries
- Barry Peters: Do NRCS reservoirs have potential in our region?
- Paula Feldman: Have not looked at the map, but possibly.
- Tony Rojas: I wonder if just getting sediment out of reservoirs to expand their capacity could be included.
- Investigate New Groundwater Sources – no changes
- Evaluate Interconnections for Water Supply – no changes
- Expand Water Treatment Capacity
- Enhancement: consider advanced treatment technologies (emerging contaminants)
- Mark Wyzalek: We should include a note to monitor emerging contaminants.
- Paula Feldman: I like the language “monitor emerging contaminants.” Any other thoughts on that? (none)
- Promote and Evaluate Beneficial Reuse
- Mike Hopkins: Noted Clayton County doing constructed wetlands.
- Mark Wyzalek: Is anyone doing reuse?
- Paula Feldman: Gwinnett County is doing indirect potable. So is Clayton County.
- Wastewater Management Practices (Formerly within Water Quality)
- Relocate master planning and coordinated planning items to the new Administrative Group
- Merge together items related to septic impacts
- Merge together WW treatment facility expansions / construction / upgrades
- Upgrade and Construction Advanced WW Treatment Facilities – no further changes after combining
- Mitigate Impact of OSSMS/Septic Systems
- Tony Rojas: Small developments have no place to take septage. Utilities don’t design WWTPs to take septage and neighborhoods on septic aren’t paying for that capacity, but it usually ends up in the system anyway. Always felt like some type of tax on septic would help utilities design with enough capacity in mind for septage.
- Mike Hopkins: We have 8,000 sewer customers but 27,000 water customers. Need a structure where people build up a balance for septage hauling.
- Paula Feldman: That’s a sophisticated option that we can investigate. I like the idea because sewer customers must pay a connection fee and septic customers don’t.
- Tony Rojas: Spartanburg Water has a good model to pay for septage treatment
- Evaluate Constructed Wetlands (Beneficial Reuse) – no changes
- Stormwater Management Practices (formerly within Water Quality)
- Remove water quality monitoring and TMDL implementation since they are state requirements.
- Relocate public education to items to the new Administrative Group
- Merge stormwater standards for rural areas with practice pertaining to forests and dirt roads
- Merge watershed assessments and plans with runoff reduction practice, since both items include programs to manage stormwater in the sub-bullets
- Adopt Ordinances to Protect Sensitive Land – no changes
- Establish a Stormwater Utility to Ensure Funding – no changes
- Tony Rojas: Stormwater management fees should help with maintenance. The list of assets local governments take care of includes more than sanitary sewer.
- Implement Watershed Improvement Projects – no changes
- Implement Stormwater Standards for Rural Areas and Forest and Dirt Roads – no changes after combining
- Tony Rojas: When we did our assessment, we asked why we would do all this without a plan to do something about it.
- Paula Feldman: Overall sounds like this is good then, including both an assessment and a plan in the management practice.
- Develop / Implement Watershed Assessment / Protection Plan Measures – no changes after merging
- Implement Water Quality Trading – no changes
- Tony Rojas: I didn’t think that nutrient trading was allowed.
- Veronica Craw: EPD has guidance on trading.
- Paula Feldman: If this is already part of EPD and guidance out there, we could eliminate this.
- Tony Rojas: I say keep it and update bullets to indicate EPD guidance exists.
- Develop Commercial / Industrial Pollution Prevention Programs – no changes
- Education Initiatives
- Reorganization: Move the only item to the new Administrative Group
- Administrative Management Practices (New)
- Promote Full-Cost system Accounting (former WD-2)
- Paula Feldman: Should full-cost accounting go under asset management?
- Tony Rojas: Yes.
- Develop and Update Local Utility Master Plans (former WS-1, WQ-1, WQ-16 merged)
- Promote Coordinated Environmental Planning (former WQ-5)
- Develop Regional Educational Materials for Localized Implementation and Outreach (Former WQ-14, ED-1 merged)
- Develop Residual / Biosolids Management Plans (New)
- Develop and Update Asset Management Plans (New)
- Tony Rojas: Needs to be broken out into water, WW, and stormwater.
- Paula Feldman: That is the intent and that can be done in the bullets under the practice.
- Promote Full-Cost system Accounting (former WD-2)
- Additional Discussion Followed (paraphrased for brevity)
- Paula Feldman: Any other feedback on these before we break for lunch?
- The council discussed expansion of the Ocmulgee historic park and is supportive of conservation easements which help wetlands and watershed health.
- Paula Feldman: I like it and we’ll find a place to fit that in the Water Quality area.
Draft Regional Water Plan Updates, Section 4
(Paula Feldman, FNI)
Paula briefly noted that the draft of Section 4 was sent to the Council members after the August meeting. While there will be other opportunities to review Section 4 in the Draft Plan, information was requested on any changes that need to be made ahead of the Draft Plan. Elmo Richardson noted that the Section is fine for inclusion in the Draft Plan without further adjustment. Newton County’s industrial demands need to be updated based on the most recent information.
- No public comments.
- Mike Hopkins and the NCWSA were thanked for hosting the meeting and providing lunch to the group.
Next Steps and Wrap Up
Next council meeting will be held in first quarter of 2023.
Council Members Present:
- Elmo Richardson, Chairman
- Cassandra Cox
- Larry McSwain
- Barry Peters
- Tony Rojas
- Ben Copeland, Jr (Call-in)
- Marcie Celeb (Call-in)
Partners & Visitors
- Mike Hopkins, Newton County Water & Sewer Authority
- Mark Wyzalek, Macon Water Authority
- Paul McDaniel, GA Forestry Commission
- Carol Flaute, Northeast GA Regional Commission
GA Environmental Protection Division
- Veronica Craw, MOC Council Liaison & EPD Nonpoint Source Program Manager
Freese and Nichols, Inc. (Planning Contractors)
- Paula Feldman, Council Lead
- Casey Porter, Council Support (Call-in)
- Shay Coombs, Council Support
- Chad Simmons, Council Support / Presenter