Watershed Based Permitting Case Study Cache La Poudre River Colorado

Watershed-Based Permitting Case Study

C-o^cl^e (a. F*OiAdre River, doior^do

Kodak Colorado Division Water Quality Monitoring

Permitting Authority:

Colorado Department of Public Health and Environment (CDPHE) -
Water Quality Control Division

Permit Writer

Andrew Neuhart

Permits Section, Industrial Unit

Water Quality Control Division, CDPHE

4300 Cherry Creek Dr. South

Denver, CO 80246-1530

ph: 303-692-3655

and rew, neu ha rt@state ,co. us

Permittee Environmental Engineer

Eric Peterson

Kodak Colorado Division

9952 Eastman Park Drive

Windsor, CO 80551-1334

ph: 970-686-4014

eric.petersen@kodak.com

Permit Type: Individual NPDES permit

Permit Issued:

CDPS permit number CO-0032158 Issued 09-25-2008,

Effective 01-01-2009

(note: permits are not available online)

Pollutants of Concern in the Watershed:

E. coli: Cache la Poudre River, Box Elder Creek to S. Platte River

Selenium: All tributaries to the Cache La Poudre River, including all
lakes reservoirs and wetlands, from the North Fork of the Cache La
Poudre River to the confluence with the South Platte River

Overview

Kodak Colorado Division (KCD), a film and paper manu-
facturing facility, became a United States Environmental
Protection Agency (EPA) Performance Track member
in 2004. The Performance Track program recognizes
and drives environmental excellence, encouraging facili-
ties with strong environmental records to go above and
beyond their legal requirements by pledging to make four
measurable environmental achievements to Improve the
quality of the nation's air, water, and land. KCD estab-
lished commitments in the areas of total water use,
nonhazardous-waste generation, air emissions, and total
non-transportation energy use. Through the program, KCD
explored monitoring flexibilities that could be incorporated
into its Colorado Discharge Permit System (CDPS) permit
that expired in July 2005.

KCD worked with local facilities, the Colorado Depart-
ment of Public Health and Environment (CDPHE), the
North Front Range Water Quality Planning Association
(NFRWQPA), and EPA Region 8 to coordinate water qual-
ity monitoring along a 45-mile stretch of the Cache la
Poudre River. This effort coincided with development of
new CDPHE monitoring guidance, Baseline Monitoring

Monitored Parameters:

Physical: Flow (where possible), Temperature, Conductance
Inorganic Nonmetallic: Dissolved Oxygen, pH, Hardness, Alkalinity
Nutrients: Ammonia-N, Nitrate+Nitrite-N, Kjeldahl-N, Phosphorus (total)
Benthic Macroinvertebrates: Population characteristics
Microbiological: E. coli, Fecal Coliforms
Fish Species: Population Characteristics, Fish for flash samples
Metals: Arsenic, Cadmium, Chromium, Copper, Iron (dissolved and total
recoverable), Lead, Manganese, Mercury, Nickel, Selenium, Silver, Zinc
Other: Sulfate, DOC, Cyanide

Baseline Monitoring Frequency, Sample Type, and Reduced Monitoring
Frequency Policy for Industrial and Domestic Wastewater Treatment Facilities
Policy Document

www.cdphe.state.co.us/wq/PermitsUnit/POLICYGUIDANCEFACTSHEETS/
PolicyandGuidance/Monitori ngReductionPolicy.pdf

Watershed Powdre River,
C-oloKa.do

Key Water Quality Concerns: E-^oii select'*™

Stakeholder Involvement Techniques:

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• of a votcter tv*Ob\t~6orfb\j jrotAj?

• HoS'tib\j stakeholder *00 rfc$C\Op>$
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Case Study Issues of Interest

POTW Discharges

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Industrial Process Wastewater Discharges

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Concentrated Animal Feeding Operations

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Municipal Separate Storm Sewer System Discharges

Construction Site Stormwater Discharges

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Watershed-Based Permitting Case Study

C.(a. PCHAdre River, C-oiot^do

Frequency, Sample Type, and Reduced Monitoring Frequency
Policy for Industrial and Domestic Wastewater Treatment
Facilities, that addresses reductions in effluent monitoring fre-
quencies and the role of ambient water quality monitoring. As
a result, KCD has been able to integrate ambient water moni-
toring with its existing effluent monitoring practices. This case
study discusses how KCD's CDPS permit provided efficiencies
and cost savings for collecting ambient water quality data in
the Cache la Poudre watershed and helped shape Colorado's
monitoring policy.

Background

since 1970. In 2006, KCD began working with other local
stakeholders through the regional watershed association,
NFRWQPA, to explore the possibility of forming a watershed
monitoring group. KCD also began considering the role its
ambient monitoring could play in obtaining flexibility in its
CDPS permit monitoring requirements.

Cache la Poudre River Water Quality Monitoring Group

EASTMAN DRlvC

Kodak
Pond

KCD Industrial
Wastewater Treatment
Facility

Poudre River
Staff Gauge

Cache la
Poudre River

Poudre River
Sharkstooth

Since 1969, KCD has occupied a 640 acre site along the
Cache la Poudre River in Windsor, Colorado, about 60 miles
north of Denver. The Cache la Poudre River originates in
northern Colorado near the Continental Divide. The river
flows north and east out of Rocky Mountain National Park,
through the Roosevelt National Forest, down the Front
Range, and then southeasterly through the city of Fort Col-
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
in Figure 1.

Through EPA Region 8 Performance Track staff, KCD invited
staff from the CDPHE, local publicly-owned treatment
works, NFRWQPA, and EPA Region 8 to the KCD Windsor
facility for a meeting and presentation on a proposed Cache
la Poudre River monitoring group. The Cache la Poudre

Figure 1. r—-——

Cache la A I I

Poudre —y / wv

Watershed I I

Map \ T —1

Figure 2. KCD Property Site Map

Kodak FE, Storm &
Ditch Discharge

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
Piatt 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

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Watershed-Based Permitting Case Study

C.(a. PCHAdre River, C-oiot^do

Water Quality Monitoring Group officially includes six signed
members committed to monitoring ambient water quality:

KCD

City of Fort Collins

South Fort Collins Sanitation District

Boxelder Sanitation District

Town of Windsor Sanitation District

City of Greely Sanitation District

The monitoring group aimed to eliminate duplicate
sampling sites, reduce repetitive monitoring, and save
resources while increasing the value of the water quality
data its members collected. The data would help state
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 permit has
since been reissued with an effective date of January 1,
2009.

Water Quality Monitoring Plan

The impending permit renewal presented KCD and the
Performance Track staff with the opportunity to expand upon
and leverage the facility's existing voluntary water quality
monitoring. Scientists and public officials were also seek-
ing additional water quality data to assist them in making
decisions to further protect the Cache la Poudre River. KCD
and the NFRWQPA started hosting workshops and planning
meetings to give other stakeholders opportunities to partici-
pate in the process of working on a coordinated ambient
water quality monitoring plan.

The ambient water quality plan developed by the Cache la
Poudre Water Quality Monitoring Group, in cooperation with
the CDPHE, covers segments 11,12 and 13 of the Cache
la Poudre River, a 45-mile stretch bounded by North Fort

Collins and the confluence with the South Piatt River East of
Greeley. Eight times a year, at each of ten river assessment
sampling sites, the water quality in the river is monitored
and recorded (see Figure 3). This water quality monitor-
ing includes sampling for 46 parameters such as flow, pH,
dissolved oxygen, and metals concentrations. In addition to
water quality, benthic analyses to observe and evaluate the
organisms that reside in the lowest level of the water body
are conducted four times a year, and fish tissue studies to
observe and evaluate the fish population that resides in a
section of the river are conducted annually. These types of
evaluations go beyond analysis of the chemical constituents
present in the water to observe the aquatic life that resides
within, and is supported by, the water column.

Figure 3. Cache ia Poudre Water Quality Monitoring
Group Sampling Sites

^ ,!/ I Site#1

The Cache la Poudre Water Quality Monitoring Agreement,
which includes the sampling and monitoring detailed above,
was officially signed into effect in October 2007. This agree-
ment provides data collection and analysis methods that
meet state quality assurance standards and as reporting
requirements for data and testing results. Because of KCD's
participation, its required effluent monitoring frequencies for
BODL pH, ammonia, cyanide, and silver have been further
reduced in the reissued 2009 permit.

Monitoring Frequency Policy

In addition to working with the Cache la Poudre Water Quality
Monitoring Group, CDPHE's Water Quality Control Division
(WQCD) updated its monitoring policy and developed a guid-
ance document regarding reduced monitoring frequencies in
CDPS permits and the role of ambient water quality monitor-
ing. WQCD's previous policy, entitled Sample Frequency and
Sample Type - Domestic Wastewater Facilities: provided

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Watershed-Based Permitting Case Study

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~ 400

Untitled

I Other

Sludge

I Waterwater Process Control

NPDES Effluent Monitoring + QAQC

Kodak

Ft.Collins

Greeley

Windsor

Boxelder

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Collins, Jim A. and Sprague, Lori A. U.S. Department of the Interior, U.S. Geological Survey. "The Cache la Poudre River, Colo-
rado, as a Drinking-Water Source." May 2005.

Colorado Department of Public Health and Environment, Water Quality Control Division. Baseline Monitoring Frequency,
Sample Type, and Reduced Monitoring Frequency Policy for Industrial and Domestic Wastewater Treatment Facilities. Effec-
tive May 1, 2007.

Colorado Department of Public Health and Environment, Water Quality Control Division. Practical Quantitation Limitation
Guidance Document. July 2008.

Colorado Department of Public Health and Environment, Water Quality Control Division. Sample Frequency and Sample Type,
Domestic Wastewater Facilities, Policy Number WQP-13. August 21, 1989.

Colorado Department of Public Health and Environment, Water Quality Control Division. Status of Water Quality in Colorado
2008. April 2008.

Colorado Department of Public Health and Environment, Water Quality Control Commission. Regulation No. 38 Classifications
and Numeric Standards South Platte River Basin, Laramie River Basin, Republican River Basin, Smoky Flill River Basin.
Amended: February 9, 2009, effective: March 30, 2009.

Email communication between Jennifer Duckworth, Tetra Tech, Inc. and Andrew Neuhart, Colorado Department of Public
Health and Environment, Water Quality Control Division.

Email communication between Jennifer Duckworth, Tetra Tech, Inc. and Eric Peterson, Kodak Colorado Division.

Fiorino, Daniel J. The EPA's Performance Track Creates Partnerships with the Nation's Top Environmental Performers. Storm-
water: The Journal for Surface Water Quality Professionals, Editorial. May/June 2005.

U.S. Environmental Protection Agency, National Environmental Performance Track. Coordinating and Integrating Effluent and
Ambient Water Monitoring - Case Study on Kodak Colorado. March 18, 2008.

U.S. Environmental Protection Agency, National Environmental Performance Track. David Pusey, Kodak Colorado Division,
Windsor, CO. Performance Track Teleseminar, Summary and Presentation. Kodak Colorado.- Ambient Water Quality Monitoring.
March 13, 2007.

U.S. Environmental Protection Agency, Surf Your Watershed. Cache La Poudre Watershed- 10190007 Website. Accessed
December 11, 2009.

Note: All Web references current as of December 11, 2009.

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