environmental protection commission - Iowa DNR

MINUTES

OF THE

ENVIRONMENTAL PROTECTION COMMISSION

MEETING

SEPTEMBER 20, 2016

STATE OF IOWA CAPITOL 1007 EAST GRAND AVE

DES MOINES, IOWA

APPROVED BY EPC AT OCTOBER 18, 2016 MEETING

RECORD COPY

Filename: ADM 1-1-1 Sender’s initial: ___JZS____

TABLE OF CONTENTS

Call to Order .................................................................................................................................... 2

Commissioners Present .................................................................................................................... 2

Commissioners Absent .................................................................................................................... 2

Adoption of Agenda ........................................................................................................................ 2 APPROVED AS PRESENTED ....................................................................... 2

Approval of Minutes ........................................................................................................................ 2 APPROVED AS PRESENTED ........................................................................ 2

Monthly Reports .............................................................................................................................. 2 INFORMATION ........................................................................................... 2

Nutrient Reduction Strategy Annual Report Presentation ............................................................... 2 INFORMATION ........................................................................................... 2

Public Comment .............................................................................................................................. 2

Directors Remarks ........................................................................................................................... 2 INFORMATION ........................................................................................... 2

Farmed Wetland Study Summary .................................................................................................... 2 INFORMATION ........................................................................................... 2

FY 18 Budget Request ..................................................................................................................... 2 APPROVED AS PRESENTED ........................................................................ 3

State of Iowa Public Drinking Water Program 2015 Annual Compliance Report .......................... 4 INFORMATION ........................................................................................... 4

Water Supply: Water Use & Allocation Annual Permit Fee ........................................................... 5 APPROVED AS PRESENTED ........................................................................ 5

Clean Water and Drinking Water State Revolving Loan Fund – Second Quarter Updates to the FY 2017 Intended Use Plans ..................................................................................................... 6

APPROVED AS PRESENTED ........................................................................ 6

Contract with I & S Group, Inc. for Revising the Iowa Storm Water Management Manual .......... 7 APPROVED AS PRESENTED ........................................................................ 7

Contract with the United States Geological Survey for Stream gaging and real-time water quality support ................................................................................................................................. 8


Contract with the State Hygienic Laboratory at the University of Iowa for Ambient Groundwater Analytical support ................................................................................................................ 9

September 2016


Contract amendment with the USDA Animal Research Service/USGS Laboratory at Marshfield Wisconsin for Ambient Groundwater Analytical support ................................................. 10


Notice of Intended Action – Chapter 61 – Water Quality Standards (Copper Criteria Update) ... 11 APPROVED AS PRESENTED ........................................................................ 11

Adopted and Filed Chapter 100 – Scope of Title – Definitions – Form – Rules of Practice, Chapter 101 - Solid Waste Comprehensive Planning Requirements, and Chapter 111 – Annual Reports of Environmental Management Systems ............................................................................... 12


Adopted and Filed – Amendments to Flood Plain Management Rules to streamline certain development types ............................................................................................................. 13


General Discussion ........................................................................................................................ 14 INFORMATION ........................................................................................... 14

Referral to the Attorney General - J.S. Properties, L.L.C. (J.S. Properties) and Terry Anderson . 14 DNR MAINTAINS THE CASE ..................................................................... 16

Referral to the Attorney General – Swiss Valley Farms Cooperative ........................................... 16 REFERRED TO ATTORNEY GENERAL ......................................................... 17

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MEETING MINUTES

CALL TO ORDER The meeting of the Environmental Protection Commission was called to order by Chairperson Mary Boote at 10:00 a.m. on September 20, 2016 at the Iowa State Capitol in Des Moines, Iowa.

COMMISSIONERS PRESENT Mary Boote, Chair Nancy Couser Cindy Greiman, Secretary Chad Ingels, Vice Chair LaQuanda Hoskins

Ralph Lents Joe Riding Gene Ver Steeg

COMMISSIONERS ABSENT Bob Sinclair

ADOPTION OF AGENDA Motion was made by Joe Riding to approve the agenda as presented. Seconded by LaQuanda Hoskins. Motion carried unanimously.

APPROVED AS PRESENTED

APPROVAL OF MINUTES Motion was made by Cindy Greiman to approve the August 10, 2016 EPC meeting minutes. Seconded by Nancy Couser. Motion carried unanimously.


MONTHLY REPORTS • Bill Ehm shared with the Commission the AFO rule package is planned to be presented in

October. • Bill Ehm provided an update for the Rivers program activities. Through a Request for

Proposals, the Department is seeking a consultant to develop best practices for landowners, agencies, engineering firms, and more.

• Bill Ehm shared with the Commission a potential Demand for Hearing from Cerro Gordo County for the October EPC meeting.

• Bill Ehm shared with the Commission the Department’s investment in process improvement activities. Streamlining processes to be efficient benefits the environmental and public health. Last spring, environmental program supervisors were trained to identify areas of improvement and then implement the findings. The report out of their efforts yielded a number of positive results. The Title V air program will be conducting a Value Stream Mapping event in October. Iowa will be assisting Delaware DNREQ with starting a process improvement program.

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• The following monthly reports have been posted on the DNR website under the appropriate meeting month: http://www.iowadnr.gov/InsideDNR/BoardsCommissions.aspx

1. Rulemaking Status Report 2. Variance Report 3. Enforcement Status Report

4. Administrative Penalty Report 5. Attorney General Referrals Report 6. Contested Case Status Report

INFORMATION

NUTRIENT REDUCTION STRATEGY ANNUAL REPORT PRESENTATION Adam Schnieders from the DNR shared with the Commission tentative details for the November EPC tour highlighting Nutrient Reduction Strategy (NRS) practices. He summarized the efforts and phases of the NRS. Laurie Wissler from Iowa State University distributed a handout to the Commission and guests summarizing the Nutrient Reduction Strategy annual report. She provided background information and approaches for measuring success in the categories of Inputs, Humans, Land, and Water. For each of the categories, she summarized some of the challenges and opportunities.

INFORMATION

PUBLIC COMMENT • None

Written Comments Submitted

• None

END OF PUBLIC COMMENT

DIRECTORS REMARKS Director Chuck Gipp stressed to the Commission the importance of the Nutrient Reduction Strategy (NRS). The program is not just the DNR but also urban and agriculture groups working collaboratively together. The NRS will take time but with everyone at the table, we will all be part of the solution.

INFORMATION Chair Mary Boote thanked all the Nutrient Reduction Strategy presenters and looks forward to continued updates.

http://www.iowadnr.gov/InsideDNR/BoardsCommissions.aspx

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FARMED WETLAND STUDY SUMMARY Vince Evelsizer, Furbearer & Wetland Biologist of the Wildlife Bureau, provided the Commission a handout summarizing the results from the study. He shared with the Commission the study was funded by EPA to obtain a baseline of information for farmed wetlands. There is limited data available regarding the subject. He summarized the approach for conducting the study with sampling rotation over a couple years during various time of the year. The study looked at drainage, wildlife management, water quality, and watershed health. Private landowners were a major stakeholder in the study for most of the parcels of land selected for the study were privately owned. Landowners were highly receptive to the study and engaged with the efforts. He summarized the findings from species counts, laboratory analysis, and lessons learned. He thanked the Commission for supporting the study and looks forward to 5 manuscripts being published in the Journal of Wetlands.

INFORMATION

FY 18 BUDGET REQUEST Chuck Gipp, Director of the DNR, presented the following item. The Environmental Protection Commission approval was requested for the Department’s appropriation request for Fiscal Year 2018. The State Budget Director has directed all departments to submit a status quo budget. The budget is required by statute to be submitted to the Department of Management by October 1, 2016.

DEPARTMENT OF NATURAL RESOURCES

FY 2018 BUDGET REQUEST

APPROPRIATION NAME FY 17

Appropriation FY 18 Department

Request

GENERAL FUND Department Operations $12,862,307 $12,862,307 Floodplain Management $1,950,000 $1,950,000

Forestry Health Management $500,000 $500,000

Total General Fund Appropriations $15,312,307 $15,312,307

INFRASTRUCTURE Lake Water Quality Improvements $9,600,000 $9,600,000 Water Trails/Lowhead Dam $1,000,000 $1,000,000 Park Infrastructure Improvements $3,000,000 $3,000,000

Total Infrastructure Appropriations $13,600,000 $13,600,000

ENVIRONMENT FIRST Resource Enhancement and Protection $16,000,000 $16,000,000 Ambient Air Quality Monitoring $425,000 $425,000 Water Quality Monitoring $2,955,000 $2,955,000

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GIS Data for Watershed Managers $195,000 $195,000 Park Operations and Maintenance $6,235,000 $6,235,000 Water Quantity $495,000 $495,000 Animal Feeding Operations $1,320,000 $1,320,000 Water Supply Appropriation $500,000 $500,000 Geological and Water Survey $200,000 $200,000

Total Environment First Appropriations $28,325,000 $28,325,000

NON-GENERAL FUND Fish and Wildlife Operations $43,147,993 $43,147,993 Groundwater Fund $3,455,832 $3,455,832 UST Administration Match $200,000 $200,000 Snowmobile Transfer to Fish and Wildlife $100,000 $100,000

Total Non-General Fund Appropriations $46,903,825 $46,903,825

TOTAL $104,141,132 $104,141,1322 Motion was made by Nancy Couser to approve the agenda item as presented. Seconded by Gene VerSteeg. Motion carried unanimously


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STATE OF IOWA PUBLIC DRINKING WATER PROGRAM 2015 ANNUAL COMPLIANCE REPORT Diane Moles, Executive Officer of the Water Quality Bureau, presented the following item. The Department submitted the State of Iowa Public Drinking Water Program 2015 Annual Compliance Report to the Environmental Protection Commission for information purposes. The Safe Drinking Water Act (SDWA) Amendments of 1996 require the Department to issue an annual report of the SDWA violations in the state. This report fulfills the reporting requirement in Iowa for the 2015 calendar year. It was prepared by the Department’s Water Supply Engineering & Operations Sections in the Water Quality Bureau of the Environmental Services Division. The report contains a summary of the program, a description of the requirements that systems must meet, the year’s violation statistics, and the list of the systems with each health-based standard or major monitoring or reporting violation incurred during the year. The photographs in the report were from Drinking Water State Revolving Loan Fund projects that were completed during the year. The maps depict the public water supply system universe in Iowa and the locations of the systems that incurred the health-based standards and major monitoring and reporting violations. Development of the report was accomplished through the use of the state water supply database. It was provided to EPA on July 1st, which met the deadline. An electronic copy has also been provided to the members of the SDWA Technical Advisory Group, the State Library, and is available on the IDNR’s website. 2015 Report highlights: • There were 1,878 regulated public water systems in Iowa that served water at least one day during the

year, serving more than 2.91 million people. • There were no reported waterborne illnesses or deaths from Iowa public water supply systems in

2015. • There were 205 violations of health-based standards at 103 public water supply systems serving

193,090 people. On a percentage basis, 94.5% of the systems were in compliance with all health-based standards and 91.5% of the population was served water with no violations of health-based standards.

• There were 673 violations of major monitoring and reporting requirements at 315 public water supply systems serving 170,790 people. The system compliance rate was 83.2% and 94.1% of the population of Iowa’s systems were served by systems with no major monitoring or reporting violations.

• For the health-based standards, 73% of the violations are attributed to three contaminants: coliform bacteria, combined radium 226 & 228, and nitrate nitrogen.

• There were 6 systems with a total of 11 acute E. coli bacteria maximum contaminant level violations. • There were 16 violations of the nitrate standard at 10 systems. • There were 5 systems that received a violation for failure to obtain a certified operator during the

year. • There were 27 community systems that failed to prepare and distribute their annual consumer

confidence report in 2015, which is a 97.5% compliance rate.

INFORMATION

September 2016

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WATER SUPPLY: WATER USE & ALLOCATION ANNUAL PERMIT FEE Diane Moles, Executive Officer, of the Water Quality Bureau presented the following item. The Commission was asked to approve the Water Use and Allocation Program annual permit fee of $66.00 per permit for SFY 2017. Background - Water use permits are required of any person or entity using 25,000 gallons of water in a single day during the year, and are issued for a period of up to 10 years. Previously, appropriations from the General Fund were used to fund the water allocation and use permits program. During the 2008 legislative session, the legislature authorized the department to collect up to an additional $500,000 in fees each fiscal year. Iowa Code §455B.265(6) requires the fees to be based on the Department’s “reasonable cost of reviewing applications, issuing permits, ensuring compliance with the terms of the permits, and resolving water interference complaints.” There are two types of fees in the Water Use and Allocation Program: an application fee and an annual permit fee. This request is for the determination of the annual fee for SFY 2017. The annual fee rule, adopted in 2009, is summarized below (IAC 567-50.4(2)“b”): • Each year, the Commission is asked to set the annual fee based on the budgeted expenses for that year

minus the amount of any unused funds from the previous year and any general fund appropriations. • The department reviews the annual permit fee each year and adjusts the fee as necessary to cover all

reasonable costs required to develop and administer the water use permitting program. • The annual fee is based on the number of active permits. • Each permit holder pays the same annual fee. • The fee is not prorated and is nonrefundable. • The department requests Commission approval of the amount of the annual fee no later than September 30

of each year. • The department provides an annual fee notice to each permittee at least 60 days prior to the fee due date. • The annual fee due date is December 1st; 60 days prior is October 1st. There is no annual fee required for either a water storage permit (permitted for the life of the structure) or a minor nonrecurring water use registration (one-year permit duration). The annual permit fee was $135.00 in the first two years, $95.00 in SFY 2012, and $66.00 in SFY 2013 and SFY 2014, and $99.00 in SFY 2015 and SFY 2016.

SFY 2017 Budget - The worksheet included with this agenda brief illustrates the actual expenditures in SFY 2012 – 2016 and the budgeted amounts for SFY 2016 and SFY 2017. The final accounting figures for SFY 2016 are not expected to change. In addition to accomplishing the normal work activities of the program, the budget in 2017 includes the following: • Continuing with the well-matching efforts for the various aquifers, • Increase use of the on-line database by permittees for annual use reports and fee payment, and • Continue to implement the Jordan aquifer management strategies, working with affected systems that are

near Tier 2-3 levels. Fee Analysis - At the Water Use Stakeholder meeting on July 28, 2016, the program’s activities and budget were reviewed. A $66.00 annual water use permit fee was proposed for SFY 2017, which is a reduction of $33.00 from the SFY 2016 annual fee. The stakeholder members participating in the meeting concurred. Motion was made by Gene VerSteeg to approve the agenda item as presented. Seconded by LaQuanda Hoskins. Motion carried unanimously


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CLEAN WATER AND DRINKING WATER STATE REVOLVING LOAN FUND – SECOND QUARTER UPDATES TO THE FY 2017 INTENDED USE PLANS Patti Cale-Finnegan, SRF Coordinator of the Water Quality Bureau presented the following item. Commission approval was requested for the second quarter updates to the Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) Intended Use Plans (IUPs) for FY 2017 (July 1, 2016 – June 30, 2017). The State Revolving Fund programs are authorized through federal legislation and administered by the State of Iowa under the oversight of the U.S. Environmental Protection Agency. The CWSRF finances publicly owned wastewater and sewer facilities, storm water management for water quality, and nonpoint source control practices to keep pollution out of Iowa’s water. The DWSRF covers water system projects, including source water, treatment, storage, and distribution and transmission, as well as consolidation and connections. The Iowa SRF is operated through a coordinated partnership between the Department of Natural Resources (DNR) and the Iowa Finance Authority (IFA). DNR administers the environmental and permitting aspects of the programs, with IFA providing financial assistance including loan approval and disbursements. Other important partners include the Iowa Department of Agriculture and Land Stewardship, Soil and Water Conservation Districts, county sanitarians, participating lenders, and others. The FY 2017 IUPs include plans of action for the SRF programs, including goals and objectives, an analysis of current and projected financial capability, financial management strategies, the project priority lists, discussion of set-aside programs and efforts, and planned uses for administrative accounts. The IUPs are developed and updated quarterly, in June, September, December, and March or more often as needed. Each draft IUP and update is released for public comment, and then presented for approval to the Commission. A public meeting was held August 11, 2016 to receive comments on the proposed IUP updates. There were no attendees. The written comment period closed on August 18, 2016. There were no written comments. The Sources and Uses tables for both CWSRF and DWSRF show that funds are available or obtainable to provide anticipated disbursements. The IUPs will be updated quarterly during FY 2017. Patti Cale-Finnegan answered questions from Commissioners regarding the loan forgiveness program and qualifications. Motion was made by Gene VerSteeg to approve the agenda item as presented. Seconded by Nancy Couser. Motion carried unanimously


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CONTRACT WITH I & S GROUP, INC. FOR REVISING THE IOWA STORM WATER MANAGEMENT MANUAL Joe Griffin, Environmental Specialist Senior of the Water Quality Bureau, presented the following item. Commission approval was requested for a 2.5 year contract with I & S Group, Inc. The estimated contract start date is October 17, 2016 and the estimated contract end date is April 17, 2019. The total amount of this contract shall not exceed $31,500. Funding Source: This contract will be funded from storm water permit fees. Background: The Iowa Storm Water Management Manual (ISWMM) was originally written under contract with Iowa State University’s Center for Transportation Research and Education in 2004-2006. It has since been updated once and this contract is to update it again. Purpose: The parties propose to enter into this Contract for the purpose of retaining the Contractor to write two new chapters and revise three existing chapters of the ISWMM. Contractor Selection Process: I & S Group, Inc. was chosen through a competitive bidding process. Contract History: The original, FY04 contract to write 17 chapters of the ISWMM was for an amount not to exceed $125,342.00, of which $105,609.53 was paid. This contract had no amendments. The FY13 contract to write two new chapters and amend two existing chapters was for an amount not to exceed $9,998.00, of which $7,498.50 was paid. There were two amendments to this contract including an amendment to terminate. Motion was made by Chad Ingels to approve the agenda item as presented. Seconded by Cindy Greiman. Motion carried unanimously


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CONTRACT WITH THE UNITED STATES GEOLOGICAL SURVEY FOR STREAM GAGING AND REAL-TIME WATER QUALITY SUPPORT Roger Bruner, Water Monitoring Supervisor of the Water Quality Bureau, presented the following item. Commission approval was requested for a one year-service contract with the United States Geological Survey (USGS) in Iowa. The contract will begin on October 1, 2016 and terminate on September 30, 2017. The total amount of this contract shall not exceed $ 310,520.00. Funding Source: This contract will be funded through Environment First funds through cost center HB8A under the authority of Iowa Code section 455B.103. Background: Water quantity and quality information is of key importance to understanding ecosystem health, flood potential and the level of risk to humans within and beyond the watershed. Surface-water flow information in Iowa is collected on a nearly continuous basis at 128 stream gaging stations (23 supported in this agreement), and real-time water-quality sensors (8 sites supported in this agreement) across Iowa. Lastly, the ability to estimate surface-water flow at ungaged sites in Iowa is critical for estimating pollutant loading and flux, Use Attainability Assessments and is needed by State Nutrient Reduction Strategy. The completed applications StremStat and StreamEst will be maintained and will be made available to the public and used by the Department and others to support management and planning decisions. Purpose: The parties propose to enter into this Contract for the purpose of retaining the Contractor to provide: gage data on streams, real-time nitrate sensor operation and maintenance for the state. Contractor Selection Process: The United States Geological Survey in Iowa was chosen for this project because of their expertise in water resource measurement and analyses. Contract History: Since 1973 the USGS has been cooperating with the State to monitor stream flows. Since 2000 the USGS has cooperated with the Department to collection quality information and to update stream flow statistics. Motion was made by Joe Riding to approve the agenda item as presented. Seconded by Ralph Lents. Motion carried unanimously


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CONTRACT WITH THE STATE HYGIENIC LABORATORY AT THE UNIVERSITY OF IOWA FOR AMBIENT GROUNDWATER ANALYTICAL SUPPORT Roger Bruner, Water Monitoring Supervisor of the Water Quality Bureau, presented the following item. Commission approval was requested for a one year-service contract with the State Hygienic Laboratory at the University of Iowa. The contract will begin on October 1, 2016 and terminate on June 30, 2017. The total amount of this contract shall not exceed $ 88,333.20. Funding Source: This contract will be funded through Environment First funds through cost center HB8A under the authority of Iowa Code section 455B.103. Background: The groundwater monitoring program was re-designed in 2012 and will continue as a part of the ambient monitoring tasks for the Department. The data collected in this contract will provide the data necessary to evaluate baseline conditions and long-term trends in groundwater quality. The data will be made available to the public and used by the Department to support management and planning decisions. Purpose: The parties propose to enter into this Contract for the purpose of retaining the Contractor to provide: sampling and analytical assistance to DNR. Contractor Selection Process: DNR is allowed to contract with the University of Iowa pursuant to Iowa Code section 455B.103. The University of Iowa was chosen for this project because of their expertise in water quality sampling and analyses. Contract History: Since 2012 a contract with the State Hygienic laboratory has been executed to analyze groundwater samples submitted by selected municipal water operators. The Department has coordinated the sample collection with Municipal water operators who volunteer their time to collect the samples and ship the samples to SHL. Prior to 2006 the Department contracted with the USGS to provide both sample collection and analyses. Motion was made by Cindy Greiman to approve the agenda item as presented. Seconded by Chad Ingels. Motion carried unanimously


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CONTRACT AMENDMENT WITH THE USDA ANIMAL RESEARCH SERVICE/USGS LABORATORY AT MARSHFIELD WISCONSIN FOR AMBIENT GROUNDWATER ANALYTICAL SUPPORT Roger Bruner, Water Monitoring Supervisor of the Water Quality Bureau, presented the following item. Commission approval was requested for an amendment to 12 month-service contract (16-ESD-WQB-JPALM-0002) with the ARS/USGS Laboratory at Marshfield Wisconsin. The amendment will begin on October 1, 2016 and terminate on March 31, 2017. The total amount of this amendment shall not exceed $ 49,500.00. The total amount of the original contract and amendment would not exceed $ 82,000.00. Funding Source: This amendment will be funded through Environment First funds through cost center HB8A under the authority of Iowa Code section 455B.103 and a USEPA Section 106 grant. Background: The groundwater monitoring program was re-designed in 2012 and will continue as a part of the ambient monitoring tasks for the Department. The data collected in this contract will provide the data necessary to evaluate baseline conditions and long-term trends in groundwater quality. The data will be made available to the public and used by the Department to support management and planning decisions. A contract currently exists with this agency and this amendment will increase the value of that contract above $25,000. Purpose: The parties propose to enter into this amendment for the purpose of retaining the Contractor to provide: specialized analytical assistance to DNR. Contractor Selection Process: DNR is allowed to contract with the governmental agencies like the ARS/USGS laboratory pursuant to Iowa Code section 455B.103. The ARS/USGS laboratory was chosen for this project because of their expertise in specialized water quality analyses. Contract History: This is the first contract for this specialized analysis for the Ambient Groundwater Program. Motion was made by Ralph Lents to approve the agenda item as presented. Seconded by Joe Riding. Motion carried unanimously


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NOTICE OF INTENDED ACTION – CHAPTER 61 – WATER QUALITY STANDARDS (COPPER CRITERIA UPDATE) Jon Tack, Bureau Chief of the Water Quality Bureau, presented the following item. Commission approval was requested to initiate the rulemaking process to gather public comments. The proposed rule is necessary to create additional flexibility for wastewater dischargers by adding the option to use the Biotic Ligand Model (BLM) or Water-Effect Ratio (WER) in the determination of site-specific copper criteria. Copper is found in most municipal wastewater effluents due to the corrosion of copper plumbing and it is expensive to remove. The BLM accounts for site-specific variations in the toxicity of copper due to actual levels of copper bioavailability in a given waterbody. The adoption of a Copper BLM criterion will reflect site-specific Iowa surface water conditions. The BLM accounts for several water chemistry parameters to predict the concentration of copper that would actually result in toxicity to an organism in a given waterbody. The following water chemistry parameters have an impact on copper toxicity due to elevated levels of copper: Temperature, pH, Dissolved Organic Carbon, Calcium, Magnesium, Sodium, Potassium, Sulfate, Chloride and Alkalinity. An Implementation Procedure for Biotic Ligand Model-Based Copper Criteria was developed for site-specific data collection and it is incorporated by rule-reference. The WER method allows permittees to take into account the difference between the toxicity of a metal measured in laboratory water versus the toxicity of the metal measured in ambient water of the discharge site. The WER method allows facilities to calculate a ratio between the two measured toxicity levels and use it to adjust the existing copper criteria shown in IAC 61.3(3), Table 1. The proposed changes are protective of the water quality and allow permittees the flexibility to use the existing copper criteria and the WER or the ability to use the BLM to generate copper criteria that reflect site-specific water characteristics of the receiving waterbodies for point source discharges. Motion was made by Nancy Couser to approve the agenda item as presented. Seconded by Ralph Lents. Motion carried unanimously


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ADOPTED AND FILED CHAPTER 100 – SCOPE OF TITLE – DEFINITIONS – FORM – RULES OF PRACTICE, CHAPTER 101 - SOLID WASTE COMPREHENSIVE PLANNING REQUIREMENTS, AND CHAPTER 111 – ANNUAL REPORTS OF ENVIRONMENTAL MANAGEMENT SYSTEMS Leslie Bullock Goldsmith, Program Planner of the Land Quality Bureau, presented the following item. The Commission was requested to approve this Adopted and Filed rule that amends 567 IAC Chapters 100, 101, and 111. Notice of Intended Action was published in the Iowa Administrative Bulletin as ARC 2630C on July 20, 2016. A public hearing was held on August 9, 2016 in the Wallace State Office Building. The Department of Natural Resources (Department) also accepted written comments through August 9, 2016. The Department did not receive any comments. The rule amendments:

• Move certain definitions from Chapter 101 to Chapter 100. • Make minor corrections to Chapter 101 for consistency with the applicable state statutes. • Rescind rule 567—101.3(455B,455D) pertaining to the state’s waste management hierarchy and replace all

references to rule 567—101.3(455B,455D) with references to Iowa Code section 455B.301A. • Amend rules 567—101.6(455B,455D) and 567—101.7(455B,455D) and rescind subrule 101.13(8) to reflect

recent legislative changes to Iowa Code section 455D.3 regarding required solid waste management techniques for planning areas that fall below the 25 percent waste volume reduction goal. See 2013 Iowa Acts, House File 225, signed by Governor Branstad on March 28, 2013.

• Remove the waiver in subrule 101.7(3) that exempts from the state tonnage fee waste generated during a declared disaster. The Iowa Code does not give the Department the authority to issue this waiver.

• Rescind rules 567—101.10(455B,455D) and 567—101.11(455B,455D), which, in effect, will remove the requirement for local governments to complete the Municipal Solid Waste and Recycling Survey and accompanying forms.

• Adopt new paragraph 101.13(2)“k” in order to recognize that annual reporting efforts of planning areas and service areas that are designated as Environmental Management Systems (EMS) under Iowa Code chapter 455J meet the comprehensive plan update requirements in subrule 101.13(2).

• Adopt an updated definition of “comprehensive plan update” to reflect the 2009 amendments to Chapter 101, such that in the definition of “planning cycle,” the length of time between the due date of each comprehensive plan was extended from three years to five years. The current definition of “comprehensive plan update” requires planning agencies to incorporate a proposed course of action for the “next two planning cycles” (10 years), which has proven to be too long to allow for accurate planning. As such, the new definition requires the “comprehensive plan update” to address only the next planning cycle (5 years). Additional revisions have been incorporated throughout the proposed amendments to meet this objective. This rule making reflects legislative changes to the Iowa Code and encompasses the comprehensive

five-year review of rules that the Department is currently conducting pursuant to Iowa Code section 17A.7(2). The changes eliminate inconsistencies with the Iowa Code, remove redundant reporting requirements, eliminate unnecessary and obsolete language and make corrections to Iowa Code references, thus simplifying the rules of the Commission and making them easier to use and understand. Motion was made by Joe Riding to approve the agenda item as presented. Seconded by Cindy Greiman. Motion carried unanimously


September 2016

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ADOPTED AND FILED – AMENDMENTS TO FLOOD PLAIN MANAGEMENT RULES TO STREAMLINE CERTAIN DEVELOPMENT TYPES Ken Bouma, Program Planner of the Land Quality Bureau, presented the following item. Pursuant to the authority of Iowa Code section 455B.263, the Department of Natural Resources requested the Environmental Protection Commission (Commission) to amend Chapter 70, “Scope of Title—Definitions—Forms—Rules of Practice,” Chapter 71, “Flood Plain or Floodway Development—When Approval Is Required,” and Chapter 72, “Criteria for Approval,” Iowa Administrative Code as set out below. The amendments change the criteria for the construction of bridges, road embankments, and culverts in a flood plain. Oftentimes, to construct bridges and other structures in a flood plain, the Iowa Department of Transportation (IDOT) and other contractors have had to apply for waivers or variances from the Commission’s rules, a process which could be time-consuming and costly. In response to this concern, the rules have been reviewed and a determination made that certain portions of existing rules are redundant or unnecessary, and changes could be made that would allow for a higher percentage of compliance with rules. The proposed amendments will reduce the need for these contractors to seek waivers and variances. Equally important, the amendments will not sacrifice public safety. The amendments also add exemptions to the flood plain development permit requirements for certain activities, such as excavations installed for conservation practices, and for the installation of signs, utility poles and other similar structures. These exemptions were developed in cooperation with stakeholders such as electric utilities and the Natural Resources Conservation Service (NRCS). The amendments also modify the waiver and variance provision in the flood plain rules so that the provision is consistent with the Iowa Code. The amendments make minor changes to Chapters 70, 71 and 72 to update definitions, references to Iowa Code sections, forms, and agency contact information. A public hearing was held on Wednesday, August 10, 2016 at 1 p.m. in Conference Room 2 North, 2nd Floor, Wallace State Office Building, 502 E. 9th Street, Des Moines, Iowa. Three public comment letters were received. A Responsiveness Summary is attached to this brief. Due to the public comments received, clarifying language was added to the definitions of “high damage potential” and “low damage potential” in Chapter 70. Motion was made by Chad Ingels to approve the agenda item as presented. Seconded by Cindy Greiman. Motion carried unanimously


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GENERAL DISCUSSION Upcoming Meetings

• Bill Ehm provided information on the rulemaking process, timelines, and approaches. • Jerah Sheets summarized the educational and business meeting logistics for the upcoming

meetings. • Jerah Sheets provided an update regarding the ALJ’s remand to the EPC of the P&J Pork

construction permit. • Jerah Sheets provided advance notice that during the October meeting, the Commission will

determine the 2017 meeting dates and locations.

INFORMATION Lunch Break

REFERRAL TO THE ATTORNEY GENERAL - J.S. PROPERTIES, L.L.C. (J.S. PROPERTIES) AND TERRY ANDERSON Kelli Book, Attorney for the DNR’s Legal Services Bureau, presented the item. To her aid was Tom Wuehr, from DNR who runs the DNR’s asbestos program. The Department requested referral of Terry Anderson and his company J.S. Properties for numerous asbestos violations in connection with a demolition of an apartment building in Oskaloosa, Iowa.

Inhalation of asbestos fibers can cause lung disease, asbestosis and cancer. There is no known safe level of exposure to asbestos. Because of the seriousness of asbestos exposure, federal regulations are in place to regulate the removal and disposal of asbestos during demolition of commercial buildings. DNR has adopted the federal regulations for asbestos and is the agency responsible for ensuring that asbestos is properly removed and handled during demolition projects in the state.

J.S. Properties owned an apartment building in Oskaloosa, Iowa. The apartment building was a 15,000 square foot two story building. J.S. Properties purchased the building in October 2015.

In November 2015, DNR received a complaint that the apartment building was being demolished and dust was blowing around. The complainant was concerned the building had asbestos in it. Prior to the inspection DNR confirmed with Terry Anderson that he was demolishing the building. Mr. Wuehr contacted Mr. Anderson and asked him to stop the demolition. Mr. Anderson stated he was conducting the demolition on his own and that most of the building had already been demolished and the debris had been disposed of at the landfill as regular demolition waste. Mr. Anderson told Mr. Wuehr that no asbestos abatement had occurred prior to the demolition. He stated the City had previously conducted an asbestos inspection and there was virtually no asbestos in the building. Mr. Anderson suggested Mr. Wuehr obtain the report from the City.

Mr. Wuehr followed up with the City of Oskaloosa and was provided a copy of the inspection done in 2014, not conducted as part of this demolition. The report indicated that the building had asbestos containing material throughout the building ranging from 1.2% Chrysotile asbestos to 91.5% Chrysotile asbestos. The report indicated that the building contained over 10,000 square feet of regulated asbestos containing material and that the material must be removed by a qualified asbestos abatement firm. There is no evidence this material was removed prior to the demolition.

September 2016

15

Mr. Wuehr conducted an inspection at the building site; the building had been removed. Mr. Wuehr observed damaged steam pipes with air cell insulation on the ground in the area where the building was. The laboratory sample indicated the insulation contained 40% Chrysotile asbestos.

In December DNR issued a Notice of Violation letter Mr. Anderson for the asbestos violations discovered during the investigation. The letter informed Mr. Anderson that further enforcement may be pursued.

Mr. Anderson admitted that he demolished the building. J.S. Properties and Mr. Anderson failed to submit a notification for the demolition of the building. They also failed to conduct a thorough asbestos inspection prior to the demolition activities. J.S. Properties and Mr. Anderson failed to remove all asbestos containing material prior to demolition activities. Mr. Anderson admitted that he did not remove any asbestos prior to the demolition and Mr. Wuehr found asbestos containing material on the ground in the area of the building; J.S. Properties and Mr. Anderson failed to keep all asbestos containing material adequately wet – Mr. Wuehr found dry asbestos containing material on the ground in the area of the building. There was not a trained supervisor on site during the demolition. And J.S. Properties and Mr. Anderson failed to properly seal all asbestos containing material as Mr. Wuehr found dry asbestos containing material on the ground in the area of the building. The violations warrant referral to the Attorney General’s Office and the DNR asked that the Commission vote to refer J.S. Properties and Mr. Anderson to the Attorney General’s Office for further enforcement. Kelli Book provided a copy of the City of Oskaloosa report for the Commissioners review. Terry Anderson shared with the Commission he is not in dispute of items presented but wanted to share his viewpoint of the scenario. The City of Oskaloosa approached him regarding the abandoned building. The City did not have an interest in owning the site but also didn’t want it to remain abandoned. The City deeded the site over to him. The City had a report developed by Terracon and Mr. Anderson called Jason at Terracon to better understand the report. Jason told Mr. Anderson there wasn’t enough asbestos to worry about and Mr. Anderson could demo the building on his own without any employees. Mr. Anderson shared that Wyatt Russell from the City contacted the DNR and verified the accuracy of Terracon’s assessment and the DNR confirmed Jason’s statements. With these two confirmations, Mr. Anderson took ownership of the building and begun demolition. Mr. Anderson shared the building came down quicker than expected. He pulled one support and the entire building fell down. He had to shut down the operation because the red clay title was so old it turned to dust during the fall. The next time when he continued demolition, he had to shut down because it started raining. Another time he was working the site, he had to shut down because the red tile dust was so thick. The day Mr. Wuehr called, Mr. Anderson had obtained water to wet down the site to control the dust. The following day, even with the rain, the demolition generated enough dust to shut down again. The fire department was supposed to wet down the site but the chief was on vacation so the city sent staff from the water department to set up a meter. City staff, councilmen, and the city attorney stopped by the site during the demolition to take photos and ensure the building was coming down. Mr. Anderson shared most everything in the building was stripped out by the time he took ownership and begun demolition. The strip out included the boilers, steam pipes, and radiators. Regarding the steam pipe found by Mr. Wuehr, Mr. Anderson believes Mr. Wuehr found it honestly even though he thought they got it all out. Mr. Anderson shared there was dust and when the dust was too much, he shut down the demolition. The initial dust came from the roof as the building fell to the ground in less than an hour. The site sits next to a senior center and many of the residents were outside watching the demolition. He tried to control the dust. Mr. Anderson believed the Terracon inspector that there wasn’t enough asbestos to need to test. He felt the building sat vacant and wasn’t identified as a commercial property. He therefore believed residential demolition rules applied which allowed him to take it down without employees.

September 2016

16

Commissioners focused their discussion on the City of Oskaloosa report and laboratory samples testing higher than 1% which is the threshold for determining abatement. Commissioners gathered information on the differences in law and procedures for commercial and residential asbestos removal and demolition. Commissioners attempted to determine the level of responsibility the City of Oskaloosa would have for this case. Mr. Anderson felt he did his due diligence over 4-6 weeks by reviewing the report, talking to Terracon about the report, verifying with the city the residential and not commercial status of the building, and having the city confirm with the DNR Terracon’s assessment of demolition. He typically hires work like this out but due to the assessment, he did not hire employees and conducted the demolition himself. He is not trying to hide anything, he thought he was doing everything correctly. Motion was made by Ralph Lents to refer Terry Anderson and his company J.S. Properties to the Attorney General. Seconded by Joe Riding. Chad Ingels-nay, Joe Riding-yea, Bob Sinclair-absent, Ralph Lents-yea, LaQuanda Hoskins-yea, Nancy Couser-nay, Gene Ver Steeg-nay, Cindy Greiman-yea, and Mary Boote-nay. Motion failed.

NO REFERAL TO THE ATTORNEY GENERAL

REFERRAL TO THE ATTORNEY GENERAL – SWISS VALLEY FARMS COOPERATIVE Anne Preziosi, Attorney for the DNR’s Legal Services Bureau, presented the item. To her aid from the DNR were Chris Roling, Brian Hutchins, Mark Fields, Rick Martens, and Joe Sanfilippo. The DNR seeks referral of Swiss Valley Farms to the Attorney General’s Office. Swiss Valley was not in attendance to present its case. Swiss Valley representatives contacted Anne Preziosi September 19, 2016 to inform her they would not be attending the EPC meeting. Anne Preziosi summarized the materials provided to the Commission including a timeline history of the DNR interactions with the company. Throughout the interactions with the company, DNR stressed the importance of using the baghouse for compliance with air quality standards. The company chose not to utilize the technology by removing the baghouseeven with a $21 million dollar expansion of the facility. The DNR has worked with the company on retrofit and consent order options without success. Anne Preziosi and Catharine Fitzsimmons provided information to the Commission on the reasoning for the long time frames between inspections. With over 8,000 minor source emissions and EPA funding for 3 staff for the entire State of Iowa, regular inspections are not possible. Complaints of a facility are prioritized for inspection. Commissioners received information on how baghouses clean the air, are maintained, and the life cycle of the equipment. Cleaning the air reduces the fine particulate that can be impact human health.

September 2016

17

Director Gipp shared with the Commission Congress passed the Clean Air Act and the State of Iowa is responsible for safe air to breath. Swiss Valley removed the baghouse at some point and have refused for a couple years to sign a consent order to regain compliance but moved forward with a $21 million expansion that doesn’t address the current problem. Motion was made by Joe Riding to refer Swiss Valley to the Attorney General. Seconded by LaQuanda Hoskins. LaQuanda Hoskins-yea, Nancy Couser-yea, Gene Ver Steeg-yea, Cindy Greiman-yea, Chad Ingels-yea, Joe Riding-yea, Bob Sinclair-absent, Ralph Lents-yea, and Mary Boote-yea. Motion passes.

REFERRED TO ATTORNEY GENERAL

Chairperson Boote adjourned the Environmental Protection Commission meeting at 2:05 p.m., Tuesday, September 20, 2016.

The Iowa Nutrient

Reduction Strategy

Contact:Laurie Wissler Nowatzke

[email protected]

Background 1997 – U.S. Environmental Protection Agency established task force to address the Gulf of Mexico Hypoxia

2011 – Stoner Memo urged Mississippi River states to develop plans to reduce nutrient loss by 45%

2013 – Iowa releases the Iowa Nutrient Reduction Strategy (NRS)

NRS Goal:45% reduction of Iowa’s contribution of nitrogen (N) and phosphorus (P) to the Gulf of Mexico.

1

How do we measure Iowa’s progress?

A team of representatives from Iowa Department of Natural Resources, Iowa Department of Agriculture and Land Stewardship, and Iowa State University are developing indicators for measuring efforts and change.

The NRS logic model (above) outlines changes that will ultimately lead to improved surface water quality.

Progress reports are released annually, and can be accessed at www.nutrientstrategy.iastate.edu/documents

2

Farmer awareness of the NRS

2015 Outreach Efforts

Number of Events

Average Attendance

Total Reported

Attendance

Outreach— Fairs, Tours, and Community Education

98 140 14,375

Field Days 57 41 4,159

Workshops 19 34 1,172

Conferences 4 291 1,281

Total 178 20,987

2016 Annual Report Highlights

Approximately $10 million more in Nutrient Reduction Strategy (NRS) funding was reported by partner organizations for the 2016 reporting period than in 2015. Future analyses will explore the future availability of these programs and the capacity for accelerated NRS implementation.

For the 149 wastewater treatment facilities currently listed in the NRS to receive new permits and conduct feasibility studies to explore improved technology and nutrient removal systems, 86 permits have been reissued. Twenty facilities have submitted feasibility studies. Sixty-three facilities remain.

In the 2016 reporting period, 178 face-to-face outreach and education events were conducted by partner organizations. These events brought in approximately 21,000 attendees in total.

Early analyses of a new survey project showed a potential increase in knowledge of the NRS, when compared to an identical question asked in a 2014 survey. While these two surveys were conducted with different sampling techniques and should not be compared directly, the 5-year NRS farmer survey project will provide a better understanding of how this NRS knowledge affects farmers’ attitudes and behavior related to nutrient management and water quality.

3Presented to the Iowa Environmental Protection Commission20 Sep 2016

Cover crop adoption through cost-share programs has increased dramatically since 2011, showing some promise for further adoption. In-field nutrient management practices are used by farmers outside of government financial programs. Efforts are underway to establish new protocols for collecting these data and painting a more complete picture of conservation in Iowa.

Addressing data challengesThe data provided through cost-share programs do not pain the whole picture of conservation in Iowa. Inconsistent reporting and the inability to account for practices adopted with cost-share funding are among the current challenges of tracking progress. For information on efforts to address these challenges, see page 23 of the 2016 NRS Annual Progress Report.

Nutrient Load Reduction from Select Conservation Practices (pounds)

2014 2015

Nitrogen - Total 3,830,000

Cover Crops 2,356,000

CREP wetlands 1,474,000

Bioreactors 6,000

Phosphorus - Total 134,947 217,884

Cover Crops 112,518 196,967

No-till 10,622 14,229

Reduced till 345 7

Extended rotation 1,463 6,680

Phosphorus—annual CRP fluctuations†

-104,134 +56,311

The NRS calls for nonpoint sources statewide to reduce nitrogen loss by 126,000 tons and phosphorus loss by 4,800 tons.

Statewide nitrogen and phosphorus load reductions were estimated from the practices conducted through cost-share programs.

Only selected practices could feasibly be incorporated into the calculations at this point, but improved practice data collection and development of appropriate units for the data will improve future calculations.

A report on statewide surface water monitoring was released in September 2016. “Stream water-quality monitoring conducted in support of the Iowa Nutrient Reduction Strategy” documents Iowa’s known water monitoring efforts. This report is a step towards identifying opportunities and gaps in surface water monitoring efforts for the purpose of measuring progress of the NRS. Access at www.nutrientstrategy.iastate.edu/documents .

Ecological Assessment of Iowa Farmed Wetlands (2011-2014)

Project Background, Goals and Objectives

Approximately 95% of nearly 4 million acres of wetlands located in Iowa’s portion of the Prairie Pothole Region (PPR, Des Moines Landform Region) are drained and farmed primarily for row crops.

Project goal was to inform decisions related to drainage, wildlife management, water quality, and watershed health in the PPR.

Monitoring Design

8 Townships were randomly selected and stratified from North to South for study (see map above).

The study covered a range of hydrologic conditions from drought (2011-2012) to very wet (2013).

Partnerships with the landowners were critical to the success of the project.

Project objectives were to determine the quality of farmed (drained) wetlands in Iowa and to assess the health of these ecosystems with respect to providing habitat for water birds, invertebrates and amphibians.

Funding came from EPA through a State Wetland Grant. Total project $ 484,470.

Project Elements:

Water Bird Survey (ISU lead) o Roadside Survey of observed birds

from snowmelt to migration onset. Groundwater Level and Quantity (UI

Geological Survey lead) o Eight shallow monitoring wells

instrumented with continuous water level probes.

o Samples analyzed for Common Nutrients (ammonia, Nitrate, Phosphorus).

Amphibian/Macroinvertebrate Survey (DNR lead)

o Visual Encounter Surveys to document amphibian and reptile wetland usage.

Water Quality of Ponded Water (DNR lead) o Ponded water sampled 3x a year:

Pre-planting, Planting, Post-planting

o Samples analyzed for Nutrients (Ammonia, Nitrate, Phosphorus); Pesticides (Herbicides: Atrazine, Acetochlor, etc.; Insecticides: Carbaryl, Chlorpyrifos and Malathion; Neonicotinoids -2014 only).

Photo 1. Ponded water in Iowa’s PPR after a heavy rain. Guy Zenner, Iowa DNR Waterfowl Biologist (Retired).

Waterbird Usage. 2011 (black bars), 2012 (gray), 2013 (black stippled), 2014 (white). Class 1 (0-0.1 ha), Class 2 (0.1-0.25 ha), Class 3 (0.25-0.50 ha), Class 4 (0.5-1.0 ha), Class 5 (>1.0 ha).

Surface water quality in Drained (blue); Reference

(yellow) and Wetland Reserve (green) Wetlands.

Groundwater Quality in Drained Wetlands. Nitrate (NO3-N) and Soluble Reactive Phosphorus (SRP).

Detection Frequency of common pesticides in drained

wetlands. ESA and OXA are degradate products.

Lessons Learned

Spring migrant waterbirds use drained wetlands and wetland size is an important driver (# of species and total visits).

Groundwater contributes to surface water ponding occasionally, but impact is minimal due to widespread subsurface tiling (except for extremely wet periods of landscape-wide saturation).

Shallow groundwater has high concentrations of nitrate (average 16.7 mg/l, maximum 102 mg/l), and to a lesser extent dissolved phosphate (typically less than 0.3 mg/l).

Average nitrate conc. exceeded 10 mg/L in ponded surface water, while Total P was 2.0 mg/L. Herbicides and associated degradate products were detected frequently in temporary ponds.

Concentrations of Acetochlor, Atrazine and neonicotinoids (Clothianidin and Thiamethoxam) were detected at levels that exceeded aquatic life benchmarks for chronic toxicity.

Drained wetlands do not appear to be serving as functioning habitat for breeding amphibians.

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Asbestos Survey

517 BAvenue West Oskaloosa, Iowa

July 17, 2014

Torrocon Project No. 08147059

Prepared for: City of Oskaloosa Oskaloosa, Iowa

Prepared by: Terracon Consultants, Inc.

Des Moines, IA

1"''ilrl'" '""' lrerracon

Env1ronmrnlnl Fncililics (ico11•r:hn1r..1I Mntc•r1.;1I!.

July 17, 2014

City of Oskaloosa 220 South Market Street Oskaloosa, IA 52577

Attn: Mr. Akhllesh Pal, City Engineer P: (641) 673-7472 E: akhllesh [email protected]

Re: Asbestos Survey 517 BAvenueWest Oskaloosa, Iowa Terracon Project No. 08147059

Dear Mr. Pal:

lrerracan

Terracon ConsuHanls, Inc. (Terracon) Is pleased to submft the attached report for the above referenced alte to the City of Oskaloosa. The purpose of this report Is to present the resulls of an asbestos survey conducted on July 2, 2014. The survey was conducted In general accofdance v.ilh our proposal dated June 10, 2014. We undereland this survey was requested due to planned demolition of the building.

Terracon appreciates the opportunity lo provide this servloo to the City of Oskaloosa. If you have questions regarding this report please contact the undersigned at 615-244·3184.

Sincerely, Terrocon Consultants, Inc.

¥-- 14-Tyter R. Puls Project lndusttlal Hygienist

~~u Randy A. Milbrath, CIH Senior lndusttlal Hygienist

Torracon Consultants, Inc. 600 SW Sevonlh St. O.• Molnu , IA ~309 P 515· 244-3164 F 615·244-5249 ttrmon.0011

En1ti1a1in1ental a fJcilitics • GC!oltthrdc11I • Mater1,1ls

lferracon

TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................... 1 1.0 INTRODUCTION .............................................................................................................................. 1

1.1 Reliance ............................................................................................................................. 1 2.0 BUILDING Dl!SCRIPTIONs ....................................................................................... - .................. 1 3.0 FIELD ACTlVlTIES ......................................................................................................................... 2

3. 1 Visual Assessment ............................................................................................................. 2 3.2 Physical Assessment ......................................................................................................... 2 3.3 Semple Collection ...... ................................................................. ....................................... 2 3.4 SampkJ Analysis ......................... ....................... ................................................................. 3

4.0 REGULATORY OVERVIEW ....... ................................................................................... ................. 3 6.0 FINDINGS AND RECOMMENDATIONS ........................................................................................ 4 6.0 LIMITATIONS/GENERAL COMMENTS ................................................. ....................................... 6

APPENDIX A IDENTIFIED ASBESTOS-CONTAINING MATERIALS BY HOMOGENEOUS AREA (HA)

APPENDIX B ASBESTOS SURVEY SAMPLE LOCATION SUMMARY

APPENDIX C SAMPLE LOCATION DIAGRAM

APPENDIX D ASBESTOS ANALYTICAL LABORATORY DATA

APPENDIX E LICENSES AND CERTIFICATIONS

APPENDIX F PHOTOGRAPHS

Responsive a Resourcoful • Reliable

lferracon EXECUTIVE SUMMARY

Terracon Consuttants, Inc. (Terracon) conducted en asbestos survey of the building located at 517 B Avenue West, Oskaloosa, Iowa. We understand the survey was requested due to planned demofitlon of the on-site building. The purpose of this survey was to sample and Identify suspect asbestos·containing materials (ACM) and provide Information regarding their Identity, location, condition and approximate quantities, If ldentlfled. The survey was conducted on July 2, 2014 by a team of Asbestos Hazard Emergency Response Act (AHERA) accredited and Stoto of lowo lloonood 03bc3to3 lnspoctore In gcnarel eccordenee with our p<OpoHI dated

June 10, 2014, and the sampling protocols established In United States Environmental Protection Agency (USEPA) 40 Code of Federal Regulations (CFR) Part 763 Subpart E 763, known as AHERA. Terracon collected 39 bulk samples from homogeneous areas of suspect ACM.

The followfng asbestos containing materials were ldentlned as a result of laboratory analysis:

Material Description Material Location Esllmated Quantity•

Black Wood Panel Mastic Unit 2 Dining Room 23051 Unit 2 Livi1g Room 50Sf

Shectrod< Joint Compound Unit 2 OfflC8 Walts 20051 Unl 6 OfflC8 Walls 200Sf

Brown/Yellow Unolaum Floaing Uni 3 Ki!d1en 5051

Uni 4 Dining Room 100Sf Uni 4 Uviog Room 130Sf

Residual Floor Mastic Untt4 OlflC8 95Sf

Unit 4 Bedroom 7051 Unit 4 Entry/Closet 85Sf

Grey Sink Insulation Unlt6 Kitchen 1 Ea 1 'x1' VFT - Gold Rook PaUern Unit 6 Kitchen 50Sf

AlrCell TSI Basement Steam Piping 200Lf Steam TSI Joints Basement Stoam Piping 25Ea Exterior Window Glazing Exterior Windows 36Ea Extorlor Stucco/Pl8'1e< Building Exterior 9,500SI - Foot VFT - Wiyt !loo< tile TSI - thermahyslom Insulation Ea- MC11 U - t.r.oor laet Sf-square 1aet

•estlmatod quantities are based on a cursocy field ovaluation, and eclual quantities may vary slgnlf1Cantly, espedally ACMs that are present in hidden and/or Inaccessible areas not evaluated as part of this survey.

Materials Identified to con:aln asbestos greater than 1 % should be removed by a qualified and lowa-certlRed asbestos abatement firm.

The followfng materials were identified to contain asbestos less than 1.0% by point counting:

Responsive• Rosourceful •Reliable

I

/

llerracan Material Doscrlption Matcrlal Location Estlmalod Quantity•

Unit 1 Offico 9551 Residual Floor Mastic Unft 1 Dini11g Room 100$1

Unll 1 Llvi11gRoom 13051 Unit 1 Bedroom 7051 Brown Woad Panel Mastic Unit 2 Offico 20051 White Texture Plaster Throughout Bulldl11g Wells 20,00051 Vllhite T 8lC!ure Plaster Throughout Building Collings 4,400 Sf 9'lc9" VFT - Brown wlWhlo

Unit 3 Bathroom 80SJ 8pecs

Unit 3 Dining Room 100Sf Residual Floor Mastic Unit 3 Living Room 130Sf

Un• 3 Office 9551 Unit 3 Bedroom 7051 • - lncllos VFT - \Ofnyl l!oor Ulo SI - square fool

Although these materials are not ciassltled as an ACM per the EPA and are not required to be abated prior to renovation or demolition of a building, the renovatlon'demolitlon contractor should be notified that these materials could generate airborne concenlrallons of asbestos so thal he/she can take the necessary precautions lo protect their personnel from potential exposures during worlc-refated activities as per the OSHA standard. Since renoll!ltion/demol tion contractors are typically not equipped or adequately trained to address this potential exposure Issue, we strongly rocommond thal the while texture plaster on ceilings and walls should be removed by a qualified and Iowa-certified asbestos abalemenl firm due to the potential exposure issue this material presents to the renovatlon/demolilion contractOf's employees.

At your request, Terracon can provide a proposal for developing asbestos abatement specifications (project design) and for conducting abatement oversight and visual clearance seMc:es.

Rellablo • Responnlve • Renourcolul

ASBESTOS SURVEY 517 B Avenue West, Oskaloosa, Iowa

Terracon Project No. 08147059 July 17, 2014

1.0 INTRODUCTION

Torrooon Consultants, Inc. (Terracon) r.nnducted an asbestos survey of the building localed at 517 B Avenue West, Oskaloosa, Iowa. The survey was conducted on July 2, 2014 by a team of AHERA accredlled and State of Iowa Mcensed asbestos Inspectors In general accordance Wilh Terracon Proposal No. P08140347 dated June 10, 2014. Interior and exterior building components were surveyed, and homogeneous areas of suspect ACM were visually Identified and documented. Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located In walls, In voids or In other concealed areas. Suspect ACM samples were collected In general accordance with the sampling protocols outlined In USEPA 40 CFR Part 763 Subpart E 763, known as AHERA. Samples were delivered to an accredited laboratory for analysis by Polarized Light Microscopy (PLM).

We understand lhat the oroject service was requested to assess lhe building for asbestos in conjunction \'iilh the proposed demolition. EPA regulation 40 CFR 61, Subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during demolition or renovation activities. The asbestos NESHAP requires that potentially regulated ACM must be Identified, ciassified and quantified prior to planned disturbances.

1.1 Reliance

This report Is for the exclusive use of the City of Oskaloosa (City) for lhe project being discussed. Reliance on this report by olher parties Is prohiblled without written authorization of Terracon and the City. Reliance on this report by the City and all authorized parties will be subject to the terms, conditions, and limltalions stated In the proposal, this report and Terraoon's Agreement for Services. The limitallon of liability denned In Terracon's Agroemenl for Services Is the aggregate limit of Ten·acon's liability to the City.

2.0 BUILDING DESCRIPTIONS

The building, which is lo:ated on a 0.35 acre lot, was previously used as an apartment complex. The structure Is a three-story 15,300 square foot bllllding that was built In 1852. The building was vacant at the lime cf our survey. Photos of lhe building are Included In Appendix F.

Responslvo • Resourceful • Reliable

/ Asbestos Survey 517 B Avenue West• Oslcaloosa, Iowa July 17, 2014 • Terracon Pro)ecl No. 08147059

lrerracan

3.0 FIELD ACTIVITIES

The survey was conducted by Adam Corcoran and Tyler Puls, l\HERA accredited and Stale of Iowa licensed asbestos Inspectors. Coples of Mr. Corcoran's and Mr. Puls' asbestos Inspector licenses are Included in Appendix E. The survey was conducted In general accordance with the sample collection protocols established In USEPA 40 CFR Part 763 Subpart E 763.86, AHERA. A summary of lhe survey activities Is provided In the following subsections.

3.1 Visual Assessment

Survey actlvltlos were Initiated with visual assessments of Interior and exterior areas of the building to ldenmy homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear slmltar throughout In tenns of c.Jlor and texture, with consideration gM!n to the date of appllcaUon. The Interior assessment was limited to visually accessible areas of the buildings.

3.2 Physlcal Assessment

A physical assessment of each HA of suspect ACM was conducted to assess the friabllity and condition of the materials. A friable material Is defined by the USEPA as a material, which can be crumbled, pulverized or reduced to powder by hand pressure when dry. Friabflity was assessed by p/lysfcal!y touching suspect materials.

3.3 Sample Collection

Based on results of the \/fsual assessment, bulk samples of suspect ACM were collected In general accordance with USEPA AHERA sampling protocols. Samples of suspect materials were collected from randomly selected locations In each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealabfe containers and labeled with unique sample numbers using an Indelible marker.

The selection of sample locations and frequency of sampling were based on Terracon's observations end the assumption that like materials In the same area are homogeneous rn content.

Terracon collected 121 bulk samples from 39 homogeneous areas of suspect ACM. A summary of suspect ACM samples collected during the survey Is Included as Appendix B.

Reeponslve • Resourceful • Rollabte 2

Asbestos Survey lrerracan 517 B Avenue Wost • Osl\aloose, Iowa July 17, 2014 • TerrtlCOn Pro.eel No. 08147059

3.4 Sample Analysts

The bulk samples were submitted under chain of custody to International Asbestos Testing Laboratories (IA n) of Mt. Laurel, NJ for analysis by polarized light microscopy with dispersion staining techniques per USEPA methodology 600/R-931116. The percentage or asbestos. whore appllcoblo, was determlnoo by microscopic visual estimation. IATL Is an accredited National Voluntary Laboratory Accreditation Program ((NVLAP) Accreditation No. 101 165-00) laboratory.

4.0 REGULATORY OVERVIEW

The Iowa Department of Natural Resources (IDNR) and Iowa Workforce Development through the Iowa Division of Labor (IDOL) regulate asbestos activities In Iowa. IDNR enforces the Asbestos NESHAP as adopted by reference In Iowa Administrative Code (IAC) 167-23.1(3). The owner or operator must provide IDNR and IDOL with written notification at least 10 working days prior to the commencement of asbestos abatement activilles that wlll disturb regulated asbestos-containing materials (RACM) In amounts greater than or equal to 160 square feet, 260 linear feet or 35 cubic feet.

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the ldentiflcatlon and classification of existing ACM according to fr/ability prior to demolition or renovation activities. Friable ACM Is a material containing more than 1% asbestos that, when dry, can be crumbled, ~ulverized or reduced to powder by hand pressure. Friable ACM Is considered RACM.

The asbestos NESHAP regulaUon classifies ACM as either RACM, Category I non-friable ACM or Category II non-friable ACM. RACM includes friable ACM, along with Category I and Category II non-friable ACM that has become friable, will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder In the course of renovation or demoliUon activities. Category t non-friable ACM are exclusively asbestos-containing paci<ings, gaskets, resilient floor coverings, resiOent floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are non-friable materials other than Category I non-friable ACM that coitaln more than 1% asbestos. Category II non-friable ACM generally Includes, but Is not limled to, cemenlltlous material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

Reaponslvo • Rosourcolul • Rollablc

Asbestos Survey lrerracan 517 B Avenue West • Oskaloosa, Iowa July 17, 2014 • Terracon Project No. 08147059

The IDOL regulates occupational exposure to asbestos under IAC 875-10 and asbestos removal and encapsulation activities under IAC 875-155. IAC 875-10 adopts the Occupational Safety and Health Administration (OSHA) Asbestos standard for construction (29 CFR 1926.1101) by reference. The OSHA standard requires that employee exposure to airborne asbestos fibers must be maintained at or below 0.1 fiber per cubic centimeter of air (0.1 flee) as an 8-hour time weighted average (TWA) and must not exceed 1.0 flee of air over a 30-minute time period known as an excursion limit (EL). The TWA and EL are known as OSHA's permissible exposure limits (PELs). The OSHA standard classifies construction and maintenance activities that could disturb ACM, and specifles work practices and precautions that employers must follow when engaging In each class of regulated work.

5.0 FINDINGS AND RECOMMENDATIONS

The following ACMs were Identified as a result of laboratory analysis:

Material Description Material Location Estimated Quantity•

Black Wood Panel Mastic Unit 2 Dining Room 230Sf Unit 2 Living Room SO Sf

Sheetrock Joint Compound Unit 2 Office Walls 200Sf Unit 6 Office Wa•s 200Sf

Brown/Yellow Linoleum Flooring Unit3Kltchen 50Sf Unit 4 Dining Room 100Sf Unit 4 Living Room 130Sf

Residual Floor Mastic Unit 4 Office 95Sf Unit 4 Bedroom 70Sf Unit 4 Entry/Closet 85Sf

Grey Sink Insulation Unit 6 Kitchen 1 Ea 1'x1' VFT - Gold Rock Pattern Unit 6 Kitchen SO Sf AltCellTSI Basement Steam Piping 200Lf Steam TSI Joints Basement SteMJ Piping 25Ea Exterior Window Glazing Exterior Windows 36Ea

.!_xterior _StlJC<:Q/Plast~r_ ___ _13_ulldln!lExterlor _ 9,500 Sf ·-·Foot VFT,.;-Vlnyt floor tile TSI - uiermafsystem Insulation Ea - each lf - Linear feet Sf- sqi"

' Estimated quantities are based on a cursory fleld evaluation, and actual quan'.ltles may vary significantly, especially ACMs are present In hidden and/or Inaccessible areas not evaluated as part of this suNey.

Materials identified to contain asbestos greater than 1 % should be removed by a qualified and Iowa-certified asbestos abatement firm.

Responsive • Resourceful • Reliable 4

Asbestos SuNey 517 B Avenue West• Oskabosa. Iowa

l rerracan July 17, 2014 • Terracon Project No. 08147059

The laboratory reanalyzes samples with an initial reported asbestos concentration of less than or equal lo (S) 10% by point counting, as established by 40 CFR Part 763, Subpart E. Appendix E, Section 1.7.2.4. The poi~t counting method allows for a more definitive analysis of asbestos content to establish If the material Is asbestos-containing.

Based on an EPA clarification letter dated January 31, 2007, rt is allowable to round point count results to the nearest Whole percent. If a reported result is less than (<) 1.5% by point counting, the result Is rounded to 1%. However. point count analysis results must also be consistent for a homogeneous material (i.e. 3 sample set). Therefore. If one of the samples for a homogeneous material rs greater than(>) 1% asbestos by point counting, the material is considered to meet lhe regulatory threshold for designation as an ACM, regardless of the other reported point count results for lhe sample seL For samples analyzed by point counting that are >1% asbestos content, the material Is classified as asbestos-containing per the EPA and It Is required to be abated prior lo demolition of the building.

The following material was Identified to contain asbestos less than 1.5% by point counting:

Material Description Material Location Estimated Quantity' Unit 1 Office 95Sf

Residual Floor Mastic Unit 1 Dining Room 1oosr Unit 1 Llvfng Room 130Sf

Unit 1 Bedroom 70Sf Brown Wood Panel Mastic Unit 2 Orfice 200$1

Whl e Texture Plaster Throughout Bulldlng Walls 20,000Sf Whae Texture Plaster Throughout Building Ceilings 4.400SI

9"x9" VFT - Brown wNVhlle Unit 3 Bathroom 90Sf Specs

Unit 3 Dining Room 100SI

Residual Floor Mastic Untt 3 Living Room 130Sf Unlt30fliee 95Sf

Unit 3 Bedroom 70Sf - Inches VFT - vinyl floor Hlo Sf- square feet

For those materials with an asbestos content <1.5% that are not classified as an ACM per the EPA and are not required to be abated prior to renovation or demolftion of a building, the renovation/demolftlon contractor should be notifled that these materials could generate airborne concentrations of asbestos so that he/she can take the necessary precautions to protect their personnel from potential exposures during work-related activities as per the OSHA standard. Since renovation/demolition contractors are typically not equipped or adequately trained to address this potential exposure Issue, we strongly recommend that the white texture plaster on ceilings and walls should be removed by a qualified and Iowa-certified asbestos abatement finn

Responsive • Resourceful 1 Hellable !;

Asbestos Suivey lrerracon 517 B Avenue West • Oslulloosa, klwa July 17, 2014 • Terraoon Prcjecl No. 08147059

due to the potential exposure issue this material presents to the renovalion/demof~ion contractor's employees.

A summary of the classlfication, condition and approximate quantity of identified ACM is presented in Appendix A A summery of lhe samples collected Is presented in Appendix B. Bulk sample location diagrams ere included In Appendix C. Laboratory analytical reports are included In Appendix D. Photos of the ACMs are provided In Appendix F.

It should be re-emphasized that although reasonable efforts were made to survey accessible suspect materials, additional suspect bul un-sompled materials could be located under existing building materials, In Isolated areas or In other concealed areas of the buildings. Therefore, if suspicious materials are encountered during demolition activities that do not appear to have been characterized as ACM or non-ACM, samples should be collected and analyzed prior to disturbing lhese materials.

Upon reques~ Terracon can provide the Cily with a proposal for developing asbestos abatement specifications (project design) and for conducting abatement oversight and visual clearance services.

6.0 LIMITATIONS/GENERAL COMMENTS

Although Terracon conducted sampling that required aggressive methods such as knocking holes In walls, dismantling of equlpmenl or removal of protective coverillgs, we did not identify areas that required demolition to access suspect materials. Reasonable efforts to access suspect materials within known areas of restricted access (e.g., cravA spaces) were made. However, confined spaces or areas that can pose a health or safety risk to T 8IT8COll personnel were not sampled. Also, samples of suspect materlals that could not be safety reached with available ladders/man-lifts were not collected.

This asbestos survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currenUy practicing under similar conditions in the same locale. The results, findings, and conclusions expressed In this report are based on conditions observed during our survey of the buildings. The information contained In this report is relevant lo the date on which this suivey was conducted, and shou'd not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by Doyle Properties for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must drew their own conclusions regarding further Investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying

Responsive • Resourcoful • Rollablo 6

Asbestos Suivey 517 B Avenue West• Oskaloosa, Iowa

lrerracon July 17, 2014 • Tetraeon Project No. 08147059

Information which may ha1e been used in the pteparatlon of this report. No warranly, express or Implied Is made.

Responslvo • Resourceful• Reliable 7

APPENDIX A 517 B Avenue West, Oskaloosa Iowa

IDENTIFIED ASBESTOS.CONTAINING MATERJALS BY HOMOGENEOUS AREA (HA)

HA No. Material

Material Location %andType NESHAP

Condition Estimated

Description Asbestos• Classificatlon Quantity ..

07 Blacl< Wood Panel Unit 2 Dining Room PC 1.8% Chrysotile Category II Good 230$1 Mastic Un ff 2 Living Room PC 1.8% Chrysotile Category II Good 50$1

13 SheetJ'odc Joint Unff 2 Office Walls PC 1.5% Chrysotlle RACM Good 200$1 Compound Unl 6 Office WaDs PC1.5% .,,,,,,.,,,;., RACM Good 200$1

22 '&T:Nln/'(flkNi

Uni 3 Kitchen PC 21.3% Cluysotile categol'y I Good SOS! Unolel.m Flooring Unl4 Oiling Room PC 1.5% Chrysoti1e Cslegory I Good 100Sf

Residual Floor Unl4 Living Room PC 1.5% Chrysotile Categoiy I Good 13051

24 Unlt4 Office PC 1.5% Chtysotile Categoiy I Good 95$1 Mastic

Unlt4 Bedroom PC 1.5% Chrysotile Category I Good 70Sf Unit 4 Entry/Closet PC 1.5% Chrysotile Category I Good 85Sf

25 Grey Sink

Un! 6 Kitchen 12% Chrysotile Category II Good 1 Ea Insulation

26 1 'x1' VFT - Gold

Uni! 6 Kildlen PC 1.8% Ctvysccile Category I Good SOS! Rock I'-..

33 /IJICelTSI Basement Steam~ PC 91.5% Ctvysotile RACM Damaged 200U 34 SieamTSIJohs 8aser""'1I Stdln P;po,g PC20.3%C~ RACM o....nogcd 25 E<>

35 ExlelforWindow

Exterior Windows PC 5.8% Chrysotile Category II Damaged 36Ea Glazfng

37 Exterior

Building Exterior PC 3.5% Chrysotile RACM Damaged 9,SOOSf Stuceci/Plaster

- .. ·- ... ... - .. -- . . . ... -· -·-·· . . ... ain!31ning material

'% & Typo Asbestos • this column contains both the analytical result of the sample with the highest concentratlon ol asbestos detected In the samples that makes up the HA and the types of a$bestos Identified. Also, the laboratory reanalyzes samples with an Initial reported asbestos coneentration of less than or equal to (s) 10% by point counting, as estabrished by 40 CFR Pait 763, Subpart E, Ap1>9ndlx e, Section 1.7 2.4. The poht counting method provides a more definitive analysis of asbestos content to eslablish W the material is asbestos-containing.

"'Estimated quantitlea are based on a curscoy field evaluation, and adual quantties may Vat'f significantly, espec;.Jly l ~ining materials are present in hidden and/or inaccessi>le .,... nol l!llaluated as part of this surwy.

The materials lisl9d in this table have been sampled and delllml"1ed to <:Ol'l!3in ~ in concentraOOm: ~r !hon 1%. When cficb.Jrbed, variouc federal, state and local regulations may apply. These materials should be monlored for damage over tine enc repaired as necessaiy by appropriately trained personnel Removal may be necessary before renovations and In most cases before a demoil'.ion. See Appendix B for a summary of samples conected. See Appendix D for detailed analytical result.

IDENT1F1ED MATERIALS CONTAINING LESS THAN 1% ASBESTOS' BY HOMOGENEOUS AREA (HA)

HA No. Material Description Material Location %andType NESHAP

Concltlon Esm.ated

Asbfftos• Classification Quanttty-Unll 1 Olllce PC 1.2'14 Chrysolile calego<yl Good 95Sf

01 Residual Floor Mastic Unit 1 Dining Room PC 1.2% Chrysolh category I Good 100Sf Unit 1 Living Room PC 1.2% ChrytOlle Category I Good 13051

Unit 1 Bedroom PC 1.2'14 Chrysolile Category I Good 70Sf

09 Brawn Wood Panel

Unit 2 Office PC 1.3% ClvySCClo Cs1eg0ry II Good 200 Sf Mastic 11 Wiiie Texture Plaster ThroughOUt Building wans PC 1.~'14 Clvysodt RACM Good 20,000Sf 12 Whla Texll.re Plaster Throughout Buiding Ceiings PC 1.4'14 Clvysodt RACM Good 4.400$1

20 !l"ldl. VFT - Brawn

Uni 3 Balhtoom PC 1.3'14 ClwysoCle Cs!l!gcXyl Good 90$1 w/Miie Specs Una 3 Dining Room PC 1.3'14 Chrysolile Cs'9gOC'yl Good 100$1

23 Residual Floor Mastic Unit 3 Uving Room PC 1.3% Chrysolile ca1eg0ry1 Good 130Sf

Unit 3 Office PC 1.3% CNylolllt category I Good 95Sf Unit 3 Bedroom PC 1.3% Chrylolie Cslegoty I Good 70Sf

PC - Point Counting Sf - square feel

'Based on an EPA elariflealion letter dated January 31, 2007, It is allowable to round point oount results to the nearest whole percent

"'% & Type Asbestos • this cok.rnn ocntam boll! the analytical result or the sample wi!tl the highest conceulratio<I al asbestos detected in the sornp!K that malc8t ..., !M HA Md the types d asbeslos ldend'led. Also. the labonlfory reanalyZes samples ...th en initial repa1ed asbestos c:onc:entralion or less than or equal to (SJ 10% by point counting, as estallfished by 40 CFR Part 763, StJbpart E, Ajlperdl>c E. Section 1.7.2.4. The poill counting method provides a more definitive analysis of asbestos content to estabbh W the material is asbeslm<ontllnfng.

NEstimated quantitlos are based on a cursory field e\/81uation, and adual quantities may vary signiflcantty, especially W asbestos-containing materials are present in hidden and/or in&cte$Sible •reas not evaluated as part of this survey.

The msterials lis1ad in this table have been sampled and de1en'nined to contail asbestos in concentrations less than 1%. Materials with an asbestos content <1% are not claSsified as an ACM per the EPA and are not required to be at>a:ed prior to renovation or demolition of a building, the

renovatkm/demolltion contractor should be notified that these materials could generate airborne concentrations of asbestos so that he/she can take the necesaary precautions to protect their personnel from potential exposures during wor1<-relate<I aetMtles as per the OSHA standard. See Appendix B for a summaiy of samples colfect9d. Sae Appendix D for detailed analytlcal result

APPENDIXB

517 B Avenue West, Oskaloosa Iowa

ASBESTOS SURVEY SAMPLE SUMMARY

HA No. Material Description Material Location Lab Results

Unlt10ffice PC 1.2% Chryso1ile

Una 1 Dining Room PC 1.2% Chrysotile

517-HA-01 Residual Floor Mastic Unit 1 Living Room PC 1.2% Chrysoble

Unit 1 Bedroom PC 1.2% Chrysoble

Unit 1 Entry/Closet PC 1.2% Chrysoble

Unit 1 Kitchen None Detected

517-HA-02 1'x1' Diamond Pattern Linoleum Tiie Unlt3 Entry None Oe1ected

UnitS Kitcllen None Detected


517-HA-02 Layer 2 Clear Mastic Unlt3Enuy None Detected

Untt 5 Kitcllen f\one Detected

Unit 1 Kitchen !'\one Detected

517-HA-02 Layer 3 1l<1' VFT - TanwlStown Specs Unlt3 Entry None Detected

Unit s Kitchen None~..ected

Unit 1 Kltchen None Detected

517-HA-02 Layer4 Yellow Mastic Unlt3 Entry None Deteded


Unit 1 Kit:l1en None Detected

Untt 2 Office None Detected 517-HA-03 2""4' ACT · Smooth

Unit 2 Entry NoneDetecled

Unlt30ffice None Detected


517-HA-03 2'x4' ACT - Smooth Unit 3 Restroom None Detected

517-HA-04 1'x1' Blue Square Pattern Linoleum Tile Unit 1 Bathroom None Detected

517-HA-04 Layer 2 Clear/Yel ow Mastic Unit 1 Bathroom None Detected

Unit 1 Bathroom None Detected

Unit 2 Bathroom Nooe Detected

Unit 3 Bathroom None Detected 517·1-IA-05 2'*4' ACT - SWir1 Pottcm


Second Floor Porell NoneDetecled

Third Floor Pocdl None Detected

First Floor S1airwell None Detected

517-HA-06 Red carpet Second Floor Stafiwell NooeDetecled

Thitd Floor Stairwell None Detected

First Floor StairweO None Detected

517-HA-06 Layer 2 Yellow Mastic Second Floor S1a!rwell None De'.ected

Thltd Floor Stairwell None Detected

517-HA-07 Black WOOd Panel Mastic Unit 2 Dining Room PC 1.8% Chrysotile

Unit 2 LMng Room PC 1.8% Chrysoble

517-HA.OS 1'x1' White w/Gray Sv.irls Linoleum Tiie Unit 2 Kitchen None Detected

517-HA.OS Layer 2 Clear Mastic Unit 2 Kitchen None Detected

517-HA.()9 Brown WOOd PaMI Mastic Unh 20ffice PC 1.3'4 Chrysotile

Unl 2 Office None Detected

517-HA-10 Residual Aoor Mastic Unit 2 Living Room Noll8 Delee'~

Unit 2 Bedroom None Delec1ed

517-HA-11 While Texture Plaster Throughout Buildi~ Walls PC 1.4% Chrysotile

517-HA-11 Layer2 Light Tan Plaster Throughout Building Wai s Nooe Detected

517-HA-12 Whb Texl!Jra Plaster Throughoot Building Ceilings PC 1.4'4 Chrysolilo

517-HA-12 Layer 2 Ught Tan Pla&er ThRl<Jghout Building Ceilings Nooe Detected

2

HA No. Mate-rial Description Ma·tcriaJ Location Lab Results

\/\lhite $heetrock Toxrure Unlt2 Office PC 1.4% Chl}'Solile

517-HA-13 Unlt6 Office PC 1.4% Chrysotile

Unlt20ffice None Detected 517-HA-13 Layer 2 TanlWhlte Sheetroclc

Unit 6 Office None Detected

Unlt2 Office PC 1.5% Chrysolile 517-HA-13 Layer 3 Tan Joint Compound

Unit 6 Office PC 1.5% Chrysotile

Unit 2 Office PC Trace Chrysotile 517-HA-13 Layer 4 Sheetrock Wal Composite

Units Office PC Trace Chrysotile

2'x4" ACT - Random Stlanow Fissures Unit 4 Living Room None Detected

517·HA-14 Unll 4 Dining Room None Detecled

Unll 4 Bathroom None Oeteaed 517-HA-15 2'x4' ACT· Random Hole

Unit 3 Uving Room None Detecced

517-HA-16 1'x1' Grey Uoolai.m Tole Unit 4 Kitchen None Oetaded

517·HA-17 Black Sink lnslAation Unlt4 l<ilehen None Oeteded

Unlt4 Kitchen None Oeteded

517-HA-18 G<eyWan Panel Mastic Unlt 4 Bathroom None Oetec:ed

Unll3Bathroom None Detected

Unlt 4Bathroom None Deteele<l 517-HA-19 \Mllte Tole Thlnset

Unit 6 Bathroom None Oeteded

Unit 4 Bathroom None Oeteded ~·17-HA- 19 L.ayer2 Tj!O Mastic

Unit 6 Bathroom None Oeteded

Unit 4 Bathroom None Detected 517-HA-19 L.ayer3 Grey Plastar


517-HA-20 1'X1' Gray Square Pattern Undeum lile Unit 3 Bathroom None Detected

517-HA-20L.ayer2 Clear Mastic Unit 3 Battlroom l'bne Detected

517-HA-20 Layer 3 rrN VFT - Brown w!WtUte Specs Unit 3 Bathroom PC 1.3% Chrysotile

517-HA-20 Layer 4 Blad< Mastic Unit 3 Bathroom f\l>ne Detected

3


517-HA-20 Layer 5 Blad< Tar Paper Unit 3 Ba1hroom None Oetec!ed

517-HA-20 Layers Brown Mastic Unit 3 Bathroom None Detected

517-HA-20 Layer 7 Tan Mastic Unit 3 Bathroom None Detected

517-HA-21 Tan Wall Panel Mastic Unit30ffioe None Detected

517-HA-22 1'x1' Gray Square Pattem Unolei.m Tole Unit3 l<itehen None Detected

517-HA-22 Layer 2 ClearMas:ic Unlt3 l<ilehen None Oet:ected 517-HA-22 Layer 3 Brown/Yellow Linolleum Unit 3 Kitchen PC 21.3% Chrysotile

Unll 3 Dining Room PC 1.3% Chrysoble

517-HA-23 Residual Floor Mastic Unit 3 Living Room PC 1.3% Chl}'SOtile

Unlt30ftice PC 1.3% Chrysotile

Unit 3 Bedroom PC 1.3% Chrysotile

Unit 4 Dining Room PC l.5%Chrysotile

Unit 4 Living Room PC 1.5% Chrysotile

51 7-HA-24 Residual Floor Masli1: Unlt4 Ofl!oe .PC 1.5%Chryson1e

Unit 4 Bedroom PC 1.5% Chrysolile

Unit 4 Emry/Closet PC 1.5% Chryso•le

517-HA-25 Grey Sink Insulation Unit 6 Kitchen 12% Chrysotile

517-HA-26 1'x1' VFT - Gold Reek Pattern Unlt6 l<jtehen PC 1.8% Chrysotlle

517-HA·26 Layer 2 Tan Mastic Unlt6 l<jtehen None Detected

Unit 6 Dining Room None Detected

Unit 6 Living Room None Detected

Unlt60ffiee None Oeteeled 517../iA-27 Residual Floor Mastic

Unit 6 Bedroom None Detected

Unit 6 Entiy/Closet NooeDelected

Unit 6 Ba1hroom None Deteele<l

517-HA-28 Residual Floor Mastic Unit 5 Dining Room None Dele<led

Unit 5 LMl1g Room N:ine Detected

4

HA No. lbteri.tt Descrlpllon M11911.11 Location LabRosults

Unit50!Sce tione Oelecled

517~8 --- Unit5Bedrcotn Honelleleded

Urit 5 Entry/Clcsel HoneDeteded

517.W..29 Datt< Bmwn Wiit 1'11MI Mistie Una 5 Bathroom Hone Deteded

517-HA.30 Bn>wn Flooring a....1111 carpet UnltSBatt>room Nonelleteded

517-HA-30 Layer 2 BrownM .. Hc Untt 5 Bathroom Nono Detected

517-HA-31 Rosldult Floor Mostlc Sta!rTl1!ads !lone Oeleded

Unit 6 Dining Room llono Deteded

517~2 Sheelrodc Ceil ng TOld1lte Unlt e O!fico Hone Deteded

Unit 1 Dirll1g Room lloneDeteded

U1"1 e IMng Room /lone Do-.cl

517.w..32 I.ayer 2 -c.1111g Unite 01lc:e None Oe!eded

Unit 1 Dining Room None Dollicle<f

517-HA-33 AirCel lnt11181Son 8-nt Sten Piping PC91.5%Clu'ys01ile

517-HA-34 Steam TSI Joints Bosemont Sten Piping PC 28.3% Chrysolile

517.w..35 Exterior Window Glazing ExtoriorWondows PC 5.8% Chrysolile

517-HA.Je Green/lllac:t< Shingle Roof NonoDo:ec:ted

517..HA.J8Llyer2 Grey/Bild< Slmgle Roof NonoOO:ec:ed

517.w.3$ l.oyer 3 Blade ShOlgle Roof Nono Do:ec:ed

517.w.3$ l.oyer' Blacl<Ter"- Roof Nono DofleC::9d

517-HA..37 Elderior Stucco T e>c1Ure ~Exterior NonoDolBc=ed

517.w..37 Loyer 2 Oll-Whita Placer &Jilcfing Exterior PC 2.5% Ctvysotile

517-HA..37 Llyer 3 Grey Plaster Bulld!1'g Exterior PC 3.5% Chrysollle

517-HA-38 ExtellC>.' SNCCO Patch Sou1h Exterior None Detected

517-HA..39 Grey Brlck Mo<1ar Building Walts None Deteded - inc:hot • - !Ht VFT - W!yt ftoor tile ACT - ec:oustic ceJlng tile TSI - - ~ insulat!on PC - point c:cont

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APPENDIX D

ASBESTOS LABORATORY ANALYTICAL DATA

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CERTIFICATE OF ANALYSIS

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Amil)"lis PtrforMtd By: R. Kc-.!y

011k: 7110ll014 .... J1eU1

IATL INTERNATIONAL ASll"'1'0S'Tt:ml«l LAllOaA'IOM!S

9000 ~ Pn"°Y• Suite B • Mounl IAlrcl, NJ OIOS4 "''°""' tn-41B-42JSllS6-231-9'449 • Fu: 856-231-9111

I I I i

~ I Chain of Custody

-Bulk Asbestos -contnct lnfonnntion

l&l~]j)_5_1 Client Company: Terracon Consullants, Inc.

Oflicc Address: 600 SW 7th St., Su lie M City, Stoic, Zip: Des Moines, IA 60309

" l'l'ojcci Number: Projccc Nnme:

l'rhnm·y Coutnct: 611 f> Av-- vJ ~ A C/11 s .... .., T~erPuls

Fax Numbe": 515-244-6249 Office Phone: 515-557:3821 .

Emnll Atld1·ess: [email protected] Cell Phone: 515-330-8193

PLM lnstl'uctlons; l!J PLM: Bulk A$be.stos Building Mntcrinls BPA 600 R-9)/116, 1993 0 PLM: Bulk Asbestos Building Mnterinls l!PA 600 M-'l/82·020, 1982 0 PLM: Bulk Asbestos Building Mnterinls NIOST 19002, 198S 0 PLM: Bull< Asbestos Building Mnterlnls NVSDOI l·BLAP 198. l, 2002 0 PLM: Bulk Asbestos Building Mntctinls NYSDOH·ELAP 198.6, 2010 0 TEM: Bulk AJbcstos Building MatctlalJ NVSDOH·BLAP 198.4, 2009

l!J PLM: Point Counting 0 PC: via !!LAP 198.1 (!] PC: 400 Points

0 PLM: Analyze Until Posilive (Posilive Stop) 0 AUP: by Homogenous Arel\ as No1ed 0 AUP: by Material Typo as Noted

0 PC: 800 Points • D PC: 1600 Points •

Iii PLM: lnstnJctions for Mulli·Layer<d S11nplcs

0 Pl.M: NOB via 198.6 0 PLM: Friable via EPA 600 2.l 0 If <1% by PLM, "'TEM via 198.4 • 01£<1% by PLM, Hold for Instructions

l!J AnalylCll!ld ReportAllSepmbloLayerspetl!l'A 600 0 Report Composile for Oly\¥111 Sy.taus per NESHAP l!l Report All Layers and Composite Where Appllcnblc D Only Analyze ind Rq>Cl1 Specirocolly Noted Layer

0 PLM: Non-Building Material'.•• (Dust, Wipe. Tope) D Soil or Venniculite Analysis• DCARB<IS

Specinllnslruclions: _____________________________ _

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1ni11 ofCustocly -- ~II J · • ... · Relinquished (Non•e/Orgnnb.ation):. .{"1J< Dote: l · 2•/4 __ Tun~Z~C E. I V E Receivcd(Name/iATL): _ Dote: Tim '--------S•mple Login (N•mo /IATL): / P\;; Onto: · fil ({IA, Time . An•lysis(Nomc(s) /IATL): ' !tla:J.a-.1-D•to:.:;ilS/,fJ._t< 4' Time ~l4,

Di QA/QC Review (Nome / IA 11..): • jl(~ Doto: 7-ll-1¥== Tinie: · ~~·; : Archived I Released =---~A/QC lnle1·LAB Use: __ Doto: Ti1110: . , · .{· '" · .:

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9000 Commetee hrttw1y. Suite ll • Mo.ml t.-urcl. NJ OIOS4 l'llono: tn"'121-411S/IS6-23 HM49. fox: 8S6·2JJ.91 ll

. Chain of Custody

- Bulk Asbestos -Contqct rnronURlion C llonl Compnnys Tel'f'QOOn Consultants. Inc.

Office Address: 600 SW 7th SI., Suite M City, S hotc, Zip: Des Moines, IA 50309

l'nx N oo ml>or: 515·244-5249

It.moll Aclch.._,., [email protected]

l'LM 1nstrnctions:

., Project Nu111bc1•1

Projccl Nnono:

J'l'in1nry Confnct:

Office Phoooc:

Cell Phone:

~lilPS'~ '511 & All!- Ir.I - A CM 5.,....., Tylor Puls

515-557-3621

515·330·6193

1iJ PLM: Bulk Asbestos Building Materials IJ~A 600R·93/l16, 1993 0 PLM: Boolk Asbestos Building Materials llPA 600 M-4182-020, 1982 0 PLM: Rulk Asbestos Buildil1g MntcrU.ts NIOSH 9002, 1985 0 PLM: Bulk Aabestos Building Matctiols NVSOOH·BLAP 198.1, 2002 0 PLM: Bulk Asbestos Building Mfttcrials NVSOOH·ELAP 198.6, 2010 0 TllM: Bulk Asbestos Bulldu1g Materials NVSOOH-llLAP 198.~. 2009

liJ PLM: Polnl C011nli11g D rLM: Analyzo Unlll Positive (l'os.itlvo Slop) D PC: vi• El.AP 198.1 D AUP: by Homogcnous Area os Noted l!J PC: 400 Poil1ts D AUP: by Material Type H Noted D l'C: 800 Points • 0 PLM: NOB vl1 191.6 D JlC: 1600 Points• 0 PIM: Friable via !!PA 600U

Iii PLM: Instructions for Mulli-1.a)'OrCanble laycrs per llPA 600 D Pl.M: Non-Building Ma1cri11··" (Ousl, Wipe. Tope) 0 Report Composilo for Orywioll Systems per NESHAP

Iii Report All Lay.:rs and Composilo Where Applicoble D Soil or VmnlaJlito Analysis• D Only Analyze and Report Specifically Noted I.ayer DCARBOS

S1"'d nl lnsl rucllons:

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ChnlnofCustody ~rn . IV r: D Relinquished(Nnmo/Organi7J>tion): ~ _ Date: l·2·i~T1111~Z~£ E " 0 Received (Nome/ IATL): Dato: 11on • Snmplo Login (Nnmo/ iA1'1..): Ollie: Z/ 2 /lf.1 Timc _ _ _ , AMlysls(Nnme(s) / IATL): · i•~n Onto: 9: Timc ~u1,.::::3:2i[4 I/ QA/QCRevlew(Nanoo/IATL): . -C.-· Date:]-//~;g 11nlo: il • ; ... An:hlve<l / l{ol""sed: ---~A/QC lnterLAB u..,: __ Dote: Tlrnc: /?.;; •. · ,}/.

Cck.•hnllill,g l!i )~lln ... noc Run pk cit nllmi: \\,\'W.i11ll,((ltfl

Temccm PN: O'b\'\J Q'i\ Aabostos Samplo Location Log ~--'-"'_§_ ClentName: C;b .f O$k,lotS'\

Building Name: i:n l 'VX vJ Inspector: 'f 1 r Ado, l•r£p((U\ Date Sam)les Colecled: 1-2 -/'(:

·~ · ...... Sample No: Sample Location . - r . Material .Descrlptlon " ··• ·.

in.:~!\:~!~---- -~.i.ll. __ ~~------- J!~l<..-~!!'.sL_rt'J~.!----~~!f.._i.sis~2 ----------~---- -- ----~~~!-!:. __ ....,_ -------.1:-----------------.5..a~.A.§~ . --------~oi~--- --- ---~~~-------- ,~-1>r;-~J-t:#~-r;;re;..:--f1~-.::e-~~~I~ ---------------- --- ------~~--·--- .'.::l..l_~'l.1!!.'::h.._~-----------"5"3'611'~

~ ' ---------------- --- ------t.-----~--- -------~-------------7------536-4;2-6

l ". ~----------------- --- ---------------- -----------------------------s:nr.4Jl:l7 ________ :~?~--- -c~~-1.--~~---~-- ~-«t~~.T....::~~~~----------~s~~~~~-~ ---------------- -----------~------- -------1-------------------------... 1'. .. -(. v ·~· 3. bff.,'«. 53~4$12'9 ---------------- --'11--------------·-- ---------------------------------------------'-~~_A ____ JllliJ_.J"_J!l±hi:!Dn--~- 1~LPJ.::L~~ ... L-~..J:t~~-~~~!~-.r!_~~~.:.~ .

::::::::::::t:::: ::::::~:::::::::::: :::::::~:::::::::::_-:::::::~~::::~~:~ ________ :b~~---- _________________ : __ ~~j_ftf(_"_~!!:'!~t __ f!._~~~------~~~-~~-3-~

-----------~---- ~!~~-~--~~~--,-- -------~----------------~!3_6_1§_~4 ___________ !'.,____ ~~[t __ :S_.f!!.~~------ ----------------------------.5.3.S~J. _______ :~~A___ Ji~_£1.!~--~~,u ___ ._ K~--~-"~t __ f:!Le!"!5fil. _______ .s.6s+It.·

-----------~--- -~~-~{~-~~~~~-- --------~-------------------~~~· --------------- -------------------- ---------------------------.5.ls'~d' ---------~-~1~--- _\l.~:!·_f::_~~~i:$.-.t~_ .... _ ~l~~-Y-!!O)_J~~--~~~~~-----.5.3.-645.J ' ------------~--- --t----~"..~~J:L_. __ --------L------------------5..3..64.s.4".

(, L l. . -.. ---------------- _________________ :__ ----------------------------SJ-6-454-!-· ________ :_~~~--- ~~.1.:,_z_ __ ~~~h~----- !~l-~~£~---r.'.~~-~.!:'i£~ __ f 0.!l~4B'.!la_,

------------~--- ------~---------~-- --------~-----------------~3~~~5~~~--· ---------------- -------------------- --------------------------------------! ------t;;~~:;t-;~--Jf crst.----;c,---------~--------------------------------------1

I

Tomicoo PN: 0'61'\ 1 ~!j1\ Asbestos Sample Location Log

Cioni Name: Cth of t>sk,(..es, P1ge2_ot2.__

Builcrl'lg Name: S 17 6 Ave. vJ Inspector: 1 f A. A C Date Samples Collected: ] - J-Jc./ -:,

" .... . !"· • .• .!

SamploNo: Simple Location Matonal Do1erl11tlon

-~!]_-Jj~_:Q~}t __ ll~J_Z._Qff~~------ ~-'!~--~~--f~·~1.L..tf!i~L ____ ..5..3.Sl:i.4.

-------------~-- -----t------------- --------±-------------------~-}~~~~:' ::::::::::!~£t:: Y~Lf ~::Q:lii..~:::::::: ~~~~:~:~:!i~~:l!~~ti;::~~t~~~~~

e, J_ u~~ m .\.. ~:is 4.5 4 ---------------- --i::------~-------- --------1.---------------------~--·~~· _____________ :__ --------~~~~------ -----------------------------~~1~§_5.;QI ________ :JJ_~--- Y_iil_l.._0"~~-g!!_~-- f l~J1r __ ~~u~ _______________ Ji.J£_t-s5.J..

------------~--- _l!..i!_i_J.~!~-g~-~-- -------1 ____________________ §_:t§J£i~~ ____________ l,;.___ .?::'.' __ f !~:-~±~~~~u-~-- -------- ____________________ S.J.6'l..l.5

------------~-~- ~=.-!i~~t~~~L-~~- -------- --------------------;~!~41 ---------------- ___ !i_ _____ ,!9..~------ ------------------------------.,.---§,~ ... _______ :lt~ __ .:_ ~~I.U. __ 1,.,}l~_f!:J_____ !l~k-~~b11J----------------~A~1.i .. 'i ------~---~-- 9_~i-~~~~-----~- --------1------------------~.J.&4.5..5. ___________ S:____ 1:.ir_~l~_)~~~--- --~---- -------------------~_'.3-~~_;;-~ ___________ ,!) __ ::_ -~~-11!~-~!!~lL___ ________ _ __________________ !iJ.6..4.~ ___________ §[___ -~~!--~-1.:i~~-~-...:.- ----------------------------...S.~ ________ :!~_/!___ J~!~1. __ Q.f.t.'tt. _____ ~-- ?-~~..J.__.(J(.I.~-----------~~.ll.t.

___________ _!>____ -----~-----------~- --------~-------------------~J~?i~r. ___________ !::_ ____ 'l'!it __ ! __ ~!fi~----~-- _____________________________ 5j~_.s.~

________ : L'tll ___ _v!'Il:..iJJ.vA}-~----'-- ?!...~L.l!.fl:_f~cb.Jl.!_Jb.U!!'..._ft11JLf!4.6J.S~ ___________ )_ __ , ______ :-_ ________ ~-- ---------;t------------------~!L~~-i-~~ ____________ (.___ ~~!-~-~!!1-i~f.~--~- ---~-------------------------~~~-1~.!>-~ ________ :J~'A___ Y.'.'.!'t_i_~~L'!~----- f.!1_.'UKt:_~~J!.A~_JioJ~ _______ ::i.16:4.5.s1_ ------------~--- -~~t-1k~~-i-~--- ---------1-----------------i~tHi-~-------------~--- -------------------- --------------------------------------c. "\\wi~ &A t ... ~ 3

Temaoon PN: 116l't1 O'S\ Asbostos Samplo Location Log ~-2-ot _2_ Cfient Name: (;;~ •T ·~o,Jq Buildir1g Name: ~I g 4,t. Inspector. 'H 8. )\ £.. Dalo s~ Collected'. 7 -z ,.tt.,,,

~ l~ Sample No: I Sampl• Location I Malertal Description •'

.. 2L1~11}..~1~A--- y_,.~~-1_.k;_~----- hLG~_.bu-.h~.----------:~~f ~lQ_

============~=== ======t=========·:== ======t==================~~=~:;~i~= .uf ~--------.:J_1_~--- ~!!L~.k:Lt.~------ ~lL-~lr>-~ __ .I:.H!<.l.J...:!k! _____ ~--!l_~!~~!-3_1 ?I -----------~--- ------~------------- ------~--------------------~;:~;;~

=========:I~it== =~~f =9==~!~~===:== ~~=1iJi=~~~t==h~;~~=======~~~1~{~§~ ------------~-~ u:;i-~~i--~-:------- ------~--------------------~~-i,!;~z-1 ~r--------------- --------~th!~!l'O.------ ____________________________________ a_

1 ... _________ : JlA_:. .\6~t_t_}.!>ih~--.!.--- ~!~LI~ __ 1J.!~l(,.t..1-~.!!.".!'-1:1!~_t._~~-6-~§:U_ ___________ _!__ _ ____ .J:______________ -------~-------------------~~~~~~ii.Q_,

-------:-20-A~-- ~-~}-!--~P~_ .... __ "fii"l?f:s;;---:.7;w~-1~-;-n~ri~1.§.?_L ---------------- -~----~~---~--•--- ~~.!."!.-f~"/l!.n_~~Vl'-----------~BJ..._

t> ± 53645 83

==========~=== =~====~============= =======--======--====~-===;~;~== _______ "..llA..;_ _V..'liL~P.iti.1.t.---~---- ~".!' __ kMLJA111L_t!.':J!1L ____ §},~ •.t~ :: __ , 11 ± . ' ·<:l .,

____________ 2___ ----±~------------- ------- -----------.----~~4 ' 6--l. .. . . .

-------:.----;--- i~~-~-~~.i:-------- i;j~EP~-v.~-r:-;:i.:;7~~ttt~+--________ :1..i._____ -------------;------ -- D-!l:Yl!..-----------------Ji 4.~..8Ji __

------------~--- -----:!:-------------- -------.:t-----------------..5.3..6.A.51'-..9.--------------~--- -------------------- __________________________ Ji.3.£..4..S~--· ________ :J~A___ Y~~-~LP.!~~JY:! _____ f.::~'~--~!jb,_-::Y..'!lf_.1 ___ ..iJ.~~+--·

------------~--- --].:-----~~~-~--- -------±:-----------------~-;:~;:;---· ---------------- ____________ M_______ --------------------------------------! ------~o;f.f:ii-- ~--~11---"/---------r-------------------------------~-====

I ~·

•.

Tamic:oll PN: • oi \I\ 1 OS°\ Asbestos Samplo Location Log

Client Name: lrl, 0( Osk,J.-s, ;,..!/_o1_2_

Budding Name: S-17 8 11... I.I lnspoclor: Tr 1 /tl.

Sample No: Sanple Location

Dalo Samples Collected: 7 -Z-1'1 Y,·ti> '

Matoital Doscrlptlon

~~~:~~-:~jf!~_ ~£!_1_!Bi!L ________ ~~jJ~J __ '.'.!!~6~-=-~~i:t----~-----5-~§_1:§~-"---------------~-- --~----~~5..!~----- --------~------------------~~-~{fs~~--· ---------------- ___________ ':]________ --------------------------------------· _________ :!:5-1__ .!>:it_!_~fh~-------- ~~-~\!l..l_.t'~!!l~~~----------~.J-~·~Jl.2 __ ,

:::::::::::::~:: ::::~::::::::::::: :::::::J::::::::::::::::::~:~~::.:.:::1 _________ :H.lL_ _V_11iL __ i~f:~----- i~_Yfl:faJ>lLB~tA!t'!!~----~~~-~~~-~--

------------~-- -----1-------------- -------~------------------~~~6~~0~--·

=====~===~:ii.A~= :!l~l=~=~~======:== ~~[=~~~~~=tl~l=f ~========~~~=~§:fr>=i=i -------------~-- --l----~~~~-~~---~-- -------t-----;-~~-~---------~!-~~pr~~--------------~-- ________ B~L'!b!"I_______ ----------------------------~~§_{~9.!i. _________ ::!:!A:._ Y!!f_~ __ g~~------:.- ~J:~-!!~.fis_:f-!!Lf. _________ 5_~~-4_~g_6-

e, f f)rni\ t.N 5 3 6 4 6 0 7 --------------- -- ----l..,~i~ri------- -------1---------------------3-~r~----• ------------°'--- -- -------~--------- -----~-------------------..5.. B:a..&.o..a.-_________ :3~-~-- __ --~~~------ ~~,_LJ!'.."!.~_fBL11':.~1'! ____ J)_~Ji~D-<t_,

-------------~-- __ -----1---------- ------~-------------------:~~~~Le __ ---------------- ------------------ _________________________________ 1.l __ _________ :)~_'! _ _'.° -~'.'.f !_?_~_:!!~~--.:___ ~~-tkA~J--~--('!ll'f __ §_~§J_~j1_ __

-------------~-- -----~------------- ------1:------------------~.J..6.d.6.J..J----------------~-- -------------------- __________________________ 53.li:~O-µ---· _________ .:1l8_.::· -~~-f~!C_~h~l ____ ~1~_..[ __ /1~fa.::_~b:L _____ .5.J.6::\fl+&----· -------------~-- .3:.-:._.H9!_.$bl!:~JL·___ -------1-----------------§}_QJtlc ____ , -------------~-- ______ -!:----------~-- -----·--------------------SJ.G.4.G-1-11----·

------{;ii;~~v~- ~----~;;.-'('.---~--- ------------------------~-------------

Tomicon PN: 0'6\l\11>51 Asbestos Sample Location Log ;. _i;_ o1..2__ CliootName: a-1-, rl O)k ... leoY\ Blrilding Name: S'll i tht. W Inspector. f 1' J, If C. Date Samples Collecled: 7-Z -/'! .

y, Sam"'iiio No: I Samele Locnilo_n _ _ _ I Matedal DoscrinUon

_'2'~J~-~~~~F-~- -~~i±--~--~~"l_gri __ ~~..k!~~-(~~~~-~-_[~-~--~)_6~4§_t~-e l.. Offit.t L 5364619

---------------- -------------------- --------J:---------------------------~

-------------L___ ~-~i_J-_.1.__~i~i~-~~-- ---------------------------~~-~~~-~~-_________ :3_3.-1__ ~~~1___________ ~!'.:.-~ll_.f ~.:i~~-----------~~.!>~1§_2_k_

-------------~~- ----1--------------- -------f------------------~~~~~~~.-~~--c 5364623 ---------------- ---- --------------- --------------------------------------_________ :3~-- ---- ----------~---- ~~.!l!' __ TI_:f __ J~-~--------§-~~~:.6-~~---------------~~- ---- -------------- ------~-----------------[)_If 4-§_'l~---

l ~ 5364626

=========:~~Ji== ~~~=~=~(~=~~===== :ii:~~~~==~i~~~==~I~~====~;~~~~j=i===: ------------~~- __ !: ___ ~~~----- --------1:-----------------~.!3~~-~~---

l u..:i 2. 5 1.1;..IGW , 536462 '.1

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========:}::i~=== =~~~~~============= ~=~~===~~~=============~~={~:-ii===· ------------~~-- ~_f}._t; ____ ~-------- -------1-----------------..S.3~16.2-i---------------~--- f-.K~L _____________________________________ Ji3.&..4:6fil. __ _ ________ :.?..~~-- __ JfJih. _____________ k~! __ ~b1!_.:Mj.L _____ ..5.l.6..4..6J£ __ _

------------~-- ---±:---------------- -------~--~-------------..5.3.&4.G.J..'--~ _____________ s__ ____________________ ------------------------~-!iJ9_4.6.3.Jl __ ~ ________ :~!lt__ -~-~ic;t_____________ .!>.:i!-~ __ t\.~~-~--'---------~§-~~~~~~---

------------~-- -~-~(~------------- -------±.------~---------5§3)6644s94~~-------------------- -------------------- ------------------------------------------------~V\.<l:-------------------t-------------------------------------j

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Updated 9/18/16

Environmental Protection Commission September 20, 2016

State of Iowa Capitol Room 116

1007 East Grand Ave Des Moines, Iowa

EPC Business Meeting 10:00 AM – Meeting begins 1:00 PM – Referral to the Attorney General - J.S. Properties, L.L.C. and Terry Anderson – Asbestos Violations

in Oskaloosa, Iowa 1:30 PM - Referral to the Attorney General – Swiss Valley Farms Cooperative – Air Quality Violations in

Luana, Iowa Public Participation1 – Requests to speak during the business meeting Public Participation must be submitted to Jerah Sheets at [email protected], 502 East 9th Des Moines, IA 50319, 515-313-8909, or in-person by the start of the business meeting. Please indicate who you will be representing (yourself, an association, etc.), the agenda item of interest, and your stance of For, Opposed, or Neutral.

If you are unable to attend the business meeting, comments may be submitted via mail and email for the public record. The Commission encourages data, reports, photos, and additional information provided by noon the day before the meeting to allow ample time for review and consideration.

Agenda topics

1 Approval of Agenda

2 Approval of Minutes

3 Monthly Reports Bill Ehm (Information)

4 Nutrient Reduction Strategy Annual Report Presentation Laurie Wissler – ISU Adam Schnieders – IDNR Matt Lechtenberg -IDALS

5 Public Participation

6 Director’s Remarks Chuck Gipp (Information)

7 Farmed Wetland Study Summary Vince Evelsizer (Information)

8 FY 18 Budget Request Jennifer Nelson (Decision)

9 State of Iowa Public Drinking Water Program 2015 Annual Compliance Report Diane Moles (Information)

10 Water Supply: Water Use & Allocation Annual Permit Fee Mark Moeller (Decision)

11 Clean Water and Drinking Water State Revolving Loan Fund – Second Quarter Updates to the FY 2017 Intended Use Plans

Patti Cale-Finnegan (Decision)

12 Contract with I & S Group, Inc. for Revising the Iowa Storm Water Management Manual

Joe Griffin (Decision)

mailto:[email protected]

Updated 9/18/16

13 Contract with the United States Geological Survey for Stream gaging and real-time water quality support

Roger Bruner (Decision)

14 Contract with the State Hygienic Laboratory at the University of Iowa for Ambient Groundwater Analytical support


15 Contract amendment with the USDA Animal Research Service/USGS Laboratory at Marshfield Wisconsin for Ambient Groundwater Analytical support


16 Notice of Intended Action – Chapter 61 – Water Quality Standards (Copper Criteria Update)

Jon Tack (Decision)

17 Adopted and Filed – Chapter 100 – Scope of Title – Definitions – Form – Rules of Practice - Chapter 101 - Solid Waste Comprehensive Planning Requirements - Chapter 111 – Annual Reports of Environmental Management Systems

Leslie Bullock Goldsmith (Decision)

18 Adopted and Filed – Amendments to Flood Plain Management Rules to streamline certain development types

Ken Bouma (Decision)

19 Referral to the Attorney General - J.S. Properties, L.L.C. (J.S. Properties) and Terry Anderson

Kelli Book (Decision)

20 Referral to the Attorney General – Swiss Valley Farms Cooperative Anne Preziosi (Decision)

21 General Discussion

22 Items for Next Month’s Meeting • October 18, 2016 – EPC Business Meeting, Windsor Heights • November 14, 2016 – EPC Education al Tour, Wright County • November 15, 2016 – EPC Business Meeting, Wright County

For details on the EPC meeting schedule, visit

http://www.iowadnr.gov/InsideDNR/BoardsCommissions.aspx 1 Comments during the public participation period regarding proposed rules or notices of intended action are not included in the official

comments for that rule package unless they are submitted as required in the Notice of Intended Action.

Any person attending the public meeting and has special requirements such as those related to mobility or hearing impairments should contact the DNR or ADA Coordinator at 515-725-8200, Relay Iowa TTY Service 800-735-7942, or

[email protected], and advise of specific needs.


MINUTES

OF THE

ENVIRONMENTAL PROTECTION COMMISSION

MEETING

AUGUST 10, 2016

STATE OF IOWA CAPITOL 1007 EAST GRAND AVE

DES MOINES, IOWA

______________________________________________ Chuck Gipp, Director

RECORD COPY

Filename: ADM 1-1-1 Sender’s initial: _______

TABLE OF CONTENTS

Call to Order .................................................................................................................................... 3

Commissioners Present Commissioners Absent ........................................................................ 3

Adoption of Agenda ........................................................................................................................ 3 APPROVED AS PRESENTED ....................................................................... 3

Approval of Minutes ........................................................................................................................ 3 APPROVED AS PRESENTED ........................................................................ 3

Monthly Reports .............................................................................................................................. 3 INFORMATION ........................................................................................... 3

Public Comment .............................................................................................................................. 2

Directors Remarks ........................................................................................................................... 8 INFORMATION ........................................................................................... 8

Water Supply: Water Use & Allocation Annual Permit Fee ........................................................... 9 INFORMATION ........................................................................................... 9

Contract with University of Iowa for Mapping Review Services ................................................. 10 APPROVED AS PRESENTED ........................................................................ 10

Adopted and Filed –Disposal of Yard Waste ................................................................................ 11 APPROVED AS PRESENTED ........................................................................ 11

Solid Waste Environmental Management System Program’s Funding Assistance Criteria-Update12 APPROVED AS PRESENTED ........................................................................ 12

Contracts with Iowa Department of Agriculture and Land Stewardship and City of Clear Lake for Watershed Projects .............................................................................................................. 2


Contract Amendment with IDALS for Program Staffing--Regional Basin Coordinators .............. 3 APPROVED AS PRESENTED ........................................................................ 3

Adopted and Filed – Amendments to Wastewater Rules related to the Iowa Antidegradation Implementation Procedure as adopted by reference in the Iowa Administrative Code, Chapters 61 and 64. ............................................................................................................................. 4


General Discussion .......................................................................................................................... 5 INFORMATION ........................................................................................... 5

Referral to the Attorney General – Gary Eggers ............................................................................. 5 REFERRED ................................................................................................. 5

June 2016

MEETING MINUTES

CALL TO ORDER The meeting of the Environmental Protection Commission was called to order by Chairperson Mary Boote at 10:00 a.m. on August 10, 2016 at the State of Iowa Capitol in Des Moines, Iowa.

COMMISSIONERS PRESENT COMMISSIONERS ABSENT Mary Boote, Chair LaQuanda Hoskins Nancy Couser Chad Ingels, Vice Chair Cindy Greiman, Secretary Ralph Lents Joe Riding Bob Sinclair Gene Ver Steeg

ADOPTION OF AGENDA Motion was made by Chad Ingels to approve the agenda as presented. Seconded by Joe Riding. Motion carried unanimously.


APPROVAL OF MINUTES Motion was made by Ralph Lents to approve the June 21, 2016 EPC meeting minutes. Seconded by Cindy Greiman. Motion carried unanimously.


MONTHLY REPORTS • Bill Ehm shared with the Commissioners the annual report for the Animal Feeding Operations EPA

Workplan was submitted and posted on the DNR website. In the report, 65.5% of inspections have been completed in three years.

• Bill Ehm provided an update for the November EPC Tour and Meeting in Wright County. The tour will concentrate on agricultural best management practices related to Iowa’s Nutrient Reduction Strategy.

• The following monthly reports have been posted on the DNR website under the appropriate meeting month: http://www.iowadnr.gov/InsideDNR/BoardsCommissions.aspx

1. Rulemaking Status Report 2. Variance Report 3. Enforcement Status Report 4. Administrative Penalty Report 5. Attorney General Referrals Report

6. Contested Case Status Report 7. Bypass Report 8. Manure Report 9. Spill Report

INFORMATION


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PUBLIC COMMENT Jessica Harder – Association of Business and Industry (ABI) Jessica Harder shared with the Commission as one of the original petitioners, ABI supports the antidegradation rulemaking package. She commended the DNR for bringing the proposed rule forward in a manner understandable to the public. She also stated the changes to the rulemaking add clarity that ABI supports. Jeneane Moody – Iowa Public Health Association Jeneane Moody shared with the Commission that Iowa Public Health Association (IPHA) opposes the proposed changes to Agenda item 13, Notice of Intended Action and Petition for Rulemaking regarding Iowa’s Antidegradation standards. She believes the rule changes will significantly weaken Iowa’s antidegradation standards and take consideration of water quality benefits such as improved public health out of the equation. As the voice for public health in Iowa, IPHA supports strong anti-degradation standards and the enforcement of these standards to protect the safety and quality of Iowa’s water. The health of Iowans is inextricably linked to the health of the environments in which they live, work, learn and play. Iowa’s greatest health challenges and solutions are highly complex and extend beyond the doctor’s office. She would be surprised if any of the Commissioners see themselves as public health professionals, however, the fact that Commissioners have stewardship over this vital and shared resource of water positions them to protect the health of Iowans. The roots of public health practice are in addressing environmental causes of disease and originally focused on infectious diseases related to poor water and air quality, unsafe disposal of wastes, and environmental sanitation. The health of our environment is absolutely foundational to everything else that we seek to accomplish in improved public health outcomes. In fact, your zip code is a greater predictor of your health than your genetic code. Water has a profound influence on health. A minimum amount is required for consumption each day for survival, but the influence of water on health goes far beyond this as water is a principal medium for disease prevention. The risks to the health of Iowans from polluted water are real. Exposure to water affected by harmful algal blooms can result in dermatological, gastric, neurological and respiratory problems. Exposure to nitrates and other compounds in drinking water pose risks to infants and is associated with birth defects. In Iowa studies, long-term, low dose exposure to nitrates is associated with an increased risk for bladder, ovary and thyroid cancers. There are real public health benefits to improved water quality. The existing rules allow for that benefit to be considered before eliminating less polluting alternatives. IPHA advocates that the Iowa Environmental Protection Commission and Iowa Department of Natural Resources apply a health lens to the proposed rules change. Please reject the proposed antidegradation changes and work with communities and stakeholders on ways to account for environmental benefits including the public health value of clean water. Keith Hobson – Fox Engineering Associates and Various Water & Engineering Associations Keith Hobson shared with the Commission he is in favor of the proposed rules for antidegradation. He congratulated the DNR staff for summarizing and organizing the comments and responses to all the comments. He felt the proposed rules are not doing anything to cause any more problems but rather maintain the water quality. The proposed rules allow for the next step to move forward with improving Iowa’s water.

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Neila Seaman – Sierra Club Neila Seaman shared with the Commission the Sierra Club does not support the proposed rules for antidegradation. She delivered the below comments. You will today have the thankless task of deciding whether or not to change Iowa Antidegradation Implementation Procedure. This document has been in use for about six years after taking more than two years to develop it. I am very disappointed that the DNR thought this rule change recommendation should be fast-paced through the process. I represent one of the organizations that originally petitioned for Rulemaking so we would have an acceptable antidegradation policy. Trust me when I say it was not thought to be an emergency rulemaking at that time. The original stakeholders had little input this time around while the current petitioners were involved in every step along the way between 2008 and 2010. We consider this rulemaking to be a serious deviation from the original AIP. I hear when DNR says that the current AIP needs to establish regulatory certainty. Surely after the court issued its ruling, DNR could have reassembled all of the original stakeholders to hammer out a plan that is more acceptable to us than this one. The AIP does retain language that says in part the AIP applies to all surface waters of the state regardless of use designations or water classification and an antidegradation review must not result in the impairment of an existing or designated use. A regulated applicant is required to evaluate alternatives if it plans to degrade water quality to determine if it’s necessary and no reasonable alternatives exist to prevent the degradation. It’s troubling to us that any costs at or above 115 percent of base cost of the minimum level of pollution control are not considered economically efficient. It seems that if the regulated community has a brite line standard they won’t look at reasonable alternatives that might cost a bit more but would provide more benefit. The AIP also says that alternatives identified as most practicable and economically efficient are considered affordable if the applicant does not supply an affordability analysis. We are concerned that this language coupled with a brite line standard gives applicants a pass to simply skip doing this important step -- the affordability analysis. I saw the chart in the responsiveness summary that shows what other states require. So what? Iowa has always proven to be a leader. Binding regulations to the same standard as Alabama and West Virginia is not impressive even if those two states are 5 percent lower that this particular rulemaking would require in Iowa. Poverty levels in those two states are higher than in our state. Even Missouri requires 120 percent albeit that figure is non-binding. I reiterate our position from May that the original stakeholders should have been brought back together to come up with a reasonable proposal to address the issues ruled by the court. There is still time. Reject this proposal and direct DNR to start over. Josh Mandelbaum – Environmental Law & Policy Center Josh Mandelbaum shared with the Commission the Environmental Law & Policy Center does not support the proposed rules for antidegradation. He delivered the below comments. Commissioners, thank you for the opportunity to address you today. My name is Josh Mandelbaum. I’m a staff attorney at the Environmental Law & Policy Center (ELPC). I’m here to address, Agenda item 13, Adopted and Filed – Amendments to Wastewater Rules related to Iowa’s Antidegradation standards. We are opposed to the proposed changes and urge the Commission to reject them because they will significantly weaken Iowa’s antidegradation standards and undercut Iowa’s nutrient reduction strategy.

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I spoke at the May EPC meeting when the proposed rule changes were first considered to express concerns and with my colleagues, to suggest that a better approach would be to convene a stakeholders group to develop a collaborative approach that addresses stakeholders concerns without weakening water quality protections. Unfortunately, DNR has never convened the stakeholder process that we recommended and the proposed changes have remained largely the same. These rules are a one-size fits all approach to regulation with an arbitrary cost threshold instead of the weighing of environmental benefit and cost. We regularly hear from farmers and industry that when it comes to regulations one size fits all doesn’t work. This is a one size fits all approach that doesn’t work. The same test applies to a facility that serves hundreds of thousands or just hundreds – a large industrial facility or a small town. This approach doesn’t care if the pollution is upstream of a community drinking water source or where kids play. The approach to cost-effectiveness in the rule changes is different than any other approach people would take to evaluating cost-effectiveness. For example, a homeowner shopping for a home security system considers more than just the cost of the system – they also consider the safety and security they get for that cost. All systems provide some measure of safety and benefit, but the homeowner would evaluate exactly what they are getting for the cost. Furthermore, this evaluation would vary from home to home (e.g. high crime neighborhood, young kids in the home, etc.) Similarly, a strong approach to antidegradation requires evaluation and judgment to determine where to draw the line when comparing cost to environmental benefit, and not a one-size fits all approach. DNR argues that it does not know how to implement the existing rule, and it wants to provide certainty. We have significant water quality challenges in this state. If we throw our hands up every time addressing stakeholder concerns is hard or does not have a road map already in place, we will not solve our water quality problems. We need to innovate and develop those solutions and now is the time. We urge you to prioritize protection of our water quality, reject the proposed changes to Iowa’s antidegradation standard, and push DNR to bring stakeholders together to address concerns without weakening water quality protections. That’s how we’ll make progress towards clean water, not with these rule changes. Tim Whipple – Iowa Association of Municipal Utilities Tim Whipple shared with the Commission Iowa Association of Municipal Utilities support for the proposed rules on antidegradation. As one of the 3 petitioners for the rule change, the lawsuit issues for the City of Clarion was the main reason for initiating the petition. Evaluating the percentage of cost is not efficient. There is more than just the price consideration when purchasing a Ford or a Cadillac but the industry is being forced to buy the Cadillac. He believed that these decisions should be made at the community level - local decisions strengthen communities. Municipalities want clean water just like everyone else but they also want some say in the process of what costs are incurred. Vitality of small towns is a need and when debt gets too high other needs are unmet and people move out of the community. Susan Heathcote – Iowa Environmental Council Susan Heathcote shared with the Commission the Iowa Environmental Council does not support the proposed rules for antidegradation. She delivered the below comments. The purpose of Iowa’s Antidegradation rules is to maintain and protect existing water quality by requiring a review of alternative treatment options for new or expanding wastewater treatment facilities. The goal is to determine whether a reasonable treatment alternative exists that would reduce pollution and to require that alternative to be implemented if it is found to be practicable, economically efficient, AND affordable.

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The proposed rule changes before you today eliminate the requirement to consider environmental benefits of alternative treatment options, which is contrary to the entire purpose of Antidegradation. For example, the model Antidegradation Procedure provided by EPA Region 8 states that the MINIMUM requirement of an evaluation of alternatives must “provide substantial information pertaining to the costs and environmental impacts associated with” each alternative. We understand the need for clarity and predictability in this process; however, trying to achieve this by creating a one-size-fits-all “bright line” cost limit that applies in every case, regardless of the pollutants being discharged or the local economic and environmental conditions, is misguided. DNR has argued that the bright line test is more reasonable than the existing rule language, but we contend that the opposite is true. Anti-degradation requires a case-by-case approach because the impact of pollutants will vary by location depending on downstream uses. It’s also not reasonable to apply the same cost threshold to both a small town and a large industrial facility. The existing review procedures are reasonable and balanced, and provide a flexible approach that considers both costs and environmental impacts. If DNR believes that greater clarity is needed on how to conduct the environmental benefit review procedure, we propose that DNR work collaboratively with all of the stakeholders to provide more detailed guidance to applicants. We would welcome the opportunity to contribute to such a collaborative effort. Finally, it’s important to point out to the Commission that while DNR’s Responsiveness Summary lists several states with binding cost tests for economic efficiency, none of these state procedures were approved under the new federal requirements issued by EPA in August of 2015. We strongly believe that the changes that DNR is proposing are not consistent with the new federal minimum requirements for state Antidegradation programs. EPA is required to review and approve - or disapprove - these changes to Iowa’s water quality standards. If they disapprove, then any permits issued based on this revised procedure would be invalid under the Clean Water Act. We urge you to reject the proposed rule changes and keep clean water clean in Iowa.

John Schmidt – Self John Schmidt shared with the Commission how impressed he was with all the experts speaking about water quality and admitted that he was not an expert. He had read the petition for rulemaking and had a few questions. He asked the Commission, how did the petitioners, DNR, & EPC determine the value of certainty, clarity, and predictability? He believes the DNR did a great job in responding to all the comments. Minnesota adopted rules in 1988 with no quantitative value and cities and polluters work with the MN DNR to value environmental protections. In his own view, this topic is not just for the City of Clarion but all cities, states, and the nation. He encourages the federal government to provide monetary assistance to communities who need assistance and the Iowa Legislature needs to be involved rather than city by city. Molly Hanson – Iowa Rivers Revival Molly Hanson shared with the Commission Iowa Rivers Revival support and opposition of the proposed rules for antidegradation. She delivered the below comments. Good morning. My name is Molly Hanson and I am the Executive Director of Iowa Rivers Revival (IRR). We are a non-profit, statewide river advocacy group. IRR supports the current Anti-Degradation Implementation Procedure and opposes the proposed amendments that would eliminate the requirement for new or expanding wastewater treatment facilities to consider environmental benefits along with costs when evaluating less degrading treatment alternatives.

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Nearly two years of work went into crafting the current Anti-Degradation rules. During that process, stakeholders from environmental groups, municipalities and industries all had a seat at the table. Shouldn’t the approach to addressing the concerns of businesses and municipalities, ‘who contend the cost-benefit analysis is too difficult and expensive to calculate without clear methodology or process from the state,’ be similar in order to hear from all parties and compromise to find a reasonable path forward? We ask EPC to suspend this rulemaking effort and ask DNR to convene a stakeholder meeting to address the petitioners’ concerns for guidance and find a solution that will consider environmental benefits from a practical and affordable perspective. The Clean Water Act has provided critical protections for the nation’s waters for nearly 45 years. Anti-degradation standards are an important component of the act and are meant to keep clean water clean by preventing unnecessary new or increased pollution and are designed to ensure economic and environmental considerations are balanced. In other words, we all have to do our part and work together for clean and healthy water in Iowa. The proposed changes also undermine Iowa’s Nutrient Reduction Strategy, which calls for reductions from all sources contributing to water pollution. We should be aligning our permit process with the Nutrient Reduction Strategy rather than contradicting it. The Nutrient Reduction Strategy is another example of the principle that everyone is responsible for doing their part to reduce nutrients and pollution. Whether point-source pollution from cities and industry or multiple point pollution from agriculture, urban or rural, big or small, liberal or conservative; the plan will work only when everyone is willing to do their part. Attempting to adopt this rule change on an “emergency” basis seems like an unwarranted rush. What’s the emergency? And isn’t high nitrate and phosphate levels making their way into the waters that we drink from and recreate in a much greater emergency? The current rules require new or expanding wastewater treatment facilities to review a range of treatment alternatives and requires the selection of the least degrading alternative that is practical, economically efficient and affordable. For alternatives that are found to be affordable and practicable, the procedure allows elimination of less degrading alternatives if it can be demonstrated that the alternative is not economically efficient because the cost of treatment is disproportionate to the environmental benefit. If further clarification is required, then let a working stakeholder group help develop a clear methodology or process. Janis Elliot – ICCI Janis Elliot proposed to the Commission a year moritorium on approving new factory farms. She has attended a number of commission meeting listing to people speak with tears in their eyes on how factory farms have destroyed their lives. She spoke with a Legislator who lives next to a factory farm and he claimed he had not noticed any difference. She suggested all factory farms should be built in a way where there is no impact. Hearing how factory farms have ruined rural communities, she is scared when land goes up for sale. What is going to be built there? She asked the Commission to take time out and really investigate for those who have and have not been hurt by factory farms. Stephen Throssel – Eldora Land Owner Stephen Throssel shared with the Commission his accomplishments in 2000 by receiving the Governors Clean Water Award for his work in and around Pine Lake. He believes voluntary nutrient reduction programs are a disaster in Hardin County. Starting in the 1960’s, they have accomplished a number of projects to protect Pine Creek which starts on their property. In 2015, NRCS approached them with another project which he believes won’t stop or further help water quality. His family started as farmers and it is an honorable profession but they eventually got out of farming and went into manufacturing. Pine Lake watershed is in trouble with toxic water not safe to swim in. The beach sand is open but the

7

water has warning signs of E.coli and blue green algae. He believes NAFTA devastated their community. He asked the DNR where their community goes from here. Curt Lambertsen – Friends of Pine Lake Curt Lambertsen shared with the Commission background information about the Friends of Pine Lake organization. The state park has two lakes in which one lake has been unfit to swim in for the past couple of years. The process is broken despite the audits and inspections. The manure management plans up stream are not working and the manure is killing the lake. The reality is the lake is unfit and toxic. He doesn’t know how to get it fixed. There are fancy policies, audits, and rules but only practical farming and experience will fix it. As a volunteer at the state park, it kills him to watch his lake dying. Brenda Brink – ICCI Brenda Brink shared with the Commission the Chicago Tribune’s series on investigating Illinois hog factory farms as an unsustainable industry. In the article, the three main people who started factory farms were interviewed and at the time, they were leaders for the safety of hogs. But over time, corporations took over the business leaving the family farms behind. Young farmers are indentured servants to the corporations. She urged the Commission to issue clean water act permits. Erica Blair – ICCI Erica Blair shared with the Commission the below comments. On August 1, the Iowa Department of Natural Resources (DNR) submitted its 3-year progress report for the Work Plan Agreement between the DNR EPA, explaining what it has done to date to better implement the CWA for Iowa’s thousands of factory farms. But despite showing progress on paper, Iowa is still in a water crisis. The number of polluted waterways in the state continues to grow, there have been 67 manure spills into waterways since 2012, and DNR has yet to issue a single CWA permit to a hog confinement that has illegally discharged. Instead of issuing permits, DNR is allowing violators to choose to “permanently remedy” the cause of their violation without getting a permit. The loophole has undermined the entire Work Plan process and called the quality of DNR’s inspections into question. The report also reveals that in the course of conducting the Work Plan’s required state-wide CAFO inventory, DNR has discovered more than 5,000 animal feeding operations—not accounted for in the Plan—that it will need to assess for unpermitted discharges to Iowa waterways. It plans to postpone these evaluations until after the Work Plan is concluded. Public records obtained by CCI further indicate that DNR is allowing some of the few factory farms with permits to “cancel” permit coverage, without so much as a DNR inspection of the facility to confirm it is no longer discharging first. These public records also show DNR is changing its factory farm spill data entry practices to avoid public scrutiny, particularly from Iowa CCI. What the DNR is doing right now isn’t working. Iowa is in a water crisis. We need the DNR to issue CWA permits and hold polluters accountable. Debbie Neustadt – Sierra Club Debbie Neustadt shared with the Commission her role as a volunteer with the Sierra Club and her work over the years on water quality issues in Iowa. She does not agree with the Responsiveness Summary for the antidegradation proposed rules that there is a benefit at only 115%. She believes just because one

http://iowacci.org/uncategorized/dnr-open-records-request-docs/

8

spends more money doesn’t mean there will be more benefit. The EPA 2015 antideg implementation methods states lowering scores of economic benefit and environmental benefit should work hand in hand. She believes the DNR will say antidegradation and the Nutrient Reduction Strategy are two different things but she does not believe that. She believes if the state can hire a person to determine deer populations they can hire someone to determine the benefit of clean water. Written Comments Submitted

• Eric Wessels –I'd like to suggest a moratorium on the construction of hog confinements in Iowa until the legislature has an opportunity to address the failing regulatory system. When a CAFO can be constructed between a water quality improvement project and the waterway intended to be protected, there is a failure in the system. When communities pull together to implement water quality improvement programs, especially when intended to be demonstration projects, those projects need the full weight and support of the DNR and the State of Iowa. The CAFO built at Pine Lake show a lack of judgement on the part of the constructor and a lack of positive intervention on the part of the state. As a SWCD commissioner I see the positive efforts of the state and federal programs, but shake my head at the ways in which the state fails the people of Iowa and how quickly progress can be derailed. CAFOs are destroying Iowa. They need to be regulated.

END OF PUBLIC COMMENT

DIRECTORS REMARKS DNR Director Chuck Gipp shared with the Commission some people want the DNR to enforce regulations they don’t have and others don’t want the DNR to enforce the ones they do have. The Midwest states have a mutual concern for wastewater because not all towns and facilities are created equal. Iowa passed the Disadvantaged Communities law so small communities would not have to make wastewater improvements they can’t afford. On the other hand, wastewater improvements may be necessary in these communities, otherwise these communities cannot attract business for growth and expansion.

INFORMATION

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WATER SUPPLY: WATER USE & ALLOCATION ANNUAL PERMIT FEE Mark Moeller, Supervisor, of the Water Quality Bureau presented the following item. The Commission was asked to review the Water Use and Allocation Program budget and SFY 2017 annual permit fee, in anticipation of approving the annual fee at its September meeting. The proposed annual permit fee is $66.00 per permit for SFY 2017. Background: Water use permits are required of any person or entity using 25,000 gallons of water in a single day during the year, and are issued for a period of up to 10 years. Previously, appropriations from the General Fund were used to fund the water allocation and use permits program. During the 2008 legislative session, the legislature authorized the department to collect up to an additional $500,000 in fees each fiscal year. Iowa Code §455B.265(6) requires the fees to be based on the Department’s “reasonable cost of reviewing applications, issuing permits, ensuring compliance with the terms of the permits, and resolving water interference complaints.” There are two types of fees in the Water Use and Allocation Program: an application fee and an annual permit fee. This request is for the determination of the annual fee for SFY 2017. The annual fee rule, adopted in 2009, is summarized below (IAC 567-50.4(2)“b”): • Each year, the Commission is asked to set the annual fee based on the budgeted expenses for that year

minus the amount of any unused funds from the previous year and any general fund appropriations. • The department reviews the annual permit fee each year and adjusts the fee as necessary to cover all

reasonable costs required to develop and administer the water use permitting program. • The annual fee is based on the number of active permits. • Each permit holder pays the same annual fee. • The fee is not prorated and is nonrefundable. • The department requests Commission approval of the amount of the annual fee no later than

September 30 of each year. • The department provides an annual fee notice to each permittee at least 60 days prior to the fee due

date. • The annual fee due date is December 1st; 60 days prior is October 1st. There is no annual fee required for either a water storage permit (permitted for the life of the structure) or a minor nonrecurring water use registration (one-year permit duration). The annual permit fee was $135.00 in the first two years, $95.00 in SFY 2012, and $66.00 in SFY 2013 and SFY 2014, and $99.00 in SFY 2015 and SFY 2016.

SFY 2017 Budget: The worksheet included with this agenda brief illustrates the actual expenditures in SFY 2012 – 2016 and the budgeted amounts for SFY 2016 and SFY 2017. The final accounting figures for SFY 2016 are not expected to change. In addition to accomplishing the normal work activities of the program, the budget in 2017 includes the following: • Continuing with the well-matching efforts for the various aquifers, • Increase use of the on-line database by permittees for annual use reports and fee payment, and • Continue to implement the Jordan aquifer management strategies, working with affected systems that

are near Tier 2-3 levels. Fee Analysis: At the Water Use Stakeholder meeting on July 28, 2016, the program’s activities and budget were reviewed. A $66.00 annual water use permit fee was proposed for SFY 2017, which is a reduction of $33.00 from the SFY 2016 annual fee. The stakeholder members participating in the meeting concurred. Based on the budget and stakeholder input, the annual water use permit fee for SFY 2017 should be $66.00.

INFORMATION

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CONTRACT WITH UNIVERSITY OF IOWA FOR MAPPING REVIEW SERVICES Calvin Wolter, GIS Analyst, of the Land Quality Bureau presented the following item. Commission approval was requested for a ten month service contract with University of Iowa of Iowa City, IA. The contract will begin on September 1, 2016 and terminate on June 30, 2017. The total amount of this contract shall not exceed $40,000.00.

Funding Source:

This contract will be funded through Environment First funds (HB7A).

Background:

Last year, the Best Management Practices (BMP) GIS data was reviewed by GIS Section staff. This is no longer possible due to staff work load. In order to perform this necessary procedure, the GIS Section wishes to contract with the University of Iowa for GIS services. GIS Section staff will train University of Iowa staff to perform quality assurance and control on BMP mapping data. The University of Iowa has provided high quality GIS staff services to the IDNR in the past, and has been a good value for the Department.

Purpose:

The parties propose to enter into this Contract for the purpose of retaining the Contractor to provide BMP mapping review services:

This project will require reviewing the HUC12 geodatabases of BMPs mapped by ISU GIS facility for completeness and accuracy. Each geodatabase has six BMPs that are being mapped: 1) Terraces, 2) Water and Sediment Control Basins (WASCOBs), 3) Pond dams, 4) Grassed waterways, 5) Contour buffer strips and 6) Contour strip cropping. The review process will require comparing the mapped BMPs to LiDAR derived hillshade and slope grids as well as current and historical aerial imagery including CIR, NAIP and decadal images. The review will make sure all practices in that watershed are captured and that all practices captured are the correct practices. Any changes will be tracked by timestamp and initials of the reviewer in the appropriate attribute.

There are currently over 100 watersheds that need to be reviewed and in the next year at least another 100 more will be produced by the ISU GIS facility. The goal of this project is to complete all of the watersheds that have currently been submitted by ISU and all of the new watersheds completed in FY2017.

Motion was made by Bob Sinclair to approve the agenda item as presented. Seconded by Nancy Couser. Motion carried unanimously


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ADOPTED AND FILED –DISPOSAL OF YARD WASTE Theresa Stiner, Environmental Specialist Senior, of the Land Quality Bureau presented the following item. The Commission was requested to approve this Adopted and Filed to amend administrative rule 567 IAC 105.1 and subparagraph 567 IAC 113.8(1)“b”(13). These amendments are related to the disposal of yard waste. Notice of Intended Action was published in the Iowa Administrative Bulletin as ARC 2539C on May 25, 2016. A public hearing was held on June 14, 2016 in the Wallace State Office Building. The Department also accepted written comments through June 14, 2016. The Department received one written comment from Cindy Turkle of Turkle-Clark Environmental Consulting. She expressed concern that allowing landfills that operate a methane recovery system that produces energy to accept yard waste for disposal will make it difficult for residents to understand why some communities are allowed to include yard waste with their trash while others are not. She is also concerned that sanitary landfills that are not allowed to accept yard waste will have difficulty keeping the yard waste out of their landfill. She suggested expanding the exemption to all sanitary landfills. Because the law specifies that yard waste is prohibited from landfill disposal other than in the specific circumstances listed, the DNR does not have the authority to allow yard waste disposal at landfills that do not have a methane recovery system that produces energy. Therefore no changes to the proposed amendments have been made. The amended rule will allow yard waste to be disposed in a sanitary landfill in the following circumstances:

• When yard waste is collected for disposal as a result of a severe storm and the yard waste originates in an area declared to be a disaster area.

• When yard waste is collected for disposal to control, eradicate or prevent the spread of insect pests, tree and plant diseases, or invasive plant species.

• When yard waste is disposed of in a sanitary landfill that operates a methane collection system that produces energy.

The amended rule will also remove the requirement for municipalities that provide for the collection of solid waste to also provide for separate collection of yard waste. The exemptions to the prohibition of yard waste disposal were added to Iowa Code section 455D.9(1) by Senate File 2212 (2014), signed by Governor Branstad on April 3, 2014 and House File 266 (2015), signed by Governor Branstad on March 31, 2015. The requirement for municipalities to provide separate collection of yard waste was removed from Iowa Code section 455D.9(2) by House File 225 (2013), signed by Governor Branstad on March 28, 2013. These amendments are needed to make changes to the administrative rules to be consistent with the above legislation. Motion was made by Gene Ver Steeg to approve the agenda item as presented. Seconded by Joe Riding. Motion carried unanimously


12

SOLID WASTE ENVIRONMENTAL MANAGEMENT SYSTEM PROGRAM’S FUNDING ASSISTANCE CRITERIA-UPDATE Leslie Goldsmith, Program Planner, of the Land Quality Bureau presented the following item. The Department requested commission approval of the revised funding assistance criteria for the Environmental Management System (EMS) Program. The authority for commission approval for these criteria is provided in Code of Iowa Subsection 455J.7(3). This provision states that the Solid Waste Alternatives Program Advisory Council (council) shall recommend to the Environmental Protection Commission (commission) a reasonable allocation of the moneys to eligible program participants and shall adopt and use a set of reasonable criteria that shall be approved by the commission. Funding Source: The funds for the EMS budget are authorized in Code of Iowa Subparagraph 455E.11(2)”a”(1). The source of the funding is a portion of the remitted solid waste tonnage fees deposited into the Solid Waste Alternatives Program (SWAP) account and is earmarked for use by the EMS program. Background: In 2008, the Iowa Legislature passed House File (HF) 2570 establishing a Solid Waste Environmental Management Systems (EMS) program for solid waste planning areas across Iowa. The legislation identified six specific areas that solid waste agencies participating in the program must be able to document continuous improvement in terms of meeting specific goals and objectives. These areas are:

• yard waste management • hazardous household waste management • water quality improvement

• greenhouse gas reduction • recycling • environmental education.

The legislation appropriated funding to assist in developing the program and providing ongoing support to the program participants. A nine-member council appointed by the Director provides program oversight and recommendations to the commission regarding program budget and participants. The EMS program currently includes thirteen (13) participants representing planning areas and permitted facility service areas serving 30 counties across Iowa. After the FY2016 Funding Assistance round, the EMS Council, EMS program participants and DNR staff determined the funding process utilized, similar to the Solid Waste Alternatives Program process, did not fit the needs of the program. The updated criteria is the result of three parties working together to improve the EMS program. Purpose: The council recommended that the attached updated criteria for awarding Environmental Management System Funding be approved on a unanimous vote at the May 19, 2016, meeting. A summary of changes:

• This criteria document removes “grant” funding details such as funding dates and amounts. It directs the council to set the program budget including the dollar amount of funding assistance for program participants.

• The funding application and review process is noted in the criteria document. The EMS Funding Assistance Process document is attached.

Motion was made by Ralph Lents to approve the agenda item as presented. Seconded by Chad Ingels. Motion carried unanimously


2

CONTRACTS WITH IOWA DEPARTMENT OF AGRICULTURE AND LAND STEWARDSHIP AND CITY OF CLEAR LAKE FOR WATERSHED PROJECTS Steve Hopkins, Nonpoint Source Coordinator, of the Water Quality Bureau presented the following item. Commission approval was requested for three contracts with the Iowa Department of Agriculture and Land Stewardship and one contract with the City of Clear Lake to provide funding to implement four watershed improvement projects. The total amount of these contracts shall not exceed $933,793.

Funding Source:

These contracts will be funded through a federal grant from the United States Environmental Protection Agency, under Section 319 of the Clean Water Act.

Background:

The following contracts with IDALS are presented for approval:

Easter lake Watershed Project – Phase 2 $185,646

Big Creek Watershed Project Phase II $323,255

Silver Creek Watershed Project $220,000

Contract with City of Clear Lake:

Clear Lake Enhancement and Restoration Project $204,892

Total $933,793

Purpose:

The parties propose to enter into these contracts for the purpose of implementing watershed improvement practices and water quality educational programming for the projects selected.

Contractor Selection Process:

These projects were chosen using a grant proposal application and committee review process.

Motion was made by Bob Sinclair to approve the 3 contracts with IDALS and the 1 contract with the City of Clear Lake, as set out in Agenda item #10. Seconded by Cindy Greiman. Motion carried unanimously


3

CONTRACT AMENDMENT WITH IDALS FOR PROGRAM STAFFING--REGIONAL BASIN COORDINATORS Steve Hopkins, Nonpoint Source Coordinator, of the Water Quality Bureau presented the following item. Commission approval was requested for a Contract Amendment with the Iowa Department of Agriculture and Land Stewardship (IDALS). The amendment will begin on August 10, 2016 and terminate on August 31, 2017. The total amended amount shall not exceed $150,000.

Funding Source:

This Contract Amendment will be funded through a federal grant from the United States Environmental Protection Agency under Section 319 of the Clean Water Act.

Background:

For more than a decade, IDALS has provided staffing support to the Section 319 program through the deployment of 3 Regional Basin Coordinators in various locations throughout Iowa. The Regional Basin Coordinators are charged with assisting to implement the State of Iowa’s Nonpoint Source Management Plan in coordination with the Iowa Department of Natural Resources, through general outreach opportunities and technical and administrative assistance to local watershed groups, the public, agency staff, municipal leaders and politicians.

Purpose:

The parties propose to enter into this Contract Amendment for the purpose of retaining the Contractor to provide Regional Basin Coordinator staffing for watershed planning and project implementation.

Contractor Selection Process:

IDALS was selected for this project because of its ongoing overall program coordination with DNR in providing Regional Basin Coordinator staffing for watershed planning and project implementation.

Contract History:

This Contract Amendment is a one-year amendment to an existing contract, which followed a series of contracts with IDALS to provide Regional Basin Coordinator program staffing to support watershed planning and project implementation.

Motion was made by Gene Ver Steeg to approve the agenda item as presented. Seconded by Nancy Couser. Motion carried unanimously


4

ADOPTED AND FILED – AMENDMENTS TO WASTEWATER RULES RELATED TO THE IOWA ANTIDEGRADATION IMPLEMENTATION PROCEDURE AS ADOPTED BY REFERENCE IN THE IOWA ADMINISTRATIVE CODE, CHAPTERS 61 AND 64. Jon Tack, Bureau Chief, of the Water Quality Bureau presented the following item. Changes to Chapter 61 “Water Quality Standards” and Chapter 64 “Wastewater Construction and Operation Permits,” are being presented to the Commission for Final Adoption. The purpose of the proposed amendments is to update the Iowa Antidegradation Implementation Procedure, which is incorporated by reference into rule. The Commission and the Department of Natural Resources (Department) received a Petition for Rulemaking from the Iowa Association of Municipal Utilities, the Iowa League of Cities, and the Iowa Association of Business and Industry on April 25, 2016. The Petition was filed in response to concerns by petitioners regarding the Department’s cost-benefit analysis in its Antidegradation Implementation Procedure. Petitioners believe that without a bright-line standard to conduct this analysis, municipal and industrial permit applicants will face excessively burdensome costs to quantify, evaluate and compare environmental benefits with the costs of each treatment alternative being considered during the antidegradation review process. Because the Department has not developed a methodology to be utilized for such a comparison and a process and methodology for the review and approval of such an evaluation, the petitioners urged the Commission to revise the Iowa Antidegradation Implementation Procedure to prevent the imposition of such a burdensome and expensive requirement. In response to the Petition, the Commission approved a Notice of Intended Action on May 17, 2016, initiating this rulemaking. The final rule amendments modify the language of the Antidegradation Implementation Procedure to establish a bright line standard for reviewing the economic efficiency of proposed less degrading wastewater treatment and disposal alternatives. The Department received 421 public comments in response to the Notice of Intended Action. In response to comments, a responsiveness summary has been prepared and revisions to the implementation procedure have been made to provide clarification. The revised Iowa Antidegradation Implementation Procedure and responsiveness summary can be viewed at: http://www.iowadnr.gov/Environmental-Protection/Water-Quality/Water-Quality-Standards/Antidegradation . Jon Tack addressed comments made during the Public Comments portion of the agenda to clarify for the Commissioners the 115% figure, history of the process, approach for gathering comments, newspaper articles, and how the proposed rules do not impact the Nutrient Reduction Strategy. Motion was made by Chad Ingels to approve the agenda item as presented. Seconded by Ralph Lents. Motion carried unanimously


http://www.iowadnr.gov/Environmental-Protection/Water-Quality/Water-Quality-Standards/Antidegradation

5

GENERAL DISCUSSION Annual Report – Ed Tormey shared with the Commission two Iowa Code references that contradict each other on when to submit the EPC report (biennial vs. annual). From the discussion, Ed Tormey gained the preference of the Commission and DNR will begin exploring options for fixing the conflicting code. Upcoming Meetings - Jerah Sheets summarized the EPC meeting locations for September, October, and November. Accolades – Commissioner Joe Riding complimented the DNR on its assistance with nuisance geese.

INFORMATION Chairperson Boote excused herself from the remainder of the meeting. Lunch Break

REFERRAL TO THE ATTORNEY GENERAL – GARY EGGERS David Scott, Attorney of the Legal Services Bureau, represented the Department on the following item. To his aid was David Miller, Environmental Specialist, of the Mason City Field Office. Gary Eggers was not in attendance or had representatives on his behalf. Dave Scott requested that the EPC vote to refer Mr. Gary Eggers of Stacyville, Iowa to the Iowa Attorney General’s office for civil enforcement. The information in the litigation package explains this matter has been ongoing since at least 2013. Mr. Eggers has illegally dumped thousands of tires on his property and has ignored efforts by DNR to have him properly remove and dispose of those tires. Photos also show some of those tires have been washed into a creek that runs through his property. The Iowa legislature has established that this kind of land disposal of waste tires is prohibited. Administrative efforts by DNR, including correspondences, notices of violation, and the filing of an Administrative Order against Mr. Eggers have failed to achieve DNR’s goal of getting the property cleaned up. David Scott believes additional administrative enforcement action will not be effective, so he asked that the matter be referred to the Attorney General’s office for civil judicial enforcement. Motion was made by Bob Sinclair to refer the Gary Eggers to the Attorney General’s Office. Seconded by Joe Riding. Motion carried unanimously

REFERRED Vice-Chairperson Ingels adjourned the Environmental Protection Commission meeting at 1:08 p.m., Wednesday, August 10, 2016.

Item No. Facility/City Program DNR Reviewer Subject Decision Date1 Barnum Water Supply Water Supply Contruction Skipp Slattenow variance from fuel separation distance from existing well. approved 5/31/2016

2 County Road E39 over Otter Creek Flood Plain Karen Smith Variance to freeboard criterion that low chord of bridge must be set 3 feet above 50-year flood elevation. approved 6/20/2016

3 Iowa-American Water Co-Clinton District Waster Supply Construction Lanie Boas

variance to use (DIP) ductile iron pipe with nitrile gaskets where storm sewer less than 18 feet above sanitary sewer instead of constructing storm sewer of water main material. Water main will be installed in PVC casing pipe with casing spacers and end seal where minimum vertical clearance can't be maintained approved 7/5/2016

4 Souther Iowa Rural Water Association Waster Supply Construction Robert Campbell variance to new water main bacteria sampling locations and surface water crossing requirements. approved 7/6/2016

5 Little Swan Lake Outlet Flood Plain Jonathan Gartonvariance to criterion that dam with single spillway to pass freeboard design storm with two feet of freeboard. approved 7/7/2016

6 US 67 Trail & Pedestrian Bridge Flood Plain Andy Jensen variance to required 3 feet freeboard required for Q50 flow rate approved 7/7/20167 University of Iowa Air Quality Brian Hutchins variance to allow use of construction exemptions while utilizing PAL permits. approved 7/7/20168 Land Quality Bureau IDNR Land Quaility Lauri Sharp variance to well drilling contactor certification fees approved 7/7/2016

9 Amsted Industries Industrial Waste Landfill Land Quaility Mick Leatrequesting all data collected using earlier sampling techniques not be used to calculate control limits, and replacement of dissolved iron analysis with total analysis. approved 7/7/2016

10 Iowa-American Water Water Supply Contruction Lanie Boas

construct water main of ductile iron pipe (DIP) with nitrile gaskets or construct storm sewer of gasketed RCP instead of constructing sewer of water main material where it crosses under or less than 18 inches over sewer. Water main is being installed in casing pipe where minimum vertical clearance can't be maintained approved 7/11/2016

11 Oakland Foods LLC Wastewater Mark Valmorevariance to install aeration equipment with lower amount of total mechanical aeration horsepower than required. approved 7/11/2016

12 Lemars Water Department Water Supply Contruction Lanie Boasvariance to construct water main of ductile iron pipe (DIP) with nitrile gaskets at critical crossings where storm sewer crosses over water main instead of constructing storm sewer with water main material. approved 7/11/2016

13 Silgan Containers Mfg Corp Air Quality Dennis Thelen variance to extend deadline to perform stack testing as facility isn't operating at capacity. approved 7/12/201614 American Concrete Air Quality Reid Bermel variance for a temporary process change without obtaining modified construct permits. approved 7/21/2016

15 Hospital Connector Trail Phase 2 Flood Plain Karen Smith Variance to freeboard criterion that low chord of bridge must be set 3 feet above 50-year flood elevation. approved 7/27/2016

Monthly Variance ReportJuly 2016

DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION COMMISSION

ATTORNEY GENERAL REFERRALS August, 2016

Name, Location and New or Region Number Program Alleged Violation DNR Action Updated Status Date

1

Abatement Specialties, LLC Cedar Rapids (1)

Air Quality Asbestos Referred to Attorney General

Referred 2/16/16

Cedar Rapids Community School District Cedar Rapids (1)

Air Quality Asbestos Referred to Attorney General

Referred 2/16/16

Feinberg, Marty; Feinberg Metals Recycling Corp. Fort Madison (6)

Solid Waste Operation Without Permit; Illegal Disposal

Referred to Attorney General

Referred Petition filed 7/1/16

4/14/15

Frye, Jim Independence (1)

Animal Feeding Operation

Prohibited Discharge – Confinement; WQ Violations – General Criteria; Failure to Report a Release; Operational Violations


Referred Petition Filed 7/20/16 Consent Decree Approved 7/21/16

2/16/16

Kossuth County (2) Animal

Feeding Operation

DNR Defendant Defense Petition for Judicial Review State’s Answer P&J Pork Motion to Intervene Order Granting Motion to Intervene Kossuth County Brief State’s Brief District Court Review Without Oral Argument Ruling on Petition for Judicial Review Remanded to EPC EPC Rehearing EPC Reconsideration Kossuth County Application for Rehearing Petition for Judicial Review EPC’s Answer P&J Pork Motion to Intervene Kossuth County Brief State’s Brief P&J Pork Joinder in State Brief Kossuth County Application for Leave To Present Evidence State’s Resistance to Application District Court Review Without Oral Argument Court Hearing on County Application For Leave to Present Evidence Ruling on Motion for Remand – Remanded to EPC

9/18/14 10/08/14 11/07/14 11/20/14 2/03/15 2/13/15 3/04/15 7/30/15 10/20/15 11/17/15 12/07/15 12/15/15 1/14/16 1/15/16 2/23/16 3/11/16 3/14/16 3/21/16 3/21/16 3/21/16 4/18/16 6/07/16


ATTORNEY GENERAL REFERRALS August, 2016

Name, Location and New or Region Number Program Alleged Violation DNR Action Updated Status Date

2

Peeters Development Co., Inc.; Mt. Joy Mobile Home Park Davenport (6)

Wastewater Water Supply

Monitoring/Reporting; Compliance Schedule; Discharge Limits; Operation Violations; Certified Operator Discipline


Referred Petition Filed Answer Filed Trial Scheduling Conference Order Setting Trial for 9/13/16 Amended Petition Filed State’s Application for Default Entry of Default State’s Motion for Judgment Withdrawal of Motion for Judgment Answer to Amended Petition Settlement Agreement Executed

3/18/14 6/18/15 7/16/15 9/25/15 9/25/15 12/17/15 1/25/16 2/18/16 2/19/16 3/08/16 3/17/16 6/27/16

SABEER, LLC d/b/a Sleepy Hollow Campground Oxford (6)

Wastewater Water Supply Air Quality

NPDES Permit Violations; Water Supply Permit Violations; Open Burning


Referred Settlement Agreement signed-not approved by district court yet

6/16/15

Sunrise Farms, Inc. Osceola Co. (3)

Animal Feeding Operation

Construction Without Permit; Operating Violations; WQ Violations – General Criteria


Referred 3/23/16

City of Sioux City (3) Wastewater Referred to

Attorney General Referred 6/27/16

Sedore Inc.; Troy and Emily Sedore Air Quality

Solid Waste Wastewater

Open Burning; Operation Permit Violations. Illegal Disposal; SWAP Agreement Violations; Operation Without a Permit


Referred 6/27/16

Gary Eggers (2) Wastewater

Solid Waste Operation Without Permit; Illegal Disposal; Prohibited Discharge


Referred 8/24/16


CONTESTED CASES September, 2016

DATE RECEIVED

NAME OF CASE

F.O. ACTION APPEALED

PROGRAM ASSIGNED

TO

STATUS

1

3/11/10 Bondurant, City of 5 Order/Penalty WW Hansen 7/2013-On hold pending further investigation. 5/15 – Letter to City Attorney regarding meeting to discuss appeal.

8-27-12 Ag Processing, Inc.; Sergeant Bluff

4 Permit Conditions AQ Preziosi Met with appellant on 7/8/15. Settled in concept. Last communication with appellant 6-15-16.

11-21-12 Ag Processing Inc. 6 Permit Conditions AQ Preziosi Met with appellant 8/6/15. Settled in concept. Last communication with appellant 4-18-16.

6-10-13 Mike Jahnke 1 Dam Application FP Schoenebaum Hearing held 7/30/14. ALJ upheld the permit issued by the Department. Mr. Jahnke appealed but on 11/3/14 he asked that his appeal be put on hold until April, 2015. For various reasons has asked that the appeal be postponed through Summer 2016.

1/16/14 Council Bluffs Water Works 4 Permit Conditions WW Tack Hearing continued. Settlement discussions ongoing.

4/17/14 REIC/Iowa Co. Sanitary Landfill 6 Permit Conditions WW Tack 4/27/15 Consent Order signed by REIC. Awaiting receipt.

2/05/15 Mahle Engine Components USA 4 Order/Penalty WW Hansen Negotiating before filing. 5/15 – Settlement conference to be scheduled.

3/31/15 Duane Covington 5 Notice to Revoke License WS Hansen Hearing continued to 4/18/16.

5/22/15 Cedar Ridge Vineyards 6 Order/Penalty WW Hansen Negotiating before filing.

7/02/15 Emmetsburg, City of 3 Permit Conditions WW Crotty 4/16 - City originally requested a permit appeal. Now, in lieu of permit appeal, City has requested an administrative consent order with a compliance schedule. Terms of the consent order are being negotiated. Meeting with city first week of September 2016.

10/12/15 Ames-Story Environmental C&D Landfill, Inc.

5 Amendment #4 to SDP SW Scott DNR and the party are in negotiations concerning amended permit terms. The party requested that a hearing not be scheduled until negotiations are completed.

10/20/15 Diana Costello 6 Permit Issuance FP Schoenebaum Negotiating before filing.

11/15/15 Cargill, Inc. 5 Permit Conditions AQ Preziosi Last communication with appellant 4-12-16.

2/25/16 Rathbun Area Solid Waste Commission (RASWC)

5 Permit Condition Amendments

SW Scott Negotiating before filing.


CONTESTED CASES September, 2016

DATE RECEIVED

NAME OF CASE

F.O. ACTION APPEALED

PROGRAM ASSIGNED

TO

STATUS

2

3/08/16 Chariton Municipal Water Works 5 Order/Penalty WS Hansen 4/20/16- Letter received from Chariton attorney regarding appeal.

4/29/16 Burt’s Tavern 1 Permit Conditions WS Hansen Negotiating before filing.

6/27/16 Plum River Fault Line Golf Inc.; Meadowcrest Farms, Ltd.

1 Order/Penalty WS Hansen 6/27/16 – Letter received from James Holst regarding appeal.

7/25/16 Hilltop Road Association #1 6 Order/Penalty WS Hansen 7/25/16 – Letter received from Association president regarding appeal.

DATE: September, 2016 TO: EPC FROM: Ed Tormey RE: Enforcement Report Update The following new enforcement actions were taken during this reporting period: Name, Location and Field Office Number Program Alleged Violation Action Date Donald, Ronald, Anne, and Ericka Breuer

Solid Waste, Air Quality

Illegal disposal; open burning Administrative Order

8/17/16

Patricia Plagge Jorgensen Animal Feeding

Operation Prohibited discharge; water quality violations

Consent Order 8/22/16

Steven R. Hopkins Air Quality,

Solid Waste Fugitive dust Consent Order 8/23/16

Schon Manure Hauling LLC Animal Feeding

Operations Prohibited discharge; water quality violations

Consent Order 8/23/16

IOWA DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION COMMISSION

RULE MAKING STATUS REPORT September 2016

Proposal

Stakeholder Engagement

Sent for Governor’s Pre-Approval (Job Impact) Statement

Notice to EPC

Notice Published

ARRC No.

ARRC Mtg.

Hearing

Comment Period

Final Summary To EPC

Rules Adopted

Rules Published

ARRC No.

ARRC Mtg.

Rule Effective

1. Ch. 20, 21, 22, 23, 25, 26, 27,28, 31 and 33 – 5-Year Rules Review Plan

12/17/15

2. Ch. 61 – WQ Standards - Copper

1/14/16 3/08/16 9/20/16

3. Ch. 61, Ch. 64 – Antidegradation Implementation Procedure

5/17/16

6/08/16

2579C 7/14/16

6/29/16

6/29/16 8/10/16 8/10/16 8/31/16 2695C 8/12/16

4. Ch. 64 – NPDES – General Permit No. 7

12/17/15 1/27/16

2/17/16

3/16/16

2441C

4/08/16

4/05/16

4/05/16

5/17/16

5/17/16

6/08/16

2572C 7/14/16

5/18/16

5. Ch. 64 – NPDES – General Permit No. 5

1/11/16 2/11/16

2/17/16

3/16/16

2442C

4/08/16

4/07/16

4/07/16

5/17/16

5/17/16

6/08/16

2571C 7/14/16

7/13/16

6. Ch. 65 – Animal Feeding Operations

1/15/16 2/22/16

3/15/16

4/13/16

2496C

5/10/16

5/23-26/16 5/31/16 6/03/16

6/03/16

7. Ch. 70, 71 and 72 – Flood Plain Development Permit

4/07/16 5/17/16

6/21/16

7/20/16 2629C

8/10/16

8/10/16 9/20/16

8. Ch. 100, 101 and 111 – Solid Waste Comprehensive Planning Requirements – Rule Clean-Up

2/18/16 5/02/16

6/21/16

7/20/16 2630C

8/09/16

8/09/16 9/20/16

9. Ch. 105, 113 – Yard Waste Disposal

2/12/16 3/24/16

4/19/16

5/25/16

2539C

6/14/16

6/14/16

6/14/16 8/10/16 8/10/16 8/31/16 2692C 10/5/16

10. Ch. 20, 21, 22, 23, 25, 26, 27, 28, 31, and 33 – Air Quality

6/15/16

#Animal Feeding Operation BOLD Entries Have Been Referred to DRF

1

IOWA DEPARTMENT OF NATURAL RESOURCES LEGAL SERVICES BUREAU DATE: September 1, 2016 TO: Environmental Protection Commission FROM: Ed Tormey SUBJECT: Summary of Administrative Penalties The following administrative penalties are due:

NAME/LOCATION PROGRAM AMOUNT DUE DATE James Harter (Fairfield) WW 1,336 8-01-01 Floyd Kroeze (Butler Co.) AFO 1,500 2-20-01 Albert Miller (Kalona) AQ/SW 9,735 9-26-03 Interchange Service Co., Inc., et.al. (Onawa) WW 6,000 5-07-04 Cash Brewer (Cherokee Co.) AFO/SW 10,000 8-25-04 Harold Linnaberry (Clinton Co.) SW 1,000 5-18-05 Joel McNeill (Kossuth Co.) AFO 2,500 1 21-06 Joshua Van Der Weide (Lyon Co.) AFO 3,500 2-25-08 Jon Knabel (Clinton Co.) AQ/SW 2,000 12-16-08 Rick Renken (LeMars) AFO 996 7-03-09 Brian Lill (Sioux Co.) AFO 755.07 7-18-09 Denny Geer (New Market) SW 9,476 10-31-09 Shrey Petroleum; Palean Oil; Profuel Three (Keokuk) UT 10,000 3-19-10 Alchemist USA, LLC; Ravinder Singh (Malcom) UT 8,260 5-03-10 LJ Unlimited, LLC (Franklin Co.) AFO/AQ/SW 3,500 5-27-10 AKD Investments, LLC; H.M. Mart, Inc. (Blue Grass) UT 6,900 8-06-10 Joe McNeill (Kossuth Co.) AFO 2,460 12-23-10 Steve Friesth (Webster Co.) AQ/SW 6,650.24 11-26-11 Josh Oetken (Worth Co.) AQ/SW 8,220 3-11-12 Bhupinder Gangahar/Saroj Gangahar/International

Business UT 7,935 4-20-12

Terry Philips; TK Enterprises (Washington Co.) AQ/WW 2,841.67 5-30-12 Boerderij De Vedhoek, LLC (Butler Co.) AFO 8,500 11-16-12 B Petro Corporation (Cedar Rapids) UT 7,728 5-13-13 Ken Odom (Iowa Co.) AQ/SW 4,940 4-26-13 Massey Properties, LLC; The Wharf (Dubuque) WS 10,000 10-05-13 Robert Downing (Mahaska Co.) AQ/SW 9,414 11-20-13 Randy Wise; Wise Construction (Buena Vista Co.) AQ/SW 3,000 4-10-14 Advanced Electroforming, Inc. (Cedar Co.) AQ 1,500 4-03-14 Western Iowa Telephone Assoc. (Lawton) WW 4,000 5-24-14 Wendall Abkes (Parkersburg) SW 3,000 7-30-14 Annie’s LLC; Togie Pub (Lime Springs) WS 2,720 12-22-14 Joel Thys; Thys Chevrolet, Inc. (Benton Co.) AQ/SW 10,000 1-04-15 West Central Cooperative (Halbur) WW 4,000 1-04-15 Mark Yeggy; Randalyn Yeggy (Washington Co.) AFO 5,000 3-23-15 Tim VanEaton (Orient) AFO 6,000 7-21-15 Gary Eggers (Stacyville) SW/WW 10,000 10-17-15 Sedore, Inc.; Sedore Sanitation and Recycling

(Stockport) AQ/SW/WW 10,000 3-09-16


2

Dennis R. Phillips; Marty’s Convenience Mart (Riverton)

UT 10,000 3-29-16

Jeremy VanderVegt; Boerderij DeVeldhoek LLC (Butler Co.)

AFO 10,000 4-29-16

Sedore Inc.; Sedore Sanitation & Recycling (Stockport) SW/AQ/WW 10,000 5-09-16 Oxford Junction, City of WW 1,000 5-09-16 Guthrie Co. Board of Supervisors; Country View Estates WW 1,000 5-09-16 John Westra; Summit Dairy (Primghar) AFO 1,750 6-1-16 Frank Robak (Little Sioux) UT 10,000 6-10-16 New Liberty, City of WW/WS 6,800 7-23-16 Mary Jo Engle; Doug Engle; Jo’s Longbranch Bar (Cresco)

WS 4,500 7-26-16

Pieper, Inc. (Lee Co.) AFO 3,000 8-07-16

TOTAL 263,416.98 The following penalties have been assessed but are not due at this time:

Donald, Ronald, Anne, and Ericka Breuer SW/AQ 7,694.50 9-17-16 Steven R. Hopkins AQ/SW 750 9-23-16 TOTAL 8,444.50 The following penalties have been placed on payment plans: Douglas Bloomquist (Webster Co.) AQ/SW 3,500 12-01-07 Jerry Passehl (Latimer) SW/WW/HC 3,845 7-01-09 Jerry Wernimont (Carroll) AQ/SW 216 4-19-10 R.H. Hummer Jr., Inc.; 2161 Highway 6 Trail (Iowa Co.) AQ/SW 3,643 9-15-13 Millard Elston III; The Earthman (Jefferson Co.) AQ/SW 1,815 2-15-13 Simon Simonson (Kossuth Co.) SW 2,500 11-30-14 Steve Boevers and Dresden LLC (Chickasaw Co.) AFO 3,000 2-01-16 Terry McMurray; Virginia McMurray (Bussey) AQ 2,260 12-01-15 Lavern VanLoon (O’Brien Co.) AFO 500 5-15-16 Bret Cassens; J & J Pit Stop (Columbus Junction) UT 700 6-20-10 Paul Koth (Buena Vista Co.) WW 6,000 3-23-17 TOTAL 27,979 The following administrative penalties have been appealed: Bondurant, City of WW 10,000 Mahle Engine Components USA, Inc. (Atlantic) WW 10,000 Cedar Ridge Vineyard, LLC (Swisher) WW 1,500 Chariton Municipal Water Works WS 10,000 Plum River Fault Line Golf; Meadowcrest Farms (Preston) WS 9,000 Hilltop Road Association #1 WS 5,000 TOTAL 45,500


3

The following administrative penalties have been collected: Simon Simonson (Whittemore) SW 100 Krauskopf Pumping Service, LLC (Allamakee Co.) AFO 2,000 Patricia Jorgensen (Denison) AFO 500 Schon Manure Hauling LLC AFO 5,000 John Meyer (Poweshiek Co.) AQ/SW 5,610 Terry McMurray; Virginia McMurray (Bussey) AQ 100 Bret Cassens; J & J Pit Stop (Columbus Junction) UT 100 TOTAL 13,410

Iowa Nutrient Reduction Strategy Annual Progress Report

Prepared by:Iowa Department of

Agriculture & Land Stewardship,

Iowa Department of Natural Resources,

Iowa State University College of Agriculture &

Life SciencesJuly 2016

Reporting Period: June 1, 2015

through May 31, 2016

Annual Progress Report | 2015-2016 | Page i

Inputs

Human

Land

Water

Highlighted Partner Updates...........................................Page ii

Tracking Progress...........................................................Page iii

Introduction....................................................................Page 1

......................................................................Page 3

Public Comment...........................................................Page 37

....................................................................Page 25

Appendix B: Progress of the Conservation Practice Mapping Project.........................Page 38

Appendix A: INRS Updates Evaluation.........................Page 38

....................................................................Page 19

....................................................................Page 14

Table of Contents

Annual Progress Report | 2015-2016 | Page ii

Highlighted Partner Updates

Water Quality Monitoring

IIHR—Hydroscience and Engineering deployed 30 nitrate sensors in the 2015 calendar year, and 45 in 2016.

The Iowa Department of Natural Resources (DNR) coordinated a collaborative paper to review the current network of water quality monitoring across Iowa (publication forthcoming).

NRS Measurement

12 member organizations of the Water Resources Coordinating Council and the Watershed Planning Advisory Committee and 4 other partners submitted reports on funding and efforts. These data contribute to tracking of Nutrient Reduction Strategy (NRS) progress.

The three-year NRS Measurement Pilot Project commenced, and has begun evaluation of protocols for improving NRS tracking.

A public-private partnership was formed between Iowa State University (ISU) and the Iowa Nutrient Research and Education Council (INREC) to tackle data challenges by surveying in-field practices through agricultural retailers and crop advisors.

A conservation practice mapping project conducted by DNR, Iowa Department of Agriculture and Land Stewardship (IDALS), and ISU has digitized over 9 million acres to map structural practices including terraces, ponds, grassed waterways, and water and sediment control basins.

Point Source Updates

DNR has issued permits to 86 point source facilities, up from 54 reported last year. The NRS requires permits for 149 facilities.

Water quality data are obtained from 41 publicly owned treatment works, up from 13 last year.

New Awarded Funding

Collaborative efforts have resulted in new funding availability for the 2017 reporting period, including:

• $96.6 million from the U.S. Department of Housing and Urban Development for a five-year project focusing on flood mitigation and nutrient reduction.

• The Regional Conservation Partnership Program (RCPP), under U.S. Department of Agriculture, has awarded $9.5 million to the Midwest Agriculture Water Quality Partnership for conservation demonstration projects.

• An urban-rural partnership led by Charles City was awarded $1.6 million from RCPP to support the Rock Creek Watershed.

NRS Research

Three projects funded through the Iowa Nutrient Research Center have been completed. These projects shed light on the scientific processes behind nutrient loss and the effects of conservation practices.

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Tracking Progress

Inputs

Approximately $10 million more in Nutrient Reduction Strategy (NRS) funding was reported by partner organizations for the 2016 reporting period than in 2015. The majority of this funding was sourced through annual appropriations, allowing for some predictability. Future analyses will explore the future availability of these programs and the capacity for accelerated NRS implementation. These figures do not account for Conservation Reserve Program rental payments, which totaled $225 million in 2016.

For the 149 wastewater treatment facilities currently listed in the NRS to receive new permits and conduct feasibility studies to explore improved technology and nutrient removal systems, 86 permits have been reissued. 20 facilities have submitted feasibility studies. 63 facilities remain.

Human

2015 Outreach Efforts

Number of Events

Average Attendance

Total Reported Attendance

Outreach (fairs, tours, community education)

98 140 14,375

Field Days 57 41 4,159Workshops 19 34 1,172Conferences 4 291 1,281Total 178 20,987

In the 2016 reporting period, 178 outreach and education events were conducted by partner organizations. These events brought in approximately 21,000 attendees in total.

Early analyses of a new survey project showed a potential increase in knowledge of the NRS, when compared to an identical question asked in a 2014 survey. While these two surveys were conducted with different sampling techniques and should not be compared directly, the recently started farmer survey will continue for five years and will allow for more robust findings in the future. Additionally, this survey project will provide a greater understanding of how NRS knowledge affects farmers’ attitudes and behavior related to nutrient management and water quality.

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Land

State and federal cost-share programs provide financial assistance for applying nutrient-reducing practices on agricultural fields. Cover crop adoption has increased dramatically since 2011, showing some promise for further adoption. The NRS suggests that millions of acres of cover crops may be necessary to meet nutrient reduction goals, so this progress only scratches the surface.

In-field nutrient management practices are used by farmers outside of government financial programs. Efforts are underway to establish new protocols for collecting these data and painting a more complete picture of conservation in Iowa.

Selected Edge-of-Field Practices Installed Through Public Funding

2014 2015Wetlands, CRP (acres treated) 99,309Bioreactors (acres treated) 676 838Terraces (feet) 16,076,690 19,821,659Water and Sediment Control (#) 18,609 19,321

The table above displays current understanding of edge-of-field practices installed though cost-share programs. However, the units are inconsistently reported and the data are, in some cases, inaccurate. Collaboration is occuring between partners to address these data needs. Also, a project that maps various structural practices through aerial imagery is underway to record a baseline of Iowa’s conservation efforts.

Water

Nutrient Load Reduction from Select Conservation Practices (lbs)

2014 2015Nitrogen - Total 3,830,000

Cover Crops 2,356,000CREP Wetlands 1,474,000Bioreactors 6,000Phosphorus - Total 134,947 217,884

Cover Crops 112,518 196,967No Till 10,622 14,229Reduced Till 345 7Extended Rotation 1,463 6,680Phosphorus - annual CRP fluctuations -104,134 +56,311

Statewide nitrogen and phosphorus load reductions were calculated with a modeled estimate by factoring in the practices conducted through cost-share programs. Only selected practices could feasibly be incorporated into the calculations at this point, but improved practice data collection and development of appropriate units for the data will improve future calculations. The selected practices account for approximately 0.6 percent reduction in both nitrogen and phosphorus in 2015, when compared with the baseline estimates established for the NRS.

New data from wastewater treatment facilities’ monitoring show substantial levels of nutrient removal and will contribute to improved understanding of point source contribution to Iowa’s nutrient loads. (Table 11, page 33)

Introduction

The Iowa Nutrient Reduction Strategy (NRS) is a research- and technology-based approach to assess and reduce nutrients delivered to Iowa waterways and the Gulf of Mexico. The strategy outlines opportunities for efforts to reduce nutrients in surface water from both point sources, such as wastewater treatment plants and industrial facilities, and nonpoint sources, including farm fields and urban areas, in a scientific, reasonable, and cost-effective manner.

The NRS was developed in response to EPA recommendations provided in their March 16, 2011, memo, “Working in Partnership with States to Address Phosphorus and Nitrogen Pollution through Use of a Framework for State Nutrient Reduction.” The Annual Progress Report provides updates on point source and nonpoint source efforts related to action items listed in the elements of the strategy and updates on implementation activities to achieve reductions in nitrogen and phosphorus loads. The NRS documents, including each year’s annual progress report, can be accessed at http://nutrientstrategy.iastate.edu/.

Partners

The NRS and the annual progress report are collaboratively written by representatives of Iowa State University College of Agriculture and Life Sciences (ISU-CALS), Iowa Department of Natural Resources (DNR), and Iowa Department of Agriculture and Land Stewardship (IDALS). The Water Resources Coordinating Council (WRCC), a body of governmental agencies to coordinate around water related issues in the state, is presented with the annual progress report each year. Additional partners comprise the Watershed Planning Advisory Council (WPAC), which includes private organizations and non-governmental organizations. These partners, among others outside of WRCC and WPAC, voluntarily contributed valuable data that provided the basis for analysis of NRS funding, staff, outreach, and water monitoring to track efforts that have been conducted during the 2016 reporting period.

The logic model approach

The 2015 progress report introduced the “logic model” framework as the basis of considerations set forth by the WRCC Measures Subcommittee. The Logic Model is guided by measurable indicators of desirable change that can be quantified, and represents a progression towards goals for achieving a 45 percent reduction in nitrogen and phosphorus loads. This development of a measurement framework assists the annual reporting process, which was recommended by the 2011 EPA memo.

A significant reduction in nutrient loads is the ultimate goal of the NRS, and is represented by the right-most category of Figure 1. In order to affect change in water quality, there is a need for increased inputs, measured as funding, staff, and resources. Inputs affect change in outreach efforts and human behavior. This shift toward more conservation-conscious attitudes in the agricultural community is a desired change in the human dimension of water quality efforts. With changes in human attitudes and behavior, changes on the land may occur, measured as conservation practice adoption and wastewater treatment facility upgrades. Finally, these physical changes on the land may affect change in water quality, which ultimately can be measured through both empirical water quality monitoring and through modeled estimates of nutrient loads in Iowa surface water. The measurable indicators that correspond to each category provide quantified parameters in which to track year-to-year changes and continual trends to develop a standardized protocol for evaluating NRS progress.

In measuring progress of the NRS, the logic model serves as a comprehensive reporting tool to inform data collection, indicator development, and assessment of the successes and challenges associated with reducing nutrient loads from point and nonpoint sources. The logic model guides the assessment of not only a progression of changes, but also can inform improvements in each of the four primary categories. With continually refined measurement of each category, potential adjustments may be made to the inputs and efforts that partner organizations devote to the NRS in order to impact change over time.

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Challenges associated with measuring change

Measuring NRS progress is a complex undertaking that is accompanied by a variety of challenges, a few of which are outlined here. First, measurable indicators that direct change toward the end-goal must be identified. In the case of the NRS, measurement efforts assess a wide variety of factors that are impacted by many stakeholders. In an effort to develop indicators that represent meaningful change in each logic model category, each indicator was evaluated based on available data, the trends or year-to-year changes that can be used to evaluate progress, and whether the indicator can inform management if progress is not made.

Second, data availability to accurately assess progress in each category of the logic model is a hurdle. For example, current analyses—as discussed in the “Land” section of this report—rely on public cost-share data to evaluate conservation practice adoption on agricultural land. There is limited knowledge of the extent to which farmers employ conservation without public financial assistance, but efforts are currently underway to capture this critical information.

The 2016 reporting period kicked off the three-year NRS Measurement Pilot Project, which aims to develop protocols for measuring annual progress of the NRS. As part of this project, ISU-CALS has partnered with the Iowa Nutrient Research and Education Council (INREC). INREC, a collaboration of agricultural businesses, organizations, and industries, will solicit information from agricultural retailers across Iowa who provide services to crop producers with a goal of gaining more insight into farmers’ in-field nutrient management decision-making. These efforts will aim to address the challenges associated with reliable tracking of in-field practices, such as cover crops and fertilizer management.

The following sections discuss the evaluation of NRS logic model indicators and the progress that was made in since June 1, 2015. While indicators of each category and the related data sources are discussed, these factors are continually under evaluation and may be subject to change in the future.

Figure 1: The logic model of the Iowa Nutrient Reduction Strategy, guided by measureable indicators of desirable change.


Inputs represent the earliest indicators of change in Iowa’s efforts to improve water quality within the state and downstream. Increase in inputs are necessary to encourage changes in human behavior and to promote water quality improvement and conservation in Iowa. Progress of the NRS is measured, in part, through the documentation of partnerships, annual funding, staffing, and continued sociological and scientific research. Positive changes in these indicators from year to year demonstrate initial progress of the NRS.

Partnerships

Collaboration, knowledge-sharing, and participation have been identified as necessary components to the NRS’s integrative approach to reducing Iowa’s nutrient load. These factors are difficult to quantify, so they are reported qualitatively; more quantitative methods of assessment are under examination.

At its core, the NRS framework and annual reporting are led by the Iowa Department of Natural Resources (IDNR), Iowa Department of Agriculture and Land Stewardship (IDALS), and Iowa State University College of Agriculture and Life Sciences. However, many other partnerships are vital to the implementation of the NRS, particularly those that cross the private, public, and civil sectors. Many of these partnerships exist as partnerships in grant-funded projects. Informal partnerships have also formed, facilitated by NRS and the emergence of common goals. Still, since the initial introduction of the NRS in 2012, some of these partnerships have been formed as formal institutions and initiatives, as described in Table 1 (page 5).

Funding

The total estimated funding for information, education and implementation that was dedicated to NRS implementation in the 2016 reporting period was an estimated $122,670,000 (Figure 2).This figure encompasses public and private funding and was estimated from the voluntarily submitted reports of WRCC and WPAC member organizations and by other partner organizations that conduct work contributing to NRS implementation. Of this total funding, 98 percent was appropriated through public funds, and two percent through private funds. The public funding was comprised mostly of federal and state programs that provide financial and technical assistance for implementation of conservation practices, primarily administered in partnership with the local Soil and Water Conservation Districts. This summary does not account for or estimate the contributions of private entities, farmers, or landowners to match public resources. Neither does it account for those practices that are financed completely by the farmer or landowner.

While the level of public funding for NRS implementation in the 2016 reporting period accounts for the vast majority of total funding, private organizations and partnerships reported approximately $2,760,000 of funding for NRS efforts during the year. Much of

Inputs

Measuring Partner Efforts

Beginning in the 2015 reporting period, organizations affiliated with the Water Resources Coordinating Council (WRCC) and the Watershed Planning Advisory Council (WPAC) reported their NRS-related funding and efforts to be included in the annual report.

This data collection method was continued, but adapted, in the 2016 reporting period. In this report, funding, staff, outreach efforts, and monitoring efforts were collected through a standardized data entry process. This method reduced duplication of reported inputs and efforts that are performed collaboratively. For example, a grant that was disbursed by one organization and awarded to another may be reported by both organizations, but double-reporting was minimized by obtaining specific information about different funding sources. Similarly, outreach events that were held by two partner organizations were treated with care to prevent double-counting of one event.

Partner organization reports are included as an appendix to the online version of this annual report.


Table 1: Partnerships that have been formed to support the implementation of the Nutrient Reduction Strategy.

Partnership Mission and Description Affiliated Organizations Outcomes in 2016 Reporting Period

Contribution to Logic Model Measurement

Iowa Nutrient Research Center

Regent’s center established by legislature with the purpose to identify and improve nutrient reduction practices.

Iowa State University, University of Iowa and University of Northern Iowa

Funded 11 research projects addressing nutrient loss and understanding water quality in the field and landscape. www.nutrientstrategy.iastate.edu/center

Inputs Facilitates and supports continued scientific research.

Iowa Agricultural Water Alliance

Aims to foster partnerships between urban and rural stakeholders while identifying and leveraging resources for implementation of the NRS.

Iowa Soybean Association, Iowa Corn Growers Association, and Iowa Pork Producers Association

Human Organizes water quality-centered outreach efforts.

Iowa Nutrient Research and Education Council

A private nonprofit organization formed of broad representation across the agricultural industry and focused on measuring and demonstrating environmental progress, fostering innovation and development of new technologies, and enhancing crop advisor and ag retailer roles as “change agents” working with Iowa farmers to achieve environmental goals.

Board members represent all facets of the agricultural industry, bringing together major farm and commodity organizations, fertilizer and crop production companies, agricultural retailers, and crop advisors.

INREC has partnered with ISU in a three-year pilot project to explore how to measure Iowa farmers’ progress in reducing nutrient loss from agricultural fields.

Land Developing measurement protocols for evaluating statewide adoption of in-field conservation practices.

Iowa Soil and Water Future Task Force

The group is outlining a comprehensive approach to address the state’s water quality challenges, with layers of solutions that may include legislation, education, and technology. The solutions are intended to position Iowa agriculture, Iowa communities, and Iowa businesses as global leaders in water quality and soil health.

Thought leaders in business, agriculture, public policy, and academia. For a full list of participating organizations, visit http://www.capitalcrossroadsvision.com/iowas-water-future/

Presented the state of Iowa with a document of strategic implementation, direction, and recommendations related to successfully carrying out NRS goals. These recommendations can be accessed at http://www.capitalcrossroadsvision.com/iowas-water-future/

Inputs Evaluating and creating recommendations for strategic planning and measurement of NRS implementation.

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this funding was sourced from commodity check-offs and organizations’ membership dues.

In 2015, organizations reported aggregated estimates of funding that was appropriated for the NRS, totaling approximately $112 million. [While $105 million was actually reported in 2015, the figure presented here is adjusted to account for estimated funding from organizations whose inputs were not reported in the 2015 annual progress report.]The reporting method and data processing for this figure differed from those of the 2016 reporting period, and should not be compared directly, but the results suggest that funding for NRS-related efforts increased from 2015 to 2016. To improve measurement of NRS progress since the framework’s introduction in 2012, efforts are underway to retroactively estimate annual funding for the years 2011 through 2015 using similar data collection methods as employed for this annual report.

The Conservation Reserve Program (CRP) comprises a substantial public source of funding for land retirement through rental payments. CRP funding in Iowa totaled $225 million dollars during the 2016 reporting period, as reported by the Farm Service Agency. This source of funding supports perennial plantings that contribute to NRS goals of nutrient load reductions.

Substantial sources of funding have been announced for the coming fiscal year, some of which will support multi-year projects. The following list contains highlights of new funding awards that can be expected for NRS progress in the 2017 state fiscal year.

• The U.S. Department of Housing and Urban Development has awarded IA agencies with a total of $96.6 million to conduct a five-year demonstration of flood mitigation and nutrient reduction. Over $30 million will be spent in watersheds for structures. One focus of the project is financial support for conservation implementation in the watersheds that have been declared disaster areas.

• A public-private partnership came together, led by IDALS, IAWA, and DNR to request funding through the USDA-NRCS Regional Conservation Partnership Program (RCPP). In 2016, the Midwest

Agriculture Water Quality Partnership was awarded $9.5 million for expanded use of practices on conservation demonstration projects. The project will leverage $4.75 million in state funding and $33 million from the private sector. Totaling nearly $47 million, this funding will provide a substantial increase in available conservation resources in targeted watersheds and build private sector capacity to deliver conservation planning and technical assistance.

• An urban-rural partnership, led by the City of Charles City, has received $1.6 million from the RCPP to leverage existing efforts in the Rock Creek Watershed, where a farmer advisory board is working with local partners to advance practice implementation according to goals set in the Rock Creek Watershed Management Plan. The project will implement conservation practices in agricultural areas and will also conduct outreach activities through partners to increase adoption of practices.

Current challenge: The capacity for acceleration

The NRS serves as a foundation for improved partnership and collaboration for water quality in Iowa. This summary represents a vastly more comprehensive assessment regarding inputs that has ever been assembled before, providing much greater prospective on the current status of state and federal program delivery. This is also likely the first attempt in Iowa to quantify non-governmental investments in advancing water quality improvements. Though not complete, as detailed previously, this effort will continue to be refined and improved to gather additional information from other sectors currently not covered in this assessment. Due to the complexity and scope of various programs, efforts to implement the NRS will require greater collaboration among the partners to assess and prioritize which inputs—funding, staff, and research—will be needed to advance implementation in the future. The capacity for accelerating the availability of these inputs is a distinct challenge. Short-term, grant-based funding, constitutes approximately one percent of current NRS funding, as reported by partner organizations. Annual appropriations, as potentially more reliable sources of funding with some uncertainty surrounding year-to-year availability, account for 99 percent of NRS funding, as reported


by partner organizations. Funding sources that are stable, predictable, and incrementally increased may help government agencies, non-governmental organizations, and private industry develop a greater capacity to hire staff, fund long-term research projects, and conduct multi-year education curricula to better implement physical changes that will reduce nutrient losses to surface water. In short, stability and predictability of funding sources, coupled with increased funding, can assist the acceleration of NRS implementation.

The challenge of developing capacity for implementation will exist even as increased funding becomes available. Reducing nonpoint and

point source nutrient contributions will require technical assistance, practice design, and, in some cases, construction. New staff will need training, and private contractors will need to be available to review and implement the practices that must occur across Iowa’s landscape in order to reach the goal of 45 percent reduction of nitrogen and phosphorus loss. Current efforts operate this way to some extent, but the challenge will be to scale up these efforts and to incorporate new practices that are not widely deployed. Multi-year watershed projects and others that are supported by state and federal programs are helping to address this need for increased infrastructure and capacity for NRS implementation, but continued increases in capacity will be necessary.

Figure 2: Funds supporting the Iowa Nutrient Reduction Strategy in the 2016 Reporting Period.


Staff

One indicator for NRS progress in Iowa is an increase in staff working to implement the strategy. There is a persistent need for administrative support, researchers, and technical staff including agricultural, conservation, and engineering specialists, for the continued installation of conservation practices in rural and urban landscapes.

Member organizations of WRCC and WPAC, as well as other partner organizations, reported having 226 full-time equivalent (FTE) staff members on NRS-related efforts (Table 2). Of these staff members, 124 comprise the infrastructure, or administrative and planning support, of the NRS. Eleven people comprise research staff, 80 conduct on-the-ground implementation of practices that reduce nutrient loss and improve water quality, and 11 were categorized as other forms of NRS support. Consistent with the analysis and discussion of annual funding, the personnel estimate cannot be compared directly to reports of staff in the 2015 reporting period. However, by counting only the staff that are funded directly by each reporting organization, duplication and peripheral data were minimized, and tracking of staff inputs will be conducted annually by this method.

Table 2: Nutrient Reduction Strategy Staff - 2016 Reporting Period

FTE Staff For Infrastructure

FTE Staff for Research

FTE Staff for Implementation

FTE Staff for Other Areas

124 11 80 11226 Full-Time Staff conducting work related to the NRS

Current challenge: Accounting for contractors

Generally, the method by which organizations report the number of NRS-focused staff members accounts for permanent employees that are paid directly by the organization. This method fails to track a key component of Iowa’s capacity for reaching NRS goals: contracted workers. The need for accelerated adoption of conservation practices to reduce nutrient contributions from point and nonpoint sources will

require frequent hiring of contracted work. This need especially pertains to the installation of structural practices, such as terraces, bioreactors, and saturated buffers, which require skilled technical assistance, design, and construction. Options for measuring and tracking the extent of contracted work will be explored during the 2017 reporting period.

Continued water quality research

Continuation of research in the physical and social sciences will be necessary to better understand the processes driving and the conservation measures that can mitigate nutrient loss. It is difficult to quantify the research updates that address these knowledge gaps. In this section, a subset of research updates are discussed anecdotally, while more quantitative means of assessing progress in scientific research are under assessment.

The Iowa Nutrient Research Center (INRC) was established in 2013 by the State Board of Regents in response to legislation passed by the Iowa Legislature and signed by Governor Branstad. The center, administered by Iowa State University, is meeting the need for continued research and innovation to address Iowa’s nutrient load concerns. Center research evaluates the performance of current and emerging in-field and edge-of-field practices, provides recommendations on implementing new or tested practices, and develops tools to aid decision-making in adopting effective management practices.

In 2015, the INRC funded 11 projects that address nutrient loss and aim to improve understanding of water quality in the field and landscape. Ten projects were funded in each of the previous two years. Of these research projects funded by the INRC, five projects have been completed; the private investigators have submitted impact reports as the final assessments. Of those completed projects, three have been summarized and made publicly available.


Measuring the effectiveness of stacked nutrient reduction practices

The objectives of this project were to work with Johnson County Soil and Water Conservation District to establish multiple NO3-N reduction practices within a sub-watershed of Rapid Creek; deploy stream-stage sensors and NO3-N probes at the outlets of the treatment sub-watershed and a control sub-watershed; and monitor continuous discharge and stream concentrations at the outlets of the paired sub-watersheds during a three-year deployment period to measure the effectiveness of stacked nutrient reduction practices to reduce NO3-N loads at the watershed scale. Bridge (stage) sensors and water quality sensors (NO3-N and turbidity) were purchased and installed at the outlets of treatment and control sub-basins in Rapid Creek watershed. Water quality data collected are displayed on the Iowa WQIS web page (http://iwqis.iowawis.org/app/). The stage and water quality monitoring data collection effort will continue in 2016 and 2017 as the data is leveraged with the Rapid Creek watershed project managed by the Johnson County Soil and Water Conservation District.

Modeling of nitrate loads and concentrations in the Raccoon River

The main objective of this project was to develop statistical models to describe temporal changes in nitrate concentrations in the Raccoon River at Van Meter that relate the response variable (monthly nitrate concentrations) to predictors that are potentially useful in describing its variability. The predictors that were considered were related to climate and agriculture. The modeling results show it is possible to successfully describe monthly flow-weighted average concentrations for the Raccoon River over the 1974-2013 period. Plus, researchers found that base flow and planted soybean acreage are the two predictors most often identified as important.

Phosphorus loss from ephemeral gully formation and sediment transport

The goal of this project was to determine the quantity of phosphorus loss in 12 Iowa watersheds and the proportion of total phosphorus loss that originates from ephemeral gully formation. This research showed,

in watersheds with 100 percent row crop, approximately 50 percent of total phosphorus loss was ephemeral gully sourced. The contribution of phosphorus loss from ephemeral gullies is reduced by an average of 50 percent in watersheds that contain perennial cover in strategic locations reducing ephemeral gully formation. Average loss of water-soluble phosphorus from ephemeral gullies also was reduced by 40 percent when perennial grasses were strategically placed to reduce ephemeral gully formation. This research was conducted on small watersheds managed with no-till and a corn-soybean rotation. The small watershed size requires caution when trying to uniformly apply results across the Iowa landscape. However, the evidence from this study supports other research indicating ephemeral gullies contribute a grossly disproportionate amount of sediment and phosphorus per unit land area compared to sheet and rill erosion on hill slopes in the watershed. The potential positive water quality impact of armoring the soil surface with perennial vegetation in relatively small locations that repeatedly form ephemeral gullies seems more effective at reducing phosphorus than other approaches.

More information about the INRC and the funded research projects can be found at www.nutrientstrategy.iastate.edu/center.

Nutrient trading: Recent innovative approaches

Interest in exploring nutrient trading has continued as the NRS implementation has moved forward. DNR, EPA, and several stakeholder groups continued discussions about the different aspects of successful trading programs. DNR has met with EPA to discuss NPDES permitting options to accommodate different styles of trading programs and is aware of several cities interested in the concept.

The Iowa League of Cities was recently awarded a USDA-NRCS Conservation Innovation Grant (CIG) to develop a water quality credit trading (WQCT) framework as a means to advance the goals of the NRS and beyond. Work over the last year included initial development of a “Nutrient Reduction Exchange” (NRE) that would serve as a tracking


system and would allow nutrient sources across the state to register and track nutrient reductions resulting from installed best management practices (BMPs) that target NRS goals.

The three-year CIG will be completed with a formal NRE structure and WQCT framework by October 2018. As a result of these recent developments, Section 1 of the NRS has been updated to solidify the WRCC and its member organizations commitment to cooperate with and assist non-governmental organizations interested in developing a voluntary nutrient credit trading program in Iowa (see Appendix A for proposed updates to the NRS).

Prioritization of watersheds

The 2011 “Stoner Memo”, through which the EPA urged states to develop plans for reducing nutrient loss, called for the identification of watersheds that account for a substantial portion of the state’s nutrient load export through surface water and to the Mississippi River. Identification of these watersheds was conducted during the 2014 reporting period and has guided the prioritization of watershed-based activities across the state.

In an effort to establish targeted action in watersheds that carry the majority of Iowa’s nutrient export, demonstration projects have been established in hydrologic unit code – 12 (HUC12) watersheds that lie within the priority HUC8 watersheds, with the goal of spreading awareness of nutrient reducing practices that can affect change in the nutrient load of these catchments. The Iowa Water Quality Initiative (WQI) provides targeted funding and support for 16 projects, three of which began in 2015 (Figure 3).

While these 16 projects target the priority watersheds, there are, in total, 81 ongoing watershed projects in 65 Iowa counties. The majority of these projects operate as locally led efforts, and are supported through leadership from Iowa’s Soil and Water Conservation District commissioners, who, in partnership with watershed coordinators, tailor

the projects to meet the specific needs, concerns, and values of the surrounding communities.

Stormwater, septic and minor POTWs

The WQI has funded 22 urban demonstration projects, which highlight the conservation practices that focus on capture and infiltration of stormwater. These practices reduce the contribution of stormwater to water quality degradation, flash stream flows, and flooding. Nine of these demonstration projects received funding in 2015, and 13 have received funding in 2016. Efforts are underway to calculate estimates of nutrient reductions associated with these projects, and to update the Iowa Stormwater Management Manual to include recent technological advances and modifications related to stormwater management.

Figure 3: The distribution of watershed demonstration proejcts funded by the Iowa Water Quality Initiative (WQI).


DNR and IDALS partner on the State Revolving Fund (SRF)-Sponsored Project program to leverage investments made by municipalities to upgrade wastewater facilities to include additional resources for urban and agricultural stormwater projects. This program is currently funding 57 projects, up from 38 reported during the 2015 reporting period.

Upgrading of failing septic systems continues through implementation of Iowa’s “time of transfer” law that took effect in 2009. Database improvements continue to progress to better enumerate the success of this program. Approximately 16,000 out of ~26,000 time of transfer records have been entered into a database that allows systems to be sorted by condition and type. These records are uploaded to a cloud based storage system that will facilitate access to the records. A surge in home sales in late 2015 and in early 2016 means many more time of transfer inspections are being done this year.

In this reporting period, there are no updates to report on efforts related to minor publicly owned treatment works (POTWs)

Progress of point source facility permits

Steady progress has been made in issuing permits requiring the submittal of a nutrient reduction feasibility study to point sources listed in the strategy – the first step in advancing nutrient reductions by point sources. Good progress has also been made in issuing such permits to point sources in priority watersheds; 62% of these permits have now been issued. Table 3 provides a general summary showing targets, where applicable, and progress in implementing the NRS for point sources.

Table 3: Summary of NRS point source implementation

MetricNumber Required Number Complete

2013-2014

2014-2015

2015-2016

2013-2014

2014-2015

2015-2016

Total

Permits issued 130 147 149 21 32 34 87

Permits issued in targeted watersheds 37 37 39 8 7 9 24

Feasibility studies submitted

- - 15 0 1 19 20

Permits with construction schedule

- - - 0 0 2 2

Permits with limits 130 147 149 0 0 1 1

Nitrogen - - - 1 1

Phosphorus - - - 1 1

Permits meeting % reduction targets

- - -

Nitrogen - - - 9 14 14

Phosphorus - - - 2 6 6

Total permits with nutrient monitoring (including those not in nutrient strategy)

- - - 169 201 ? ?

There was a significant increase in the number of feasibility studies submitted during the past year, as facilities whose permits were issued in 2013-14 completed the required two years of raw waste and final effluent monitoring and evaluated alternatives for nutrient reduction technologies. As these feasibility studies are reviewed and approved by DNR, the schedules they contain for installing nutrient reduction technologies are added to facilities’ National Pollution Discharge Elimination System (NPDES) permits by amendment. Once the construction outlined by the schedules is complete and treatment processes are optimized, facilities will sample total nitrogen and total phosphorus for 12 months. Effluent limits based on those results will


then be added to the permit and become enforceable.

For the first time, enough data are available for point sources to compare actual treatment plant loadings and reductions with the assumptions made during the development of the INRS. This may be the most complete set of nutrient data available in the country for point sources, and the amount of data will continue to increase as more permits are issued. Using these data, we have determined what reductions in loadings of total nitrogen and total phosphorus are occurring today, even before nutrient reduction technologies are installed.

Additional facts and information on each of these measures as well as our preliminary analysis of data collected by point sources since the inception of the NRS is presented this report

How many NPDES permits have been issued that require feasibility studies?

The INRS established a goal for DNR to issue or reissue NPDES permits to at least 20 of the total point sources listed in the strategy each year. These permits include a requirement to complete and submit a nutrient reduction feasibility study (feasibility study) that evaluates the feasibility and reasonableness of reducing the amounts of TN and TP discharged by these larger publicly-owned treatment works (POTWs) and industries. Figure 1 shows that a total of 86 permits have been issued that require feasibility studies as of May 31, 2016; 21 permits in 2013-14, 33 during 2014-15 and 32 in 2015-16. The goal of 20 permits per year has been exceeded in each of the three years that the strategy has been in place and 58% of the 149 facilities affected by the strategy now have permits that require submittal of a feasibility study.

The total number of facilities addressed by the NRS and therefore the number of permits that will require completion of a feasibility study changes slightly from year to year for several reasons:

• New industries begin operating. For example, Iowa Fertilizer Company and Iowa Premium Beef are new major industries that began operating facilities in Iowa after the NRS was released in 2013.

• Industries previously discharging to POTWs begin operating separately from the city. DariConcepts is an existing minor industry that constructed and began operating a biological wastewater treatment facility after having discharged its’ wastewater to a city treatment facility for many years.

• An industry may cease operations altogether or dispose of it wastewater by means other than discharging to a river or stream. For example, Sioux Preme Packing Co. began land applying all of its

Figure 4: Of the 149 permits that are required by the NRS, 86 requiring feasibility studies have been issued.


wastewater beginning in May 2015.• City wastewater treatment facilities are replaced with new facilities or

are expanded to treat larger volumes. If the new or upgraded facility is designed to treat 1.0 million gallons or more per day it becomes a major facility and is subject to the NRS. The City of Eldridge’s South Slope treatment plant expanded to treat a larger volume in 2013.

• A city may downsize its treatment plant capacity as industries leave the city. If this downsize results in the design flow dropping below 1.0 million gallons per day, the facility is no longer classified as a “major” facility and is therefore not subject to the NRS. For example, in 2013 the City of Garner replaced its treatment facility that had a design flow of 1.05 million gallons per day with a new facility that has a design flow of 0.873 million gallons per day.

• A city may eliminate its discharge by connecting to another facility that provides treatment for its wastewater. The City of Ankeny began sending its wastewater to the Des Moines Water Reclamation Facility in January 2014. The City of Waukee is scheduled to do the same by January 2019.

How many NPDES permits have been issued to facilities in priority watersheds?

In 2013, shortly after the NRS became effective, the WRCC designated nine watersheds throughout the state as priority watersheds. These priority watersheds are intended to serve as areas in which to focus targeted conservation and water quality efforts through nonpoint source demonstration projects, implementation activities by nonpoint sources, and implementation of nutrient reduction technologies by point sources. Thirty-seven of the point sources listed in the strategy discharge in one of these nine priority watersheds. Permits have been issued to 23 (62%) of these facilities as of May 31, 2016. All of the facilities in the Boone, East Nishnabotna, Turkey and West Nishnabotna watersheds now have permits that require the submittal of a feasibility study. Figure 5 shows the progress to date in issuing permits to point sources in the priority watersheds.

How many nutrient reduction feasibility studies have been submitted?

Point sources listed in the strategy are required to monitor raw waste and final effluent for total nitrogen and total phosphorus during a two-year period following the issuance of the first NPDES permit requiring completion of a feasibility study. However, some industries (e.g. power plants) that do not have a treatment plant are required to monitor only the final effluent. A facility uses the data collected during this two-year period to evaluate the feasibility and reasonableness of reducing the amounts of nutrients discharged into surface water. The NRS establishes a target of reducing total nitrogen and total phosphorus from point sources by 66% and 75% respectively. The feasibility study must include an evaluation of facility operational changes that could be implemented to reduce the amounts of total nitrogen and total phosphorus discharged.

If the implementation of operational changes alone cannot achieve the targets, the facility must evaluate new or additional treatment technologies that could achieve reductions in the nutrient amounts discharged. Twenty (20) feasibility studies have been submitted as of May

Figure 5: Point source progress in priority watersheds


31, 2016, and another 66 are required to be submitted in the next two years (Figure 6).

How many NPDES permits have been amended to include schedules for constructing nutrient removal technologies?

The feasibility study must include a proposed schedule for implementing the operational changes and/or installing new or additional treatment technologies found to be feasible and reasonable. Upon approval of the proposed schedule by the DNR, the NPDES permit is amended to include the schedule for construction and/or implementation of changes. Currently, two permits have been amended to include construction schedules and one draft amendment is waiting to be finalized. How many permits have been amended to include nutrient limits?

One permit was amended in 2015-16 to include effluent limits for both

total nitrogen and total phosphorus. Manildra Milling made operational changes at their wastewater treatment facility and determined that it was meeting the targets established in the INRS.

There are a total of 123 permits that have been issued, primarily to facilities that are not affected by the NRS, which specify limits for one or more nitrogen compounds (excluding ammonia nitrogen). There are two permits that have been issued to facilities that are not affected by the NRS which specify limits for one or more phosphorus compounds. Limits in these permits are either required by federal effluent standards in the case of certain industries (e.g. meat processing, fertilizer manufacturing, etc.) or are based on a total maximum daily load (TMDL) developed by DNR to address an identified water quality impairment. In many cases these limits do not require a reduction in the amount of nitrogen discharged, but the limits also do not allow for an increase in the amount discharged.

How many nutrient reduction facilities are in place or under construction?

Several POTWs and industries have constructed or are presently constructing biological or chemical nutrient reduction facilities. Many others are planning to construct facilities in the coming years.

Previous annual reports have highlighted the City of Clinton who completed construction and began operating a new wastewater treatment plant in 2013 that utilizes biological nutrient removal processes as envisioned by the INRS. In Clinton’s case this involves anaerobic treatment to remove TP and anoxic treatment to remove TN in addition to typical biological treatment to reduce conventional pollutants. Samples collected and analyzed by the City every other month since December 2014 show that the effluent TN concentration has averaged 8.84 mg/L compared to an annual average target of 10 mg/L listed in the INRS. During the same time period, the average effluent TP concentration was 1.7 mg/L compared to a target annual average of 1.0 mg/L. Neither the percentage removals achieved nor the total pounds of pollutants removed during this period could be determined due to a lack of raw waste data.

Iowa City and Sioux City both operate newer wastewater treatment

Figure 6: The progress of issued permits and submitted feasibility studies among the total required facilities.


plants designed to remove total nitrogen and will be evaluating opportunities to reduce total phosphorus as part of their feasibility studies. The annual average effluent concentrations of total nitrogen for the period from 5/1/2015 through 4/30/2016 were 9.66 mg/L (range 2.90 – 23.20) for Iowa City and 16.20 mg/L (range 2.58 – 139.0) for Sioux City. Annual average effluent total phosphorus concentrations for the same time period were 1.09 mg/L (range non-detect – 3.73) and 4.40 mg/L (range 0.14 – 19.90) for Iowa City and Sioux City respectively. Overall, the Iowa City treatment plant removed approx. 894,075 lbs of TN and 138,533 lbs of TP during this 12 month period while Sioux City removed approximately 2,171,162 lbs of TN and 629,921 lbs of TP.

Removal rates were almost identical for the two treatment facilities at 75 percent for total nitrogen and 81 percent for total phosphorus at Iowa City and 78 percent and 80 percent at Sioux City. Both facilities exceeded the target percentage removal goals for total nitrogen and total phosphorus established in the NRS of 66 percent and 75 percent respectively. While Iowa City met the annual average effluent target concentration for total nitrogen of 10 mg/L, and was close to meeting the total phosphorus target of 1.0 mg/L, Sioux City did not. The reason appears to be that the average raw waste concentrations for both parameters at Sioux City were significantly higher than at Iowa City. This is likely attributable to differences in the characteristics and amounts of industrial wastewater that are treated by the two facilities.

Funding was approved in 2016 for the Des Moines Water Reclamation Authority to install an Ostara process. Although the main reason for proceeding with this project at this time is to significantly reduce the buildup of struvite, which causes operation and maintenance problems and increases treatment costs, it is also projected to result in a significant decrease in total phosphorus in the final effluent. Installation of this technology is scheduled to be completed in 2019 and is expected to remove approximately 365 tons or 730,000 pounds per year of phosphorus from the wastewater.

The Tyson Fresh Meat, Inc. industrial wastewater facility in Perry, IA is constructing chemical phosphorus removal and additional nitrogen

removal upgrades with a planned operational date of August 2017.

Inputs are applied to affect change in nutrient loads, which will require widespread adoption of conservation practices to reduce nutrient loss from nonpoint sources. In order to implement nutrient-reducing practices and cut nitrogen and phosphorus loss by 45 percent, attitudes of people must first shift to affect a change in perspectives and behavior related to water quality.

There are currently three factors that have been analyzed in order to measure the progress of human attitudes related to the NRS: education and outreach events; media pieces for spreading awareness; and farmer attitudes and perspectives.

Increased public awareness, education and outreach

Outreach and education events

Outreach and education events that were held across Iowa during the 2016 reporting period reflect the efforts by partner organizations, both public and private, to spread awareness and educate the public about nutrient reduction options for water quality improvement.

These events, which provide information to make informed decision about conservation practices, were self-reported by WRCC and WPAC members, and include four types of events: general outreach, including fairs, tours, and community education; field days, which often serve to educate farmers and landowners; workshops, which entail training in a particular skill or topic area; and conferences, which facilitate knowledge-sharing, networking, and partnering. During the 2016 reporting period, partner organizations hosted 98 outreach events, 57

field days, 19 workshops, and 4 conferences (Table 4).

Human


Table 4: Summary of the education and outreach events held by partner organizations between June 1, 2015 and May 31, 2016

Number of Events

Average Attendance

Total Reported Attendance

Outreach (fairs, tours and community education)

98 140 14,375

Field Days 57 41 4,159Workshops 19 34 1,172Conferences 4 291 1,281Total 178 20,987

Media pieces for spreading awareness

Media pieces that were released by partner organizations are another measure of the extent of outreach related to the NRS. These pieces include online newsletters, printed materials, and television and radio spots, and serve to inform the public and spread awareness of the NRS, water quality, and conservation practices that reduce nutrient loss.

At 1360 reported pieces, online content, which include newsletters, blog posts, and videos, was the predominant form of media outreach in the 2016 reporting period, (Figure 7). There were 322 print articles, 90 radio spots, and 16 television pieces. These outreach methods will be tracked annually to identify changes in the extent of NRS-focused media in Iowa.

Farmer knowledge and attitude

In an effort to better understand farmer knowledge, attitudes, and behavior, a five-year survey funded by IDALS and conducted by ISU researchers has completed its first round of data collection. This survey, which will assess farmers’ understanding of and attitudes toward the NRS, is conducted in select priority and non-priority HUC8 watersheds, so as to track changes in both over time. The design of the survey and its first-year results will be available through ISU-CALS in August 2016.

Figure 8 illustrates the knowledge of the NRS that farmers reported in 2015. About six percent of respondents reported that they were very knowledgeable of the NRS, and 22 percent rated themselves as knowledgeable. The largest category, at 42 percent, was “somewhat knowledgeable,” while 23 percent and seven percent of farmers reported that they were slightly knowledgeable and not at all knowledgeable,

Figure 7: Media pieces for NRS outreach released during the 2016 reporting period, as reported by partner organizations.


respectively. These results show a greater level of knowledge of the NRS compared to the results of the same question in the 2014 Farm and Rural Life Poll conducted by ISU researchers. The sampling techniques differ between the two studies, so the results should not be directly compared. In particular, the 2015 study surveyed farmers in selected watersheds, while the 2014 study surveyed farmers across the state. However, the greater levels of knowledge of the farmers surveyed in the 2015 NRS Farmer survey suggest a possible general increase between 2014 and 2015.

As this survey is conducted in select watersheds in the coming years, this question will monitor change in farmers’ awareness of the NRS. As Nutrient Reduction Strategy-related extension and outreach efforts increase, farmers’ knowledge is expected to increase. Additionally, annual

data on NRS knowledge will be compared to other questions in the survey to better understand whether increased knowledge correlates with behaviors related to water quality and soil conservation.

These values will be further examined as the subsequent rounds of the survey are conducted to document changes or stagnation of NRS attitudes that may occur among the farmers and landowners in the target watersheds.

The survey also aims to explore farmers’ attitudes toward the NRS and water quality in Iowa. There were many statements presented and respondents expressed their level of agreement with each statement. Three of these statements are of particular interest in measuring progress of the human dimension of the NRS. The statements and their corresponding percentages of responses are shown in Table 5 (page 18).

The first and second statements received high levels of agreement from farmers, at 83 percent and 75 percent, respectively, when the “Strongly Agree” and “Agree” responses are added together. These figures are promising. With most farmers having at least some knowledge about the NRS, and with statements regarding awareness and concern over Iowa water quality receiving agreement from more than three-quarters of those surveyed farmers, there appears to be foundation for increasing conservation and water quality knowledge, concern, and intent to act among the surveyed group. The next rounds of this survey will aim to identify whether a change is occurring in farmers’ perceptions of water quality concerns among this sample of respondents.

Figure 8: Percent of respondents describing their knowledge of the NRS. These data were obtained from the 2015 NRS Farmer Survey and the

2014 Farm and Rural Life Poll conducted by ISU researchers. Sampling techniques differed between the two studies; the two sets of results should not be compared directly, but this figure serves to illustrate a

possible shift in farmers’ knowledge of the NRS.


Table 5: Responses to statements related to attitudes toward water quality and nutrient management. These results, and others, are discussed further in the 2015 Nutrient Reduction Strategy farmer survey report.

Strongly Disagree

Disagree Uncertain AgreeStrongly

Agree

PercentI am concerned about agriculture’s impacts on Iowa’s water quality

1.2 4.2 11.7 64.1 18.7

I would like to improve conservation practices on the land I farm to help meet the Nutrient Reduction Strategy’s goals

1.3 2.2 21.3 59.9 15.3

The nutrient management practices I use are sufficient to prevent loss of nutrients into waterways

0.4 3.1 39.2 48.9 8.4

Other statements exploring attitudes toward water quality focused on respondents’ own management decisions. Fifty-seven percent of the surveyed farmers agreed that “the nutrient management practices I use are sufficient to prevent loss of nutrients into waterways,” suggesting a level of contentedness surrounding status quo practice implementation. Future analyses of these data will explore the relation between farmers’ attitudes and their behaviors, such as use of conservation practices, to explore whether conservation is associated with the reported attitudes toward nutrient loss and the NRS. A change in these responses over time may serve to indicate successful educational programming and

communications about the practices that contribute to or mitigate nutrient loss from agricultural fields. With increased concern over nutrient management decisions may come increased adoption of conservation practices to improve water quality in Iowa.

The second iteration of the survey was conducted in Spring 2016. The responses will be analyzed and reported in Fall 2016. As the survey is conducted in various watersheds throughout Iowa, statistical analyses will also be conducted to determine whether significant differences in farmer knowledge, attitude, or behavior arise in priority watersheds as compared to non-priority watersheds. Some targeted outreach and education programming, particularly through the WQI, is currently designed for watersheds that contribute greatly to Iowa’s nutrient export; the future results of this farmer survey will potentially serve as a partial evaluation of the effectiveness of this programming, and may help facilitate improved curricula for the communities in those watersheds.

Opportunity for surveying landowners

The NRS farmer survey is instrumental in gauging farmer knowledge and attitude related to the NRS, and may contribute to improved curricula design to target the population that was sampled (i.e. operators who farm owned or rented land). However, it will be necessary to reach non-operator landowners, as well, to achieve NRS goals. In 2014, 81 percent of Iowa’s agricultural landowners were non-operators. This subset should be considered when designing future survey projects to capture the perspectives they have on water quality, the NRS, and their role in affecting change in the landscape. Extension and outreach programming focuses heavily on farmers, but there is an opportunity for designing curricula that target landowners specifically.

Cover Crop Survey

In 2014 and 2015, IDALS conducted a cover crop user survey facilitated through the local Soil and Water Conservation District offices. Participants using cover crops (with or without financial assistance)


were asked to complete the survey. The goal of the survey was to learn from these cover crop users their management practices; assess their understanding of cover crops; examine what would help facilitate expanded acreage of cover crops on their operation and/or on other farms in their area; and to inform program design and operation.

One question that carried over from the 2014 to the 2015 survey asked respondents whether they planned to use cover crops the subsequent year. In 2015, 77 percent said that they were planning use cover crops the following year, 23 percent said that they were unsure, and less than one percent said that they would not. These results showed no functional change from the 2014 survey results.

In 2015, the survey asked respondents whether owned, rented, or managed the fields in which they seeded to cover crops. Most farmers, 62 percent, owned and operated the field in which they seeded to cover crops. Twenty-five percent reported that they were the tenant or operator on their cover crop fields, but that the landowner did not request the practice be implemented. Nine percent reported that they were a tenant or operator, and that the landowner had requested the practice be implemented on their fields. These results support the view that landowners present an opportunity for adapted outreach efforts that may facilitate increased adoption of cover crops, and other conservation practices.

A list of the 2015 survey questions and a summary of responses can be found in Appendix C, available in the online version of this report at http://nutrientstrategy.iastate.edu .

Recent innovations in NRS outreach

The Iowa Watershed Academy

A project was initiated in 2014 to develop and implement hands-on training for watershed coordinators, project managers, and conservation leaders in Iowa to improve the effectiveness of watershed scale projects

to achieve water quality results. The first Iowa Watershed Academy training event was held May 24-25, 2016, at the Field Extension Education Laboratory west of Ames. Twenty-five watershed and basin coordinators participated in hands-on, collaborative learning sessions featuring the following topics: nitrogen sources and products, the Maximum Return to Nitrogen calculator, choosing nitrogen management practices, cover crops, water monitoring, in-field measurement tools, project management, budget management, communication strategies, partnership opportunities, field day and event planning, project and event evaluation, Agriculture Conservation Planning Framework and setting measurable project goals and objectives. The evaluation feedback was very positive and the participants found the hands-on field sessions and small group discussion sessions to be especially effective. Plans are underway for a fall 2016 event. The training was provided at no cost to the participants through grants and sponsorship from the Iowa Natural Resources Conservation Service, Soil and Water Conservation Society, North Central SARE, Iowa State University Extension and Outreach, Conservation Districts of Iowa, Iowa Department of Agriculture and Land Stewardship and Iowa Agriculture Water Alliance.

retaiN

The retaiN project seeks to give farmers the tools and information they need to make conservation decisions on their land, starting by helping farmers test for, understand and take steps to retain their nitrogen. The nitrate test kits facilitate farmer engagement in collecting on-farm nitrate

Iowa Watershed AcademySelect participant comments:

“You got my mind thinking of other ways to really look at my watershed and maybe

expand my focus area.”

“Good use of varied discussion and group planning methods.”

“Content was great overall. Very diverse and helpful - especially for new coordinators!”

“Thought conent was VERY relevant to what my project goals are.”

“Liked having indoor and outdoor sessions; hands-on is a must.”

“Beneficial to have trainings like this so we can meet with other coordinators and

exchange struggles/ideas.”


concentration data. The project, funded by the State Soil Conservation Committee, is a partnership between Conservation Districts of Iowa, ISU Extension and Outreach, Iowa Learning Farms, and with support from the IDALS Division of Soil Conservation and Water Quality. In 2015, 500 nitrate concentration test kits and supporting materials developed and distributed to producers through existing watershed projects and ISU Extension field specialists in 2015. The retaiN project is designed to build awareness the nitrogen concentrations in tile outlets and does not maintain a database of measurements. The evaluation feedback from farmers, watershed coordinators, and ISUEO specialists was overwhelmingly positive. One farmer wrote, “The kit is quick, very simple to use and gives you immediate results. It helps me determine if I am losing any nitrogen”.

While the discussion of the data allows farmers to understand the nitrogen loss on their field, these efforts also represent a potentially valuable outreach strategy that should be considered for helping farmers make informed decisions about employing conservation practices suitable for their operations.

The current landscape in Iowa

Iowa’s landscape is predominantly agriculture. According to the United States Department of Agriculture’s census, Iowa had 30,622,700 acres of farmland in 2012. In 2015, these acres were comprised of 13,218,900 acres of corn and 9,720,900 acres of soybeans. The remaining acres were dedicated to other agricultural operations, including small grains, pasture, and Conservation Reserve Program (CRP) enrolled acres.

Land use and cropping systems impact the loss of nutrients to surface water, but must be balanced with the economic viability of farmer operations. With time and widespread adoption of practices, changes in land use, nutrient management, and soil stewardship on agricultural fields can have significant, positive effects on Iowa’s water quality.

The NRS is a collaborative, research-based framework, so its success relies heavily on the cooperation between all stakeholders including, but not limited to, state/federal agencies, NGOs, private companies, farmers, landowners, and point-source facilities to take stock of the nutrient loss that can be mitigated through improvements to in-field and edge-of-field management. The following discussions explore the extent conservation practices have been voluntarily adopted in Iowa agricultural operations.

Data sources for conservation practices

In order to accurately track the annual adoption of conservation practices that reduce nutrient loss, three data sources were analyzed:

1. Farm Service Agency – Crop acreage data, reported by producers. The FSA data provide the information concerning land use in Iowa.

2. USDA-NRCS – The adoption of select conservation practices through financial assistance and cost-share programs (e.g. EQIP).

3. IDALS – The adoption of select conservation practices through financial assistance and cost-share programs (e.g. REAP).

Baseline and Temporal Scale: Annual totals of conservation practice adoption, on a calendar year cycle. Land-based conservation has been tracked back to 2011 as the year of EPA reccomendations and NRS initial nutrient load estimates.

Note: The cost-share measure accounts for a portion of new practices added but does not account for existing practices that were removed. This concern will be factored into future attempts to address data challenges.

Land


Nonpoint source nutrient reduction for water quality improvement

Within Iowa’s agricultural system, dominated by corn and soybean production, a variety of practices can be implemented to mitigate the loss of nutrients from farm soils. Employing effective strategies for reaching out to producers and landowners, educating the public on the options available for nutrient loss reduction, and adjusting efforts as farmer perspectives become better understood, will accelerate the adoption of conservation practices on farms. Quantifying the extent to which these practices are adopted each year, and how the use of these practices changes from year to year, provides a series of metrics for measuring progress of the NRS. These practices are categorized into three general forms of management: land use change, in-field nutrient management, and edge-of-field practices.

Land use changes are comprised of substantial alterations to the conventional cropping system, including perennial establishment for land retirement, pastures, and extended rotations. In-field nutrient management practices encompass tillage; fertilizer application methods, timing and rate; and cover crops. They are techniques that are applied within the field boundaries. Edge-of-field practices mitigate soil and nutrients from exiting the field. Terraces, wetlands, buffers, bioreactors, and drainage water management are included in this category.

A brief discussion of the practices that comprise these categories and their estimated impacts on crop yields and on the loss of nitrogen and phosphorus can be accessed in “Reducing Nutrient Loss: Science Shows What Works,” an ISU Extension & Outreach publication.

A more detailed discussion of nutrient-reducing practices can be found in the Science Assessment of the Iowa Nutrient Reduction Strategy, at http://www.nutrientstrategy.iastate.edu/.

Table 6: Conservation land use in Iowa. Alternative field crops (e.g., alfalfa, rye, and wheat), pasture, and conservation reserve program (CRP) acres were obtained from the Farm Service Agency crop acreage data. †The adoption of cost-share perennial vegetation since 2011 were calculated from federal and state cost-share data. This perennial vegetation was calculated from new installations of critical area planting and conservation cover, both of which are NRCS-standardized practices.

Land Use (Acres)Year 2011 2012 2013 2014 2015Total alternative field crops and pasture

2,180,000 2,131,000 2,258,000 2,819,000 2,830,000

Total CRP 1,043,000 1,047,000 1,531,000 1,456,000 1,464,000

Installation of perennial vegetation, non-CRP†

12,347 29,968 41,450 51,021 58,413

Land use change and land retirement

Land use in Iowa and the extent of extended crop rotations, pasture, and perennial native plantings have a substantial effect on nutrient loss. The NRS Science Team of researchers have estimated that pastures reduce nitrogen loss by about 85 percent and phosphorus loss by nearly 50 percent, compared with conventional corn and soybean rotations. Alfalfa can reduce nitrogen loss by over 40 percent. Perennial systems can play a significant role in reducing nutrient losses from the acres enrolled in programs such as the federal Conservation Reserve Program (CRP), which have been shown to reduce nitrogen loss by 85 percent and phosphorus loss by 75 percent.

In 2015, there were an estimated 2,830,098 acres of alternative field


crops and grassland (Table 6). Alternative field crops are a sum of the planted area of oats, alfalfa, rye, and wheat. Grassland includes pasture, turn areas, and planted grasses. The extent of grassland and alternative field crops has increased by about 650,000 acres since 2011. Efforts are underway to further refine this data collection method to improve accuracy and avoid double counting.

The USDA-FSA program, CRP, compensates landowners through land rental payments in exchange for planting and maintaining native plant mixes. These types of programs benefit water quality, wildlife, and soil health. In 2015, 1,463,759 acres in Iowa were enrolled in CRP, about 400,000 acres more than in 2011. Additionally, between 2011 and 2015, 58,413 acres were enrolled in perennial vegetation government cost-share programs—not CRP.

Since 2011, there has been some increase in land use change that benefits of nutrient loss reduction and water quality improvement, although future tracking efforts will explore the drivers for these land use changes and the roles that they play in overall nutrient reduction. The NRS Science Assessment evaluated potential for different scenarios that would feasibly meet NRS goals. Within those scenarios, maintaining at least 1.2 million acres of land retirement can contribute to success in meeting the goals of 45 percent reduction of nitrogen and phosphorus, when employed with other combinations of conservation practices.

Table 7: The annual implementation of in-field practices under cost-share programs

In-Field Nutrient Management (acres)Federal and Iowa Cost-Share Programs

2011 2012 2013 2014 2015Cover crops 35,909 66,433 226,473 251,622 317,132Nutrient Management, 590 Standard

41,472 37,993 40,329 50,637 35,797

Conservation Tillage

45,079 42,714 32,105 37,354 39,016

In-field nutrient management

Nutrient and soil management practices conducted within field boundaries to mitigate the loss of nutrients from row-cropped acres are discussed as in-field nutrient management. These practices are applied at various stages before, during, and after the annual growing season.

Cover crops have been adopted at a rapid pace in recent years. In 2015, 317,132 acres were planted through government financial assistance programs, a stark increase from 35,909 acres in 2011 (Table7). Cover crops are estimated to reduce nitrogen loss by around 30 percent and phosphorus loss by 29 percent. It is certain that cover crops have also been adopted without the use of cost-share. While adoption has increased dramatically since before 2011, there is not currently an effective process to collect total acres of cover crops annually in the state absent state/federal programs. Acceleration of cover crop adoption will need to continue this trend to achieve the NRS goals.

Nutrient management, which incorporates an improved rate, source, placement, and timing of fertilizer application,, has received fluctuating adoption through cost-share programs. In 2015, 35,797 acres had nutrient management, a slight decrease from the 41,472 acres in 2011 and a sharp decrease since 2015, which had 50,637 acres (Table 7). This management system has been widely promoted through the “4Rs” campaign largely led by industry, agency, and conservation groups. While it reduces nutrient loss to a lesser extent than do cover crops and perennial vegetation, adoption of the 4Rs are considered economically feasible and environmentally beneficial, and thus are encouraged on cropland through multiple agricultural retailers, cooperatives, NGOs, consumer facing companies, and government agencies. Currently, adoption of the 4Rs is certainly employed on many more acres than are reflected by cost-share data, but comprehensive data collection to assess the private use (i.e., without government assistance) would be necessary to better estimate the extent of the 4Rs among Iowa farmers.

Conservation tillage, through reduced till and no-till operations, can potentially reduce phosphorus loss by 30 to 90 percent and is also


considered a relatively low-barrier conservation practice. The use of conservation tillage, however, is also difficult to estimate due to the fact that many farmers have adopted no-till and reduced-till management without government assistance. In 2015, 39,016 acres received reduced or no tillage through cost-share programs. This rate of reduced tillage through cost-share assistance is down significantly than in previous years (Table 7), but this decrease can be attributed to a variety of potential factors. For instance, a shift in focus of cost-share programs toward other practices, coupled with the possible adoption of tillage without government assistance, may explain this decrease. Improved data collection will help with more accurate measurement of the extent to which these practices are adopted each year. USDA National Agriculture Statistics Service (NASS) surveys show, in Iowa, nearly 7 million acres of no-till in 2012 with an additional 8.7 million acres under use of conservation tillage [https://www.agcensus.usda.gov/]

Edge-of-field practices

Edge-of-field practices were also assessed through their implementation under cost-share programs. These practices are structural and help prevent the loss of nutrient from boundaries of agricultural fields. Phosphorus loss is mitigated by erosion control methods, including terraces [Although terraces are constructed within the field, they are evaluated alongside other edge-of-field practices due to their capacity for sediment loss reduction and due to the fact that they are a structural practice], sediment control, and perennial buffers, which reduce phosphorus loss by 77, 85, and 58 percent, respectively.

Table 9: The cumulative installation of structural edge-of-field practices between 2011 and 2015. ‡CREP wetlands are reported as acres treated. †The standards for bioreactors and saturated buffers are still under assessment, and so have had limited adoption.

Edge-of-Field and Erosion Control (acres)Federal and Iowa Cost Share Programs

2011 2012 2013 2014 2015Drainage Manage-ment

0 0 15 279 544

Wetlands, CREP

99,309‡

Bioreac-tors†

0 236 501 676 838

Saturated Buffers†

0 0 0 0 0

Perennial Buffers†

296,137 3,710,030 3,812,222 5,113,665 11,815,711

Terraces (feet)

4,556,460 8,378,866 11,906,248 16,076,690 19,821,659

Water and Sediment Control (number)

1,181 7,588 13,649 18,609 19,321

Since 2011, 19,822,000 feet of terrace have been constructed under cost-share programs (Table 8). Similarly, cost-share programs have funded the rapidly increasing construction of water and sediment control basins, at 19,321 basins installed between 2011 and 2015. While these figures indicate an increase in adoption of these practices, future data collection will aim to estimate the total number of acres benefited. Collaboration between representatives at ISU, NRCS, and IDALS will aim to address these data collection concerns to identify and use a standardized unit that describes these practices’ impacts on NRS goals and to tackle minor data quality concerns.

Nitrogen loss is mitigated by wetlands, bioreactors, saturated buffers, and drainage water management. Wetlands, when designed and constructed


under Conservation Reserve Enhance Program (CREP) standards, can reduce nitrogen loss by 52 percent. In 2015, approved CREP wetlands projects treated an estimated 99,000 acres (Table 8).

Bioreactors reduce nitrogen loss to surface water by 43 percent on tile-drained land. Between 2011 and 2015, 838 acres of bioreactors were reportedly installed, although this estimate is limited by some data quality concerns and should reflect between 50 and 75 individual bioreactors. Future data processing efforts will attempt to accurately report the total treated acres of this practice, which is a more meaningful unit for tracking estimated nitrogen load reductions.

As illustrated in the NRS, it will require a systems approach to reach the goals set forth. Edge of Field practices have been identified as an area needed for expanded implementation to meet the goals of the NRS. However, there are current challenges to scaling up these practices. These challenges include, but are not limited to, the following: these practices are relatively new and not as familiar to landowners as are traditional practices like terraces and grassed waterways; and there are currently efforts underway by multiple partners to build capacity to deliver these practices at a greater scale to provide site location, outreach, technical assistance and verification to expedite delivery and installation of these key practices.

Perennial buffers, which can reduce nitrogen loss by 91 percent and phosphorus loss by 58 percent, are an effective practice for reducing nonpoint source pollution and improving surface water quality. This practice presents an opportunity for improved data collection and processing. Many buffers are installed under CRP, but the reliable CRP data presented in Table 6 does not distinguish between stream buffers and in-field perennial plantings. Therefore, a significant portion of perennial buffers is not highlighted in these data. Table 10 shows the cumulative installation of non-CRP buffers from 2011 to 2015, but these figures are presumed to be vastly lower than the total acres of stream buffers in Iowa.

Addressing data availability challenges

These estimates of conservation practice adoption represent a big step in beginning to enumerate the collective effort of state and federal program funded practices. However; this information is still incomplete when considering the additional practices that are implemented outside of local, state, and federal programs. While they are relatively accurate in illustrating the increasing use of cost-share and other governmental financial assistance for applying agricultural practices that reduce nutrient loss, there are a few challenges to painting the entire picture of conservation in Iowa.

Data for in-field practices

It is certain that practices are adopted and maintained without the use of governmental financial assistance. For example, some estimates suggest that there were nearly 500,000 acres of cover crops planted in Iowa in 2015, though cost-share programs financed only about 317,000 acres in 2015. This rough calculation has significant limitations, but suggests that there are more acres of cover crops than are funded by government programs. It is also certain that other nutrient-reducing practices, including no-till and nutrient management (4Rs), are also in use by farmers who did not utilize federal or state cost-share.

In partnership with ISU, the Iowa Nutrient Research and Education Council (INREC) will explore how to measure Iowa farmers’ progress in reducing nutrient loss from agricultural fields. In the three-year pilot project, INREC will solicit information from agricultural retailers who provide the bulk of services to producers. The aggregation of field-scale data will contribute to efforts to track conservation practice adoption in Iowa. By combining the information gathered into an anonymized dataset, a more accurate view of nutrient-reducing practices and product implementation will be formed. This project, through a public-private partnership, will contribute to an improved understanding of the extent to which farmers employ practices recommended by the NRS. This project will rely upon the existing roles of Iowa’s agricultural retailers—1300 certified crop advisors and an estimated 5000 total


advisors—who demonstrate a capacity for widespread one-on-one consultations with farmers. INREC will work to enhance retailers’ roles by providing increased outreach and training to help these professionals with advising farmer decisions regarding environmental technologies and practices. While assessment of the 2016 reporting period relies on the limited availability of conservation practice data, the NRS Measurement Pilot Project and the associated INREC project will facilitate improved reporting in coming years.

Data for structural practices

To date, there have been various challenges associated with the collection and processing of cost-share data pertaining to structural edge-of-field practice adoption. These practices are recorded consistently by specific units. However, the acres treated by these installations are of greater utility when tracking the practices’ contribution to meeting NRS goals. These values have been reported inconsistently and the units are not standardized among different data sources. Collaboration between ISU, NRCS, and IDALS aims to standardize the data collection process and build cost-share databases to provide improved metrics for NRS progress.

In an effort to help support progress measurement and accountability efforts of the Iowa Nutrient Reduction Strategy, IDALS and DNR are collaborating with ISU to conduct GIS analyses in selected watersheds to identify and enumerate the aggregate amount of certain structural conservation practices, independent of government programs, outlined in the NRS Science Assessment. Practices include terraces, water and sediment control basins, grassed waterways, pond dams, contour buffer strips, and contour strip cropping. These practices are identifiable by use of LiDAR elevation data and aerial photos, thereby enabling an accurate accounting of the practices present on the landscape. Beneficial outcomes include:

• Establish a baseline of practices established• Assign nutrient and sediment load reduction/prevention amounts to

current and future practice levels• Analysis is blind of public/private investment – as such it

encapsulates all activity• Track progress going forward from LiDAR baseline years (2007-2010)• Hindcast to past conditions using historic photos to show progress

made over time• Utilize for planning purposes to target resources to areas most in need

of select BMPs• This analysis is complementary to other similar spatial analysis work

to document conservation practices that is being funded by the Iowa Nutrient Research Center. Efforts will be cross-coordinated to maximize efficient use of resources

This project will pilot efforts into the WQI Demonstration Watershed Projects and other areas to begin utilizing the tool to ground truth, test the effectiveness and capabilities of the tool, and help validate its usefulness. An additional 202 HUC12 watersheds were completed in the past year.

The information generated by this project will supplement cost-share

Figure 9: The progress of the DNR, ISU, and IDALS collaborative project to map selected conservation practices in selected watersheds.


data and will paint a more complete picture of conservation in selected watersheds and future installations can be tracked against this baseline. Figure 9 displays the progress of this project’s mapping efforts as of May 2016, and the current aggregated results are shown in Appendix B. The baseline practices will contribute to improved estimates of nutrient load reductions in future analyses

The NRS establishes a goal of reducing the amounts of nitrogen and phosphorus leaving Iowa by 45 percent each and outlines a process for achieving this goal through increased efforts by both point sources and non-point sources to control nutrient losses due to human activities. As displayed in the NRS logic model (Figure 1), nutrient reduction will result from effective changes in human behavior, land use, and point source nutrient removals.

One of the key elements of the NRS is to develop new and maintain existing programs to measure water quality and the changes that occur over time as nutrient reduction practices are implemented by both point sources and non-point sources.

The 2015 NRS annual report states that “efforts are underway to improve understanding of the multiple nutrient monitoring efforts that may be available and can be compared to the nutrient WQ monitoring framework to identify opportunities and potential data gaps to better coordinate and prioritize future nutrient monitoring efforts.”

During the 2016 reporting period, DNR coordinated and drafted a collaborative report titled “Stream Water-Quality Monitoring Conducted in Support of the Iowa Nutrient Reduction Strategy,” that describes the current network of surface water monitoring in Iowa, details the challenges and data gaps associated with water quality monitoring, and suggests ways to improve and coordinate the collection and evaluation of water quality data for these purposes. This is consistent with the WRCC

commitment “to continue to coordinate and evaluate opportunities for monitoring locations and focused study areas in order to track progress”. This section provides a summary of many of these discussions.

Current known stream nutrient monitoring efforts in Iowa are reported in the context of the Nutrient Water Quality Monitoring Framework presented in Figure 10. The Nutrient Water Quality Monitoring Framework was developed to graphically show that the length of time needed to show a measurable change in water quality increases as the size of the watershed increases. Generally less time and fewer samples are needed to measure a change in the quality of runoff from an individual field of ten to a few hundred acres in size following implementation of nutrient reduction practices, whereas more samples collected over a longer period of time to show a change in water quality at the terminus of a larger watershed that consists of tens of thousands of acres or more. There are a variety of reasons this is the case, pertaining to challenges to monitoring surface water quality, but, in general, as the watershed size increases there is an increase in the number of factors that affect water quality. Natural systems become more complex as size increases.

Edge-of-field monitoring

Agricultural fields, particularly if they are tile-drained, serve as small catchments where water quality measurements can be obtained on fine spatial and temporal scales. These monitoring efforts are practical for better understanding how conventional management and conservation practices impact the concentrations of nutrients and sediment in water that leaves the field. An array of projects and outreach strategies utilize edge-of-field monitoring.

ISU researchers conduct studies on multiple sites to assess the impacts of NRS conservation practices on the loss of nutrients from farms. The Iowa Soybean Association (ISA) also conducts an array of monitoring projects and edge-of-field studies on farmland. In coming months, the extent of edge-of-field monitoring across the state will be evaluated to continue to track progress of this scale of water quality monitoring.

Water


Small watershed-scale monitoring

Iowa Water Quality Initiative

The Iowa WQI was established during the 2013 legislative session to help implement the NRS. The WQI seeks to harness the collective ability of both private and public resources and organizations to rally around the NRS and deliver a clear and consistent message to the agricultural community to reduce nutrient loss and improve water quality. A number of demonstration projects have been established to promote increased awareness and adoption of available conservation practices and technologies. Projects serve as local and regional hubs for demonstrating nutrient reduction practices and providing practical information to farmers, peer networks, and local communities.

A total of 45 demonstration projects are currently located across the state. This includes 16 targeted watershed projects, 7 projects focused on expanding the use and innovative delivery of water quality practices and 22 urban water quality demonstration projects (Figure 3). Eighteen of these projects focus on small scale targeted watershed areas for agricultural based conservation practice implementation in alignment with the INRS. These projects were initiated as demonstration and engagement projects with the eventual goal of scaling conservation implementation progress and efforts both within and beyond the current project watershed areas. Consequently, water quality monitoring conducted by the majority of these projects focuses primarily on informing watershed stakeholders of nutrient loading and targeting resources for effective conservation implementation and planning decisions. A subset of the watershed and practice-based projects currently conducting water quality monitoring is shown in Figure 6. The frequency of sample collection and analysis for nutrients and other parameters varies but is generally weekly or bi-weekly throughout the monitoring season and includes monitoring of tile lines as well as steam water quality. Information about each of these demonstration projects can be found at http://www.cleanwateriowa.org/practice-demonstration-projects.aspx.

National Water Quality Initiative

In 2012, the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) launched the National Water Quality Initiative (NWQI), in collaboration with the Environmental Protection Agency (EPA) and state water quality agencies, to reduce nonpoint sources of nutrients, sediment, and pathogens related to agriculture in small, high-priority watersheds in each state. A key part of the NWQI targeting effort includes the implementation of conservation systems that avoid, trap, and control run-off in these high-priority watersheds.

In Iowa there are currently four NWQI watershed projects; Wall Lake Inlet/Black Hawk Lake, Badger Creek, Lower South Fork Chariton River and Lost Branch – Chariton River. Only one of these, the Wall Lake Inlet/

Figure 10: A framework of nutrient and water-quality monitoring, and the approximate time frame in which change in water quality may be

measured and detected.


Black Hawk Lake project measures surface water quality and there is too little data available so far to begin to identify changes, if any, in nutrient concentrations or amounts.

Paired Watersheds

Paired watershed projects involve the selection of two watersheds of similar size and land use characteristics. In one watershed conservation practices are extensively implemented while the other receives few new conservation practices. Stream water quality is monitored in both watersheds to assess the effect on water quality of the installed practices. There are four examples in Iowa, of the use of the paired watershed approach to evaluate water quality effects associated with nutrient reduction conservation practices. Three of these projects were completed prior to the 2016 reporting period, but the Black Hawk Lake project commenced in 2015 under the NWQI. This five-year project will aim to determine if water quality improvement strategies have been effective at reducing sediment and nutrient loads in the watershed.

Conservation Reserve Enhancement Program

The Iowa Conservation Reserve Enhancement Program (CREP) is a joint effort of the Iowa Department of Agriculture and Land Stewardship (IDALS) and the USDA Farm Service Agency in cooperation with local Soil and Water Conservation Districts that provides incentives to landowners to voluntarily restore wetlands targeted for water quality improvement in the heavily tile-drained regions of Iowa.

The goal of the program is to reduce nitrogen loads and movement of other agricultural chemicals from croplands to streams and rivers. A representative subset of wetlands is monitored and mass balance analyses performed to document nitrate reduction. In addition to documenting wetland performance, this allows for the continued refinement of modeling and analytical tools used in site selection, design, and management of future CREP wetlands. In 2015 a total of 20 CREP wetlands were monitored, up from approximately 12 a few years ago.

The monitored wetlands are instrumented with automated samplers and flow meters to measure inflows and outflows. Water levels are monitored continuously at outflow structures in order to calculate changes in pool volume and discharge and wetland water temperatures are recorded continuously for modeling nitrate loss rates. An annual report has been prepared each year since 2007 that document the results of that year’s monitoring and evaluates performance measures such as patterns in nitrate concentrations and loads and patterns in nitrate loss. Additional information including copies of each annual report can be accessed at http://www.iowacrep.org/

Conservation Learning Lab

The Conservation Learning Lab is a three-year pilot project between the Iowa Department of Agriculture and Land Stewardship (IDALS) and the Natural Resources Conservation Service (NRCS) designed to answer “Can the high levels of implementation necessary to meet the goals of the NRS be obtained on a small watershed scale?”, and “Can water quality improvements be documented accordingly?”

The NRS Science Assessment estimated the potential reductions in nitrogen and phosphorus loads that could be achieved by a wide range of in-field and edge-of-field conservation practices. These estimates were based on a careful review/assessment of the published research on the effectiveness of various practices and their potential applicability. However, most of the studies used in developing the NRS were conducted at the plot scale. While these studies were essential, the report highlighted the critical need for studies that scale up the area of practice implementation in order to better assess water quality impacts across landscapes and with multiple practices.

Nutrient loads and load reductions at the plot scale can differ substantially from loads actually delivered to surface waters. For example, phosphorus in subsurface tile flow at the plot scale can be substantially lower than at the scale of even a few hundred acres. Nutrient loads at larger watershed scales (HUC 12 and above) can also differ substantially from loads actually delivered to surface waters due


to the effects of in-stream processes (for example, the effects of bed and bank erosion and phosphorus exchange with stream sediments). Most prior work on practice performance and nutrient loads in Iowa has been done at either the plot scale or larger watershed scale (HUC 12 and greater). However, the most appropriate scale for assessing agricultural nonpoint source loads to surface water is the scale at which the load is actually delivered. This is the scale on which the proposed Central Iowa Conservation Learning Lab is focused.

The focus will be on extensive implementation of nutrient reduction practices in two small watersheds; one in Story County (~1400 acres) and another in Floyd County (~650 acres). The nutrient reduction practice most likely to be implemented is planting of cover crops. In addition to widespread practice implementation, the project will evaluate corresponding nitrogen and phosphorus loads delivered to surface waters and relate these loads to land use, nutrient management and soil test phosphorus. In the long term, this demonstration should improve the predictability of practice performance, improve the understanding of practice uncertainty, increase farmer implementation of practices through outreach and education, and validate load reduction tools developed to evaluate progress toward nonpoint source load reduction.

Large watershed-scale monitoring

Fixed-Station Network

The primary source of data for determining changes in statewide nutrient load export and the contributions that designated priority watersheds make to the statewide nutrient load is the fixed-station stream monitoring network.

Monitoring at fixed-station stream water quality monitoring sites in Iowa began in the late 1970s. The number of monitoring locations, the frequency of monitoring, and the parameters monitored have varied over time for a variety of reasons including changing objectives and available funding. Sixteen locations have been monitored on a monthly

basis since 1986 thus offering a 30-year continuous record of water quality monitoring at these locations. Until 2000, the majority of the approximately 95 active and discontinued locations represented by the fixed-station network were monitored on a quarterly basis. Since 2000, all fixed stations have been monitored monthly for water quality parameters including both nitrogen and phosphorus.

In 2015, the fixed-station monitoring network included 60 sites that were monitored monthly and served primarily to provide data to evaluate water quality status and trends in Iowa’s interior rivers and streams. Figure 11 shows the locations of these sites, and Appendix A lists each site with information on location (e.g. county, river basin) and identifies those sites used in the 2014 nitrate load calculation. Monitoring objectives have evolved throughout the history of the stream monitoring program. Initially, the focus was to provide data to characterize water quality in large rivers and reservoirs. However, these monitoring locations were biased toward measuring water quality impacts from large point source discharges and runoff from urban areas. The network was modified in 1986 to provide a broader geographic representation of streams that drain medium and large-size watersheds across the state thus eliminating those earlier biases. Drainage areas at these current locations range from 34 mi2 to 14,038 mi2 and the median size is 820 mi2.

Data from these sites is used to prepare the biennial report of Iowa’s water quality for the U.S. Environmental Protection Agency (US EPA) and the public. The data also support water programs within the DNR, such as water quality standards and wastewater permitting, and has been used more recently to evaluate long-term trends in levels of nutrients and other water quality parameters.

Samples from these monitoring sites are collected and analyzed by the State Hygienic Laboratory following a US EPA-approved Quality Assurance Project Plan and US EPA approved test methods. This data is available to the public from the Iowa STORET/WQX water quality database (https://programs.iowadnr.gov/iastoret/).


IIHR Hydroscience and Engineering

The IIHR – Hydoscience and Engineering (IIHR) center at the University of Iowa conducts research in a variety of areas including hydraulics, hydrology, and water quantity and quality. IIHR operates a continuous water quality monitoring network that has steadily increased in size since 2012. Remote sensors installed throughout Iowa provide near real-time data, which are relayed back to the center every 15 minutes. The sensors measure nitrate, dissolved oxygen, water temperature, specific conductance, turbidity and pH.

Sensors were deployed at 30 locations throughout the state in 2015 and the network will expand to 45 sites in 2016 (Figure 11). The number and location of IIHR monitoring sites can vary from week to week

depending upon research needs, equipment maintenance, and other factors. Sites are selected based on a number of factors including:

• Sensing equipment funded specifically for a research proposal or project in a selected watershed.

• Major interior river sites based on their strategic importance for nutrient load estimations.

• Significance of the stream for recreation, municipal water supply, or other designated uses.

• Suitability of the site for sensor equipment, i.e. security, water depth, etc.

• Requests from outside stakeholders.

The sensors that are positioned to provide data to assist in determining statewide nutrient load estimates are located in close proximity to a U.S. Geological Survey (USGS) gaging station to provide the stream flow information needed to calculate loads. Other sensors are located to provide information to monitor nutrient reduction progress in targeted watersheds.

The IIHR has developed the Iowa Water-Quality Information System (IWQIS) to disseminate water quality data from remote sensors as well as climate data such as rainfall amounts and frequency, daily snow melt data and air temperature. IWQIS displays near real-time data on nitrate and other water quality variables in a Google Maps interface. It provides researchers, agencies, and land-owners with a tool they can use to directly monitor the impact of land-use strategies/changes on downstream water-quality, enables watershed stakeholders to understand the fate and transport of nutrients in Iowa’s waterways; and helps in measuring the impact of the NRS on water quality. Users can see the total amount of nitrate being carried along a waterway at a certain time, and can compare those levels to previous years. All archived IIHR water quality data is also made available to interested persons upon request. IWQIS can be accessed at https//iwqis.iowawis.org.

Figure 11: The distribution of fixed stream monitoring sites and nitrate probes operated by DNR, the U.S. Geological Survey (USGS), and the

Iowa Institute for Hydraulic Research (IIHR).


Challenges associated with water quality monitoring

Water quality monitoring presents challenges with estimating nutrient load exports from Iowa’s watersheds. These challenges are discussed fully in the draft collaborative report on Iowa stream monitoring efforts, and are summarized in this report to highlight the need for increased research into options for addressing these challenges.

• Legacy nutrients, which are present in the soil and groundwater from natural and anthropogenic sources, are released to surface water through bank erosion and groundwater movement. These legacy nutrients can be detected in surface water under a variety of landscape conditions, and so distort the effects that conservation has on surface water nutrient loads.

• Lag time, or the difference in time between conservation implementation and measurable change in water quality, occurs on a variety of scales. Lag time is often dependent on watershed size, and the inappropriate design of monitoring projects can impact the capacity to detect change in surface water quality.

• Variable precipitation and stream flow, extreme weather events, including heavy rainfall and flooding, lend to drastic variability in measured nutrient concentrations. Increased intermittent heavy rainfall will make it more difficult to detect reductions or trends in nutrient export.

• The importance of having comprehensive data on nutrient reduction practice implementation.

• The value of long-term monitoring to measure progress and the importance of properly situated and maintained monitoring locations.

These concerns related to reliable water quality monitoring and estimated nutrient export contribute to concerns that measurable change in statewide nitrogen and phosphorus loads will not be detected in the short term. Therefore, this annual report assesses the current monitoring network in Iowa and highlights progress in establishing new and informative water quality monitoring efforts.

Statewide nutrient load estimates

The NRS called on the DNR to convene a technical work group beginning in 2013 to define the process for providing a regular nutrient load estimate (i.e., nutrient budget) based on the fixed-station stream water quality monitoring network. This was to include specifying the most appropriate estimation method, the acceptability of existing data with which to evaluate methods, and a process for making future adjustments based on the latest information and advancements in science and technology. An interdisciplinary team of Iowa scientists and engineers from state, federal, university and commodity groups was assembled to evaluate and recommend a nitrate load estimation procedure for the State of Iowa. Representatives from DNR, ISU, IDALS, ISA, USGS, and University of Iowa first met on December 3, 2013. The work group first developed a methodology to compare the six most commonly used nitrogen load estimation models and also assembled a single standardized data set to use in comparing model results. Individual work group members were assigned to calculate a load estimate using the standardized data set and one of the load estimation methods. The full work group then compared the results obtained using each method.

The work group recommended using the linear interpolation method because it provides the simplest and most straightforward approach to estimate loads. Linear interpolation fills data gaps between measured concentrations by a straight line. Because of its simplicity different users can expect to produce approximately the same load estimate from a given set of data. Linear interpolation was also found by others to provide the overall best results for load estimation in agricultural and mixed-use watersheds. However, linear interpolation requires consistent sample collection to be effective. Missing sampling periods that lengthen the interval between measurements will result in greater potential error in load estimation.

After accepting the work group recommendation, the linear interpolation method was used to develop statewide nitrate load estimates for calendar years 2013 and 2014. Data from 63 fixed-station monitoring sites were used for the 2013 estimate and 50 sites for the 2014 estimate. Linear


interpolation was used to fill in daily concentrations between measured monthly sample results. Interpolated daily concentrations were then multiplied by corresponding daily stream flows to obtain daily nitrate loads. In addition to recommending that the linear interpolation method be used for estimating nitrate loads, the work group recommended that the sampling frequency for nitrate increase from the current once per month to a minimum of biweekly at each of the fixed-station locations to enhance the ability to quantify changing water quality due to implementation of nutrient reduction practices.

A similar effort to that undertaken for estimating nitrate loads is underway to develop a method for quantifying phosphorus loads. However, quantifying phosphorus loads has challenges distinct from those associated with quantifying nitrogen loads. A work group has compiled multiple phosphorus data sets to be used to evaluate different load estimation methods. The data sets indicate that the monthly frequency of monitoring at fixed-station sites is not sufficient to estimate phosphorus loads because the amount of phosphorus in rivers and streams changes very rapidly with changes in stream flow. It is unlikely that phosphorus load estimates can be obtained without event-based sampling or continuous monitoring. Unlike nitrate however, there are no in-stream phosphorus sensors available that can help overcome this challenge. The work group is exploring the possibility of using a surrogate parameter—possibly turbidity—that can be measured with currently available and deployed sensors. Evaluation of potential surrogates is expected to be completed in 2016.

Finally, it may be possible to eliminate altogether the need for load estimation models for both nitrate and phosphorus by using in-stream sensors (Feng et al., 2013; Davis et al., 2014). Although sensors require periodic maintenance and calibration they provide actual measurements of pollutant concentrations on a nearly continuous basis. When coupled with stream flow measurements made at or near the location of each sensor, loads can be measured rather than estimated

Table 9 outlines the baseline loads estimated for the NRS in 2012. While this baseline, an average of 2000 to 2010 modeled estimates, serves as

the reference for evaluating NRS progress, particularly pertaining to the impact of conservation practices on nutrient export, future analyses will incorporate more frequent calculations of nutrient loads using the linear interpolation method for nitrogen and, eventually, methods that are under assessment for modeling phosphorus loads. Additionally, the load estimate will improve based on the extensive database that has been built as a result of the monitoring conducted by wastewater treatment facilities.

Table 9: The loads of nitrogen and phosphorus in Iowa calculated as an average from 2000-2010 data, and the respective goals for reductions from nonpoint sources (NPS) and point sources (PS).

Baseline Estimates from the NRS Nitrogen Phosphorus

Statewide baseline load (tons) 307,000 16,800Load reduction needed for 45% reduction 138,150 7,560NPS portion of load reduction 125,870 4,872PS portion of load reduction 12,280 2,688% of target load reduction from NPS 91.1% 64.4%% of target overall load reduction from PS 8.9% 35.6%

Calculating nutrient load reductions

The NRS Science Assessment evaluated the effects of conservation practices on nutrient losses from nonpoint sources. Load reductions were calculated for the subset of practices based on the relative ability to enumerate the reductions. Efforts are underway to address the lack of data and information that would support more robust calculation of load reductions. Table 10 displays the pounds of nitrogen and phosphorus reduced by selected practices. Nitrogen reductions were calculated based on the cover crop acres reported through cost-share programs in 2015, and based on the total acres treated by CREP wetlands that had been installed in Iowa. Bioreactors were also factored in, but few have been installed to date and so the resulting reduction was negligible compared to those of cover crops and wetlands. With projects underway to address the challenges of gathering data on in-field practices adopted without government assistance programs, future practice data will likely show


greater rates of nitrogen load reduction.

Phosphorus reductions from in-field practices were calculated based on cover crops, extended rotations, and no-till and reduced till practices. Calculations were conducted using cost-share data from 2012 through 2015. The adoption of these practices reduced the statewide phosphorus load by an estimated 217,884 pounds in 2015. This heightened reduction over four years was driven by the rapid rate of cover crop adoption.

Table 10: Load reductions from estimates of selected conservation practice implementation in 2014 and 2015. Nitrogen was calculated as reduction of nitrate-N. Efforts to complete the calculations of nitrogen reduction for years prior to 2015 are underway. †The phosphorus load reductions caused by CRP acres are calculated based on the change from the previous year’s CRP acres. Negative phosphorus reductions indicate an increase in phosphorus load due to a decrease in CRP acres.

Nutrient Load Reduction from Select Conservation Practices partially funded through State & Federal Programs (pounds)

2014 2015Nitrogen - Total 3,830,000

Cover Crops 23,560,000CREP Wetlands 1,474,000Bioreactors 6,000Phosphorus - Total 134,947 217,884

Cover Crops 112,518 196,967No-Till 10,622 14,229Reduced Till 345 7Extended Rotation 1,463 6,680Phosphorus - annual CRP fluctuations† -104,134 +56,311

Separate phosphorus reductions were also calculated based on the annual extent of CRP acres, which fluctuates from year to year. These reductions should be interpreted as a comparison to the previous year, because

much of the retired land stayed in CRP from year to the next. However, the fluctuation in total CRP acres drove a fluctuation in the effect on phosphorus load reductions. Some CRP was removed between 2013 and 2014, resulting in a relative gain in phosphorus loads attributed to that practice. However, an increase in CRP acres between 2014 and 2015 resulted in a relative decreased in phosphorus loss attributed to the practice. In 2015, phosphorus loss was reduced by net CRP acres by an estimated 56,311 pounds. This figure will monitored annually, and stresses that conversion of CRP back to crop production can contribute to an increase in phosphorus loss from one year to the next. This assumes that CRP was returned back into row crop production and not an alternative cropping or long-term perennial use (e.g. pasture), which would have a lower impact on nutrient loss.

In the future, phosphorus reduction calculations will aim to assess the effects of terraces and other structural practices that reduce sediment loss. This is important because a large proportion of funding is directed to these practices, and has been historically; the exclusion of these practices skews load reduction estimates. Current inconsistencies among state and federal cost-share data reporting methods currently prevent the capacity to calculate standardized totals that would assist load reduction calculations. However, coordination between partner organizations aims to standardize data collection in the future to identify units that would improve the ability to calculate load reductions from these structural practices. Efforts are underway to address these challenges in data standardization. Additionally, efforts to map structural practices in priority watersheds will provide a separate database for calculations within select areas (Figure 9).

Nutrient criteria development

DNR continues to collect and analyze lake nutrient data as part of the ambient lake monitoring and the lake restoration programs. The development of quantitative indicators of lake health, including nutrient status, remains a high priority within these programs. Additionally, DNR continues to collect and analyze stream nutrient data to evaluate draft recommendations for wade-able streams and to support the development

3 Annual Progress Report | 2015-2016 | Page 33

of recommendations for headwater creeks and large rivers.

Nutrient monitoring by point sources

When permits are issued to facilities listed in the Strategy they require that those facilities monitor effluent total nitrogen and total phosphorus once per week. There are currently 86 facilities listed in the Strategy that are required to monitor their effluent for total nitrogen and total phosphorus and this number will continue to grow as additional permits are issued that require this monitoring. In addition to these facilities, all cities and industries that treat the volume of wastewater generated by the equivalent of 3,001 or more people are required by rule to monitor effluent (but not raw waste) total nitrogen and total phosphorus. There are currently a total of 147 facilities monitoring for total nitrogen or total phosphorus or both and this number will continue to increase as more permits are reissued.

Treatment facility performance

At the time the NRS was developed, little monitoring data was available for the amounts of total nitrogen or total phosphorus discharged by point sources in Iowa. Assumptions were made based on respected engineering literature that Iowa POTWs treat raw wastewater that contains approximately 25 mg/l total nitrogen and 4 mg/L total phosphorus. These values were used together with a percentage of the wastewater treatment plant design flow to estimate the loads being discharged by each of the point sources listed in the strategy and assuming that facilities at that time were not removing any total nitrogen or total phosphorus. Estimates were also made of the amounts that would be discharged if the target concentrations of 10 mg/L total nitrogen and 1 mg/L total phosphorus were achieved.

Table 11: Performance by all facilities with 10 or more months of data.

Estimate (Target)

POTW (range) Industry (range)

Total Nitrogen (average)# of facilities 41 6raw waste (mg/L) 25 28.7 (0.1 – 285.0) 107.1 (3.63 - 748.0)

final effluent (mg/L) 10 15.2 (0.2 - 220.8) 22.6 (0.0 - 15.5)

% removal 66 44.7 (10.8 - 89.1) 74.7 (60.6 - 87.3)

Total Phosphorus (average)# of facilities 41 9raw waste (mg/L) 4.0 4.4 (-3.0 - 419.8) 27.5 (0.53 - 200.0)

final effluent (mg/L) 1 2.2 (0.0 - 23.9) 17.2 (0.05 - 176.0)

% removal 75 43.0 (-34.0 - 80.6) 51.4 (-40.9 - 89.2)

Annual Load Reduction (2015-2016)Total N (tons) - 2,949 115Total P (tons) - 599 99

Results of weekly monitoring are now available for 86 facilities whose permits have been issued since the strategy was released. Data in Table 11 reflect the actual results from 41 POTWs for which at least 10 months of weekly sample results are available for both raw waste and final effluent and nine industries with at least 10 months of data for raw waste, final effluent or both. Not all industries operate wastewater treatment plants and therefore not all have raw waste data.

16 of the 41 POTWs had an average annual effluent concentration for total nitrogen equal to or less than the target of 10 mg/L while 5 had an average total phosphorus concentration equal to or less than the target of 1.0 mg/L.

Ten POTWs met or exceeded the target percent removal for total nitrogen (66%) and four met or exceeded the target for total phosphorus (75 percent) although it is likely that if data were available for Clinton that it would also show that it met these targets.

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By subtracting the average pounds/day in the raw waste discharged by each POTW from the average pounds/day discharged in the final effluent then multiplying the resulting value by 365 reasonable approximations of the total pounds of total nitrogen and total phosphorus removed by each of the 41 POTWs during 2015-2016 could be calculated. Adding the calculated values for all of these individual facilities shows that they removed approximately 2,949 tons of total nitrogen and 599 tons of total phosphorus in a 12 month period. Industries removed approximately 115 tons per year of total nitrogen and 99 tons per year of total

phosphorus.

Treatment performance by type of treatment

Table 12 provides a summary of raw waste, final effluent and percentage removal data for both total nitrogen and total phosphorus for the same 41 POTWs and nine industries used to develop Table 11 but breaks

down the data by the type of treatment system in use today.

Table 12: Performance by treatment type for facilities with 10 months or more of data.

Treatment Type # Total Nitrogen Total PhosphorusRaw

(mg/L)Final

(mg/L)%R

Raw (mg/L)

Final (mg/L)

%R

POTW 41Aerated Lagoon 2 18.1 8.9 54.1 3.4 1.5 57.1Activated Sludge 16 34.6 18.8 43.1 5.4 2.3 48.6No Biological Treatment

0 0 0 0 0 0 0

Rotating Biological Treatment

3 18.7 11.6 37.5 2.5 1.6 34.1

Sequencing Batch Reactor

6 23.7 7.3 69.3 3.9 1.6 56.5

Trickling Filter 14 32.2 17.3 38.5 4.8 3.1 34.0Industry 9Aerated Lagoon 0 0 0 0 0 0 0Activated Sludge 6 65.4 22.9 68.4 19.1 8.9 59.5No Biological Treatment

1 30.3 5.6 81.4 51.1 17 66.7

Rotating Biological Treatment

0 0 0 0 0 0

Sequencing Batch Reactor

1 65.7 16.7 74.5 56.5 79.5 -40.9

Trickling Filter 1 350.5 44.4 87.3 25.9 5.2 80

It is difficult to draw firm conclusions from this data because so few facilities are represented for most of the treatment types. For example, while the lowest raw waste and final effluent concentrations and the second highest removal percentages for POTWs were for aerated lagoons, the data is from a single facility which may not be representative of all aerated lagoon systems. Sequencing batch reactors had the highest

percentage removals with the average removal for total nitrogen slightly exceeding the target removal of 66 percent and raw waste concentrations less than typical domestic sewage. Activated sludge and trickling filter treatment plants had almost the same raw waste, final effluent and percent removals.

It is even more difficult to draw general conclusions with respect to industries because there are so few facilities represented by the data. The one industry with a sequencing batch reactor does not currently have the capability for removing biosolids from the treatment process and instead recycles them to the head of the plant. This causes phosphorus levels to continue to build-up in the effluent resulting in a negative removal efficiency; a condition one would not expect to find in other treatment systems. The reason for the high raw waste concentrations and high percentage removals for the single industry that does not have a biological treatment plant cannot be explained with the information currently available

Estimates vs actual data

The available data show that the actual raw waste concentrations of total nitrogen and total phosphorus for POTWs are only slightly higher on average than the estimates used in preparing the NRS but that those for industries are significantly higher. In the case of POTWs considerable literature was available that described the characteristics of normal domestic sewage that could be used as a starting point for preparing estimates. That was not the case for industries where the NRS acknowledged that “data on the amounts of nitrogen and phosphorus discharged by industries is not readily available but likely varies significantly based on the type of industry.” Several factors can affect the nutrient content of industrial waste including:

• Type of industry;• Production processes and flow rates;• Whether process wastewater is treated by the industry itself or

discharged to a POTW for treatment;• Types and amounts of chemicals used;

• Government regulations

For example, phosphoric acid is the most common chemical used by food processing establishments for cleaning in order to meet USDA regulations for cleanliness. The amount of cleaning required and the type of equipment cleaned using phosphoric acid likely has a bearing on the amounts of total phosphorus in both the raw waste and final effluent. A meat processing facility will have higher amounts of both nitrogen and phosphorus due to the nature of wastewater produced than a power plant. An industry that sends its process wastewater to a municipal system for treatment and discharges only cooling water and other utility waste streams will discharge lesser amounts of nutrients than the same type of industry that treats its own process wastewater.

Perhaps the most surprising numbers in Table 12, and the greatest departure from initial estimates, is the removal percentages being achieved by some treatment facilities. It is noteworthy that significant reductions in the amounts of total nitrogen and total phosphorus occur even before most facilities have installed or implemented specific nutrient reduction measures. It was assumed at the time the strategy was developed that treatment facilities removed little, if any, total nitrogen or total phosphorus unless they were specifically designed and constructed for biological and/or chemical nutrient removal. However, the data show that POTWs on average remove about 45 percent of the total nitrogen and total phosphorus entering the treatment plant despite not having been specifically designed to do so. Industries appear to be achieving even higher rates of removal than POTWs although the data for industries represents only a small number of facilities and caution should be exercised in drawing conclusions based on this limited data.

Seasonal variability in effluent nutrient levels was expected since biological treatment plants are generally less efficient during cold weather. Figure 12 shows the variability in both raw waste and final effluent concentrations for a single POTW.


Updating information for point source contributions in the INRS

With data now available to calculate annual raw waste and final effluent concentrations and percent removal rates for total nitrogen and total phosphorus for approximately 40 percent of the POTWs listed in the strategy, it is an appropriate time to reassess the estimates made of the total contribution of total nitrogen and TP from major point sources, and the reductions that can be expected as treatment facilities are upgraded or replaced to include nutrient removal processes.

The NRS states that “Discharges from wastewater treatment plants contribute approximately 8% of the total nitrogen and 20% of the total phosphorus entering Iowa’s streams and rivers annually.” The NRS also projected that if the 147 wastewater treatment plants listed in the strategy were to meet the goals by reducing total nitrogen loads by two-thirds and total phosphorus by three-fourths that would reduce the amount of nitrogen discharged by 11,000 tons per year and the amount of phosphorus by 2,170 tons per year. These figures represented a four percent reduction in nitrogen and 16 percent reduction in phosphorus in the total estimated statewide amounts entering Iowa’s rivers and streams from both point sources and nonpoint sources.

These estimates of point source load contributions were derived by multiplying raw waste concentrations of 25 mg/L total nitrogen and 4 mg/L TP by two-thirds of the average wet weather design flow for each treatment facility and assuming no removal of total nitrogen or total phosphorus by treatment plants. The concentrations were values for typical domestic sewage taken from a respected engineering text. No removal was assumed because no treatment plants at the time were known to have been constructed with nutrient removal capabilities. While it was recognized that a number of plants were designed to treat ammonia nitrogen, this process simply converts ammonia to nitrate but does not remove total nitrogen from the wastewater. Since each facilities’ annual average (long-term average day) flow was unknown at the time an approximation was derived using a peaking factor table in the EPA Nitrogen Control Manual (Table 13).

Table 13: Comparison of estimated versus actual nutrient levels. *Estimated loads for POTWs at average annual flow and 25 mg/L TN and 4 mg/L TP. Industrial loads were not estimated.

Estimated or Actual TN TP

Estimated potential PS load reductions 11,000 T/yr 2,170 T/yrActual load reduction in 2015-16 for 41 POTWs and 9 industries

3,064 T/yr 698 T/yr

Estimated % removals w/BNR 66 75Actual % removals by POTWs today 44.7 43Actual % removals by industries today 74.7 51.4Estimated raw waste concentrations* 25 mg/L 4.0 mg/LActual raw waste concentrations: POTWs 28.7 mg/L 4.4 mg/LActual raw waste concentrations: industries 107.1 mg/L 27.5 mg/L

The actual raw waste concentrations for POTWs for both total nitrogen and total phosphorus are quite similar (Table 13). Those for industries differ significantly. The original estimates failed to take into account the significant amounts of nutrients already being removed even though most facilities have not yet installed nutrient reduction treatment technologies.


Figure 12: Seasonal variability in raw waste and final effluent total nitrogen at a Publicly Owned Treatment Works (POTW).

Looking Ahead

• The list of affected facilities in Section 3.3 of the NRS will continue to be reviewed and updated annually as new facilities become subject to the strategy and facilities are dropped from the list because they are no longer meet the criteria established for inclusion.

• Permits will continue to be issued to facilities listed in the NRS that will specify requirements to complete and submit nutrient reduction feasibility studies with a goal of issuing at least 20 more permits within the next year.

• DNR will timely review nutrient feasibility studies as they are submitted and amend NPDES permits to include construction schedules for installing nutrient reduction treatment technologies. Where a feasibility study concludes that it is not feasible and/or reasonable to meet the targets identified in Section 3 of the INRS, the facility’s permit will be amended to require submittal of another feasibility study 5 years from DNR’s approval of the first study.

• DNR will continue to analyze raw waste and final effluent data for nutrients as data from more facilities becomes available to evaluate performance of treatment facilities both before and after operational changes are made or additional treatment is installed.

• DNR will attempt to correct and/or explain anomalies in data submitted by treatment facilities. Such anomalies can include but are not limited to the reporting of negative removal efficiencies, single high or low concentrations that are inconsistent with other reported data and apparent data entry errors.

Public comment

Iowans are invited to review the updated Iowa Nutrient Reduction Strategy and supporting documents. The Iowa Department of Agriculture and Land Stewardship, the Iowa Department of Natural Resources and Iowa State University seek to continue to broaden the engagement of stakeholders and further advance the strategy.

The public is invited to provide feedback on implementation of the

strategy and comment on additional partnerships that could help strengthen the strategy and help achieve the goals of continuous improvement and broad participation by all stakeholders. The comment period will be ongoing.

Areas of focus include:

Strengthen collaborative local, county, state, and federal partnerships• Are there additional partners with a demonstrated ability to advance

implementation of nutrient reduction technologies and conservation practices to improve water quality?

Identify additional opportunities for accelerating cost effective nitrogen and phosphorus load reductions from both point and non-point sources.• Are there additional or emerging practices and/or technologies that

should be considered for inclusion in the NRS Science Assessment? The WRCC annual report on the strategy identifies a process for these new and emerging practices and technologies to be included in the list of practices.

• Are there additional delivery methods and opportunities that should be considered to increase the rate of adoption?

Electronic: Please submit your comments at nutrientstrategy.iastate.edu/comments

Mail:ANR Program Servicesattn: Nutrient Reduction Strategy1151 NSRIC 1029 N University Blvd.Ames, Iowa 50011-3611

Comments and contact information submitted here are considered public and are subject to Open Records Law requests from the media or others.

Comments received to date can be found at www.nutrientstrategy.iastate.edu/public



Appendix A: Iowa Nutrient Strategy Updates Evaluation

IDALS, ISU and DNR collaborated on identifying needed updates to the text of the Iowa Nutrient Reduction Strategy. Updates were identified as necessary to keep the text of the strategy up to date based on current information and status of efforts related to the strategy. Following is a summary of the updates that were identified.

Point Source Updates:1. Section 3 – Providing clarification to #5 New Dischargers in the Implementation Plan Details section.2. Section 3 – Providing clarification by adding #6 Power Plants in the Implementation Plan Details section.3. Section 3 – Providing clarification to #4 Treatment Impracticable in the Implementation Plan Details section.4. Section 3 – Providing clarification to the “Revisions to Section 3.3 – List of Affected Facilities” section.5. Section 3 – Annual updates to the List of Affected Facilities.6. Section 1 – Update trading section to be reflective current efforts within the state.

Appendix B: Progress of the Conservation Practice Mapping Project

BMP Mapping for WQI Watersheds (as of June 9, 2016)

HUC 8 Name HUC 8 HUC AcresHUC 12 Mapped

# Pond Dams

Grassed Waterway

(acres)# Terraces

Terraces (miles)

WASCOBs (number)

WASCOBs (miles)

Contour Buffer

Strips (ac)

Strip-cropping (acres)

Boone 07100005 581,186.0 29 63 1,247.8 127 28.4 309 25.7 314.3 0.0Floyd 10230002 586,570.0 23 168 2,840.1 13,558 2,608.6 851 37.3 1,367.9 760.8Middle Cedar 07080205 1,545,363.0 68 671 21,109.1 5,041 842.8 2,444 223.5 8,914.1 1,528.6N Raccoon 07100006 1,579,997.0 75 593 5,399.9 2,110 404.0 2,998 289.7 1,236.7 652.8Skunk 07080107 1,044,443.0 11 1,165 3,740.3 2,942 417.6 7,366 323.9 1,167.6 217.1S Skunk 07080105 1,179,099.0 15 141 2,056.5 565 84.7 808 63.4 1,064.7 78.7Turkey 07060004 1,083,426.0 53 1,131 11,176.4 9973 1,622.1 2,793 148.7 40,537.9 7,163.9E Nishnatbotna 10240003 734,993.0 2 109 894.3 1381 259.4 53 2.1 1,526.3 0.0W Nishnatbotna 10240002 1,057,490.0 8 50 341.6 2713 554.3 163 8.3 879.7 6.7

Total 9,392,567.0 284.0 4,091.0 48,806.0 38,410.0 6,821.9 17,785.0 1,122.5 57,009.2 10,408.6


Iowa Department of Natural Resources Environmental Protection Commission

ITEM 8 DECISION

TOPIC FY 18 Budget Request

The Environmental Protection Commission’s approval is requested for the Department’s appropriation request for Fiscal Year 2018. The State Budget Director has directed all departments to submit a status quo budget. The budget is required by statute to be submitted to the Department of Management by October 1, 2016.

Jennifer Nelson, Chief Financial Officer, Budget and Finance Bureau DEPARTMENT OF NATURAL RESOURCES

FY 2018 BUDGET REQUEST

APPROPRIATION NAME FY 17

Appropriation

FY 18 Department

Request GENERAL FUND Department Operations $12,862,307 $12,862,307 Floodplain Management $1,950,000 $1,950,000 Forestry Health Management $500,000 $500,000 Total General Fund Appropriations $15,312,307 $15,312,307 INFRASTRUCTURE Lake Water Quality Improvements $9,600,000 $9,600,000 Water Trails/Lowhead Dam $1,000,000 $1,000,000 Park Infrastructure Improvements $3,000,000 $3,000,000 Total Infrastructure Appropriations $13,600,000 $13,600,000 ENVIRONMENT FIRST Resource Enhancement and Protection $16,000,000 $16,000,000 Ambient Air Quality Monitoring $425,000 $425,000 Water Quality Monitoring $2,955,000 $2,955,000 GIS Data for Watershed Managers $195,000 $195,000 Park Operations and Maintenance $6,235,000 $6,235,000 Water Quantity $495,000 $495,000 Animal Feeding Operations $1,320,000 $1,320,000 Water Supply Appropriation $500,000 $500,000 Geological and Water Survey $200,000 $200,000 Total Environment First Appropriations $28,325,000 $28,325,000 NON-GENERAL FUND Fish and Wildlife Operations $43,147,993 $43,147,993 Groundwater Fund $3,455,832 $3,455,832 UST Administration Match $200,000 $200,000 Snowmobile Transfer to Fish and Wildlife $100,000 $100,000 Total Non-General Fund Appropriations $46,903,825 $46,903,825 TOTAL $104,141,132 $104,141,1322


ITEM 9 INFORMATION

TOPIC State of Iowa Public Drinking Water Program 2015 Annual Compliance Report

The Department is submitting the State of Iowa Public Drinking Water Program 2015 Annual Compliance Report to the Environmental Protection Commission for information purposes. The Safe Drinking Water Act (SDWA) Amendments of 1996 require the Department to issue an annual report of the SDWA violations in the state. This report fulfills the reporting requirement in Iowa for the 2015 calendar year. It was prepared by the Department’s Water Supply Engineering & Operations Sections in the Water Quality Bureau of the Environmental Services Division. The report contains a summary of the program, a description of the requirements that systems must meet, the year’s violation statistics, and the list of the systems with each health-based standard or major monitoring or reporting violation incurred during the year. The photographs in the report were from Drinking Water State Revolving Loan Fund projects that were completed during the year. The maps depict the public water supply system universe in Iowa and the locations of the systems that incurred the health-based standards and major monitoring and reporting violations. Development of the report was accomplished through the use of the state water supply database. It was provided to EPA on July 1st, which met the deadline. An electronic copy has also been provided to the members of the SDWA Technical Advisory Group, the State Library, and is available on the IDNR’s website. 2015 Report highlights: • There were 1,878 regulated public water systems in Iowa that served water at least one day during the year,

serving more than 2.91 million people. • There were no reported waterborne illnesses or deaths from Iowa public water supply systems in 2015. • There were 205 violations of health-based standards at 103 public water supply systems serving 193,090

people. On a percentage basis, 94.5% of the systems were in compliance with all health-based standards and 91.5% of the population was served water with no violations of health-based standards.

• There were 673 violations of major monitoring and reporting requirements at 315 public water supply systems serving 170,790 people. The system compliance rate was 83.2% and 94.1% of the population of Iowa’s systems were served by systems with no major monitoring or reporting violations.

• For the health-based standards, 73% of the violations are attributed to three contaminants: coliform bacteria, combined radium 226 & 228, and nitrate nitrogen.

• There were 6 systems with a total of 11 acute E. coli bacteria maximum contaminant level violations. • There were 16 violations of the nitrate standard at 10 systems. • There were 5 systems that received a violation for failure to obtain a certified operator during the year. • There were 27 community systems that failed to prepare and distribute their annual consumer confidence

report in 2015, which is a 97.5% compliance rate. The electronic report is available at the DNR’s website: www.iowadnr.gov/WS-Annual-Compliance-Report.

Diane Moles, Executive Officer 2 Water Supply Engineering Section Water Quality Bureau

http://www.iowadnr.gov/WS-Annual-Compliance-Report


ITEM 10 Decision

TOPIC Water Supply: Water Use & Allocation Annual Permit Fee

The Commission is asked approve the Water Use and Allocation Program annual permit fee of $66.00 per permit for SFY 2017. Background Water use permits are required of any person or entity using 25,000 gallons of water in a single day during the year, and are issued for a period of up to 10 years. Previously, appropriations from the General Fund were used to fund the water allocation and use permits program. During the 2008 legislative session, the legislature authorized the department to collect up to an additional $500,000 in fees each fiscal year. Iowa Code §455B.265(6) requires the fees to be based on the Department’s “reasonable cost of reviewing applications, issuing permits, ensuring compliance with the terms of the permits, and resolving water interference complaints.” There are two types of fees in the Water Use and Allocation Program: an application fee and an annual permit fee. This request is for the determination of the annual fee for SFY 2017. The annual fee rule, adopted in 2009, is summarized below (IAC 567-50.4(2)“b”): • Each year, the Commission is asked to set the annual fee based on the budgeted

expenses for that year minus the amount of any unused funds from the previous year and any general fund appropriations.

• The department reviews the annual permit fee each year and adjusts the fee as necessary to cover all reasonable costs required to develop and administer the water use permitting program.

• The annual fee is based on the number of active permits. • Each permit holder pays the same annual fee. • The fee is not prorated and is nonrefundable. • The department requests Commission approval of the amount of the annual fee no

later than September 30 of each year. • The department provides an annual fee notice to each permittee at least 60 days

prior to the fee due date. • The annual fee due date is December 1st; 60 days prior is October 1st. There is no annual fee required for either a water storage permit (permitted for the life of the structure) or a minor nonrecurring water use registration (one-year permit duration). The annual permit fee was $135.00 in the first two years, $95.00 in SFY 2012, and $66.00 in SFY 2013 and SFY 2014, and $99.00 in SFY 2015 and SFY 2016.

SFY 2017 Budget The worksheet included with this agenda brief illustrates the actual expenditures in SFY 2012 – 2016 and the budgeted amounts for SFY 2016 and SFY 2017. The final accounting figures for SFY 2016 are not expected to change. In addition to accomplishing the normal work activities of the program, the budget in 2017 includes the following: • Continuing with the well-matching efforts for the various aquifers, • Increase use of the on-line database by permittees for annual use reports and fee

payment, and • Continue to implement the Jordan aquifer management strategies, working with

affected systems that are near Tier 2-3 levels. Fee Analysis At the Water Use Stakeholder meeting on July 28, 2016, the program’s activities and budget were reviewed. A $66.00 annual water use permit fee was proposed for SFY 2017, which is a reduction of $33.00 from the SFY 2016 annual fee. The stakeholder members participating in the meeting concurred. Based on the budget and stakeholder input, the annual water use permit fee for SFY 2017 should be $66.00. Mark Moeller Supervisor, Water Supply Engineering Section Environmental Services Division August 10, 2016

Water Allocation and Use (7152)

FY12 Final Expenses

FY13 Final Expenses

FY14 Final Expenses

FY15 Final Expenses

FY16 Budget

FY16 Actual (through

6/16) FY17 Budget

REVENUES

General Fund $136,814 $148,885 154,268$ $312,684 192,450$ 160,072$ 169,306$ Water Use Permit Fund $319,232 $347,397 359,958$ $382,169 449,049$ 373,502$ 395,048$ WU Permit Fund Carryforward* $270,992 $287,121 247,076$ $187,195 0$ 174,497$ 174,051$

TOTAL REVENUES $456,046 $496,282 514,226$ $694,853 641,499$ 533,574$ 564,354$

EXPENSES FTE 4.17 3.54 3.72 4.01 4.25 4.12 4.25

Personal Services $299,955 $384,080 $411,419 $474,298 $461,891 $449,333 $473,255 Permanent 299,955 384,080 411,419 474,298 461,891 449,333 473,255

Non-Permanent 0 0 0 0 0 0 0 Personal Travel In-State 245 0 469 790 500 775 500

State Vehicle 0 0 0 0 0 0 0 Depreciation 0 0 0 0 0 0 0

Pers. Travel Out of State 0 467 6,162 2,153 2,000 0 2,000 Office Supplies 0 1,036 3,484 526 750 124 750

Facility Maintenance Supplies 0 78 0 0 0 0 0 Equipment Maintenance 0 0 38 0 100 0 0

Prof Supplies 0 0 0 0 0 0 0 Ag Supplies 0 0 0 0 0 0 0

Other Supply 65 373 42 12 100 0 100 Print &Binding 458 843 542 422 800 445 800

Uniforms 0 0 0 60 100 0 0 Postage 240 240 120 0 250 2,247 1,500 Communications 1,309 1,365 2,953 2,346 3,000 1,947 1,900 Rentals 13,098 13,828 8,256 0 100 0 0 Utilities 0 0 0 0 0 0 0

Professional Services 93,570 28,890 0 0 0 0 5,000 Outside Services 0 6,937 0 54 0 0 0 Intra-State Transfers 0 0 0 0 0 0 0

Advertising &Publishing 1,863 3,746 3,350 1,392 3,300 1,784 3,000 Auditors Reimbursement 0 0 0 0 0 0 0

Reimbursement 303 88 98 295 100 110 420 ITS Reimbursement 0 0 1 115 0 157 250 IT Outside Services 0 18,000 151,650 103,000 15,831 15,000

Govt Transfers-AG Office 0 0 0 0 0 0 Govt Transfers - Auditor 0 0 0 0 0 0

Govt Transfers-Other Agency 0 0 0 0 0 0 Equipment Inventoriable 0 0 1,937 0 0 0 0 Equipment Non-Inventoriable 0 0 6,292 0 500 0 1,200

IT Hardware 523 2,873 0 5,774 1,000 473 0 Other Expenses 413 356 336 1,231 1,500 1,485 1,500

Securities 0 0 0 0 0 0 0 Licenses 0 0 0 0 2,000 0 0 Fees 0 0 0 0 0 0 Refunds 0 0 0 0 0 0

State Aid 0 0 0 0 0 0 0 Capitals 0 0 0 0 0 0 0 Indirects 44,003 51,083 50,728 53,735 60,508 58,863 57,359

General Fund Rescission TOTAL EXPENSES $456,045 496,282$ $514,227 $694,853 641,499 $ 533,574 $ $564,534

Notes: Actual Expenditures for SFY2012 - SFY2015 are final. Projected actual & proposed budget expenditures for SFY2016 & SFY2017 are subject to change. This spreadsheet shows the actual revenue amount drawn from WU Permit Fund and General Fund, not the fund balances. *Actual carryforward is not additive for the revenue. Document Date: 7/22/2016


ITEM 11 DECISION

TOPIC Clean Water and Drinking Water State Revolving Loan Fund – Second

Quarter Updates to the FY 2017 Intended Use Plans

Commission approval is requested for the second quarter updates to the Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) Intended Use Plans (IUPs) for FY 2017 (July 1, 2016 – June 30, 2017). The State Revolving Fund programs are authorized through federal legislation and administered by the State of Iowa under the oversight of the U.S. Environmental Protection Agency. The CWSRF finances publicly owned wastewater and sewer facilities, storm water management for water quality, and nonpoint source control practices to keep pollution out of Iowa’s water. The DWSRF covers water system projects, including source water, treatment, storage, and distribution and transmission, as well as consolidation and connections. The Iowa SRF is operated through a coordinated partnership between the Department of Natural Resources (DNR) and the Iowa Finance Authority (IFA). DNR administers the environmental and permitting aspects of the programs, with IFA providing financial assistance including loan approval and disbursements. Other important partners include the Iowa Department of Agriculture and Land Stewardship, Soil and Water Conservation Districts, county sanitarians, participating lenders, and others. The FY 2017 IUPs include plans of action for the SRF programs, including goals and objectives, an analysis of current and projected financial capability, financial management strategies, the project priority lists, discussion of set-aside programs and efforts, and planned uses for administrative accounts. The IUPs are developed and updated quarterly, in June, September, December, and March or more often as needed. Each draft IUP and update is released for public comment, and then presented for approval to the Commission. A public meeting was held August 11, 2016 to receive comments on the proposed IUP updates. There were no attendees. The written comment period closed on August 18, 2016. There were no written comments. The Sources and Uses tables for both CWSRF and DWSRF show that funds are available or obtainable to provide anticipated disbursements. The IUPs will be updated quarterly during FY 2017. Patti Cale-Finnegan, DNR SRF Coordinator August 19, 2016

Chart 1 in 11.1.xls 1 of 5 9/1/2016

Project Name DWSRF No. Project Description IUP Yr Project Type

Priority Points

Quarter Population

Project Status

Current Requests

Loan Forgiveness

Loan Signed Original Request Loan Amount

Calumet PD-DW-17-08 Install new water distribution system.

2017 G P&D 2 R $ 132,500

Farley FS-31-17-DWSRF-008 An HMO treatment system is proposed to remove radium from the raw well

2017 A,B,E 70 2 1537 P $ 2,311,000

Farley PD-DW-17-09 Treatment to remove radium from raw well

2017 G P&D 2 1537 R $ 200,000

Janesville FS-09-17-DWSRF-009 Install new water main that connects the western portion of Janesville to the easten portion.

2017 B,E 30 2 930 P $ 1,015,000

Lacina Meadows Homeowners Association

PD-DW-17-10 Treatment and removal of Radionlulas from water system to meet Iowa standards

2017 G P&D 2 R $ 75,000

Lyon & Sioux Rural Water FS-60-17-DWSRF-011 Installation of permanent emergency generators for the Klondike WTP & Larchwood WTP to treat and pump water to the distribution system during power outages

2017 B,E 25 2 1390 P $ 131,000 75%

Murray PD-DW-17-11 Improvements to existing water distribution system includuing water main replacement, looping, addition of main, and replacement of existing fire hydrants and valves

2017 G P&D 2 R $ 70,000

Rathbun Regional Water (RRWA)

FS-04-17-DWSRF-010 Replacement of of aging water meters with a new advanced/smart metering system.

2017 C,D 15 2 28215 P $ 2,902,945 30% of cost of water meter

equipment and installation

Sioux City (Western Hills/Indian Hills)

FS-97-17-DWSRF-012 Construction of a new water tank and a large capacity water main

2017 B 20 2 82759 P $ 5,366,375

Sioux City (Zenith Water Treatment Plant)

FS-97-17-DWSRF-013 Add standby generator to Riverside Collector and improvements to the chemical feed systems

2017 B 15 2 82759 P $ 1,797,267

Washington FS-92-17-DWSRF-007 Construct new treatment plant modifications

2017 B,E 25 2 7266 P $ 3,977,790

Washington PD-DW-17-12 Water Treatment Plant Improvements

2017 G P&D 2 R $ 507,000

Amana Society Service Company

FS-48-17-DWSRF-001 Replace with 250,00 gallon new elevated water storage and construct booster station. New 8-inch main is also proposed

2017 A,B,E 95 1 1224 P $ 5,603,000 75%

Clarion DROPPED Water Main Improvement 2017 B,C,E 40 1 2850 DFort Dodge FS-94-17-DWSRF-006 Upgrade of all water meters

and addition of automatic reading system

2017 B 20 1 25,206 P $ 4,347,000 30% of cost of water meter


Gallery Acres West HOA (Solon)

PD-DW-17-01 Evaluation of system supply, possible construction of new well

2017 G P&D 1 43 R $ 75,000

Chart 1 in 11.1.xls 2 of 5 9/1/2016

Kelley FS-85-17-DWSRF-005 Connection to Xenia Rural Water System, disconnection of well, water tower rehabilitation

2017 B,E 45 1 310 P $ 552,000

Oelwein FS-33-17-DWSRF-004 Rehabilitation of existing well, new well house, chlorine feed system, emergency generator

2017 B,C,E 55 1 6415 P $ 1,033,000 75% of cost of generator


Osceola County Rural Water System

FS-71-17-DWSRF-003 New treatment plant to remove iron and manganese, generator, ground storage reservoir, well buildings

2017 B,E 40 1 754 P $ 6,643,000 75% of cost of generator


Sidney PD-DW-17-02 Water Supply and Treatment Improvements

2017 G P&D 1 1138 L 7/1/16 $ 120,000 $ 120,000

Amana Society Service Company

PD-DW-16-48 Solutions to pressure problems and well replacement

2016 G P&D 4 1224 R $ 1,150,000

Anamosa FS-53-16-DWSRF-019 Plant Expansion 2016 B,C,E 50 4 4283 P $ 1,660,000 Anamosa PD-DW-16-49 Plant Expansion 2016 G P&D 4 4283 R $ 321,350 Johnston FS-77-16-DWSRF-018 Upgrade existing aging water

distribution system2016 B 20 4 17306 P $ 1,810,000

New Sharon FS-62-16-DWSRF-017 Construction of 7,400 I.F. of 8" transmission main along with related valves, booster pump and connections. Water treatment plant improvements and 1,500 I.F. of 6" water amin

2016 B,E 30 4 1293 P $ 1,319,050

Osceola County Rural Water System

PD-DW-16-52 Construction of new 2,400 gpm iron and manganese removel water treatment plant

2016 G P&D 4 4929 R $ 465,000

Palmer FS-76-16-DWSRF-020 Construction of a backwash equalization tank to discharge the backwash water into the pressure sewer system.

2016 B,C,E 35 4 165 R $ 130,000

Solon FS-52-16-DWSRF-016 Construct additional storage capacity including 400,000 gallon storage reservoir and booster station, generator

2016 B,E 45 4 2037 p $ 1,692,000 75% of cost of generator


Spirit Lake FS-30-16-DWSRF-021 Proposed improvements consist of free copper ion feel equipment for zebra mussel control, additional intake line, replacement of sections buried raw water transmission mains.

2016 B,E 40 4 5578 P $ 2,814,000

West Des Moines FS-77-16-DWSRF-022 Construction of 1 Jordan aquifer and 2 shallow alluvial aquifer wells to provide redundancy of source water supply

2016 B 35 4 56609 P $ 8,050,000

Alta FS-11-16-DWSRF-011 Construction of a new well 2016 B,E 45 3 1960 P $ 846,000 Bedford FS-87-15-DWSRF-016 Water main replacement 2016 B,E 30 3 1400 R $ 350,000

Chart 1 in 11.1.xls 3 of 5 9/1/2016

Cushing FS-97-16-DWSRF-013 Construction of a new 55,000 gallon standpipe for water storage, water meters, emergency generator

2016 B,E 30 3 220 P $ 517,000 30% of cost of water meter

equipment and installation, 75% of cost of generator equipment and

installation

Fenton FS-55-16-DWSRF-012 Install new water tower 2016 B,C,E 55 3 281 P $ 392,000 Livermore FS-46-16-DWSRF-010 Install a new submersible

pump and process piping for Well #5 to tie into existing treatment plant, water meters

2016 B,C,E 55 3 384 P $ 1,186,000 30% of cost of water meter


Wahpeton FS-30-16-DWSRF-014 Construction of new 150,000 gallon elevated water storage tank, generator

2016 B,E 45 3 438 P $ 1,392,000 75% of cost of generator


Westgate FS-33-16-DWSRF-015 Construct a new water tower 2016 B,E 45 3 211 P $ 568,000

Denison FS-24-16-DWSRF-004 Three new wells to meet peak day demand, add redundancy, and enhance capacity during drought conditions.

2016 B,E 45 2 8298 R $ 1,994,000

Farmington FS-89-16-DWSRF-006 Replace old cast iron water man and underground storage tank with above ground tank

2016 B,C,E 40 2 664 P $ 312,000

Keswick FS-54-16-DWSRF-009 Replacement of all remaining cast iron main, add system looping and add new flushing hydrants, new isolation valves and service connections.

2016 B,C,E 40 2 246 P $ 411,497

Marshalltown FS-64-16-DWSRF-005 New GSR, HSP Station, generator, GSR Rehab and miscellaneous WTP Improvements

2016 B 15 2 27612 R $ 8,673,000 75% of cost of generator


Ridgeway FS-96-16-DWSRF-007 Water main replacement project, generator

2016 B,C,E 40 2 315 P $ 380,000 75% of cost of generator


State Center FS-64-16-DWSRF-008 Replacement of existing treatment system with new reverse osmosis treatment system.

2016 B,E 25 2 1468 P $ 1,751,000

Farley FS-31-16-DWSRF-001 Resolve radium issues 2016 A,E 60 1 1537 R $ 1,507,500 75%Grimes FS-77-16-DWSRF-003 Constuction of new lime

storage silo2016 B,E 25 1 10500 R $ 703,500

Aplington FS-12-15-DWSRF-017 (2) New single pedestal elevated tank solution.

2015 B,E 30 4 1158 R $ 227,000.00

Dakota City FS-46-15-DWSRF-020 Construct a 2nd well 2015 B,C,E 55 4 843 R $ 708,525 Guthrie Center FS-39-15-DWSRF-018 Water main replacement and

new water service connection2015 B,C,E 40 4 1569 P $ 518,660

Sabula FS-49-15-DWSRF-019 Water main replacement on Broad street, water meters

2015 B,C,E 40 4 576 P $ 787,920 30% of cost of water meter


Chart 1 in 11.1.xls 4 of 5 9/1/2016

Van Meter FS-25-15-DWSRF-020 New Water Main Treatment Plant

2015 B,E 45 4 1054 P $ 4,608,000

Mt Ayr FS-80-15-DWSRF-013 Water main replacement and water plant demo

2015 B,C,E 40 3 1691 R $ 1,005,000

Sioux Rapids FS-11-15-DWSRF-015 Water System Improvements, new treatment plant

2015 B,E 45 3 775 P $ 586,000

Blencoe FS-67-15-DWSRF-005 Replace influent piping, inspect and refurbish detention tank, pressure filter improvements, misc. chemical feed improvements, update building air handling equip. new main along Main and Maple St.

2015 B,E 30 2 224 D

Coralville FS-52-15-DWSRF-008 Water plant expansion and pumping improvements at main booster station to provide redundancy and capacity

2015 B 15 2 18907 P $ 4,116,580

Little Sioux FS-43-15-DWSRF-010 (2) Water distribution system improvements

2015 B,C,E 40 2 170 R $ 84,000

Maquoketa (supplemental) DROPPED Meter replacement with addition of radio read

2015 B,D,E 35 2 6141 D

Ruthven FS-74-15-DWSRF-006 New well to replace Well #1, aeralator rehab, control panel replacement, water main replacement to improve pressure and add new valves and hydrants

2015 B,C,E 55 2 779 P $ 1,316,550

Asbury FS-31-15-DWSRF-001 Constructing water main looping, installing new well and elevated storage tank

2015 B,E 45 1 4545 P $ 3,404,700

Dyersville FS-31-15-DWSRF-003 Hydrous Manganese Oxide (HMO) addition.

2015 A,B,E 95 1 4058 R $ 1,021,080 75%

Hull FS-84-14-DWSRF-023 Upgraded water supply connection to Rock Valley Rural Water

2014 B,C,E 55 4 2185 P $ 449,000

Muscatine Power & Water FS-70-14-DWSRF-022 Watermain replacement project, generator

2014 B 15 4 24386 R $ 2,432,416 75% of cost of generator


Muscatine Power & Water PD-DW-14-44 Water main replacement, generator

2014 G P&D 4 24386 R $ 215,915

North Liberty FS-52-14-DWSRF-020 Design and construction of a new reverse osmosis water treatment plant

2014 B 30 4 13386 P $ 13,200,000

Council Bluffs FS-78-14-DWSRF-009 Purchase Property adjacent to WW to protect wells from farm contamination

2014 D 15 3 63783 R $ 800,000

De Soto FS-24-14-DWSRF-011 New water treatment facility 2014 B,E 25 3 1050 P $ 3,295,000 Ida Grove FS-47-14-DWSRF-008 Add new permanent well 2014 B,E 45 3 2158 P $ 339,017 Schleswig FS-24-14-DWSRF-006 Replacement of aging water

main to reduce water loss, looping

2014 B,C,E 40 2 882 P $ 2,338,000

Stanwood FS-16-13-DWSRF-021 Construction of approx 2700 lineal feet of new 6 inch PVC pipe, including new valves, hydrants.

2013 B,C,E 40 4 684 R $ 786,841

Chart 1 in 11.1.xls 5 of 5 9/1/2016

Hawkeye FS-33-13-DWSRF-007 New well to replace failing backup well, new wellhouse and controls, generator, and water main replacement to eliminate 2" main

2013 B,C,E 55 2 449 L 75% of cost of generator


7/1/16 $ 818,000 $ 1,005,000

Sioux City FS-97-13-DWSRF-001 I-29 Utility Relocation 2013 B 20 1 82684 R $ 7,000,000 Cedar Falls Utilities FS-07-12-DWSRF-028 Water main extension to

connect homes with nitrate contaminated private wells

2012 A 35 4 39260 P $ 1,380,670 75%

Shenandoah FS-73-12-DWSRF-020 Water meter replacement 2012 B,C,D,E 45 4 5546 R $ 80,800 20%Albia FS-68-12-DWSRF-008 Water main replacement 2012 B,C,E 40 2 3706 P $ 350,000 Ralston FS-14-11-DWSRF-034 Redundant well, booster

pump installation, treatment plant upgrades

2011 B,C,E 55 4 98 P $ 343,600 40%

New London FS-44-11-DWSRF-001 New ground storage reservoir, high service pump, standby power, and water main replacement

2011 B,C,E 55 1 815 R $ 741,000 75% of cost of generator


$ 129,270,048 $ 938,000 $ 1,125,000

Project Status Project TypeContingency -- C A = Water Quality and Human Health Risk-Related CriteriaDropped -- D B = Infrastructure and Engineering-Related ImprovementReady for Loan -- R C = Affordability CriteriaLoan Signed -- L D = Special Category ImprovementsPlanning Stage -- P E = Project Serves Population less than 10,000

F = Supplemental Loan for Previously Approved ProjectWater and Energy Efficiency G = Planning and Design Loan Emergency GeneratorsDisadvantaged CommunitiesPublic Health Projects

Chart 1 in 11.2.xls 1 of 10 9/1/2016

Project Name NPDES No. Project Number CWSRF No. Project Description IUP Yr Needs

CategoryPriority Points Quarter Project

Status Current

Requests Loan

Forgiveness Loan Signed Original Request Loan Amount

Allison 1203001 S2014-0095 1920802 01 Wastewater Treatment Facility Improvements

2017 II 260 2 P $ 2,367,268

Ames 8503001 S2013-0327 PD-CW-17-24 I/I correction 2017 IIIA P&D 2 R $ 375,000 Corydon 9334004 PD-CW-17-18 Wastewater Treatment

Facility Improvements2017 II P&D 2 R $ 410,000

Eagle Grove 9926001 PD-CW-17-22 Wastewater Treatment System Upgrade

2017 II P&D 2 R $ 2,000,000

EIRUSS 2853001 PD-CW-17-20 Construction of Wastewater System to serve unincorporated

unsewered Petersburg Community

2017 I P&D 2 R $ 289,500

Emerson 6520001 PD-CW-17-14 Collection System Improvements

2017 IIIA, IVB P&D 2 R $ 270,000

Fayette 3342001 S2016-0375 1920812 01 Slip lining approximately 5,320 feet of sanitary

sewer main and completing spot repairs at 10 locations

throught the collection system.

2017 III-A 154 2 P $ 319,999

Fort Madison 5625001 S2013-0017 1920746 02 Replace aging equipment, repair structures,

implement nutrient removal, add biosolids

storage

2017 II 297 2 P $ 14,743,350

Lake View 8127001 PD-CW-17-23 Construction of ultraviolet disinfection system

2017 II P&D 2 R $ 140,000

Oxford 5260001 S2016-0049 1920804 01 Install UV disinifection system and other minor

improvements

2017 II 240 2 P $ 650,000

Shenandoah 3659001 S2016-0002 1920806 01 3 phase wasteater treatment facility

improvements - Phase 1: Solids Treatment & Disposal - Phase 2:

Collection System and Wastewater Plant Permit Compliance - Phase 3: Wastewater Treatment

Facility Nutient Reduction Strategy

2017 I & II 290 2 P $ 643,000

Sioux Center 8486002 PD-CW-17-19 Wastewater Treatment Improvements to meet

compliance

2017 II P&D 2 R $ 5,500,000

Sioux City 9778001 S2016-0389 1920813 01 Improve various treatment plant equipment to renew

initial capicity, improve performance, improve

reliability and improve life of treatment system.

2017 I & II 217 2 P $ 12,710,000

Slater 8580001 S2016-0293 1920803 01 Extend sanitary collection system that includes

construction of a duplex pump station

2017 IV-B 122 2 P $ 936,000

Wastewater Reclamation Authority

7727001 S2016-0238 1920805 01 Replace with stacked tray (HeadCell) grit removal

technology in the vicinity of existing grit aerated grit

chambers.

2017 I 180 2 P $ 9,500,000


7727001 PD-CW-17-15 Sewer Relining of concrete sewers over 20 years of

service to the ICA and now WRA

2017 IIIA P&D 2 R $ 220,000

Chart 1 in 11.2.xls 2 of 10 9/1/2016

Waterloo (CIPP Phase III) 0790001 S2016-0285 1920811 01 Excavating and repairing pipe using traditional methods. Rehabilitate sanitary sewers and

rehabilitate manholes that have deteriorated.

2017 III-A 185 2 P $ 2,498,000

Waterloo (Dry Run Creek Interceptor)

0790001 S2015-0280 1920807 01 New lift station, force main and gravity sewer are

proposed

2017 IV-B 150 2 P $ 4,337,000

Waterloo (Flow Equalization Facility Overflow Connection to Satellite WPCF)

0790001 S2015-0284 1920808 01 Install new gravity line from existing equalization basin

to the Satellite Aeration basins. Also include

discharge pipe from the Satellite basins to the Easton Aeration Basin

2017 I 170 2 P $ 978,000

Waterloo (Instrumentation & Controls Systems)

0790001 S2015-0365 1920809 01 Upgrade current Programmable Logic Controllers (PLCs).

Upgrade current Supervisory Control & Data

Acquisition (SCADA) system communication

protocol. Add fiber Optic for bringing new systems onto

the network

2017 II 180 2 P $ 1,089,000

Waukee 2573001 S2016-0413 1920810 01 Upgrade existing lift station and force main

2017 IV-B 119 2 P $ 11,671,000

Wilton 7078801 PD-CW-17-13 Upgrade existing WWTP to meet NPDES permit limits

2017 II P&D 2 R $ 385,000

Woodward 2576001 S2015-0344 1920814 01 Convert existing aerated lagoon to enhanced

treatment aerated lagoon with the addition of a

Lemna system. Addition of UV disinfection for new

e.coli limits

2017 II 242 2 P $ 2,763,750

Algona 5502001 S2016-0239 1920796 01 Rehabilitation project to address I/I related and

structural issues in existing sanitary sewer pipes and

manholes

2017 IIIA, IIIB, 195 1 P $ 2,396,000

Algona 5502001 PD-CW-17-01 Rehabilitation and reconstruction of the

sanitary sewer collection system

2017 IIIB P&D 1 R $ 130,000

Des Moines 77277001 (WRA) S2016-0194 1920795 01 Construction of some new storm sewer systems,

some new sanitary sewer and one pump station.

Construction of a regional detention basin to mitigate

increase of flooding

2017 IIIA, IIIB, IVA, V, VI

305 1 P $ 18,600,000

Elkhart 7730001 S2015-0187 1920798 01 Construction of an outfall sewer leading from the

existing wastewater treatment plant to the new

wastewater treatment facility

2017 I, II, IVB 305 1 P $ 3,865,000

Emerson 6520001 S2015-0430 1920790 01 Collection System Improvements

2017 IIIA, IVB 159 1 P $ 1,023,200

Chart 1 in 11.2.xls 3 of 10 9/1/2016

Grundy Center 3833001 S2014-0337 1920801 01 Add disinfection treatment for their final effluent

2017 II 220 1 P $ 963,000

Johnston 7727001 PD-CW-17-01 Installation of sanitary sewer in area currently on

septic systems, implementation of green

storm water infrastructure practices within the Green

Meadows West Subdivision

2017 IVA, IVB, VI P&D 1 R $ 288,000

Lenox 8748001 S2013-0187 1920799 01 Construction of a submerged attached

growth reactor (SAGR) system

2017 II 149 1 P $ 2,261,000

Norway 0656001 S2015-0209 1920794 01 Addition of a secondary treatment that is capable of

treating the ammonia-nitrogen. Disinfection

facilities will be installed to meet the e.coli effluent

limits

2017 I, II 222 1 P $ 3,065,000

Oelwein 3353001 S2016-0256 1920793 01 Installation of two new wastewater pumps to increase capacity of

existing 20th Street Lift Station. Improvementst6o

the electrical service, existing control panel and

addition of VFDs.

2017 IVB 122 1 P $ 248,000

Ogden 0858001 PD-CW-17-06 Plant upgraded to meet NPDES Permit

2017 II P&D 1 L 7/1/16 428,900$ 428,900$

Orange City 847001 S2015-0310 1920800 01 Construction of a sequencing batch reactor

treatment facility

2017 I, II 287 1 P $ 10,405,000

Slater 8580001 PD-CW-17-07 Wastewater treatment plant improvements

necessary in order to meet ammonia-nitrogen,

dissolved oxygen and E. coli discharge limits.

2017 II P&D 1 R $ 461,000


7727001 S2016-0243 1920797 01 Biogas Conditioning & injection Improvements

2017 II 175 1 P $ 12,814,000

Ames 8503001 S2016-0071 1920789 01 To improve screening at the WPCF city intends to replace existing channel

grinder with a mechanical bar screen

2016 I 170 4 P $ 981,000

Ames 8503001 S2013-0327 1920741 02 Address Infiltration and inflow into the City's

sanitary sewer system utilizing a variety of

rehabilitation techniques.

2016 IIIA 145 4 R $ 21,432,000

Bancroft 5507002 S2014-0136 1920777 01 Increase capacity of existing controlled

discharge lagoon. Piping improvements within

facility will also be done.

2016 I 139 4 P $ 848,000

Brandon 1011001 S2009-0160 1920779 01 Add a UV system (SAGR) to disinfect the effluent and meet the NPDES Permit requirements for E.Coli

2016 II 225 4 P $ 1,638,000

Chart 1 in 11.2.xls 4 of 10 9/1/2016

Denison 2424001 S2016-0117 1920778 01 Replacement & Rehabilitation of structures

and equipment approaching the end of

their service lives

2016 II 190 4 P $ 4,020,000

Des Moines 7727001 (WRA) S2016-0196 1920781 01 Remove storm sewer inlets within the drainage basin

that are connected to combined sewer and either eliminate or tie to dedicated

storm sewers. Existing sewers will become

dedicated sanitary sewers

2016 V 240 4 P $ 12,060,000

Dubuque 3126001 S2016-0206 CS1920792 01 Relocation and reconstruction of sanitary sewer along Kerper Blvd.

2016 IIIB 147 4 P $ 2,507,000

Fort Madison 5625001 S2016-0150 1920786 01 Construction of a new gravity sanitary sewer

interceptor along H avenue to capture sanitary sewer

flows from the north.

2016 IVB 152 4 P $ 3,250,170

Johnston 7727001 (WRA) S2016-0194 1920782 01 Installation of sanitary sewer in area currently on

septic systems, implementation of green

storm water infrastructure practices within the Green

Meadows West Subdivision

2016 IVA, IVB, VI 230 4 P $ 15,180,000

Lakeside 1145001 S2016-0200 1920787 01 Install a new lift station with two 500 gpm duplex

submersible pumps and a new 6" force main to connect to the City of

Storm lake's 24" DIP force main.

2016 IVB 119 4 P $ 945,000

Manning 1457001 S2016-0188 1920785 01 Replace existing sanitary sewer using materials and construction techniques for

reduction in I&I

2016 IIIA 142 4 P $ 600,000

Mt Pleasant 4453001 S2015-0081 1920780 01 Main plant upgrades and sewer system SSES

2016 II 275 4 P $ 3,518,000

Oelwein 3353001 PD-CW-16-40 Installation of new sanitary sewer

2016 IVA P&D 4 R $ 33,500

Reinbeck 3870001 S2015-0175 1920776 01 Construct an UV disinfection system to meet the efflluent limits dictated by The Iowa Departmentof

Natural Resources and NPDES Permiting.

2016 II 225 4 P $ 596,000

Stanwood 1681001 S2016-0154 1920783 01 Removal, replacement and abandonment of gravity

sanitary sewer and replace with a sanitary sewer that

will reduce I/I in the collection system

2016 IIIA 127 4 R $ 2,767,800

Templeton 1479001 PD-CW-16-41 Review city's existing 2-cell lagoon system and

wastewater collection system.

2016 I P&D 4 R $ 190,000

Chart 1 in 11.2.xls 5 of 10 9/1/2016

Tiffin 5288001 S2015-0202 1920788 01 Phase 1 - New Mechanical scree, standby generator for the lift station, 3 new

pumps with VFDs to increase pumping capacity

and convert duplex lift station to a triplex. Phase 2

- Separate project to include UV disinfection and

expansion of activated sludge system

2016 I, II 189 4 P $ 2,211,000

Union 4291001 S2016-0125 1920784 01 Rehabilitation of existing sanitary sewer system and

pumping facilities

2016 IIIA 154 4 P $ 990,000

West Union 3383303 S2015-0356 1920791 01 Construction of equalization basin and lift

station along with installation of ultraviolet

disinfection system.

2016 II 225 4 P $ 583,000

Cincinnati 0410001 S2014-0275 1920763 01 Utilize existing aerated lagoon for primary and

secondary treatment and construct an aerated

horizontal flow submerged attached growth reactor

(SAGR) system for ammonia removal. Constructin of small building to house the blowers, controls, and

electrical

2016 II 227 3 P $ 2,236,000

Clarence 1630001 S2016-0068 1920774 01 Sewer Rehabilitation Project consisting of

manhole replacement, grouting, and epoxy lining and a new CIPP lining is

proposed.

2016 IIIA 125 3 R $ 1,060,000

Coralville 5208001 S2014-0388 1920767 01 Improvements to the treatment system include expansion of equalizatin basin; new headworks;

new aeration basins; final clarifiers, and replacement of UV disinfection system.

2016 I, II 250 3 P $ 27,648,000

Davis City 2715001 S2016-0072 1920769 01 Rehabilitation of existing sanitary sewer mains and sanitary sewer manholes.

Drainage & erosion improvements at the wastewater facility.

2016 IIIA 100 3 P $ 457,000

Dike 3815001 S2013-0004 1920764 01 Lift Station & Collection System Improvements

2016 I, II, IIIB 290 3 P $ 4,850,000

Fort Atkinson 9641001 S2015-0087 1920770 01 Construct a larger Lagoon that will only discharge

once a year. Also includes an ultra violet disinfection

system.

2016 I, II 290 3 P $ 1,249,000

Greene 1253001 S2015-0235 1920775 01 Construct a new Submerged Attached

Growth Reactor (SAGR) system for existing aerated

lagoon and a new UV disinfection system.

2016 II 249 3 P $ 3,670,260

Chart 1 in 11.2.xls 6 of 10 9/1/2016

Hills 0047902 S2015-0027 1920765 01 Addition of a 3rd lagoon, ultraviolet disinfectoin and

a new outfall to existing treatment facilities.

2016 I, II 290 3 P $ 3,015,000

Mapleton 6727001 S2015-0440 PD-CW-16-30 Wastewater Treatment Improvements to comply with ammonia nitrogen limits, maintainn TSS limits, and meet new NPDES standards

2016 I P&D 3 R $ 225,000

Marathon 1150001 S2015-0402 1920771 01 Construct a 3 cell controlled discharge

lagoon to meet the NPDES Permit Limits

2016 I 162 3 P $ 1,171,000

New Albin 0370001 S2013-0348 1920768 01 Replacement of secondary treatment facility including

new influent pumps, preliminary screening

equipment, activated slude treatment system.

2016 I 185 3 P $ 2,185,000

Osage 6663001 S2015-0429 DROPPED Sanitary Sewer Improvements Phase 1

2016 IIIA 145 3 D

St Donatus 4979001 S2011-0308 1920773 01 Relining existing two cell lagoon and construction of

lift station

2016 I, IVB 185 3 P $ 398,000

West Burlington 2985001 S2014-0456 1920766 01 Improvements include additional activated sludge

treatment tankage and conversion of existing

aerated lagoon cells in to flow equalization basins.

New headworks facility and upgrades to existing aged equipment and standby

power.

2016 I 214 3 P $ 10,000,000

De Soto 2529001 S2014-0066 1920759 01 Wastewater Treatment Facility Improvements

2016 II 232 2 P $ 2,887,000

Grinnell 7930001 S2014-0189 1920762 01 Wastewater treatment facility improvements

2016 ll 222 2 P $ 10,403,000

Harris 7222001 S2015-0358 1920757 01 Sanitary Sewer Rehabilitation

2016 lllA 145 2 P $ 921,685

Hartford 9128001 S2015-0314 1920755 01 Lift Station and Wastewater System

Improvements

2016 lllA 165 2 R $ 281,000

Keota 5440001 S2015-0069 1920761 01 Construction of Submerged Attached Growth Reactors

and UV system

2016 ll 142 2 P $ 2,988,770

Postville 0375001 S2015-0412 1920756 01 Sanitary Sewer Rehabilitation Phase II

2016 lll-A 155 2 P $ 1,015,000

Rock Valley 8482001 S2015-0184 1920754 01 Wastewater treatment plant improvements

2016 l 175 2 R $ 1,513,000

RUSS(Moar/Powdertown) Unsewered PD-CW-16-11 2016 I,IVA P&D 2 R $ 100,000 Sanborn 7165001 S2012-0256 1920752 01 Improvements to

Wastewater treatment facility as a result of a new

NPDES permit and increase loading from and

industrial facility

2016 ll 167 2 P $ 1,946,685

Strawberry Point 2279001 S2015-0213 1920753 01 WWTP Disinfection and Ammonia Removal

2016 ll 250 2 P $ 426,000

Wellman 9276001 S2015-0226 1920760 01 Wastewater Disinfection Improvements

2016 II 260 2 R $ 836,000

Grimes 7736001 S2012-0348 1920751 01 Water & Wastewater Improvements

2016 I, IIIA 185 1 R $ 4,221,000

Chart 1 in 11.2.xls 7 of 10 9/1/2016

Lake View 8127001 S2015-0174 1920748 01 Construction of ultraviolet disinfection system

2016 II 224 1 P $ 482,400

Sabula 4975001 S2015-0208 1920749 01 Collection System Improvements

2016 IIIA 157 1 P $ 389,940


7727001 S2015-0261 1920750 01 (Phase 27, Segment 1-8

Eastside Interceptor 2016 IVB 135 1 P $ 68,340,000

Wastewater Reclamation Authority (supplemental)

7727001 S2015-0186 1920657 02 WRA Southern Tier Interceptor Phase 10

Segment 22

2016 IVB 115 1 P $ 665,310

Ames 8503001 S2013-0327 1920741 01 Sanitary Sewer Rehabilitation

2015 IIIA 160 4 R $ 2,588,970

Belle Plaine 0610001 S2012-0141 1920744 01 Wastewater Disposal System Improvements

2015 II,IIIA 259 4 P $ 2,448,180

Brooklyn 7909001 S2014-0047 1920735 01 Treatment Plant Upgade 2015 II 240 4 R $ 4,120,500 Duncombe 9427001 S2015-0164 1920740 01 Lift Station 2015 IIIB 165 4 R $ 404,990 Granville 8429001 S2015-0163 1920738 01 2015 Sanitary Sewer

project2015 IIIA 152 4 P $ 696,968

Keokuk 5640001 S2015-0088 1920732 01 Sewer Rehabilitation - Phase 1

2015 IIIA 237 4 P $ 1,484,700

Keystone 064001 S2014-0164 1920743 01 WWTF Upgrade 2015 II 247 4 P $ 3,239,919 Northwood 0032395 S2014-0292 1920733 01 Wastewater Treatment

Imrprovements2015 II 260 4 R $ 8,970,630

Pleasantville 6377001 S2013-0174 1920737 01 WWTP Improvements 2015 II 229 4 P $ 4,120,500 Readlyn 0965001 S2009-0030 1920736 01 WWTF Improvements 2015 II 207 4 P $ 3,326,500 Spencer S2016-0203 1920745 02 Fourth Avenue West CSO

separation2015 V 4 P $ 4,025,000

Spencer 2171004 S2014-0044 1920745 01 Treatment Plant Upgrade 2015 II 300 4 R $ 3,115,500 Atkins 0603001 S2013-0314 1920727 01 WWTP Improvements 2015 II 247 3 R $ 6,503,000 7/8/16 8,253,000$ 1,750,000$ Fort Dodge 9433003 S2015-0080 1920728 02 Sanitary Sewer

Rehabilitation2015 IIIA, IIIB 195 3 R $ 10,900,000

Hospers 8439001 PD-CW-15-17 Wastewater treatment plant expansion

2015 II P&D 3 R $ 277,000

Postville 0375001 S2004-0442 1920726 01 Wastewater treatment facility improvements

2015 II 255 3 P $ 4,871,637

Blencoe 6709001 S2014-0409 1920720 01 Main Lift Station Improvements

2015 IIIB 142 2 P $ 179,694

Deloit 2421001 S2013-0234 1920716 01 Lagoon Rehabilitation 2015 IIIB 147 2 R $ 496,634 New Hampton 1970001 S2014-0034 1920721 01 Wastewater treatment

plant improvements2015 II 224 2 R $ 2,095,750

Ruthven 7465001 S2014-0412 1920719 01 Wastewater System Improvements

2015 IIIA 129 2 R $ 1,549,710

Ames 8503001 S2014-0223 1920713 01 Lift Station Improvements 2015 IIIB 160 1 R $ 1,155,440 Fairfield 5131001 S2014-0008 DROPPED Inflow & Infilitration

reduction by replacing existing sewers

2015 IIIA 167 1 D

Fairfield 5131001 S2013-0368 1920705 01 Construction of a new influent and stormwater

pumping building, headworks bldg, third

oxidation ditch, UV disinfection system and

aerobic digester.

2015 II 252 1 P $ 14,856,848

Fairfield 5131001 S2013-0368 1920706 01 Construction of a forcemain

2015 IVB 157 1 P $ 3,817,548

Roland 8570001 S2014-0203 1920710 02 Cottonwood Street Sanitary Sewer

2015 IIIA 160 1 R $ 1,080,000


7727001 S2009-0219 1920457 05 (Phase 17, multiple phases)

New Main Outfall, supplemental loan to

finalize costs

2015 IVB 160 1 R $ 3,000,000


7727001 S2009-0219 1920499 02 (Phase 17, Segment 7)

New Main Outfall, Phase 17 Segment 7 final costs

2015 IVB 160 1 R $ 10,400,000

Chart 1 in 11.2.xls 8 of 10 9/1/2016

Chariton PD-CW-14-36 Increase capacity of 12th St Lift Station and replace NW Lift Station with new

structures and equipment.

2014 IVB P&D 4 R $ 137,900

Chariton 5903001 2014-0106 1920697 01 Increase capacity of 12th St Lift Station and replace NW Lift Station with new

structures and equipment.

2014 IVB 135 4 R $ 350,000

Ames 8503001 S2013-0326 1920686 01 WPCF Biosolids Storage Tank

2014 II 180 3 R $ 1,885,400

Coralville 5208001 PD-CW-14-31 Replace manholes, reconstruct sewer lines at Oakdale trunk sewer and

replace lift station and form main for Muddy Creek

2014 IIIB P&D 3 R $ 270,263

Dyersville 3130001 S2013-0342 1920690 01 SE Lift Station & Collection System Improvements

2014 IVB 127 3 P $ 1,476,620

Garnavillo 2234001 S2012-0200 1920684 01 Improvements to collection system

2014 II 199 3 R $ 4,469,250

Miles 4953001 S2013-0064 1920688 01 Construction of controlled discharge lagoon

2014 I 227 3 P $ 897,890

Dyersville DROPPED New Lift Station 2014 IIIB P&D 2 DDyersville DROPPED WWTF Expansion Project 2014 II P&D 2 D

Martensdale 9147001 S2013-0292 1920682 01 Sewer rehabilitation 2014 IIIB 150 2 P $ 833,800 Granger 2537001 S2012-0169 1920667 03 Wastewater Treatment

Plant Improvements2013 4 L 7/8/16 750,000$ 750,000$

Wellman 92760001 PD-CW-13-32 Disinfection 2013 I P&D 4 R $ 81,283 Marengo 4843001 S2013-0052 1920661 01 Infiltration/inflow correction

to address permit violations at treatment

facility

2013 IIIA 162 3 R $ 883,000

Mount Union 4455001 S2013-0118 1920664 01 Purchase of existing wastewater system currently owned and

operated by Rural Utility Service Systems (RUSS)

2013 II 127 3 D

Mt Pleasant 4453001 S2012-0407 1920665 01 Replacement of remaining portions of Snipe Run

Interceptor to transfer flows to new wastewater treatment facility

2013 IIIB 125 3 P $ 1,600,000

Patterson 6151001 S2011-0078 1920659 01 Upgrade pump station capacity, reduce

inflow/infiltration, install new force main with goal of

reducing sewer backups

2013 IIIB 165 3 R $ 54,540

Dakota City 4622001 PD-CW-13-15 Infiltration/inflow correction through sewer relining

2013 IIIA P&D 2 R $ 85,000

Sioux City 9778001 S2010-0080 1920647 02 The Iowa Department of Transportation is

constructing improvements to Interstate 29, which requires Sioux City to

relocated existing sanitary sewer interceptor and

storm sewers.

2013 IVB 130 1 R $ 34,500,000

Chart 1 in 11.2.xls 9 of 10 9/1/2016

Calamus 2320001 S2012-0126 1920628 01 WWTP Upgrades 2011-add 3rd lagoon cell

2012 I 149 4 R $ 1,360,000

Clinton (Phase II, Part 2) 2326001 S2005-0016 1920629 01 US 30/67 and Camanche Avenue (Reconstruction &

Sewer Separation)

2012 V 144 4 R $ 3,535,000

Elkhart 7730001 S2012-0137 1920634 01 Inflow and infiltration correction

2012 IIIA 129 4 P $ 609,030

Hamburg 3621001 PD-CW-12-29 2012 II P&D 4 R $ 100,000 La Porte City 0743001 S2012-0049 1920625 01 Commercial Street

Sanitary Sewer Repolacement Project

2012 IIIB 150 3 P $ 556,409

La Porte City 0743001 S2009-0187 1920620 01 Wastewater treatment plant improvements

2012 I,II 220 2 P $ 917,822

Nemaha Unsewered PD-CW-12-04 2012 I,IIIB P&D 2 R $ 75,000 North English 4858001 PD-CW-11-36 2012 II,IIIA,IIIB P&D 1 R $ 140,000 Albert City 1103001 S2014-0237 1920608 02 Phase II new lagoon,

disinfection2011 II 184 4 P $ 2,387,264 30%

Dubuque (Revised Upper Bee Branch)

N/A N/A GNS10-5 (2) Stream daylighting 2011 VII-K 162 4 R $ 7,716,000


7727001 S2010-0310 1920593 03 (Phase 19 Seg 1-4)

Interceptor sewer to convey wastewater from

Bondurant to the Wastewater Reclamation

Facility

2011 IVB 150 2 R $ 16,545,820

Bennett 1603001 S2010-0120 1920529 01 Sewer rehabilitation, pump station upgrades

2011 IIIA 137 1 R $ 1,971,000

Brighton 9209001 S2009-0288 1920515 01 Sewer rehabilitation, wastewater treatment plant

upgrade

2011 II,IIIB 140 1 R $ 2,675,000

Lamont 1061001 S2010-0116 1920576 01 Lagoon upgrade, pump station upgrade

2011 I 140 1 R $ 1,169,665

Libertyville 5148001 PD-CW-10-51 2011 I,IIIA,IIIB, VI P&D 1 R $ 95,000 Reasnor 5071001 S2009-0207 1920543 01 Lagoon expansion 2011 I 160 1 R $ 737,805 Spencer 2171004 S2010-0111 1920528 01 Combined sewer

separation2011 V 185 1 R $ 2,300,000

Coralville N/A N/A GNS10-4 Green infrastructure practices at the Iowa River

Landing

2010 VIIK 120 4 P $ 2,950,000 30%

Mingo 5052001 S2008-0304 1920510 01 Lagoon expansion 2010 I 172 3 R $ 1,515,000 Wheatland 2394001 PD-CW-10-10 2010 IIIA, IIIB,V P&D 3 R $ 67,000

$ 555,919,966 9,431,900$ 2,928,900$

Project Status Needs CategoriesI Secondary Treatment

Dropped -- DII Treatment more

stringent than secondary

Ready for Loan-- R IIIA Infiltration/Inflow rehabilitation

Loan Signed -- L IIIB Major sewer system rehabilitation

Planning Stage -- P IVA New collectors and appurtenances

IVB New interceptors and appurtenances

Green Projects V Correction of combined sewers

(*indicates that a business VI Stormwater

management programs

Chart 1 in 11.2.xls 10 of 10 9/1/2016

case is required)VII Non-point source control

projects; subcategories below:

Add Subs VIIA Agricultural cropland sources

VIIB Animal sourcesVIIC SilvicultureVIID Urban sourcesVIIE Groundwater protection

(unknown sources)

VIIF MarinasVIIG Resource extractionVIIH BrownfieldsVIII I Storage tanksVIIJ LandfillsVIIK HydromodificationXII Decentralized septic

systems

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16ESDWQBJGRIF-0001

Environmental Protection Commission Iowa Department of Natural Resources

ITEM 12 DECISION

TOPIC Contract with I & S Group, Inc. for Revising the Iowa Storm Water Management Manual

Recommendations: Commission approval is requested for a 2.5 year contract with I & S Group, Inc. The estimated contract start date is October 17, 2016 and the estimated contract end date is April 17, 2019. The total amount of this contract shall not exceed $31,500. Funding Source: This contract will be funded from storm water permit fees. Background: The Iowa Storm Water Management Manual (ISWMM) was originally written under contract with Iowa State University’s Center for Transportation Research and Education in 2004-2006. It has since been updated once and this contract is to update it again. Purpose: The parties propose to enter into this Contract for the purpose of retaining the Contractor to write two new chapters and revise three existing chapters of the ISWMM. Contractor Selection Process: I & S Group, Inc. was chosen through a competitive bidding process. Contract History: The original, FY04 contract to write 17 chapters of the ISWMM was for an amount not to exceed $125,342.00, of which $105,609.53 was paid. This contract had no amendments. The FY13 contract to write two new chapters and amend two existing chapters was for an amount not to exceed $9,998.00, of which $7,498.50 was paid. There were two amendments to this contract including an amendment to terminate. Joe Griffin Water Quality Bureau, Environmental Services Division September 20, 2016 Attachment: Scope of Work from the Special Conditions for Contract

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16ESDWQBJGRIF-0001

I & S Group, Inc. shall do the following as directed by the DNR: (1) Arrange times and locations for meetings, which shall occur approximately twice each month; (2) Attend all Committee meetings in person or via suitable audio and video communications provided by the vendor; (3) Notify Committee members by e-mail of work assignments; (4) Take notes at Committee meetings of decisions made by the Committee and DNR; (5) Submit the edited portions of the manual in Microsoft Word to DNR for approval and make necessary additional changes to those portions of the manual as directed by DNR that are within the subject areas described in the Statement of Work plan described in section 4.2 of this RFP; and (6) Locate and reimburse qualified subcontractors to perform tasks if the Contractor or the Committee members are unqualified or otherwise unable to provide necessary products or services.

In addition to the above requirements, which shall continue throughout the term of the Contract, the successful vendor shall complete the following Tasks by the Task Milestone Dates set out in the table below:

Obligation Task Milestone Date Task 1: Permeable Pavement Systems Description: Revise existing and create new design guidelines and specifications for permeable pavement systems that include pervious concrete pavement, porous asphalt pavement and permeable pavers, as approved by the ISWMM Technical Committee and the DNR. The Contractor shall: a. Conduct a literature search on the performance of permeable pavement systems; b. Following the literature search, either review and adopt from the literature or develop

design standards for each practice, as necessary; c. Create illustrations and figures for each practice, as necessary; d. Draft design guidelines and specifications for each practice; e. Communicate with and obtain approval from the ISWMM Technical Committee

regarding each practice proposed for inclusion in the pretreatment section of the ISWMM; and

f. Provide to DNR, for approval, final drafts of the design guidelines and specifications changes proposed for inclusion in the ISWMM, and make changes as requested by DNR.

No later than six months after contract beginning date.

Task 2: Pretreatment Practices Description: Revise existing and create new design guidelines and specifications for pretreatment practices that include grass swales, vegetative filter strips, sediment forebays, hydrodynamic devices, gravity separators and catch basin sumps and separators as approved by the ISWMM Technical Committee and the DNR. The Contractor shall: a. Conduct a literature search on the performance of pretreatment practices; b. Following the literature search, either review and adopt from the literature or develop

design calculations for each practice, as necessary; c. Create illustrations and figures for this section, as necessary; d. Draft design guidelines and specifications for each practice; e. Communicate with and obtain approval from the ISWMM Technical Committee on each

practice proposed for inclusion in the pretreatment section of the ISWMM; and f. Provide to DNR, for approval, final drafts of the design guidelines and specifications

changes proposed for inclusion in the ISWMM, and make changes as requested by DNR

No later than twelve months after contract beginning date.

Task 3: Native Landscaping Practices

No later than eighteen

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16ESDWQBJGRIF-0001

Description: Revise existing guidelines and specifications as necessary for native landscaping practices as approved by the ISWMM Technical Committee and the DNR. The Contractor shall: a. Conduct a literature search on the performance of native landscaping practices; b. Create illustrations figures for this section, as necessary; c. Revise design guidelines and specifications; d. Communicate with and obtain approval from the ISWMM Technical Committee

regarding material proposed for inclusion in the ISWMM; and e. Provide to DNR, for approval, final drafts of the design guidelines and specifications

proposed for inclusion in the ISWMM, and make changes as requested by DNR.

months after contract beginning date.

Task 4: Underground Chamber Systems Description: Evaluate underground chamber systems and create new guidelines and specifications as necessary for underground chamber systems as approved by the ISWMM Technical Committee and the DNR. The Contractor shall: a. Conduct a literature search on the performance of underground chamber systems for

managing the water quality volume and other factors in the Unified Sizing Criteria; b. Following the literature search, either review and adopt from the literature or develop

design calculations for this section, as necessary; c. Create illustrations and figures for this section, as necessary; d. Draft design guidelines and specifications; e. Communicate with and obtain approval from the ISWMM Technical Committee

regarding material proposed for inclusion in the ISWMM; and f. Provide to DNR, for approval a final draft of the design guidelines and specifications


No later than twenty four months after contract beginning date.

Task 5: Tree Filter Systems Description: Evaluate tree filter systems and create new guidelines and specifications as necessary for tree filter systems as approved by the ISWMM Technical Committee and the DNR. The Contractor shall: a. Conduct a literature search on the performance of tree filter systems for reducing

pollutants; b. Following the literature search, either review and adopt from the literature or develop

design calculations for this section, as necessary; c. Create illustrations and figures for this section, as necessary; d. Draft design guidelines and specifications; e. Communicate with and obtain approval from the ISWMM Technical Committee

regarding material proposed for inclusion in the ISWMM; and f. Provide to DNR, for approval a final draft of the design guidelines and specifications


No later than thirty months after contract beginning date.

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ITEM 13 DECISION

TOPIC Contract with the United States Geological Survey for Stream gaging and real-time water quality support

Recommendations: Commission approval is requested for a one year-service contract with the United States Geological Survey (USGS) in Iowa. The contract will begin on October 1, 2016 and terminate on September 30, 2017. The total amount of this contract shall not exceed $ 310,520.00. Funding Source: This contract will be funded through Environment First funds through cost center HB8A under the authority of Iowa Administrative Code (IAC) 455B.103. Background: Water quantity and quality information is of key importance to understanding ecosystem health, flood potential and the level of risk to humans within and beyond the watershed. Surface-water flow information in Iowa is collected on a nearly continuous basis at 128 stream gaging stations (23 supported in this agreement), and real-time water-quality sensors (8 sites supported in this agreement) across Iowa. Lastly, the ability to estimate surface-water flow at ungaged sites in Iowa is critical for estimating pollutant loading and flux, Use Attainability Assessments and is needed by State Nutrient Reduction Strategy. The completed applications StremStat and StreamEst will be maintained and will be made available to the public and used by the Department and others to support management and planning decisions. Purpose: The parties propose to enter into this Contract for the purpose of retaining the Contractor to provide: gage data on streams, real-time nitrate sensor operation and maintenance for the state. Contractor Selection Process: The United States Geological Survey in Iowa was chosen for this project because of their expertise in water resource measurement and analyses. Contract History: Since 1973 the USGS has been cooperating with the State to monitor stream flows. Since 2000 the USGS has cooperated with the Department to collection quality information and to update stream flow statistics. Roger Bruner, Supervisor Water Quality Bureau, Environmental Services Division August 18, 2015 Project Funding DNR Funding USGS Total Stream Gaging Network $205,920 $69,610* $275,530** Water Quality Monitoring $98,600 $65,730 $164,330 Streamest maintenance $6,000 $4,000 $10,000 $310,540 **The USGS will contribute and Additional $47,840 through their national support program. The additional support reflects a total combined program support of $323,370.00

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17S-ESD-WQB-HB8A-ChRUB-0001


ITEM 14 DECISION

TOPIC Contract with the State Hygienic Laboratory at the University of Iowa for Ambient Groundwater Analytical support

Recommendations: Commission approval is requested for a one year-service contract with the State Hygienic Laboratory at the University of Iowa. The contract will begin on October 1, 2016 and terminate on June 30, 2017. The total amount of this contract shall not exceed $ 88,333.20. Funding Source: This contract will be funded through Environment First funds through cost center HB8A under the authority of Iowa Administrative Code (IAC) 455B.103. Background: The groundwater monitoring program was re-designed in 2012 and will continue as a part of the ambient monitoring tasks for the Department. The data collected in this contract will provide the data necessary to evaluate baseline conditions and long-term trends in groundwater quality. The data will be made available to the public and used by the Department to support management and planning decisions. Purpose: The parties propose to enter into this Contract for the purpose of retaining the Contractor to provide: sampling and analytical assistance to DNR. Contractor Selection Process: DNR is allowed to contract with the University of Iowa pursuant to Iowa Code section 455B.103. The University of Iowa was chosen for this project because of their expertise in water quality sampling and analyses. Contract History: Since 2012 a contract with the State Hygienic laboratory has been executed to analyze groundwater samples submitted by selected municipal water operators. The Department has coordinated the sample collection with Municipal water operators who volunteer their time to collect the samples and ship the samples to SHL. Prior to 2006 the Department contracted with the USGS to provide both sample collection and analyses. Roger Bruner, Supervisor Water Quality Bureau, Environmental Services Division September 19, 2017 Attachment(s): Scope of Work from the Special Conditions for Contract

DNR Updated 5/2013


Obligation Task Milestone Date Task 1A: Water sampling by SHL Description: SHL shall collect samples from sixty (60) public water supply wells that are shown in Figure 1 (in blue) and listed in Table 1 between October 1 and January 31, 2017 for analysis of parameters in Table 3. SHL also shall collect duplicate samples at six (6) sites and two (2) field blanks. SHL shall provide sampling equipment and supplies for sampling of water quality parameters listed in Table 3. SHL shall provide 46 coolers and sample bottles sets to DNR for analysis of the parameters in Table 3 with the exception of the field parameters (pH, DO, and turbidity). DNR will collect 41 samples (plus 5 QA/QC samples) at sites listed in Table 3 and will package these samples on ice and ship them overnight to SHL (or drop them at the Ankeny Lab) on the day of sample collection at DNR’s expense. Virus samples: Concurrent with sampling, above, ~1000 liter samples shall also be collected using ultrafilters (provided by DNR) following procedures provided by Dr. Mark Borchardt, USDA-ARS. SHL will be responsible for adapting the virus sampling devices to use with an ultrafilter, and will maintain sterilization of this device and associated tubing and attachments. A weekly report of the sites sampled shall be provided to DNR, and shall include any deviation from normal sampling procedures, including but not limited to, a change in sampling location or an omission of samples for analysis. All samples must be collected Monday-Thursday in order to ensure sufficient time for laboratory processing.

No later than February 28, 2017

Task 1B: Shipping to WI Description: SHL will ship ultrafilters and chain-of-custody forms collected as part of Task 1A via overnight mail to Dr. Mark Borchardt (ARS, 2615 Yellowstone Drive, Marshfield, WI 54449) on the day of sampling.

No later than February 28, 2017

Task 2: Analysis of water quality parameters Description: SHL shall analyze samples collected as part of Task 1A and samples collected by IDNR staff for all parameters listed in Table 3 within holding times specified in Exhibit A unless authorized in writing by the Department. SHL shall analyze samples collected by DNR for all parameters listed in Table 3 (with the exception of field parameters) within holding times specified in Exhibit A unless authorized in writing by the Department. Samples analyzed as part of this activity shall be coded as GWMAMBIENT. All samples received from DNR shall be coded to a specific monitoring activity and shall include a detailed list of the analyses to be performed unless other arrangements have been made before delivery of the sample to SHL. SHL log-in procedures shall accommodate this code.

No later than May 30, 2017

Task 3: Data Transfer Description: SHL shall make the data generated pursuant to this Contract available to DNR electronically through the State Hygienic Laboratory OpenELIS database web portal. Data shall be available for download by DNR staff in a mutually agreeable format. The available sample information shall include the STORET station identification number, which will be provided by DNR for all station locations. Data shall be retrievable via the web portal by DNR staff.

Analytical chemistry data shall be made available to DNR staff no later than 15 calendar days following the end of the month of collection. If the contractor determines that extra time is needed to complete required analyses, then a written notification shall be made to the DNR submitter or contract manager. The

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Analytical reports may be retrieved electronically by DNR staff having the appropriate authorization. SHL shall assist DNR staff in obtaining appropriate authorization when requested. When accessing electronic data, the following information is required:

• SHL OpenELIS/Telcor Organization ID number 3916 • SHL Project Code GWMAMBIENT

notification shall include the reason for the delay and the specific analytical chemistry data requiring delayed reporting. The notification shall occur as soon as possible after the contractor has determined the need for a reporting delay.

Table 1: SHL sampling sites WELL NAME STORET ID

1 Alburnett 3 31570012 2 Algona 8 31550004 3 Andover 1 31230007 4 Atkins 3 31060009 5 Badger 3 31940010 6 Belle Plaine 4 31860001 7 Blue Grass (2), 1 31820001 8 Bristow 2 31100008 9 Calamus 2 31230008

10 Camanche 2 31230002 11 Cascade 4 31530003 12 Cedar Falls 8 31070007 13 Cedar Falls 9 31070008 14 Cedar Rapids S6 31570001 15 Charles City 8 31340005 16 Clayton 1 31220006 17 Conrad 3 31380001 18 Coralville 10 31520005 19 De Witt 7 31230009 20 Decorah 6 31960001 21 Decorah 7 31960007 22 Dubuque 9 31310002 23 Dumont 2 31100009 24 Duncombe 4 31940011 25 Eddyville 3 31900001 26 Elgin 2 31330001 27 Fairfield 94-1 (6) 31510001 28 Fremont 2-88 31620003 29 Independence 3 31100006 30 Independence 7 31100007 31 Ionia 2 31190003 32 Jesup 2 31100001 33 Joice 1 31980004 34 Jolley 1 31130005 35 Knierim 1 31130006 36 Lansing 4 (2) 31030002 37 Manchester 7 31280001 38 Marshalltown 5 31640007 39 Mount Vernon 9 31570013 40 New Vienna 4 31310007 41 Newton 13 31500002 42 Nora Springs 4 31340006 43 Orchard View Estates 1 31520006 44 Oskaloosa 26 31620003 45 Riverview Estates 1 31520007 46 Rockford 2 31340007 47 Saint Ansgar 2 31660001 48 Sheffield 5 31350004

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49 Shellsburg 2 31060001 50 Sigourney 02-5 31540004 51 Stacyville 3 31660005 52 Steamboat Rock 1 31420009 53 Tama 5 31860002 54 Toledo 2 31860009 55 Ventura 1 31170002 56 Waterloo 17 31070001 57 Waukon 2 31030003 58 Waverly 6 31090002 59 West Branch 4 31160001 60 Winthrop 3 31100005 61 QA/QC 1 62 QA/QC 2 63 QA/QC 3 64 QA/QC 4 65 QA/QC 5 66 QA/QC 6 67 QA/QC 7 (Blank) 68 QA/QC 8 (Blank)

Table 2: DNR sample sites WELL NAME STORET ID

1 Adel 3 31250002 2 Altoona 3 31770003 3 Anita 4 31150005 4 Audubon 13 31050005 5 Avoca Regional Water 19 31830004 6 Battle Creek 1 31470004 7 Boone 20 31080001 8 Brayton 1 31050001 9 Carlisle 5 31770001

10 Carson (5), 3 31780001 11 Carson 7 31780010 12 Cherokee 10 31180002 13 Coon Rapids 1, N 31140001 14 Correctionville 1 W 31970001 15 Farragut 79-2 N 31360001 16 Fontanelle 5 31010001 17 Gilbert 3 31850007 18 Hawarden 4 31840003 19 Holstein 3 31470002 20 Ida Grove 7 31470003 21 Kingsley 1 31750001 22 LS-Doon RWS 3 31600004 23 Mapleton 5 31670001 24 Massena 6 31150006 25 Mondamin 2, S 31430001 26 Moville 5 31970011 27 Nevada 8 31850009 28 Perry 22 31250013 29 Perry 9R 31250001 30 Primghar 8 31710007 31 Quimby 3 31180010 32 Shambaugh 3 31730001 33 Sheldon 6 31710001 34 Sioux Center 13 31840007 35 Sioux Rapids 2 31110001

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36 Storm Lake 18 31110007 37 Vail (1), 2 31240001 38 Van Meter 3 31250003 39 Wall Lake 3 31810001 40 Walnut 2 31780005 41 Woodward State Hosp. 2 31250014 42 QA/QC 9 43 QA/QC 10 44 QA/QC 11 45 QA/QC 12 46 QA/QC 13 (Blank)

Table 3: Water Quality Parameters

SHL Analytes Cost Units Total Field DO $7.00 68 $476.00 Field pH $7.00 68 $476.00 Field Turbidity $7.00 68 $476.00 Nitrate + Nitrite as N $14.50 114 $1,653.00 Ammonia as N $14.50 114 $1,653.00 Total Coliform by MPN $15.00 114 $1,710.00 Total Suspended Solids $14.50 114 $1,653.00 Chloride $14.50 114 $1,653.00

TOTAL $9,750.00

DNR Updated 5/2013



ITEM 15 DECISION

TOPIC Contract amendment with the USDA Animal Research Service/USGS Laboratory at Marshfield Wisconsin for Ambient Groundwater Analytical support

Recommendations: Commission approval is requested for an amendment to 12 month-service contract (16-ESD-WQB-JPALM-0002) with the ARS/USGS Laboratory at Marshfield Wisconsin. The amendment will begin on October 1, 2016 and terminate on March 31, 2017. The total amount of this amendment shall not exceed $ 49,500.00. The total amount of the original contract and amendment would not exceed $ 82,000.00. Funding Source: This amendment will be funded through Environment First funds through cost center HB8A under the authority of Iowa Administrative Code (IAC) 455B.103 and a USEPA Section 106 grant. Background: The groundwater monitoring program was re-designed in 2012 and will continue as a part of the ambient monitoring tasks for the Department. The data collected in this contract will provide the data necessary to evaluate baseline conditions and long-term trends in groundwater quality. The data will be made available to the public and used by the Department to support management and planning decisions. A contract currently exists with this agency and this amendment will increase the value of that contract above $25,000. Purpose: The parties propose to enter into this amendment for the purpose of retaining the Contractor to provide: specialized analytical assistance to DNR. Contractor Selection Process: DNR is allowed to contract with the governmental agencies like the ARS/USGS laboratory pursuant to Iowa Code section 455B.103. The ARS/USGS laboratory was chosen for this project because of their expertise in specialized water quality analyses. Contract History: This is the first contract for this specialized analysis for the Ambient Groundwater Program. Roger Bruner, Supervisor Water Quality Bureau, Environmental Services Division September 19, 2017 Table 1: Water Quality Parameters

Microorganism/Virus targeted in sample by ARS Cost Units Total Adenovirus group A, B, C, D, & F $450.00 110 $49,500.00 Enterovirus Norovirus Groups I & 11 Polyomavirus, Bovine and Human Swine Hepatitis E Pepper mild mottle virus influenza virus Enterohemorrhagic E. coli Campylobacter Salmonella

TOTAL $49,500.00

1


ITEM 16 Decision

TOPIC Notice of Intended Action – Chapter 61 – Water Quality Standards (Copper Criteria Update)

The proposed rule is necessary to create additional flexibility for wastewater dischargers by adding the option to use the Biotic Ligand Model (BLM) or Water-Effect Ratio (WER) in the determination of site-specific copper criteria. Copper is found in most municipal wastewater effluents due to the corrosion of copper plumbing and it is expensive to remove. The BLM accounts for site-specific variations in the toxicity of copper due to actual levels of copper bioavailability in a given waterbody. The adoption of a Copper BLM criterion will reflect site-specific Iowa surface water conditions. The BLM accounts for several water chemistry parameters to predict the concentration of copper that would actually result in toxicity to an organism in a given waterbody. The following water chemistry parameters have an impact on copper toxicity due to elevated levels of copper: Temperature, pH, Dissolved Organic Carbon, Calcium, Magnesium, Sodium, Potassium, Sulfate, Chloride and Alkalinity. An Implementation Procedure for Biotic Ligand Model-Based Copper Criteria was developed for site-specific data collection and it is incorporated by rule-reference. The WER method allows permittees to take into account the difference between the toxicity of a metal measured in laboratory water versus the toxicity of the metal measured in ambient water of the discharge site. The WER method allows facilities to calculate a ratio between the two measured toxicity levels and use it to adjust the existing copper criteria shown in IAC 61.3(3), Table 1. The proposed changes are protective of the water quality and allow permittees the flexibility to use the existing copper criteria and the WER or the ability to use the BLM to generate copper criteria that reflect site-specific water characteristics of the receiving waterbodies for point source discharges. Jon Tack, Chief Water Quality Bureau Environmental Services Division

2

ENVIRONMENTAL PROTECTION COMMISSION[567]

Notice of Intended Action

Pursuant to the authority of Iowa Code section 455B.173(2), the Environmental

Protection Commission (Commission) hereby gives Notice of Intended Action to amend Chapter

61, “Water Quality Standards,” Iowa Administrative Code.

The purpose of the proposed amendments is to create additional flexibility for wastewater

dischargers by adding the option to use the Biotic Ligand Model (BLM) to determine copper

water quality criteria. The amendments will also add the option to use the Water-Effect Ratio

(WER) to adjust the existing copper water quality criteria. These options have the potential to

significantly reduce costs for permit holders that are unable to comply with the existing copper

criteria. Of the 297 facilities in Iowa that are subject to the existing copper criteria, the

Department of Natural Resources (DNR) estimates that 21 to 22 facilities are unable to comply.

Of the 21 to 22 facilities unable to comply with the existing criteria, DNR estimates that 7 to 10

would be able to comply with the copper BLM or WER-based criteria proposed in this rule

making. These 7 to 10 facilities could experience a significant cost savings by avoiding the need

to install copper removal technology in order to comply with the existing criteria.

The accumulation of copper at the biotic ligand (i.e., the gill of a fish or other similar site

for aquatic organisms) above a critical threshold concentration leads to toxicity. The amount of

copper that will actually accumulate at the gill depends in large part on the water chemistry of

the particular waterbody. The BLM accounts for several water chemistry parameters to predict

the concentration of copper that would actually result in toxicity to an organism in a given

waterbody. The United States Environmental Protection Agency (EPA) has developed a BLM-

based approach for calculating water quality criteria for copper. The Commission seeks to adopt

3

by reference the EPA document, “Aquatic Life Ambient Freshwater Quality Criteria - Copper

2007 Revision (EPA-822-R-07-001), February 2007.”

The WER method allows permittees to take into account the difference between the

toxicity of a metal as measured in laboratory water versus the toxicity of the metal as measured

in ambient water of the discharge site. The WER method allows facilities to calculate a ratio

between the two measured toxicity levels and use it to adjust the existing copper criteria shown

in 567 IAC 61.3(3), Table 1. Permittees wishing to use this option will be required to conduct a

WER study approved by the DNR. WER studies must be conducted in accordance with the EPA

documents “Interim Guidance on Determination and Use of Water-Effect Ratios for Metals

(EPA-823-B-94-001), February 22, 1994,” or upon approval by the DNR, “Streamlined Water-

Effect Ratio Procedure for Discharges of Copper (EPA-822-R-01-005), March 2001,” which the

Commission seeks to adopt by reference.

The proposed amendments will give National Pollutant Discharge Elimination System

(NPDES) permit holders the ability to use the WER to adjust the existing copper criteria, or the

ability to use the BLM to generate copper criteria that reflect the unique water chemistry

characteristics of the receiving waterbody. The proposed amendments will create flexibility for

NPDES permit holders seeking to comply with water quality standards while minimizing the

need for expensive infrastructure upgrades.

Any person may submit written suggestions or comments on the proposed amendments

through November 4, 2016. Such written material should be submitted to Connie Dou, Iowa

Department of Natural Resources, Wallace State Office Building, 502 East 9th Street, Des

Moines, Iowa 50319; fax (515)725–8202; or E–mail [email protected]. Persons who

have questions regarding the amendments may contact Connie Dou at (515)725–8400.

4

Persons are invited to present oral or written comments at a series of public hearings,

which will be held throughout the state as follows:

Date Time Location

November 1, 2016 4:00-6:00 PM Nicola-Stoufer Room Washington Public Library 115 West Washington St. Washington, Iowa November 2, 2016 4:00-6:00 PM Meeting Room B Urbandale Public Library 3520 86th St. Urbandale, IA November 3, 2016 4:00-6:00 PM Council Chambers ` City Hall 620 Erie St. Storm Lake, IA Persons attending the hearing will be asked to give their names and addresses for the

record and to confine their remarks to the content of the proposed amendments.

Any persons who plan to attend a public hearing and have special requirements, such as

those related to hearing or mobility impairments, should contact the DNR and advise of specific

needs.

After analysis and review of this rule making, these amendments are expected to have a

positive impact on jobs. The amendments are projected to result in a total cost savings for cities,

industries, and semi-public entities ranging between $113 million and $215 million. This total

savings is expected to be achieved by seven to ten facilities across the state that may be able to

avoid the installation of copper removal technology by using the copper BLM or WER. These

cost savings will likely lead to further investment in production and job growth.

5

Additional information on Iowa’s Water Quality Standards, including the Fiscal Impact

Statement, Job Impact Statement, and links to the BLM and WER documents, can be found on

the Department’s Web site at http://www.iowadnr.gov/Environmental-Protection/Water-

Quality/Water-Quality-Standards.

These proposed amendments are intended to implement Iowa Code section 455B.173(2).

The following amendments are proposed.

ITEM 1. Amend subrule 61.3(3), TABLE 1, entry for “Copper,” as follows:

Copper Chronic(n) 20 — 16.9(i) 16.9(i) 16.9(i) 10 — — Acute(n) 30 — 26.9(i) 26.9(i) 26.9(i) 20 — — Human Health + — Fish — — — — — — — 1000(e) Human Health + — F & W — — — — — — — 1300(f)

ITEM 2. Adopt the following new footnote (n) in subrule 61.3(3):

(n) The copper criteria in Table 1 can be adjusted by a Water-Effect Ratio (WER). The WER factor is equal to 1.0 unless an approved WER study has been conducted by a permittee for a specific point source. The WER study shall be conducted in accordance with the “Interim Guidance on Determination and Use of Water-Effect Ratios for Metals (EPA-823-B-94-001), February 22, 1994”, or upon approval by the department, the “Streamlined Water-Effect Ratio Procedure for Discharges of Copper (EPA-822-R-01-005), March 2001”, which are hereby adopted by reference.

The copper Biotic Ligand Model (BLM) may be used as an alternative to

the copper criteria in Table 1. The copper BLM is found in the document “Aquatic Life Ambient Freshwater Quality Criteria - Copper 2007 Revision (EPA-822-R-07-001), February 2007,” which is hereby adopted by reference.

ITEM 3. Adopt the following new subrule 61.3(10):

61.3(10) Implementation Procedure for Biotic Ligand Model-Based Copper Criteria. The department hereby incorporates by reference “Implementation Procedure for Biotic Ligand Model-Based Copper Criteria,” [effective date]. This document may be obtained on the department’s Web site.

http://www.iowadnr.gov/Environmental-Protection/Water-Quality/Water-Quality-Standards

http://www.iowadnr.gov/Environmental-Protection/Water-Quality/Water-Quality-Standards

6

_______________________________ Date _______________________________ Chuck Gipp, Director


ITEM 17 DECISION

TOPIC

Adopted and Filed – Chapter 100 – Scope of Title – Definitions – Form – Rules of Practice - Chapter 101 - Solid Waste Comprehensive Planning Requirements - Chapter 111 – Annual Reports of Environmental Management Systems

The Commission is requested to approve this Adopted and Filed rule that amends 567 IAC Chapters 100, 101, and 111. Notice of Intended Action was published in the Iowa Administrative Bulletin as ARC 2630C on July 20, 2016. A public hearing was held on August 9, 2016 in the Wallace State Office Building. The Department of Natural Resources (Department) also accepted written comments through August 9, 2016. The Department did not receive any comments. The rule amendments:

• Move certain definitions from Chapter 101 to Chapter 100. • Make minor corrections to Chapter 101 for consistency with the applicable state

statutes. • Rescind rule 567—101.3(455B,455D) pertaining to the state’s waste management

hierarchy and replace all references to rule 567—101.3(455B,455D) with references to Iowa Code section 455B.301A.

• Amend rules 567—101.6(455B,455D) and 567—101.7(455B,455D) and rescind subrule 101.13(8) to reflect recent legislative changes to Iowa Code section 455D.3 regarding required solid waste management techniques for planning areas that fall below the 25 percent waste volume reduction goal. See 2013 Iowa Acts, House File 225, signed by Governor Branstad on March 28, 2013.

• Remove the waiver in subrule 101.7(3) that exempts from the state tonnage fee waste generated during a declared disaster. The Iowa Code does not give the Department the authority to issue this waiver.

• Rescind rules 567—101.10(455B,455D) and 567—101.11(455B,455D), which, in effect, will remove the requirement for local governments to complete the Municipal Solid Waste and Recycling Survey and accompanying forms.

• Adopt new paragraph 101.13(2)“k” in order to recognize that annual reporting efforts of planning areas and service areas that are designated as Environmental Management Systems (EMS) under Iowa Code chapter 455J meet the comprehensive plan update requirements in subrule 101.13(2).

• Adopt an updated definition of “comprehensive plan update” to reflect the 2009 amendments to Chapter 101, such that in the definition of “planning cycle,” the length of time between the due date of each comprehensive plan was extended from three years to five years. The current definition of “comprehensive plan update” requires planning agencies to incorporate a proposed course of action for the “next two planning cycles” (10 years), which has proven to be too long to allow for accurate planning. As such, the new definition requires the “comprehensive plan update” to address only the next planning cycle (5 years). Additional revisions have been incorporated throughout the proposed amendments to meet this objective. This rule making reflects legislative changes to the Iowa Code and encompasses

the comprehensive five-year review of rules that the Department is currently conducting pursuant to Iowa Code section 17A.7(2). The changes eliminate inconsistencies with the Iowa Code, remove redundant reporting requirements, eliminate unnecessary and obsolete language and make corrections to Iowa Code references, thus simplifying the rules of the Commission and making them easier to use and understand.

Leslie Bullock Goldsmith, Program Planner Financial and Business Assistance, Land Quality Bureau Environmental Services Division September 20, 2016

ENVIRONMENTAL PROTECTION COMMISSION [567] Adopted and Filed

Pursuant to the authority of Iowa Code sections 455B.304(1) and 455D.7, the

Environmental Protection Commission (Commission) hereby amends Chapter 100,

“Scope of Title—Definitions—Forms—Rules of Practice,” Chapter 101, “Solid Waste

Comprehensive Planning Requirements,” and Chapter 111, “Annual Reports of Solid

Waste Environmental Management Systems,” Iowa Administrative Code.

This rule making reflects legislative changes to the Iowa Code and encompasses

the comprehensive five-year review of rules that the Department of Natural Resources

(Department) is currently conducting pursuant to Iowa Code section 17A.7(2). The

changes eliminate inconsistencies with the Iowa Code, remove redundant reporting

requirements, eliminate unnecessary and obsolete language and make corrections to Iowa

Code references, thus simplifying the rules of the Commission and making them easier to

use and understand.

The amendments:

• Move certain definitions from Chapter 101 to Chapter 100.

• Make minor corrections to Chapter 101 for consistency with the applicable state

statutes.

• Rescind rule 567—101.3(455B,455D) pertaining to the state’s waste management

hierarchy and replace all references to rule 567—101.3(455B,455D) with

references to Iowa Code section 455B.301A.

• Amend rules 567—101.6(455B,455D) and 567—101.7(455B,455D) and rescind

subrule 101.13(8) to reflect recent legislative changes to Iowa Code section

455D.3 regarding required solid waste management techniques for planning areas

that fall below the 25 percent waste volume reduction goal. See 2013 Iowa Acts,

House File 225, signed by Governor Branstad on March 28, 2013.

• Remove the waiver in subrule 101.7(3) that exempts from the state tonnage fee

waste generated during a declared disaster. The Iowa Code does not give the

Department the authority to issue this waiver.

• Rescind rules 567—101.10(455B,455D) and 567—101.11(455B,455D), which, in

effect, will remove the requirement for local governments to complete the

Municipal Solid Waste and Recycling Survey and accompanying forms.

• Adopt new paragraph 101.13(2)“k” in order to recognize that annual reporting

efforts of planning areas and service areas that are designated as Environmental

Management Systems (EMS) under Iowa Code chapter 455J meet the

comprehensive plan update requirements in subrule 101.13(2).

• Adopt an updated definition of “comprehensive plan update” to reflect the 2009

amendments to Chapter 101, such that in the definition of “planning cycle,” the

length of time between the due date of each comprehensive plan was extended

from three years to five years. The current definition of “comprehensive plan

update” requires planning agencies to incorporate a proposed course of action for

the “next two planning cycles” (10 years), which has proven to be too long to

allow for accurate planning. As such, the new definition requires the

“comprehensive plan update” to address only the next planning cycle (5 years).

Additional revisions have been incorporated throughout the proposed

amendments to meet this objective.

Notice of Intended Action was published in the Iowa Administrative Bulletin as

ARC 2630C on July 20, 2016. A public hearing was held August 9, 2016, in the Wallace

State Office Building. The Department also accepted written comments through August

9, 2016. No public comments were received during the comment period.

The amendments are identical to those published as a Notice of Intended Action.

The Commission adopted these amendments on September 20, 2016.

After analysis and review of this rulemaking, no impact on jobs has been found.

These amendments are intended to implement Iowa Code 455B.301A, 455B.302,

455B.306, 455B.310 and 455D.3.

These amendments will become effective on November 16, 2016.

The following amendments are adopted.

ITEM 1. Adopt the following new definitions in rule 567—100.2(455B,455D):

“Comprehensive plan” means a course of action developed and established cooperatively

between cities, counties and municipal solid waste sanitary disposal projects regarding

their chosen integrated solid waste management system, its participants, waste reduction

strategies, and disposal methods.

“Comprehensive plan amendment” means a notification, filed between comprehensive

plan updates, that the planning agency seeks to change the participation or change the

designated disposal project(s) as set out in the most recent approved comprehensive plan

submittal.

“Comprehensive plan update” means a planning document that provides status reports

on the integrated solid waste management system and that describes revision to the

information and evaluation of the integrated solid waste management system and the

proposed course of action for the next planning cycle.

“Consumer price index” means the measure of the average change over time in the prices

paid by urban consumers for a market basket of consumer goods and services. For the

purpose of this title, consumer price index refers to All Urban Consumers (CPI-U), All

Items, as published by the U.S. Bureau of Labor Statistics.

“Contaminated soil” means soil that contains any harmful constituent in a concentration

that may harm human health.

“Fiscal year” means the state fiscal year from July 1 through June 30.

“Initial comprehensive plan” means a first or new comprehensive plan filed with the

department pursuant to the provisions of Iowa Code section 455B.306.

“Integrated solid waste management” means any solid waste management system which

is focused on planned development of programs and facilities that reduce waste volume

and toxicity, recycle marketable materials and provide for safe disposal of any residuals.

“Municipal solid waste sanitary disposal project” means all facilities and appurtenances,

including all real and personal property connected with such facilities, which are

acquired, purchased, constructed, reconstructed, equipped, improved, extended,

maintained, or operated to facilitate the final disposition of household waste without

creating a significant hazard to the public health or safety. A municipal solid waste

sanitary disposal project also may receive other types of Resource Conservation and

Recovery Act (RCRA) Subtitle D wastes, such as construction and demolition debris and

commercial and industrial solid waste.

“Planning agency” means the designated contact agency on file with the department.

“Planning cycle” means the length of time between the due date for each comprehensive

plan update submittal as approved by the department, which shall be five years effective

March 1, 2011.

“Plan participants” means any individual, group, government or private entity that has

direct involvement in an integrated solid waste management system.

“Service area” means an area served by a specific municipal solid waste sanitary

disposal project defined in terms of the jurisdictions of the local governments using the

facility. A planning area may include more than one service area. This definition does not

apply to 567—Chapter 111.

ITEM 2. Amend rule 567—100.2(455B,455D), definitions of “Planning area” and

“Solid waste,” as follows:

“Planning area” means the localities and facilities involved in any aspect of the sanitary

disposal project(s) management of waste, including out-of-state localities and facilities, if

applicable the combined jurisdiction of the local governments and the designated

municipal solid waste sanitary disposal project(s) involved in a comprehensive plan. A

planning area may include one or more municipal solid waste sanitary disposal projects.

“Solid waste” is defined has the same meaning as found in Iowa Code section

455B.301. Pursuant to Iowa Code section 455B.301(23)“b,” the commission has

determined that solid waste includes those wastes exempted from federal hazardous

waste regulation pursuant to 40 CFR 261.4(b) as amended through [effective date of

these amendments], except to the extent that any such exempted substances are liquid

wastes or wastewater. This definition applies to all chapters within Title VIII. To the

extent that there is a conflict, this definition controls.

ITEM 3. Rescind rule 567—101.2(455B,455D) and adopt the following new rule

in lieu thereof:

567—101.2(455B,455D) Definitions. For the purposes of this chapter, the definitions

found in 567—100.2(455B,455D) shall apply.

ITEM 4. Rescind and reserve rule 567—101.3(455B,455D).

ITEM 5. Amend rule 567—101.4(455B,455D) as follows:

https://www.legis.iowa.gov/docs/ico/section/455B.301.pdf

567—101.4(455B,455D) Duties of cities and counties. Every city and county of this

state shall, for the solid waste generated within the jurisdiction of its political subdivision,

provide for the establishment and operation of an integrated solid waste management

system consistent with the waste management hierarchy under rule 567—

101.3(455B,455D) Iowa Code section 455B.301A and designed to meet the state’s waste

reduction and recycling goals. Integrated systems and municipal solid waste sanitary

disposal projects may be established separately or through cooperative efforts, including

Iowa Code chapter 28E agreements as provided by law.

101.4(1) To meet these responsibilities, cities and counties may execute, with

public and private agencies, contracts, leases, or other necessary instruments, purchase

land and do all things necessary not prohibited by law for the implementation of waste

management programs, collection of solid waste, establishment and operation of

municipal solid waste sanitary disposal projects, and general administration of the same.

101.4(2) If a city or county facility planning agency refuses any particular solid

waste type for management or disposal, the city or county facility planning agency must

identify another waste management facility municipal solid waste sanitary disposal

project for that waste within the planning area. In the case of special waste, if If no

other waste management facility for that waste type municipal solid waste sanitary

disposal project exists within the planning area, the city or county planning agency must,

in cooperation with the waste generator, establish or arrange for access to another waste

management facility municipal solid waste sanitary disposal project. Municipal solid

waste sanitary disposal projects are required to maintain written approval from both the

department and the planning agency in the planning area of origin in order to accept any

Iowa-generated waste from outside the planning area.

https://www.legis.iowa.gov/docs/ico/chapter/28E.pdf

101.4(3) All cities and counties or Iowa Code chapter 28E agencies established

for the purpose of managing solid waste or implementing integrated solid waste

management systems, or both, on behalf of cities and counties shall demonstrate

compliance with the provisions of this chapter by their participation in a comprehensive

plan approved by the department.


567—101.6(455B,455D) State volume reduction and recycling goals. The goal of the

state is to reduce the amount of materials in the waste stream , existing as of the July 1,

1988, baseline, 25 percent by July 1, 1994, and 50 percent by July 1, 2000 by an

intermediate goal of 25 percent, and by a final goal of at least 50 percent, through the

practice of waste volume reduction at the source and through recycling. The updated goal

progress calculations provided by the department for each planning area shall be used by

the department in reporting to the general assembly on the state’s progress toward

meeting the 25 and 50 percent goals. If at any time the department notifies the planning

agency in writing that the planning area has failed to meet the 25 percent waste volume

reduction and recycling goal, at a minimum, the solid waste management techniques

listed in Iowa Code section 455D.3(4) and subrule 101.13(8) must be implemented

throughout the planning area. The specific methodology for determining goal progress is

outlined in rule 567—101.7(455B,455D).

ITEM 7. Amend rule 567—101.7(455B,455D), introductory paragraph, as follows:

567—101.7(455B,455D) Base year adjustment method. Planning agencies may request

that the department complete a goal progress recalculation once per fiscal year to resolve

any discrepancies and to further evaluate progress toward the state’s waste volume

reduction and recycling goals. At the time of approval of a comprehensive plan or

comprehensive plan update, the department will use the most current complete fiscal year

https://www.legis.iowa.gov/docs/ico/chapter/28E.pdf

https://www.legis.iowa.gov/docs/ico/section/455D.3.pdf

data set available to complete goal progress calculations, which will be used to meet the

requirements outlined in subrule 101.13(8) and rule 567—101.14(455B,455D).

ITEM 8. Amend subrule 101.7(3) as follows:

101.7(3) Waste generated as part of an exceptional event or contaminated soils

removed as part of a brownfield or contaminated site cleanup should not negatively affect

a planning area’s goal progress calculation.

a. Exceptional events include, but are not limited to, such unforeseen

disasters as storms, fires, floods, tornadoes, or train wrecks. Exceptional events do not

include economic development, derelict housing removal, or other planned

activities/demolitions. Written requests to exempt exceptional event debris from goal

progress calculations shall be made to the department on the required Quarterly Solid

Waste Fee Schedule and Retained Fees Report, DNR Form 542-3276.

Requests for goal progress calculation exemptions must be made within six

months after initial disposal of the debris. The determination to exempt exceptional

event exceptional-event debris from goal progress calculations shall be made solely by

the department and shall not be made independently by individual municipal solid waste

sanitary disposal projects or planning agencies. Municipal solid waste sanitary disposal

projects required to remit tonnage fees shall continue to pay solid waste tonnage fees

until written notification of fee exemption is received, at which time any applicable fee

credit shall be granted by the department. Upon review of the request, the department will

notify the municipal solid waste sanitary disposal project and planning agency of the

determination in writing or request further documentation.

(1) No change.

(2) Additional documentation to verify the exceptional event and the debris it

generated may be requested by the department. Failure to submit requested

documentation may result in denial of the goal progress calculation or solid waste

tonnage fee exemption request(s), including any fee credits authorized by the department.

Documentation may include:

1. to 7. No change.

b. If the governor of the state of Iowa declares a city or county a disaster area

as a result of an exceptional event, the municipal solid waste sanitary disposal project or

planning agency may request that the debris be exempt from solid waste tonnage fees. A

request to waive tonnage fees must be submitted in writing on the facility’s or planning

agency’s letterhead prior to or in the same submittal as the Quarterly Solid Waste Fee

Schedule and Retained Fees Report, DNR Form 542-3276. Requests to waive tonnage

fees, as provided for in this rule, must be made within 6 months after the initial disposal

of the debris. A copy of the proclamation of disaster emergency declared by the governor

of the state of Iowa is required in order for approval of tonnage fee exemptions. Any

continuing documentation shall be submitted with each Quarterly Solid Waste Fee

Schedule and Retained Fees Report, DNR Form 542-3276, within the length of time

authorized by the department. Solid waste disposed of outside the window of time

authorized by the department shall not be eligible for exemption. To be eligible for an

exemption, all exceptional event waste must be disposed of within the following time

lines:

(1) For debris clearance and emergency protective measures, as defined by

FEMA guidelines, 6 months from the end of the exceptional event.

(2) For permanent repair work, as defined by FEMA guidelines, 18 months

from the end of the exceptional event.

Upon written request, with supporting rationale, extensions to these time lines may be

granted solely by the department on a case-by-case basis.

c. b. Contaminated soils removed as part of a brownfield or contaminated site

cleanup should not negatively affect a planning area’s goal progress calculation. If the

contaminated soil is to be disposed of in a municipal solid waste sanitary disposal project,

the municipal solid waste sanitary disposal project or planning agency must request the

goal progress exemption in writing, in accordance with the procedures outlined in this

rule. Written requests to exempt contaminated soil from goal progress calculations shall

be made to the department on the Quarterly Solid Waste Fee Schedule and Retained Fees

Report, DNR Form 542-3276. Requests for goal progress exemptions must be made

within 6 six months after initial disposal of the contaminated soil.

The determination to exempt contaminated soil from goal progress calculations

shall be made solely by the department and shall not be made independently by

individual municipal solid waste sanitary disposal projects or planning agencies. The

department shall notify the municipal solid waste sanitary disposal project or planning

agency in writing of the determination or shall request further clarification to make an

exemption decision. Failure to submit additional information requested by the department

regarding the request to exempt contaminated soil may result in a denial of the goal

progress calculation exemption request. Contaminated soil occurrences not eligible for

goal progress exemption include, but are not limited to, illegal municipal solid waste

disposal sites and contaminated soils formed for the sole purpose of requesting goal

progress exemption. Exemption requests shall include, at a minimum, the following:

(1) to (10) No change.


567—101.8(455B,455D) Submittal of initial comprehensive plans and

comprehensive plan updates. Initial comprehensive plans and comprehensive plan

updates filed with the department must include a signed electronic submission

certificate , which can be printed when all online forms have been submitted to the

department for review. When hard-copy portions of the initial comprehensive plan or

comprehensive plan update are submitted to the department, only one original copy is

necessary. Initial comprehensive plans and comprehensive plan updates are required to be

double-sided and cannot be submitted in three-ring binders. Comprehensive plan updates

shall be submitted in accordance with the schedule , as and instructions provided by the

department 12 months prior to the due date of the first comprehensive plan update for

each planning cycle. Planning agencies are not required to submit hard copies of the

online forms for comprehensive plan updates.



ITEM 12. Amend paragraph 101.13(1)“g” as follows:

g. A description of the current waste composition and waste generation rates

and a projection of waste composition and waste generation rates spanning two planning

cycles during the next planning cycle. This description should include the effects of

anticipated planning area modifications on waste generation and composition in the

future. These factors may include economic changes, population changes, loss or addition

of communities to the planning area, and any other modification expected to affect the

amount of waste generated.

ITEM 13. Amend subparagraph 101.13(1)“h”(3) as follows:

(3) A detailed narrative of all other existing waste management programs in

the planning area that addresses all components of the state’s waste management

hierarchy. This narrative must include specific methodologies for the separation of glass,

paper, plastic and metal. For each specific waste management program, the following

shall be included:

1. to 5. No change.

6. The anticipated impact on the waste stream and diversion over at least two

planning cycles during the next planning cycle.

ITEM 14. Amend paragraph 101.13(1)“k,” introductory paragraph, as follows:

k. A specific plan and schedule spanning two planning cycles for

implementing the initial comprehensive plan during the next planning cycle. Items that

shall be addressed include:

ITEM 15. Amend subparagraph 101.13(2)“g”(3) as follows:

(3) A detailed narrative of all waste management programs implemented since

the last approved comprehensive plan or comprehensive plan update that addresses all

components of the state’s waste management hierarchy. For each specific waste

management program implemented since the last approved comprehensive plan or

comprehensive plan update, the following shall be included:

1. to 4. No change.

5. The anticipated impact on the waste stream and diversion over at least two

planning cycles during the next planning cycle.

ITEM 16. Amend paragraph 101.13(2)“h,” introductory paragraph, as follows:

h. An evaluation of progress toward meeting the state’s waste volume

reduction and recycling goals using the goal progress calculation provided by the

department 12 months prior to the due date of the comprehensive plan update, if

requested by the planning agency. This analysis may use any combination of the

following methodologies:

ITEM 17. Amend paragraph 101.13(2)“j,” introductory paragraph, as follows:

j. A specific plan and schedule spanning two planning cycles for

implementing the comprehensive plan during the next planning cycle. Items that shall be

addressed include:

ITEM 18. Adopt the following new paragraph 101.13(2)“k”:

k. Annual reports submitted by planning agencies designated as

environmental management systems, pursuant to Iowa Code section 455J.7, which satisfy

the comprehensive plan update submittal requirements of this subrule.

ITEM 19. Rescind and reserve subrule 101.13(8).

ITEM 20. Amend 567—Chapter 101, implementation sentence, as follows:

These rules are intended to implement Iowa Code sections 455B.301A, 455B.302,

455B.306, 455B.310 and 455D.3.

ITEM 21. Amend rule 567—111.4(455J), definition of “Planning area,” as

follows:

“Planning area” means the same as defined in rule 567—101.2(455B,455D) 567—

100.2(455B,455D).

https://www.legis.iowa.gov/docs/ico/section/455B.301A.pdf



https://www.legis.iowa.gov/docs/ico/section/455D.3.pdf


ITEM 18 DECISION

TOPIC Adopted and Filed – Amendments to Flood Plain Management Rules to streamline certain development types

Pursuant to the authority of Iowa Code section 455B.263, the Department of Natural Resources recommends that the Environmental Protection Commission (Commission) amend Chapter 70, “Scope of Title—Definitions—Forms—Rules of Practice,” Chapter 71, “Flood Plain or Floodway Development—When Approval Is Required,” and Chapter 72, “Criteria for Approval,” Iowa Administrative Code as set out below. The amendments change the criteria for the construction of bridges, road embankments, and culverts in a flood plain. Oftentimes, to construct bridges and other structures in a flood plain, the Iowa Department of Transportation (IDOT) and other contractors have had to apply for waivers or variances from the Commission’s rules, a process which could be time-consuming and costly. In response to this concern, the rules have been reviewed and a determination made that certain portions of existing rules are redundant or unnecessary, and changes could be made that would allow for a higher percentage of compliance with rules. The proposed amendments will reduce the need for these contractors to seek waivers and variances. Equally important, the amendments will not sacrifice public safety. The amendments also add exemptions to the flood plain development permit requirements for certain activities, such as excavations installed for conservation practices, and for the installation of signs, utility poles and other similar structures. These exemptions were developed in cooperation with stakeholders such as electric utilities and the Natural Resources Conservation Service (NRCS). The amendments also modify the waiver and variance provision in the flood plain rules so that the provision is consistent with the Iowa Code. The amendments make minor changes to Chapters 70, 71 and 72 to update definitions, references to Iowa Code sections, forms, and agency contact information. A public hearing was held on Wednesday, August 10, 2016 at 1 p.m. in Conference Room 2 North, 2nd Floor, Wallace State Office Building, 502 E. 9th Street, Des Moines, Iowa. Three public comment letters were received. A Responsiveness Summary is attached to this brief. Due to the public comments received, clarifying language was added to the definitions of “high damage potential” and “low damage potential” in Chapter 70. Ken Bouma, Program Planner III Flood Plains and Dam Safety, Land Quality Bureau Environmental Services Division August 29, 2016

ARC 2629C

ENVIRONMENTAL PROTECTION COMMISSION [567]

Adopted and Filed

Pursuant to the authority of Iowa Code section 455B.263, the Environmental

Protection Commission (Commission) amends Chapter 70, “Scope of Title—

Definitions—Forms—Rules of Practice,” Chapter 71, “Flood Plain or Floodway

Development—When Approval Is Required,” and Chapter 72, “Criteria for Approval,”

Iowa Administrative Code.

The amendments change the criteria for the construction of bridges, road

embankments, and culverts in a flood plain. Oftentimes, to construct bridges and other

structures in a flood plain, the Iowa Department of Transportation (IDOT) and other

contractors have had to apply for waivers or variances from the Commission’s rules, a

process which could be time-consuming and costly. In response to this concern, the

Commission has reviewed its rules and determined that certain portions of existing rules

are redundant or unnecessary, and changes could be made that would allow for a higher

percentage of compliance with rules. The amendments will reduce the need for these

contractors to seek waivers and variances. Equally important, the amendments will not

sacrifice public safety.

The amendments add exemptions to the Commission’s flood plain development

permit requirements for certain activities, such as excavations installed for conservation

practices, and for the installation of signs, utility poles and other similar structures. The

exemptions were developed in cooperation with stakeholders such as electric utilities and

the Natural Resources Conservation Service (NRCS).

The amendments modify the waiver and variance provision in the flood plain

rules so that the provision is consistent with the Iowa Code. The amendments make

minor changes to Chapters 70, 71 and 72 to update definitions, references to Iowa Code

sections, forms, and agency contact information.

The Notice of Intended Action was published in the Iowa Administrative Bulletin

as ARC 2629C on July 20, 2016. A public hearing was held on August 10, 2016, at 1

p.m. in Conference Room 2 North of the Wallace State Office Building, 502 East Ninth

Street, Des Moines, Iowa and written comments were accepted through August 10, 2016.

Representatives from the Iowa Farm Bureau Federation and the Iowa Drainage District

Association attended the public meeting. Public comments were submitted by

MidAmerican Energy in support of the proposed rules. The Iowa Farm Bureau

Federation and the Iowa Drainage District Association submitted comments

recommending changes to the rules and are summarized below.

The first comment related to the definitions of “high damage potential” and “low

damage potential.” The commenter requested clarification to the “high damage

potential” definition by using the term “significant” to distinguish it from the term

“minimal damage” in the “low damage potential” definition. After review of the rule, a

building and how it is used is considered high or low damage potential because of the

“public damages” that would occur during a flood event. “Public damages” is already

defined in the rules and means “costs resulting from damage to roads and streets, sewers,

water mains, other public utilities and public buildings; expenditures for emergency flood

protection, evacuation and relief, rehabilitation and cleanup; losses due to interruption of

utilities and transportation routes, and interruption of commerce and employment.”

Each building and its use whether industrial, commercial, agricultural or

recreational has the potential for expenditures for emergency flood protection, evacuation

of people, rehabilitation costs, cleanup costs and the costs related to interruption of

commerce and employment.

Therefore the Commission is amending the definition of “high damage potential”

by removing the descriptor “constructed of materials” and replacing it with “. . . which, if

inundated by flooding would result in high public damages as determined by the

department . . .” to mirror the wording used in 3. Public buildings and building

complexes.”

In the definition for “low damage potential” the focus is on those buildings and

their uses that would not sustain high “public damages” if inundated by flood waters. For

example, a park shelter is a low damage potential building because of its open air design

and the use is such that damage to the shelter would not result in expenditures for

emergency flood protection, costs to evacuate the shelter, rehabilitation and cleanup

costs, and no interruption of commerce and employment.

The Commission agrees that “structures used by livestock for temporary relief

from the weather elements or that are used for short-term livestock management

purposes” would be considered “low damage potential.” Therefore the Commission is

amending the definition of “low damage potential” by changing the last part of the final

sentence to “. . .park shelters, buildings used for storage of equipment or crops that can be

easily removed, and buildings used as temporary shelter for livestock.”

Therefore, the definitions are amended for “high damage potential” and “low

damage potential” in ITEM 567—70.2(455B, 481A).

Comments were received regarding ITEM 7. One commenter requested that a new

exemption be added for the broader exclusion of conservation practices installed within

100 feet of the stream or river bank. After analysis of this comment, it was determined

that adding a broader exclusion for all conservation practices would not be a logical

outgrowth of the rule.

Iowa Code 455B.277(9) states “that the commission shall establish, by rule,

thresholds for dimensions and effects, and any structure, dam, obstruction, deposit, or

excavation having smaller dimensions and effects than those established by the

commission is not subject to regulation under this section.” The thresholds shall be

established so that only those structures, dam, obstruction, deposits, or excavations

posing a significant threat to the well-being of the public and the environment are subject

to regulation.

Because the term “conservation practice” is not defined in 567—Chapter 70, the

phrase “Excavations for conservation practices installed to meet or exceed the standards

of the USDA Natural Resources Conservation Service (NRCS) Field Office Technical

Guide” was used in the rule. This statement implies a defined set of conservation

practices where a determination has been made that excavations for conservation

practices that meet or exceed the NRCS technical guidance would not pose a significant

threat to the well-being of the public and the environment. See Iowa Code 455B.275(9).

The Commenter has requested an exemption for excavations for all conservation

practices, not just those that meet or exceed the standards of the NRCS Field Office

Technical Guide. Broadening this exemption to all conservation practices would

introduce more ambiguity into the rule in that there is no definition for “all conservation

practices.” Therefore, the Commission is not adding an exemption for all conservation

practices since it may potentially exempt many undefined practices and would not be a

logical outgrowth of this rulemaking.

Two comments were received stating that removal of soil from the excavation

area should be allowed to qualify for the exemption stated in ITEM 7 paragraph “e.”

The thresholds for determining when a flood plain permit is required are laid out

in 567—Chapter 71 by project type. Often an application for a permit will contain a

scope of work that utilizes more than one of the project types listed in 567—Chapter 71.

For instance, most excavation projects that fall under 567—71.11 also have a component

of the project that falls under 567—71.12 Miscellaneous structures, obstructions, or

deposits not otherwise provided for in other rules. Therefore in determining if the project

needs a flood plain permit, the department looks at the thresholds in both rules: 567—

71.11 and 71.12.

Excavation and fill of the floodplain are subject to requirements to preserve the

natural and traditional character of the land and waterway. The Commission agrees with

the idea that potential applicants want to put the resulting spoil from an excavation on

their adjoining land. 567—71.12 can be applied in this circumstance. If placement of the

spoil or fill falls below the thresholds listed in 567—71.12, a flood plain construction

permit is not required. For that reason, 567—71.12 already gives applicants the

flexibility requested by the Iowa Farm Bureau Federation and the Iowa Drainage District

Association to spread a limited amount of spoil on their property without needing to gain

a flood plain construction permit. For that reason, the Commission is not changing the

exemption in ITEM 7.

A public comment responsiveness summary addresses all comments and is

available upon request.

After analysis and review of this rule making, no impact on jobs has been found.

On balance, the above-discussed amendments reduce the regulatory burden for the

regulated community. This is done by rescinding or changing certain flood plain

development criteria, providing more exemptions from flood plain development permit

requirements, and clarifying how to properly obtain a waiver or variance from applicable

rules.

The Commission adopted this amendment on September 20, 2016.

These amendments are intended to implement Iowa Code section 455B.264.

The amendments will become effective on November 16, 2016.

The following amendments are adopted.

ITEM 1. Amend the following definitions in rule 567—70.2(455B, 481A):

“Animal feeding operation” means the same as defined in 567—65.1(455B

459,459B).

“Animal feeding operation structure,” means the same as defined in 567—

65.1(455B 459,459B), means a confinement building, manure storage structure, or egg

washwater storage structure.

“Confinement feeding operation,” means the same as defined in 567—65.1(455B

459,459B), means an animal feeding operation in which animals are confined to areas

which are totally roofed.

“Confinement feeding operation building” or “confinement building,” means the

same as defined in 567—65.1(455B 459,459B), means a building used in conjunction

with a confinement feeding operation to house animals.

“Confinement feeding operation structure,” means the same as defined in 567—

65.1(455B 459,459B), means an animal feeding operation structure that is part of a

confinement feeding operation.

“High damage potential” means the flood damage potential associated with

habitable residential buildings or industrial, commercial, or public buildings or building

complexes of which flooding would result in high public damages as determined by the

department. the following:

1. Habitable residential buildings and building complexes which include seasonal

residential buildings; or

2. Industrial, commercial, agricultural, recreational and other similar buildings or

building complexes, which, if inundated by flooding would result in high public damages

as determined by the department or that contain high-value equipment or contents that

are not easily removed; or

3. Public buildings or building complexes, which, if inundated by flooding, would

result in high public damages as determined by the department.

“Low damage potential” means all buildings, building complexes or flood plain

use uses not defined as maximum, or high, or moderate damage potential where such

structures are designed in a manner that inundation by flood waters results in minimal

damage to the structure and its contents. Such structures include but are not limited to the

following: detached residential garages, sheds, park shelters, buildings used for storage of

equipment or crops that can be easily removed, and buildings used as temporary shelter

for livestock.

“Major water source,” means the same as defined in 567—65.1(455B 459,459B),

means a water source that is a lake, reservoir, river or stream located within the territorial

limits of the state, or any marginal river area adjacent to the state, if the water source is

capable of supporting a floating vessel capable of carrying one or more persons during a

total of a six-month period in one out of ten years, excluding periods of flooding. Major

water sources in the state are listed in Appendix B, Table 1 and Table 2 of 567—Chapter

65.

“Manure storage structure,” means the same as defined in 567—65.1(455B

459,459B), means a formed manure storage structure or an unformed manure storage

structure, as defined in 567—65.1(455B). A manure storage structure does not include an

egg washwater storage structure. “Water source,” means the same as defined in 567—

65.1(455B 459,459B), means any lake, river, creek, ditch or other body of water or

channel having definite banks and bed with visible evidence of the flow or occurrence of

water, except such lakes or ponds without outlet to which only one landowner is riparian.

ITEM 2. Rescind the definition of “Moderate damage potential” in rule 567—

70.2(455B,481A).

ITEM 3. Rescind rule 567—70.3(17A,455B,481A) and adopt the following new

rule in lieu thereof:

567—70.3(17A,455B,481A) Forms. Any private or public person or agency

desiring to secure a permit under this chapter shall file a properly completed application,

DNR Form 36. For application and supplemental forms, any private or public person or

agency should see http://www.iowadnr.gov/Environmental-Protection/Land-

Quality/Flood-Plain-Management.

Application forms may also be obtained from:

Flood Plain and Dam Safety Section

Iowa Department of Natural Resources

Henry A. Wallace Building

502 East Ninth Street

Des Moines, Iowa 50319


70.4(2) Applying for a flood plain development permit. Application for a flood

plain development permit shall be made on DNR Form 36 or a reasonable facsimile

thereof. The application shall be submitted by or on behalf of the person or persons who

have or will have responsibility by reason of ownership, lease, or easement for the

property on which the project site is located. The application must be signed by the

applicant or a duly authorized agent. Completed applications along with supporting

information shall be mailed or otherwise delivered to the Flood Plain Management and

http://www.iowadnr.gov/Environmental-Protection/Land-Quality/Flood-Plain-Management

http://www.iowadnr.gov/Environmental-Protection/Land-Quality/Flood-Plain-Management

Dam Safety Section, Environmental Protection Services Division, Iowa Department of

Natural Resources, Wallace State Office Building, 502 East Ninth Street, Des Moines,

Iowa 50319.

ITEM 5. Amend paragraph 70.4(3)“a” as follows:

a. General requirement of certified plans. An application shall not be considered

complete until sufficient engineering plans have been submitted to enable the department

to determine whether the project as proposed satisfies applicable criteria. The engineering

plans shall contain information, as specified by the department, which is needed for the

department to conduct a technical review pursuant to paragraph 70.5(3)“b.” The

engineering plans shall include specifications, operation procedures and other

information relating to environmental impacts. The engineering plans and other

engineering information shall be certified by a registered licensed professional engineer

or, if applicable, a registered licensed land surveyor, as required by Iowa Code chapter

542B. Duplicate copies of certified plans are required so that one copy can be returned to

the applicant upon approval or disapproval of the application. An additional copy of the

certified plans shall be required if the plans are incorporated as part of an approval or

disapproval order which is filed with a county recorder.

ITEM 6. Amend 567—Chapter 71, preamble, as follows:

PREAMBLE: This chapter of these rules contains administrative thresholds

which implement the statutory requirement that approval from the department be

obtained for any development including construction, maintenance and use of a structure,

dam, obstruction, deposit, excavation or “flood control work” on a flood plain or

floodway. These administrative thresholds are organized into categories such as “channel

changes,” “levees or dikes,” “buildings,” etc. Any doubt concerning whether a project or

activity requires approval under these thresholds should be resolved by requesting a

request for advice from the department.

The department may delegate regulatory authority to a local government by

approving local flood plain regulations (see 567—Chapter 75). To determine whether the

department has delegated regulatory authority over a specific category of project at a

specific location, an inquiry should be made to:

State Coordinator

National Flood Insurance Program

Iowa Department of Natural Resources

Wallace State Office Building

Des Moines, Iowa 50319

Telephone: (515)281-8690 725-8200

ITEM 7. Adopt the following new paragraph 71.11(1)“e”:

e. Excavations for conservation practices installed to meet or exceed the standards

of the USDA Natural Resources Conservation Service (NRCS) Field Office Technical

Guide are exempt if all of the following criteria are met:

(1) The resulting spoil is removed from the flood plain;

(2) The practices do not reduce the capacity of the flood plain; and

(3) The practices will not result in water being temporarily or permanently stored

above the natural ground line.

These standards may be accessed through the electronic Field Office Technical

Guide at https://efotg.sc.egov.usda.gov/. They are also available in hard copy at the

USDA NRCS office that serves the area where the practice will be implemented.

ITEM 8. Adopt the following new subrule 71.12(3):

71.12(3) Exemptions. For purposes of this rule, the following project types do not

require approval by the department:

a. Signs, navigational markers, and aids that have been placed by a public agency

to serve the public;

b. In-kind replacement of existing utility poles, including H-frame structures that

are installed as part of routine maintenance or an emergency;

c. New utility poles, including H-frame structures, that fall below the thresholds

set forth in 71.12(1) and 71.12(2).

ITEM 9. Amend 567—Chapter 72, preamble, as follows:

This division of these rules establishes The rules within this chapter establish

administrative criteria which implement certain statutory criteria, policies, and principles

in Iowa Code sections 455B.262, 455B.264, 455B.275 and 455B.277. The specific

requirements in these rules must be met for approval of a project or activity in a flood

plain or floodway. Additionally, the project or activity must satisfy all of the statutory

criteria which Iowa Code sections 455B.262, 455B.264, 455B.275 and 455B.277 require

the department to consider. Where a project or activity will result in effects which the

department must by statute consider but which are not governed specifically by these

rules, the department shall review such effects on a case-by-case basis to determine

whether the project or activity meets the statutory criteria.

ITEM 10. Amend rule 567—72.1(455B) as follows:

567—72.1(455B) Bridges and road embankments. The following criteria shall

apply to the construction, operation, and maintenance of bridges and road embankments.

72.1(1) Bridges and road embankments affecting low damage potential areas. For

bridges and road embankments affecting floodway or flood plain areas having a low

flood damage potential, the following criteria will apply:

a. Backwater Q50. The maximum allowable backwater for Q50 and lesser floods

is limited to 0.75 foot.

b. a. Backwater Q100. The maximum allowable backwater for Q100 is limited to

1.5 feet.

c. b. Freeboard. The minimum freeboard for low superstructure horizontal bridge

members above Q50 is 3 feet unless a licensed engineer provides certification that the

bridge is designed to withstand the applicable effects of ice and the horizontal stream

loads and uplift forces associated with the Q100.

72.1(2) Bridges and road embankments affecting moderate damage potential

areas. For bridges and road embankments affecting floodway or flood plain areas

occupied by buildings or building complexes having a moderate flood damage potential,

the following criteria will apply:

a. The maximum allowable backwater for Q100 is limited to 1.0 foot.

b. The criteria specified in 72.1(1)“a” and “c.”

72.1(3) 72.1(2) Bridges and road embankments affecting high or maximum

damage potential development. For bridges and road embankments affecting floodway or

flood plain areas occupied by buildings or building complexes having a high or

maximum flood damage potential, the following criteria will apply:

a. Backwater Q100. Backwater effects are to be minimized for all stages which

affect maximum or high flood damage potential buildings or building complexes or for

all stages which would tend to reduce the level of protection of certain flood control

works, unless acceptable remedial measures are provided or such buildings are removed

or the uses relating to human occupancy are prohibited.

(1) The maximum allowable Q100 backwater for new bridges and road

embankments is 1.0 foot.

(2) The maximum allowable Q100 backwater for replacement bridges and

roadway embankments is the lesser of the following: Q100 backwater for the existing

bridge and road embankment or 1.0 foot.

(3) For a new bridge and road embankment located within a stream reach for

which the Federal Emergency Management Agency has published a detailed Flood

Insurance Study which includes a floodway, the backwater for Q100 shall not exceed the

surcharge associated with the delineation for the floodway at that location.

(4) In no case shall the Q100 backwater effects of a bridge or road embankment

reduce the existing level of protection provided by certain flood control works, unless

equivalent remedial measures are provided.

b. Freeboard. In no case shall the criteria specified in 72.1(1)“a” and “c” and

72.1(2)“a” be exceeded. The minimum freeboard for low superstructure horizontal bridge

members above Q50 is 3 feet unless a licensed engineer provides certification that the

bridge is designed to withstand the applicable effects of ice and the horizontal stream

loads and uplift forces associated with the Q100.

72.1(4) 72.1(3) Bridge and channel change. For bridges and culverts involving

channel changes on the floodway of any stream draining at the location of the channel

change between 10 and 100 square miles whereby either (i) more than a 500-foot length

of the existing channel is being altered or (ii) the length of existing channel being altered

is reduced by more than 25 percent, the maximum allowable backwater shall correspond

to the limits permitted in 567—72.1(1), 72.1(2), 72.1(3) or 72.1(5) 72.1(4) depending

upon the associated damage potential.

72.1(5) 72.1(4) Culverts. The maximum allowable backwater at culvert inlets

shall correspond to the limits permitted in 567—72.1(1), or 72.1(2), or 72.1(3) depending

upon the damage potential associated with the affected area. In the case of replacement

culverts, the backwater shall not exceed that created by the culvert or waterway crossing

being replaced or that specified in 72.1(1), or 72.1(2), or 72.1(3) depending upon the

associated damage potential, whichever is greater.

72.1(6) 72.1(5) Road embankments. The criteria listed in 567—72.11(455B) for

miscellaneous flood plain construction projects shall apply to road embankments located

on the flood plain but not crossing any stream or river channel.

72.1(7) 72.1(6) Temporary channel obstructions. Temporary stream crossings and

other temporary obstructions usually constructed, operated, and maintained during the

construction phase of another flood plain construction project shall meet the following

criteria:

a. Low flow. Said structures will provide for the passage of the prevailing flow in

the stream or river.

b. Flood flow. Said structure shall be designed to fail or otherwise operate in the

event of flooding so as to prevent premature overbank flow, or meet the backwater

criteria indicated in 567—72.1(1), or 72.1(2), or 72.1(3).

72.1(8) 72.1(7) Emergency. Repairs or temporary construction required to

maintain the operation of a bridge, roadgrade or culverts in time of emergency need not

be submitted for prior department approval. Plans of such emergency or temporary

construction shall be submitted to the department for review after the event causing the

emergency has passed.


72.5(1) Minimum protection levels. The minimum level of flood protection for a

building depends on the damage potential of the building and contents. “Maximum,” and

“high” and “moderate” damage potential classifications are defined in 567—Chapter 70.

Criteria for determining minimum levels of protection are as follows:

a. Buildings with maximum damage potential shall be protected to the level of a

flood equivalent to Q500 plus 1 foot. Determination of the elevation of the department

regional flood is recommended as an alternative to establish an appropriate level of

protection for a building which has maximum damage potential (see discussion of flood

frequencies and magnitudes in 567—subrule 75.2(1)).

b. Buildings with high damage potential shall be protected to the level of a flood

equivalent to Q100 plus 1 foot.

c. Buildings with moderate damage potential shall be protected to the level of a

flood equivalent to Q50.

d. c. Buildings adjacent to an impoundment shall be protected to the elevation of

the top of the dam unless the dam has adequate spillway capacity to discharge the flood

corresponding to the damage potential of the building at an elevation below the top of the

dam.

e. d. Buildings downstream from a dam shall be protected to a level established by

the department after due consideration of the hazards posed by the dam for buildings

downstream.

ITEM 12. Rescind rule 567—72.31(455B) and adopt the following new rule in

lieu thereof:

567—72.31(455B) Variance. A request for a waiver or variance to this chapter

shall be submitted in writing pursuant to 561—Chapter 10. The contents of a petition for

waiver or variance shall include information pursuant to 561—10.9(17A,455A).

_____________________________

Chuck Gipp, Director _____________________________

Date PUBLIC PARTICIPATION RESPONSIVENESS SUMMARY

FOR ARC 2629C

DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL SERVICES DIVISION

AUGUST 29, 2016

TABLE OF CONTENTS Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Comments in Support of Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Issue 1: Definitions for “high damage potential” and “low damage potential” . . . 4 Issue 2: Broaden Scope of Excavation Exemption . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Issue 3: Exempt Fill from Excavation in the Flood Plain . . . . . . . . . . . . . . . . . . . . . . 8 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Introduction This is a summary of and response to the comments received by the Department of Natural Resources regarding the Notice of Intended Action (NOIA) to amend Chapter 70, “Scope of Title—Definitions—Forms—Rules of Practice,” Chapter 71, “Flood Plain or Floodway Development—When Approval Is Required,” and Chapter 72, “Criteria for Approval,” Iowa Administrative Code. This document also contains recommendations for final action by the Environmental Protection Commission. The NOIA was published in the Iowa Administrative Bulletin Volume XXXIX, July 20, 2016. The Administrative Rules Review Committee (ARRC) took no action on the proposed rules at its August 5, 2016 meeting. The amendments will change the criteria for the construction of bridges, road embankments and culverts in a flood plain. Oftentimes, to construct bridges and other structures in a flood plain, the Iowa Department of Transportation (IDOT) and other contractors have had to apply for waivers or variances from the rules, a process which could be time-consuming and costly. In response to this concern, the rules have been reviewed and a determination made that certain portions of existing rules are redundant or unnecessary, and changes could be made that would allow for a higher percentage of compliance with rules. The amendments will reduce the need for these contractors to seek waivers and variances. Equally important, the amendments will not sacrifice public safety. The amendments add exemptions to the flood plain development permit requirements for certain activities, such as excavations installed for conservation practices, and for the installation of sign, utility poles and other similar structures. These exemptions were developed in cooperation with stakeholders such as electric utilities and the Natural Resources Conservation Service (NRCS). The amendments modify the waiver and variance provision in the flood plain rules so that the provision is consistent with the Iowa Code. The amendments make minor changes to Chapters 70, 71 and 72 to update definitions, references to Iowa Code sections, forms, and agency contact information. A public hearing was held on August 10, 2016. Representatives from the Iowa Farm Bureau Federation and the Iowa Drainage District Association were present. Formal comments were submitted by MidAmerican Energy, the Iowa Farm Bureau Federation and the Iowa Drainage District Association. In response to comments, clarifying revisions were made to the definitions of “high damage potential” and “low damage potential” in Chapter 70.

Comments in Support of Rule MidAmerican Energy provided a comment letter in support of the proposed amendments. An excerpt from the comment letter is as follows: MidAmerican has at least 53,000 power poles located within the preliminary flood hazard area. Replacement of poles for maintenance or emergency response activities typically includes removal of the existing pole and replacement along the same wire alignment resulting in no increase in obstruction in the flood hazard area. Enumeration of a specific exemption for these activities will help MidAmerican complete maintenance activities in a timely manner to help maintain and improve electric service reliability for our customers. Additionally, this exemption will help MidAmerican respond to emergency situations such as outages caused by extreme weather events. Current requirements for miscellaneous obstructions require completion of a determination checklist, which can sometimes add days of analysis and approval time before recovery work can begin. Issue 1: Definitions for “high damage potential” and “low damage potential” Iowa Farm Bureau Federation Comment: The proposed definitions of “high damage potential” and “low damage potential” were modified to incorporate structures that are currently defined as “moderate damage potential.” We do not object to what we understand is the intent of the definitions, but we request some clarification. Paragraph 2 of the definition of “high damage potential” includes a building “constructed of materials.” We believe that the intent of the definition is to include only those materials that would be significantly damaged by the inundation of flood waters, not all materials. The word “significant” is used to distinguish it from the term “minimal damage” in the “low damage potential” definition. For your consideration we suggest the following alternative wording to clarify the language and effectuate the department’s intent: 2. Industrial, commercial, agricultural, recreational and other similar buildings or building complexes constructed of materials that would be significantly damaged by the inundation of flood waters, or containing high-value equipment or contents that are not easily removed and would be damaged if inundated by flooding; or This suggested change and the next provides differentiation between the definitions of high and low damage potential. We also suggest some clarification to the definition of “low damage potential.” We support the exclusion of structures where the contents can be easily removed as the reverse of the language used to describe “high damage potential.” We suggest that the language used in the definition of “high damage potential” is more relevant in that the contents should be easily removed from the structure rather the the more nebulous term “temporary.” Farm equipment and most crops are easily removed in the case of a threat of flood water inundation. We suggest the replacement of the word “temporary” with the words “easily removed.” “Low damage potential” means all buildings, building complexes or flood plain use uses not defined as maximum, or high, or moderate damage potential. where such structures are designed in a manner that inundation by flood waters results in minimal damage to the structure and its contents. Such structures include but are not limited to the following: detached residential garages, sheds, park shelters, buildings used for temporary storage of equipment, or

crops, or other contents that can be easily removed, and buildings used as temporary shelter for livestock. With regard to livestock shelter, we understand that any structures which provide permanent housing for livestock are not exempted from the flood plain permit requirement. Buildings which house livestock indoors are not allowed in the 100 year flood plain and certain open feedlots are required to obtain flood plain permits. We believe that the rule would exempt those structures used by livestock for temporary relief from the weather elements or that are used for short-term livestock management purposes. If this is not the case, we ask that the language be clarified to reflect this intent. Iowa DNR Response: This is an important comment because it highlights the need for clarification of how and why a building itself and the use of a building is considered high damage potential versus low damage potential. A building and how it is used is considered high or low damage potential because of the “public damages” that would occur during a flood event. “Public damages” is already defined in the rules and means costs resulting from damage to roads and streets, sewers, water mains, other public utilities and public buildings; expenditures for emergency flood protection, evacuation and relief, rehabilitation and cleanup; losses due to interruption of utilities and transportation routes, and interruption of commerce and employment. Each building and its use whether industrial, commercial, agricultural or recreational has the potential for expenditures for emergency flood protection, evacuation of people, rehabilitation costs, cleanup costs and the costs related to interruption of commerce and employment. Therefore the department proposes to amend the definition of “high damage potential” by removing the descriptor “constructed of materials” and replacing it with “. . . which, if inundated by flooding would result in high public damages as determined by the department . . .” to mirror the wording used in 3. Public buildings and building complexes. In the definition for “low damage potential” the focus is on those buildings and their uses that would not sustain high “public damages” if inundated by flood waters. For example, a park shelter is a low damage potential building because of its open air design and the use is such that damage to the shelter would not result in expenditures for emergency flood protection, costs to evacuate the shelter, rehabilitation and cleanup costs, and no interruption of commerce and employment. The department agrees that “structures used by livestock for temporary relief from the weather elements or that are used for short-term livestock management purposes” would be considered “low damage potential.” Therefore the department proposes to amend the definition of “low damage potential” by changing the last part of the final sentence to “. . .park shelters, buildings used for storage of equipment or crops that can be easily removed, and buildings used as temporary shelter for livestock. Iowa DNR Recommendation: To ensure clarity of these definitions the department proposes the following amendments to the definitions of “high damage potential” and “low damage potential”.

“High damage potential” means the flood damage potential associated with habitable

residential buildings or industrial, commercial, or public buildings or building complexes of

which flooding would result in high public damages as determined by the department. the

following:

1. Habitable residential buildings and building complexes which include seasonal

residential buildings; or

2. Industrial, commercial, agricultural, recreational and other similar buildings or building

complexes, which, if inundated by flooding would result in high public damages as

determined by the department or that contain high-value equipment or contents that

are not easily removed; or

3. Public buildings or building complexes, which, if inundated by flooding, would result in

high public damages as determined by the department.

“Low damage potential” means all buildings, building complexes or flood plain use uses not

defined as maximum, or high, or moderate damage potential where such structures are

designed in a manner that inundation by flood waters results in minimal damage to the

structure and its contents. Such structures include but are not limited to the following:

detached residential garages, sheds, park shelters, buildings used for storage of equipment

or crops that can be easily removed, and buildings used as temporary shelter for livestock.

Issue 2: Broaden the scope of the excavation exemption Iowa Farm Bureau Federation Comment: Item 7 provides an exception for conservation practices installed or constructed in the flood plain of any river or stream draining more than 10 square miles if such practices are installed using NRCS standards. We support including an exception from flood plain permits for conservation practices that will improve soil and water quality with minimal flood plain impacts. Because of the availability of technical NRCS staff is limited and the additional expense involved in the NRCS programs, most conservation practices, such as buffers and grassed waterways, haven’t been installed utilizing these programs. A recent review of several common conservation practices in a few Iowa watersheds by the DNR demonstrates that farmers are installing more practices that NRCS program utilization indicates. Therefore we request a broader exclusion for conservation practices installed within 100 feet of the stream or river bank. We suggest the following new paragraph:

f. Excavations for conservation practices installed with 100 feet of the stream or river bank are exempt if all of the following criteria are met:

(1) The resulting spoil is removed from the flood plain or distributed on the adjoining land in a manner that does not impeded surface drainage; (2) The practices do not reduce the capacity of the flood plain; and (3) The practices will not result in water being temporarily or permanently stored above the natural ground line.

While the department has not seemed to require flood plain permits for such conservation practices in the past, item 7 raises a question of whether a permit is required or whether the department’s policy has changed. In the instances of creating buffers or grassed waterways, the cost of hiring an engineer to certify NRCS standards may exceed the cost of installing the practice. In order to lower regulatory barriers for these types of practices in rural areas, we encourage the department to exclude conservation practices regardless of whether the landowner utilizes the NRCS program and obtains engineering certification that NRCS standards were followed. Iowa DNR Response: Iowa Code 455B.277(9) states “that the commission shall establish, by rule, thresholds for dimensions and effects, and any structure, dam, obstruction, deposit, or excavation having smaller dimensions and effects than those established by the commission is not subject to regulation under this section. The thresholds shall be established so that only those structures, dam, obstruction, deposits, or excavations posing a significant threat to the well-being of the public and the environment are subject to regulation.” Because the term “conservation practice” is not defined in 567 – Chapter 70, the phrase “Excavations for conservation practices installed to meet or exceed the standards of the USDA Natural Resources Conservation Service (NRCS) Field Office Technical Guide” was used in the rule. This statement implies a defined set of conservation practices where a determination has been made that excavations for conservation practices that meet or exceed the NRCS technical guidance would not pose a significant threat to the well-being of the public and the environment. [455B.275(9)] The Iowa Farm Bureau Federation has requested an exemption for excavations for all conservation practices, not just those that meet or exceed the standards of the NRCS Field Office Technical Guide. Broadening this exemption to all conservation practices would introduce more ambiguity into the rule in that there is no definition for “all conservation practices.” Subsequently the department does not recommend adding an exemption for all conservation practices since it may potentially exempt many undefined practices and would not be a logical outgrowth of this rulemaking. Iowa DNR Recommendation: The department welcomes the opportunity to work with all interested parties in the future, to define “all conservation practices” and evaluate the possibility of a broader application of this exemption. No changes to the NOIA regarding this issue are proposed. Issue 3: Allow spoil from excavation in the flood plain without a permit Iowa Farm Bureau Federation Comment: Further, within item 7, we support a change to paragraph “e” to address the concern raised by the Iowa Drainage District Association and Bolton & Menk, Inc. engineering firm. Removing soil from the excavation area is not favored by the landowner as it is soil that will likely be used in the farming operation. However, farms

would not want mounded soil to cause new ponding in the adjacent farm field that wasn’t there prior to the excavation. We recommend the following amendment to proposed ruled 71.11”3”:

e. Excavations for conservations practices installed to meet or exceed the standards of the USDA Natural Resources Conservation Service (NRCS) Field Office Technical Guide are exempt if all of the following criteria are met:

(1) The resulting spoil is removed from the flood plain, or distributed on the adjoin [sic] land in a manner that does not impede surface drainage;

(2) The practices do not reduce the capacity of the flood plain; and (3) The practices will not result in water being temporarily or permanently stored above the

natural ground line. Iowa Drainage District Association Comment: Bolton & Menk, Inc. annually provides engineering services to many drainage districts in several Iowa counties. We have concerns regarding the above-referenced section as it may be applied to common drainage district work activities in flood plains. Many drainage district facilities are designed by engineers and constructed to meet or succeed NRCS standards and these projects would be eligible for the exemption from permitting that is provided in the proposed rule. The common conservation practices for which NRCS standards exist include waterways, surface drains, diversions, open ditches, wetlands and subsurface drains. Our concerns are with the language requiring that all of the excavated spoil (extra dirt) be removed from the floodplain in order to qualify for the exemption. We believe this is an overly burdensome requirement that reasonably should be changed to allow for placement of extra excavation in the floodplain which would have no material impact upon flood flows. All of the conservation practices listed produce excess excavation which must be disposed of. The standard care practice would be to place the excess excavation in the floodplain in non-intrusive areas. For example, slightly mounding back fill over a tile drain trench is a standard practice which would not be eligible for the conservation exemption cited because of the mounded excess excavation. The standard care practice of wasting excavation from a waterway in very shallow lifts on the adjoin land would also run afoul of the rule language. The cost to needlessly transport fill out of the floodplain will often negate the use of this proposed rule and the advantages to the public intended from it. Pursuit of a permit which would then allow for the efficient wasting of excess excavation near the work will too often be the better choice, economically. The rule does not add an additional requirement, but it does make an attempted accommodation unworkable and that indirectly costs everyone who cannot benefit from the agency’s good intentions.

Iowa DNR Response: The thresholds for determining when a flood plain permit is required are laid out in 567 - Chapter 71 by project type. Often an application for a permit will contain a scope of work that utilizes more than one of the project types listed in 567-Chapter 71. For instance, most excavation projects that fall under 567-71.11 also have a component of the project that falls under 567 –71.12 Miscellaneous structures, obstructions, or deposits not otherwise provided for in other rules. Therefore in determining if the project needs a flood plain permit, the department looks at the thresholds in both rules; 71.11 and 71.12.

Excavation and fill of the floodplain are subject to requirements to preserve the natural and traditional character of the land and waterway. The department agrees with the idea that potential applicants want to put the resulting spoil from an excavation on their adjoining land. 567 - 71.12 can be applied in this circumstance. If placement of the spoil or fill falls below the thresholds listed in 567-71.12 then a flood plain construction permit is not required. For that reason, 567 - 71.12 already gives applicants the flexibility requested by the Iowa Farm Bureau Federation and the Iowa Drainage District Association to spread a limited amount of spoil on their property without needing to gain a flood plain construction permit. The thresholds for 567-71.12 are as follows:

567-71.12(455B) Miscellaneous structures, obstruction, or deposits not otherwise provided for in other rules. Approval by the department for construction, operation, and maintenance of miscellaneous structures, obstructions, or deposits, shall be required in the following instances.

71.12(1) Rural areas. In rural areas, any miscellaneous structures, obstructions, or deposits on the floodway or flood plain of any river or stream draining more than 10 square miles where such works obstruct more than 3 percent of the cross-sectional area of the stream channel at bankfull stage or where such works obstruct more than 15 percent of the total cross-sectional area of the flood plain at any stage. In determining a 15 percent obstruction of the flood plain, the concept of equal and opposite conveyance as defined in 567 – Chapter 70 shall apply. 71.12(2) Urban areas. In urban areas, miscellaneous structures, obstructions or deposits on the floodway or flood plains of any river or stream draining more than 2 square miles.

If by distributing the spoil, the thresholds are exceeded, review of the project and issuance of a permit is required to ensure that equal and opposite conveyance is maintained. For that reason, the department does not recommend a change to the exemption proposed in the NOIA for 567-71.11. Iowa DNR Recommendation: The department does not recommend changes to Item 7 as posted in the Notice of Intended Action. Conclusion After full consideration of the public comments, the department recommends the revisions to the definitions of “high damage potential” and “low damage potential” published NOIA as described above.

Appendix Following is a list of of those that commented on the proposed rule during the public comment period. Jesse Leckband, Senior Environmental Analyst, MidAmerican Energy Christina Gruenhagen, Government Relations Counsel, Iowa Farm Bureau Federation Douglas L. Struyk and James W. Carney, Carney Appleby, on behalf of the Iowa Drainage District Association

LITIGATION REPORT

Prepared by: Kelli Book Date: September 20, 2016

I. Summary The DNR seeks referral of J.S. Properties, L.L.C. (J.S. Properties) and Terry Anderson to the Attorney General’s Office for appropriate enforcement action, due to asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) violations in connection with the demolition of an apartment building in Oskaloosa, Iowa. This referral includes the following violations: failure conduct a thorough inspection, failure to notify DNR of the demolition, failure to remove all regulated asbestos containing material prior to demolition, failure to keep all regulated asbestos containing material adequately wet, failure to employ a trained asbestos supervisor during demolition, and failure to seal all asbestos containing material in leak-tight containers. No asbestos abatement occurred prior to J.S. Properties and Terry Anderson’s demolition of its apartment building in Oskaloosa, even though a 2014 inspection conducted by the City of Oskaloosa indicated there was over 10,000 square feet of asbestos containing material in the apartment building. In addition, during DNR’s inspection it was discovered that dry asbestos containing material on pipe debris had been left at the site after the cleanup was to have occurred. II. Alleged Violators J.S. Properties and Terry Anderson 2010 Suffolk Road Oskaloosa, Iowa 52577 III. Description of Facility J.S. Properties owns a building located 517 B Avenue West in Oskaloosa, Iowa. The building is a 15,000 square foot two story building built in 1852. The building had recently been used as a five unit apartment building. J.S. Properties purchased the building in October 2015. IV. Alleged Violations (including facts and applicable law) Asbestos is a known cause of lung disease, asbestosis, and cancer, specifically mesothelioma. Asbestos is a hazardous air pollutant. Failure to follow proper removal and disposal techniques of the regulated asbestos containing material creates an environmental hazard to the workers and general public through the likely release of asbestos fibers. Proper removal and disposal of asbestos containing material is required pursuant to the Clean Air Act’s asbestos NESHAP.

LITIGATION REPORT for J.S. PROPERTIES, L.L.C and TERRY ANDERSON

July 2016 EPC MEETING

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A. FACTS

On November 11, 2015, DNR received a complaint from a neighbor next to J.S. Properties’ building. The complainant stated that the building was being demolished and dust was blowing around. The complainant believed the building had asbestos in it. Reid Bermel, DNR environmental specialist, contacted Mr. Anderson and verified that he was demolishing the building. On November 12, 2016, Tom Wuehr, DNR environmental specialist, contacted Mr. Anderson to request that the demolition stop. Mr. Anderson stated he was conducting the demolition on his own. He said he used some of his own equipment and rented equipment to demolish the building. He indicated that he had already demolished most of the building. Mr. Anderson said that a City of Oskaloosa employee had taken a look at the building prior to the demolition. Mr. Anderson indicated the City of Oskaloosa had previously completed an asbestos inspection and there was virtually no asbestos in the building. No asbestos containing material had been abated prior to the demolition. Mr. Anderson stated Mr. Wuehr could obtain the inspection report from the City of Oskaloosa. Mr. Wuehr requested Mr. Anderson hire a site supervisor and keep water on the remaining debris until it could be taken to the landfill. Mr. Anderson agreed to do this. A significant portion of the building had already been taken to the landfill as regular demolition debris.

Mr. Wuehr contacted the City of Oskaloosa for the inspection report and it was forwarded to Mr. Wuehr. Terracon Consultants, Inc. completed an inspection in July of 2014. The inspection was done for the City of Oskaloosa and was not conducted as part of this demolition project. The report indicated regulated asbestos containing material throughout the building, ranging from 1.2% Chrysotile asbestos to 91.5% Chrysotile asbestos. The report stated that the “materials identified to contain asbestos greater than 1% should be removed by a qualified and Iowa-certified asbestos abatement firm.” The report indicated the building contained over 10,000 square feet of regulated asbestos containing material (material containing more than 1% asbestos).

On November 19, 2015, Mr. Wuehr conducted an inspection of the building site. The building had been removed; however, Mr. Wuehr discovered damaged steam pipes with air cell insulation remaining on the pipe on the ground in the area where the building had been. The insulation was dry and friable. He collected a sample of the insulation. The laboratory sample indicated 40% Chrysotile asbestos.



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Steam pipe with air cell insulation remaining at the site.

Air cell insulation sample taken. Sample contained 40 % Chrysotile asbestos. The 2014 inspection report indicated this type of material contained up to 91.5% Chrysotile asbestos. On December 1, 2015, DNR issued a Notice of Violation letter to Mr. Anderson for the asbestos violations discovered during Mr. Wuehr’s investigation. The letter informed Mr. Anderson that further enforcement may be pursued.



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B. APPLICABLE LAW

Iowa Code section 455B.133 provides for the Environmental Protection Commission (EPC) to establish rules governing the quality of air and emission standards. Pursuant to Iowa Code section 455B.133, 567 Iowa Administrative Code (IAC) section 23.1(3) was established, which adopts by reference the federal regulations regarding asbestos removal. The United States Environmental Protection Agency has delegated to the State of Iowa the authority to implement and enforce the demolition and renovation portions of the federal asbestos NESHAP, found at 40 CFR part 61, subpart M. 40 CFR section 61.145(a) specifies that the owner or operator of a demolition or renovation activity shall thoroughly inspect a regulated facility for the presence of asbestos prior to the commencement of demolition or renovation. Mr. Anderson stated that he did not have the building inspected for asbestos prior to the demolition project. The above facts indicate violations of this provision.

40 CFR section 61.145(b)(1) requires written notification of demolition to be submitted to the DNR prior to beginning renovation. The specific requirements for this notification are contained in the subsection. The DNR has no evidence that a notification was ever submitted prior to the demolition of the building. The above facts indicate violations of this provision.

40 CFR section 61.145(c) details the procedures for asbestos emission control and states that each owner or operator to whom the provisions apply shall comply with the procedures. The facts in this case indicate that J.S Properties and Mr. Anderson were not in compliance with these provisions when the demolition occurred. 40 CFR 61.145(c)(1) provides that all regulated asbestos containing material shall be removed from a regulated facility before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal. No asbestos abatement occurred prior to the demolition project, even though a 2014 inspection conducted by the City of Oskaloosa indicated there were over 10,000 square feet of asbestos containing material in the building. During Mr. Wuehr’s inspection he observed dry asbestos containing material on pipe debris left at the site after the cleanup was to have occurred. The facts in this case indicate violations of this provision.

40 CFR 61.145(c)(6)(i) provides that all regulated asbestos containing material, including material that has been removed or stripped, shall be adequately wet and shall remain wet until collected and contained. Proper asbestos abatement did not occur prior to the demolition project, even though a 2014 inspection conducted by the City of Oskaloosa indicated there were over



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10,000 square feet of asbestos containing material in the building. During Mr. Wuehr’s inspection he observed dry asbestos containing material on pipe debris left at the site after the cleanup was to have occurred. The facts in this case indicate violations of this provision. 40 CFR 61.145(c)(8) provides that effective one year after promulgation of this regulation, no regulated asbestos containing material shall be stripped, removed, or otherwise handled or disturbed at a facility regulated by this section unless at least one on-site representative, such as a foreman or management level person or other authorized representative, trained in the provisions of this regulation and the means of complying with them, is present. The facts in this case indicate there was not a trained supervisor on site during the demolition of the building. The above facts indicate noncompliance with this provision. 40 CFR 61.150 contains standards for asbestos waste disposal for demolition and renovation operations. Specifically, 40 CFR 61.150(a)(1)(iii) provides that all asbestos containing waste materials, while wet, shall be sealed in leak-tight containers or wrapping. During Mr. Wuehr’s inspection he observed dry asbestos containing material on pipe debris left at the site after the cleanup was to have occurred. The facts in this case indicate violations of this provision. V. Witnesses The following Air Quality Bureau staff person will be a potential witness: Tom Wuehr. Mr. Wuehr will be available during the June 2016 EPC meeting to answer additional questions.

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LITIGATION REPORT

Prepared by: Anne Preziosi Date: August 29, 2016

I. Executive Summary Sometime prior to 2006, Swiss Valley Farms Cooperative (Swiss Valley) removed a baghouse from a 1962 whey dryer located at its Luana, Iowa, facility. Swiss Valley removed the baghouse pollution control equipment without informing DNR and without submitting the required air quality construction permit modification application.1 Stack testing of the whey dryer conducted by Swiss Valley in May 2013 showed that particulate emissions from the whey dryer were more than twice the permitted limit. Prior to issuance of the March 1981 permit requiring the baghouse installation, particulate emissions from the whey dryer had been approximately three times the allowable emissions limit, according to a June 1980 stack test.2 The March 1981 air quality construction permit issued by DNR for the whey dryer required that air quality control equipment in the form of a baghouse be installed on the whey dryer. Following installation of the baghouse control equipment, a July 1981 stack test showed that the whey dryer particulate emissions complied with applicable emission limits. DNR discovered the baghouse removal during an April 2013 field office inspection. It is not clear when the baghouse was removed. DNR personnel visiting the site on February 27, 2014, were told by Swiss Valley personnel that the baghouse may have been disconnected from the dryer as far back as 2004. The whey dryer was manufactured in 1962 and was purchased by Swiss Valley as used equipment. Swiss Valley made repairs to the metal seams on the dryer to ensure that it could remain operational. According to Swiss Valley, the life expectancy for a whey dryer of this type is approximately 25 years, so that this whey dryer’s useful life would have ended in 1987. However, Swiss Valley continues to use the dryer, and Swiss Valley continues to use it without control equipment. The picture to the right, taken by DNR on May 25, 2016, shows that whey product in the form of particulate is coming out of the dryer and falling on the dryer stack and the 1 Swiss Valley received an air quality construction permit for this baghouse in March 1981. A permit modification application would have allowed DNR to evaluate the air quality consequences of the baghouse removal. 2 Due to the amount of particulate emissions in excess of the permitted limit, DNR’s predecessor (the Iowa Department of Environmental Quality) discussed with the company the issuance of an administrative order requiring actions to install appropriate control equipment. The Luana facility, purchased by the company now known as Swiss Valley in 1967, operated in the early 1980’s under the name “Mississippi Valley Milk Producers Association.”

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surrounding surfaces. According to Swiss Valley, several vendors have told Swiss Valley that the dryer is too old to retrofit with a baghouse. One vendor recommended installation of a new dryer, rather than attempting to retrofit controls on the existing dryer.3 Since the 2013 DNR inspection and discovery of the baghouse removal, discussions between DNR and Swiss Valley have resulted in attempts by Swiss Valley to address the continuing particulate emissions violations with a retrofit plan. A November 30, 2015, air quality construction permit allowed Swiss Valley to replace the whey dryer stack fan with a larger fan, to assist the Luana facility in meeting permitted emission limits. Swiss Valley has attempted to show compliance with the November 2015 permitted particulate emissions limits during a series of stack tests, both observed and unobserved4, but Swiss Valley has not been able to show compliance with all required particulate emissions limits. Consistent instances of breakdowns and adjustments to the equipment during stack testing in 2016 indicate that the dryer cannot function properly. The DNR seeks referral of Swiss Valley to the Attorney General’s Office for appropriate enforcement action. The referral is appropriate in large part due to the economic benefit this facility has received in failing to comply with the state’s air quality laws for at least ten years. II. Alleged Violator and Description of Facility The legal name of the alleged violator is Swiss Valley Farms Cooperative. According to its website, located at www.swissvalley.com, Swiss Valley was founded in 1958, and is owned and controlled by approximately 575 dairy producers. Its annual sales are over $400 million. Swiss Valley headquarters are located in Davenport, Iowa. Also according to the Swiss Valley website, the Luana, Iowa, Swiss Valley cheese manufacturing facility was acquired by the company in 1967, and was renovated in 1971 to produce specialty cheese. One of the sources of emissions to the outside atmosphere at the Luana plant is the whey dryer. Swiss Valley is conducting a $21 million dollar project to expand the facility, installing new equipment and warehouse space. The expansion is projected to be ready for production in late 2016 or early 2017. The project does not address the whey dryer issues. III. Alleged Violations (including facts and applicable law)

3 Swiss Valley’s assertions about the dryer, its life expectancy, and vendor comments are contained in a letter from Swiss Valley to DNR, dated July 28, 2014. 4 DNR is allowed to observe compliance stack tests according to the rules contained in 567 Iowa Administrative Code chapter 25.

http://www.swissvalley.com/

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History of Whey Dryer Leading to Baghouse Requirement On May 2, 1980, the Luana, Iowa, facility, then operating under the name

“Mississippi Valley Milk Producers Association”,5 was inspected by the Iowa Department of Environmental Quality’s (DEQ) Regional Office.6 During the inspection, it was discovered that the whey dryer and its associated control equipment, which was a cyclone separator at that time, had been modified without first obtaining an air quality construction permit, as required.

A May 22, 1980, letter was sent to the Mississippi Valley Milk Producers

Association, requiring submittal of a permit application for the modified whey dryer and control equipment. The May 1980 letter also required that emissions testing occur at the facility to determine compliance of the modified equipment and control equipment with emission standards. A June 10, 1980, stack test of the whey dryer was conducted.

As-built construction Permit No. 80-A-123 was issued for the whey dryer on July 30, 1980. This permit acknowledged the already-installed cyclone separator control equipment for the whey dryer.

The DEQ received the June 10, 1980, stack test results on September 18, 1980.

The stack test showed that the particulate emissions from the whey dryer were 23 pounds per hour, which was almost three times the allowable amount of emissions, which was 8.4 pounds per hour.7 A November 18, 1980, letter from DEQ informed the facility of the violation.

Extensive discussions between the parties occurred beginning in November 1980, including the proposal by DEQ of the issuance of an administrative order that would have included an emission reduction plan designed to allow the facility to achieve compliance with the applicable emission limits, and an additional requirement that the facility would provide to DEQ an alternative plan by a date certain if the first plan did not result in compliance. These discussions did not ultimately result in the 5 The company known today as Swiss Valley Farms Cooperative acquired the Luana, Iowa, facility in 1967, according to the Swiss Valley website. However, the Swiss Valley Farms brand name was first adopted on packaging in 1977, and the cooperative officially changed its name to Swiss Valley in 1981. In 1980 and 1981, the company was operating the Luana, Iowa, facility under the name “Mississippi Valley Milk Producers Association.” 6 The DEQ was the predecessor of the Iowa Department of Natural Resources. 7 Following is an explanation of the 1980 permitting and stack testing that includes the Process Weight Rate information that was the applicable law at the time. Process weight rate limits are emission limits based upon a specific throughput, and therefore they vary dependent upon actual production occurring at the time of the test. The June 10, 1980, stack test showed that the particulate emissions from the whey dryer were 23 pounds per hour. The limit of allowable emissions based upon the average wet process weight rate of 5,565 pounds per hour during the stack test was 8.14 pounds per hour. The construction permit issued on July 30, 1980, and requiring the cyclone separator control equipment for the whey dryer, also applied the Process Weight Rate to the process. The permit contained an allowable emission rate of 5.7 pounds per hour particulate, based on a rated capacity of 3,250 pounds per hour. When DNR received the September 18, 1980, stack test report for the June 10, 1980, stack testing of the whey dryer and cyclone separator control equipment, the reported emissions did not show compliance with the allowable emission rate of 8.14 pounds per hour based upon an average process weight rate of 5,565 pounds per hour during the stack test. A stack test was conducted on July 7, 1981, following issuance of the March 1981 permit for the whey dryer and baghouse control equipment. The tested emission rate was 8.4 pounds of particulate, which was less than the allowable permitted rate of 8.6 pounds per hour based on the average process weight rate of 5,690 pounds per hour during the stack test.

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issuance of an order, but on March 16, 1981, DEQ issued a supplemental permit (Permit No. 80-A-123-S1) for the addition of a baghouse to the whey dryer. The permit required stack testing of the whey dryer once the baghouse was installed.

A stack test of the whey dryer with the newly-installed baghouse occurred on

July 7, 1981. In a September 15, 1981, letter, DEQ informed the facility that the whey dryer was in compliance with its permitted emission limits. The tested emission rate was 8.4 pounds per hour of particulate. The allowable permitted rate was 8.6 pounds per hour of particulate. As a result of this small margin between the test results and the permitted limit, the letter also warned the facility that:

“Acceptance of this test report doesn’t relieve (the facility) of any responsibility for operating and maintaining this source in compliance. A special effort is warranted in the subject case because of the small compliance margin.” DNR Discovery of Baghouse Removal

On April 24, 2013, DNR Field Office 1 completed an inspection of the Swiss

Valley Luana facility. During the inspection, Field Office 1 personnel recommended that Swiss Valley contact the DNR Air Quality Bureau.

On May 2, 2013, DNR Air Quality Construction Permit Engineer John Curtin sent an email to Ed Seutter of Swiss Valley, summarizing a conversation during which Mr. Seutter had explained to Mr. Curtin that there was no baghouse on the whey dryer, and that the construction permit would, therefore, need to be modified.

On October 28, 2013, DNR received a construction permit application from Swiss Valley; however, the application accounted only for the particulate emissions due to the combustion of natural gas from the whey dryer. Swiss Valley stated that an unobserved stack test of the whey dryer was conducted in May 2013, resulting in particulate emissions from the whey dryer of 19.22 pounds per hour. In a February 3, 2014, email to DNR, Swiss Valley stated that the baghouse had been removed in approximately 2006.

On February 27, 2014, representatives of the DNR Air Quality Bureau visited the Swiss Valley Luana facility. While at the facility, one of the Swiss Valley employees recalled that the baghouse was not connected to the dryer when he began work at the facility in 2004. The space where the baghouse had been located had been re-allocated to another use.

Following the site visit, on March 14, 2014, the DNR Air Quality Bureau issued a

Letter of Non-Compliance to Swiss Valley for failure to modify the whey dryer construction permit prior to removing the baghouse and exceeding the permitted particulate matter general emission rate. The March 14, 2014, letter required Swiss

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Valley to submit a plan to DNR by April 21, 2014, describing how the Luana facility would be returned to compliance.

DNR-Swiss Valley Discussions since April 2014

An April 18, 2014, letter from Swiss Valley to DNR described a plan for return to

compliance by installing control equipment. Following receipt of that letter, the DNR Air Quality Bureau recommended that Swiss Valley withdraw its October 28, 2013, construction permit application and resubmit a new application that would reflect Swiss Valley’s newly proposed compliance plan. DNR requested that Swiss Valley submit air quality dispersion modeling and the new construction permit application by July 31, 2014. DNR further requested that the control equipment be installed within 120 days of permit issuance. Swiss Valley indicated on May 12, 2014, that it agreed to comply with DNR’s request.

On May 12, 2014, Swiss Valley withdrew the October 28, 2013, construction permit application (DNR Construction Permit Project 13-424).

On July 14, 2014, Swiss Valley requested a conference call with the DNR Air Quality Bureau to discuss its compliance plan. DNR requested that Swiss Valley submit its proposed amendments to the compliance plan, in writing, to DNR by July 31, 2014.

On July 28, 2014, Swiss Valley submitted a written proposed amendment to its compliance plan. Swiss Valley stated that the whey dryer was constructed in 1962 and that whey dryers typically have a life expectancy of 25 years. Swiss Valley further explained that a new dryer would cost approximately $6 million to $8 million dollars. Finally, Swiss Valley explained that the whey produced at the Luana facility is a desirable, specialized whey and generates a substantial profit. Swiss Valley stated in its July 2014, letter that quarterly updates would be provided to DNR regarding plans to return the whey dryer to compliance.

On November 24, 2014, DNR and Swiss Valley met to discuss the status of Swiss Valley’s compliance plan. At that meeting, DNR requested that an updated plan and schedule be submitted by the first week in January 2015. On December 29, 2014, Swiss Valley requested an extension until January 19, 2015, and DNR agreed to postpone the submission deadline until January 23, 2015. On January 16, 2015, Swiss Valley informed DNR that additional information regarding a compliance plan would be submitted to DNR by mid-February 2015.

On April 13, 2015, Swiss Valley submitted to DNR information about a plan to expand the Luana facility. The plan included facility expansion to include a refrigerated warehouse and distribution area. The plan stated the Luana facility would continue to produce cheese while the new equipment was installed, and that the new production equipment would become operational by April 2016. However, the expansion plan did

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not address the whey dryer compliance issues. DNR responded on April 14, 2015, requesting information regarding a compliance plan.

In May 2016, a newspaper article explained that Swiss Valley announced in

November 2014 a planned $21 million dollar expansion of its facility. The article included information that the 49,000-square-foot expansion project centers around improvement of the cheese manufacturing operating equipment and will allow room for new equipment and additional warehouse space. The extra production allowed by the expansion is projected to begin in late 2016 or early 2017.

Since June 2015, DNR has attempted to work with Swiss Valley to agree to the

language of an Administrative Consent Order that would contain a plan for Swiss Valley to come into compliance with air quality requirements and permit conditions. DNR sent the first draft Administrative Consent Order to Swiss Valley on June 22, 2015. DNR proposed that by August 1, 2015, Swiss Valley should submit to DNR a compliance plan for the Luana facility, and permit applications that would allow the facility to achieve compliance with all applicable air quality requirements. This draft order also proposed that Swiss Valley cease operation of the Luana whey dryer by September 1, 2015.

DNR and Swiss Valley met in July, August, September, and October 2015 to work through technical and compliance issues. Following these discussions, Swiss Valley submitted a permit application for retrofit of the whey dryer.

On November 30, 2015, DNR issued Air Quality Construction Permit No. 80-A-

123-S2 for the whey dryer, fluidized bed system, and pneumatic packaging (Emission Units 4a, 4b, and 4c, and Emission Point 4). As stated above, the original whey dryer permit, Permit No. 80-A-123, was issued on July 30, 1980; and Permit No. 80-A-123-S1 was issued on March 16, 1981, adding the requirement for a baghouse. The baghouse, as stated above, was later removed. Permit No. 80-A-123-S2 requires that the whey dryer stack fan be replaced with a larger fan, and that construction be completed by March 15, 2016.

DNR sent a second draft administrative consent order to Swiss Valley on February 15, 2016. This draft consent order required that Swiss Valley complete the whey dryer retrofit permitted in November 2015 by no later than March 15, 2016. This draft consent order also would have required that if the modifications to the whey dryer set out in the November 2015 permit did not result in compliance with applicable air quality requirements and permits conditions, then Swiss Valley would submit to DNR by no later than June 30, 2016, a written compliance plan describing alternative ways to achieve compliance. If this draft consent order had been signed, it would have provided for a plan to move forward if the solution presented by Air Quality Construction Permit No. 80-A-123-S2 for the whey spray dryer did not bring Swiss Valley back into compliance. However, DNR and Swiss Valley were not able to reach an agreement regarding a consent order. The consent order would have reserved the option for the Attorney General to pursue action against Swiss Valley for the economic benefit

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realized for the unauthorized removal of emission control equipment and the failure to comply with emission limits for an extended period of time.

On February 26, 2016, Swiss Valley informed DNR that the whey dryer retrofit

was complete. According to the whey dryer construction permit, stack testing is required to determine compliance with three separate particulate matter emission limits – PM, PM10, and PM2.5. According to the permit, the stack testing was required to be conducted by May 25, 2016; and the deadline for submission of stack test results was July 5, 2016.

Stack test Issues As stated above, the whey dryer was required by the November 2015

construction permit (Permit No. 80-A-123-S2) to be stack tested by May 25, 2016, in order to demonstrate compliance with PM, PM10, and PM2.5 emission limits. Below is a copy of the relevant portions of Permit No. 80-A-123-S2, Condition 12, containing the required stack testing for PM, PM10, and PM2.5.

Pollutant Test Run Time Test Method PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202 PM2.5 1 hour 40 CFR 51, Appendix M, 201A with 202

On May 23, 2016, Swiss Valley informed DNR that it had become aware of

conditions that would prevent testing for two of the three particulate matter limits. DNR informed Swiss Valley to conduct the testing that was possible, and on May 25, Swiss Valley conducted stack testing for one of the three particulate matter emission limits. DNR informed Swiss Valley that if, prior to the stack test report deadline of July 5, 2016, Swiss Valley conducted more testing using Methods 201A and 202, then DNR could use those results to determine compliance with PM10 and PM2.5 emission limits. Swiss Valley subsequently informed DNR that physical adjustments to the plant to allow the additional stack testing were costly. According to Swiss Valley’s consultant, in May Swiss Valley was considering installing a baghouse on the whey dryer rather than conducting the remainder of the required stack testing.

Swiss Valley did conduct partial testing on May 25, 2016. Swiss Valley conducted additional stack testing on June 30, 2016.

Test reports for testing that occurred on May 25, 2016, and June 30, 2016, were

received by DNR on July 18 and 19, 2016.

A summary of the stack test results is contained in the following table.

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Source Test Date Pollutant Result Limit

Whey Dryer EP 4 May 25, 2016

May 25, 2016* PM N/A 0.1 gr/dscf

Whey Dryer EP 4 June 30, 2016

June 30, 2016** PM PM10 PM2.5

N/A 8.68 lb/hr

N/A

0.1 gr/dscf 19.0 lb/hr

3.5 lb/hr *Method 5/202 **Method 201A/202

Stack testing for PM occurred on May 25, 2016. Due to the inability of the facility to comply with testing requirements for the other two pollutants, testing was not conducted on that date for PM2.5 and PM10. Further, inconsistent practices during and following the May 25, 2016, test event, provided evidence that the May 2016 demonstration of compliance with PM was not representative of normal operations and, therefore, the testing must be redone.

The June 30, 2016, testing was unacceptable for showing compliance with the

PM2.5 emission limit. Method 201A requires that PM2.5 cut point be greater than 2.25 microns and less than 2.75 microns. The PM2.5 cut points for each run did not meet the minimum cut point requirement.

The June 30, 2016, testing was unacceptable for showing compliance with the total PM emission limit. Total PM may be tested by using Method 201A if isokinetic rates are maintained between 90%-110%. Several points during the runs were outside this range and run 3 averaged 111%.

Consistent instances of breakdowns and adjustments to the equipment during stack

testing in 2016 indicate that the dryer cannot function properly. During the DNR-observed testing on May 25, DNR was informed that a breakdown of the system being tested occurred when the fan to the cyclone shut down. This occurred at some point during the second of the three required test runs. During run one of the June 30 testing, a process malfunction occurred and the testing was halted for about an hour. Opacity increased significantly, apparently as a result of the breakdown conditions. During the unobserved testing that Swiss Valley conducted on June 9, 2016, the system broke down for an hour and ten minutes during run three.

Further issues with the June 2016 stack testing complicated the process. First, the

June 2016 testing was not conducted at Maximum Rated Capacity, as required. Section 12 of Construction Permit 80-A-123-S2 requires that the source be tested at the maximum continuous output as rated by the manufacturer. The source was operated at 6030 lb/hr on June 30 and 6000 lb/hr on May 25, while the rated capacity is 6700 lb/hr.8 Future testing should be conducted at the rated capacity. However, if testing at less 8 For tests conducted at less than the rated capacity, a linear extrapolation may be applied to emission results to predict compliance at the maximum rated capacity. Applying a linear extrapolation to the June 30, 2016, PM10 results predicts compliance at the maximum rated capacity of 6700 lb/hr.

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than maximum rated capacity does not predict compliance, then facilities can retest at the maximum rated capacity or establish enforceable production limits based on the most recent compliance test.

Also, the report for the June 30, 2016, testing was missing required information needed to evaluate the test results. While on-site for testing on June 30, 2016, a Swiss Valley representative indicated to IDNR observers that the pressure drop across the cyclones was being monitored, as well as the set point for fan speed of the cyclone. DNR requested that Swiss Valley Farms record these parameters during the testing and submit the results with the test report. The fan speed of the cyclone and the pressure drop across the cyclones was not included with the test report. As requested by DNR, Swiss Valley submitted a copy of the pressure drop and fan speed data from the June 30, 2016, test event. In the future, Swiss Valley will need to record and submit these parameters to DNR along with testing conducted on the whey dryer, to ensure that conditions during testing are not altered once the tests are completed and are representative for normal operation of the whey dryer.

Due to the numerous issues with the stack testing, an August 2, 2016, Letter of Non-compliance was sent to Swiss Valley following review of the testing reports.

As of the date of this Litigation Report, Swiss Valley Farms still must conduct a retest to show compliance with the PM2.5 and PM emission limits. In order to ensure that conditions during the upcoming testing are similar to conditions during the June 30, 2016, testing, the DNR is requiring the dryer clean-out that Swiss Valley performs on a routine basis to be conducted within 2 days prior to the scheduled test date.

Swiss Valley Farms has scheduled a compliance test with the IDNR on August 29, 2016. Prior to the testing, DNR has required that the test protocol include the date when clean-out of the dryer will be performed prior to testing, the anticipated production rate, and the set point for the fan speed during testing.

Applicable Law

Iowa Code section 455B.133 provides for the Environmental Protection

Commission (Commission) to establish rules governing the quality of air and emission standards. The Commission has adopted 567 (IAC) chapters 20-35 relating to air quality.

567 IAC 22.1(1) provides that unless exempted in subrule 22.1(2) or to meet the

parameters established in paragraph “c” of this subrule, no person shall construct, install, reconstruct or alter any equipment, control equipment or anaerobic lagoon without first obtaining a construction permit or permit pursuant to rule 567—22.8(455B), or permits required pursuant to rules 567—22.4(455B), 567—22.5(455B), 567—31.3(455B), and 567—33.3(455B) as required in this subrule. 567 IAC 22.3(3) provides that a construction permit may be issued subject to conditions which shall be specified in writing, and that such conditions may include emission limits, stack testing

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requirements, and recordkeeping requirements. Swiss Valley failed to inform DNR or obtain a construction permit prior to altering control equipment, and has failed to comply with the requirements of its air quality construction permits by exceeding its permitted particulate matter general emission rate.

IV. Witnesses

The following DNR personnel will be potential witnesses: Chris Roling, Ann Seda, Brian Hutchins, Alyssa Fizel, Rick Martens, Mark Fields, Dennis Thielen and Joe Sanfilippo.

WHAT IS CHEESE? Cheese is a nutritious food that is made from milk. It consists primarily of the curd which is a semisolid substance formed when milk curdles or coagulates. Curdling occurs naturally if milk is not used promptly. It sours, forming an acid curd which releases whey and leaves the semisolid curd or fresh cheese. Whey is a watery fluid containing the soluble constituents.1 Different manufacturing and aging processes are used to produce the array of cheeses available today. Cheese is made by coagulating or curdling milk, stirring and heating the curd, draining the whey (the watery part of milk), collecting a pressing curd, and in some cases, ripening. Cheese can be made from whole, 2% lowfat, 1% lowfat, fat-free milk, or combinations of these milks. In some areas cheese is still made simply by allowing milk to curdle naturally or by mixing milk with juices or extracts that reduce it to curds and whey.2 According to ancient records passed down through the centuries, the making of cheese dates back more than 4,000 years (NOTE: some say it could be more than 7,500 years). No one really knows who made the first cheese. Legend has it that it was accidentally made by an Arabian merchant who put his supply of milk into a pouch made from a sheep’s stomach as he set out on a day’s journey across the desert. The rennet in the lining of the pouch, combined with the heat of the sun, caused the milk to separate into curd and whey.3

HOW IS CHEESE MADE? It is said that quality cheese begins with one (1) key ingredient – quality milk. Before the cheesemaking process begins, incoming milk is tested for quality and purity. It takes approximately 10 pounds of milk to make one (1) pound of cheese. Next, cheesemakers weigh, heat treat or pasteurize the milk to ensure product safety and uniformity. Starter cultures, or good bacteria, are added to start the cheesemaking process. They help determine the ultimate flavor and texture of the cheese. Next, a milk-clotting enzyme called rennet is added to coagulate the milk, forming a custard-like mass. It’s then cut into small pieces to begin the process of separating the liquid (whey) from the milk solids (curds). Large curds are cooked at lower temperatures, yielding softer cheeses like mascarpone and ricotta. Curds cut smaller are cooked at higher temperatures, yielding harder cheeses like parmesan and romano. Cheesemakers cook and stir the curds and whey until the desired temperature and firmness of the curd is achieved. The whey is then drained off leaving a tightly formed curd. Different handling techniques and salting affect how the curd is transformed into the many cheese varieties that can be made. The curd is then pressed. Pressing determines the characteristic shape of the cheese and helps complete the curd formation. Pressing is done by a mechanical weight or by the weight of the curd itself, such as for Colby and feta. Most cheeses are pressed in 3 – 12 hours, depending on their size.

1 From Encyclopedia Britannica (https://www.britannica.com/topic/cheese). 2 From the National Dairy Council (https://www.nationaldairycouncil.org/). 3 From the International Dairy Foods Association website (http://www.idfa.org/news-views/media-kits/cheese/history-of-cheese).

https://www.britannica.com/topic/cheese

https://www.nationaldairycouncil.org/

http://www.idfa.org/news-views/media-kits/cheese/history-of-cheese

http://www.idfa.org/news-views/media-kits/cheese/history-of-cheese

Depending on the variety and style of cheese, another step could be curing. Curing is used for aged cheeses and helps fully develop its flavor and texture. The cheese is moved to a room that is carefully controlled for required humidity and temperature and may be aged from weeks to several years.4

DIAGRAM OF CHEESEMAKING PROCESS

Figure 1 – Cheesemaking Process5

4 Adapted from the Wisconsin Milk Marketing Board (http://www.eatwisconsincheese.com/cheeses/how-cheese-is-made). 5 From Encyclopedia Britannica (https://www.britannica.com/topic/cheese).

http://www.eatwisconsincheese.com/cheeses/how-cheese-is-made

http://www.eatwisconsincheese.com/cheeses/how-cheese-is-made

https://www.britannica.com/topic/cheese

https://www.britannica.com/topic/cheese/images-videos/The-cheese-making-process/110232

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WHAT IS WHEY? Whey protein is a high-quality protein naturally found in milk products. It is considered a “complete” protein containing all nine (9) essential amino acids required of the human body, is low in lactose content, and easy to digest. Whey protein is also one of the best source of branched chain amino acids (BCAAs) including leucine, which has been shown to stimulate muscle synthesis. For these reasons people commonly use it as supplementation, alongside resistance exercise, to help improve muscle protein synthesis and promote the growth of lean tissue mass. Milk contains two (2) proteins: casein and whey. Approximately 82% of milk protein in cow’s milk is casein with the remaining 18% being serum or whey. The whey can be separated from the casein or formed as a by-product of cheesemaking. There are two (2) types of whey:

o Acid whey: This is also known as “source whey” and is a co-product produced during the making of acid types of dairy products such as cottage cheese, paneer, feta, chevre, whole milk ricotta, or strained yogurt. It has a pH less than or equal to 5.1. It has many uses including soaking grain to make bread, fed to animals, or used in skin and hair products.

o Sweet whey: This type of whey is manufactured during the making of rennet types of hard cheese like cheddar or Swiss. It can also be drained from most soft cheeses, clabbered raw milk, milk kefir, or buttermilk. It has a pH greater than or equal to 5.6. In addition to the Acid Whey uses, Sweet Whey can be used in food because it is more pleasing to most palates.

These types of whey can be further concentrated and processed into three (3) primary types of whey protein. A description of each type is below with a summary in Table 1:

• Whey protein concentrate (WPC): WPCs contains low levels of fat and low levels of carbohydrates (lactose). The percentage of protein depends on how concentrated it is as it can range from 25 – 89%. The whey protein powder supplements found in health and nutrition stores often list WPC on the label. This type of whey protein is usually 80% protein. The rest of the product consists of lactose (4 – 8%), fat, minerals, and moisture.

• Whey protein isolate (WPI): WPIs are further processed to remove all of the fat and lactose. This is the purest form of whey protein available and contains 90 – 95% protein. It is a good protein source for individuals with lactose intolerance as it contains little to no lactose. WPIs are also very low in fat. The cost in WPI is slightly higher than WPC due to the purity and higher protein content of the product.

• Whey protein hydrolysate (WPH): The long protein chains in whey protein have been broken down

into shorter chains called peptides. It is for this reason that WPH is considered to be the “predigested” form of whey protein as it has already undergone partial hydrolysis. This is a process necessary for the body to absorb protein. Hydrolysis does not reduce the nutritional quality of the whey protein. WPH does not require as much digestion as the other two forms of whey protein. This is the reason it is commonly used in medical protein supplements and infant formulas.1

1 Information from Milk Facts (http://www.milkfacts.info/), Whey of Life (http://www.wheyoflife.org/), Cultures for Health (http://www.culturesforhealth.com/learn/general/ways-to-use-whey/) and articles from Muscle Insider (http://muscle-insider.com/features/what-whey-protein-and-how-it-made) and Medical News Today (http://www.medicalnewstoday.com/articles/263371.php).

http://www.milkfacts.info/

http://www.wheyoflife.org/

http://www.culturesforhealth.com/learn/general/ways-to-use-whey/

http://muscle-insider.com/features/what-whey-protein-and-how-it-made

http://muscle-insider.com/features/what-whey-protein-and-how-it-made

http://www.medicalnewstoday.com/articles/263371.php

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Table 1 – Summary of Types of Whey Protein

Type Protein Content (%)

Lactose Content (%)

Fat Content (%) Common Use

WPC 25 – 89 4 – 52 1 – 9 Protein beverages & bars, confectionery & bakery products, infant formulas, and other nutritional food products

WPI 90 – 95 0.5 – 1 0.5 – 1 Protein supplementation products, protein beverages, protein bars, and other nutritional food products

HWP 80 – 90 0.5 – 10 0.5 – 8 Infant formula and sports & medical nutrition products

HOW IS WHEY PRODUCED?2 Just a generation ago, the whey that was produced during the cheesemaking process was considered a waste product. Today, it is highly regarded as a valuable co-product of cheesemaking. Whey is refined at the plant into a valuable ingredient that can be used in foods, beverages, and animal feed. Advances in technology and investments in research & development have enabled the whey industry to expand its product line from basic commodities to a variety of higher valued products. The block diagram below (Figure 1) summarizes the various processes that can be used in the treatment of whey and its end products.

Figure 1 – Whey Processing Alternatives The first stage is filtering the curd particles left in the whey, followed by separation of casein fines and fat (See Figure 2), partly to increase the economic yield and partly because these constituents interfere with subsequent treatment. Traditionally, production of whey powder, delactosed whey, and lactose has dominated

2 The majority of information in this section is from Chapter 15 of the Dairy Processing Handbook (http://www.dairyprocessinghandbook.com/chapter/whey-processing). Specific information about dryers is from dryer manufacturers and cited.

http://www.dairyprocessinghandbook.com/chapter/whey-processing

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the processing whey solids. However, increased demand for whey proteins has resulted in approximately 40% of processed whey solids being directed to WPC, WPI, lactose, and permeate. Whey must be processed as soon as possible after it is separated from the cheese curd as its temperature and composition promote the growth of bacteria that can lead to protein degradation and lactic acid formation. Ideally whey is drawn directly from the cheese process into short duration buffer storage then clarified, separated, pasteurized, and cooled into storage to await further processing. Casein fines are always present in whey. These fines have an adverse effect on fat separation and therefore need to be removed first. Separation devices such as cyclones, centrifugal separators, or vibrating/rotating screens can be used.

Figure 2 – Fines and Fat Separation from Whey The collected fines can often be used in the cheesemaking process. The whey cream which often has a fat content of 25 – 30% can partly be reused in the cheesemaking process. The next step for the whey is to concentrate the total solids. This typically starts by increasing the dry matter from around 6% to 18 – 25% using reverse osmosis or a combination of reverse osmosis and nanofiltration. The whey can then either be transported to another site for further processing (i.e. evaporation and drying) or dried directly on site. Whey is dried in either drum or spray dryer once it has been separated from the milk curds in the cheesemaking process. The basic principle behind a drum dryer is the material is sent from the higher section of the drum and contacts hot air. As the cylinder rotates the material flows down to the lower end with the effect of gravity and is discharged after drying. The exhaust gasses leaving the dryer typically pass through a filtration device such as a cyclone or baghouse to remove any fine material entrained in the air. Figure 3 shows a common rotary drum dryer setup. The problem with drum dryers is it is difficult to scrape the layer of dried whey from the drum surface. A filler, such as wheat or rye bran, is mixed into the whey before drying to make the dried product easier to scrape off. Currently spray drying of whey is the most widely used method of drying. Spray drying is a continuous method of drying solutions, slurries, and pastes in the shortest time possible. The drying is quick because the liquid is atomized as fine droplets in a chamber through which hot air is passed. Atomization creates a very large surface area for heat and mass transfer. Figure 4 shows a basic spray dryer setup. The whey concentrate is usually treated as mentioned above prior to drying to form small lactose crystals as this results in a non-hygroscopic product which does not go lumpy when it absorbs moisture.

Key For Figure 2:

1 – Whey collecting tank 2 – Clarifier 3 – Fines collecting tank 4 – Whey cream separator 5 – Whey pasteurizer 6 – Whey cream tank 7 – Whey for further treatment

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Figure 3 – Basic Drum Dryer Setup3

Figure 4 – Basic Spray Dryer Setup4 Acid whey from cottage cheese and casein production is difficult to dry due to the high lactic acid content. It agglomerates and forms lumps in the spray dryer. Drying can be facilitated by neutralization and the use of additives such as skim milk and cereal products. It is preferred that lactic acid be removed through a combination of nanofiltration and electrodialysis which improves the flavor, nutritional profile, drying, and handling. Salt is also removed and typically a demineralization level of >60% corresponds to a level of acid reduction that is acceptable.

3 Diagram and drum dryer principles from GEMCO Energy website (http://www.gemcopelletmill.com/rotary-drum-dryer.html). 4 Diagram and rotary dryer principles from Unitop Projects & Services Pvt. Ltd (http://www.unitop.org/zero_effluent_discharge_systems4.html).

http://www.gemcopelletmill.com/rotary-drum-dryer.html

http://www.gemcopelletmill.com/rotary-drum-dryer.html

http://www.unitop.org/zero_effluent_discharge_systems4.html

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