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5 <br /> <br />opportunities that could achieve a final effluent concentration target of 3 mg/L TIN (or <br />equivalent load reduction) on seasonal average (April – October) basis. Key elements to be <br />addressed in the NRE include: <br /> <br />• Wastewater characterization <br />• Treatment Technology Analysis <br />• Economic Evaluation <br />• Environmental Justice (EJ) Review <br />• All Known, Available and Reasonable Treatment (AKART) analysis for purposes of <br />evaluating reasonable treatment alternatives <br /> <br />The PSNGP includes specific requirements for EJ review in the NRE for evaluating treatment <br />alternatives capable of reducing nitrogen discharges. Recent legislation in Washington in the <br />Healthy Environment for All (HEAL) Act requires EJ review that covers seven state agencies <br />including Ecology and the Puget Sound Partnership. <br /> <br />Key activities to support preparation of the Nutrient Reduction Evaluation (NRE) are as <br />follows: <br />• Review historical City facilities planning reports, treatment process studies, etc. to <br />determine relevant information that may inform full-scale nitrogen removal planning <br />or might be incorporated into the NRE (2023). <br />• Conduct a meeting with City staff to discuss nitrogen removal options in light of the <br />optimization efforts, annual reports, etc. in order to outline basic options for nutrient <br />reduction for further study and development in the NRE (2023/24). <br />• Prepare detailed work plan for development of the NRE including alternatives for a <br />final effluent concentration target of 3 mg/L TIN for main-stream treatment, side- <br />stream treatment, alternative effluent management options, satellite treatment, and <br />other nutrient reduction options. Develop an approach to the AKART analysis and EJ <br />review (2023/24). <br />o Focus on unique site-specific circumstances for Everett that are distinct and <br />inform Everett-specific considerations of AKART analysis and EJ review. <br />• Conduct nutrient reduction alternatives analysis, conduct workshops with City staff to <br />collaborate on the monetary and non-monetary analysis of alternatives, and select the <br />preferred alternative or multiple alternatives (2024/25). <br />o Formulate a phased implementation plan that reflects a practical and affordable <br />schedule for the preferred alternative(s). The phased implementation plan may be <br />formulated as an Integrated Plan, as codified in the Clean Water Act in 2019, that <br />allows consideration of local priorities and affordability to guide water quality <br />management efforts and address the competing demands of compliance with <br />multiple regulatory requirements. This CWA Amendment provides for <br />compliance with effluent limits over multiple NPDES permit cycles and informs <br />compliance schedules in NPDES permits (2024/25). <br /> <br />Assumptions <br />• The City will provide written conflict-resolved review comments on the 2022 draft <br />Optimization Plan. <br />• The City will provide water quality monitoring data from the treatment processes, as well as