Trinity River Authority Regulatory Support

Plummer has assisted the Trinity River Authority of Texas (TRA) with a multitude of regulatory projects over several decades. One example is the permit amendment application for the Central Regional Wastewater System (CRWS), which provides reclaimed water to the Dallas County Utility and Reclamation District (DCURD) for nonpotable use. The amendment provided for a change of the Lake Remle discharge, a new permitted outfall, and an increased permitted discharge of up to 189 million gallons per day (mgd). The following provides details about the complexity of this project.

The “Other Requirements” section of the previous permit authorized the transfer of reclaimed wastewater effluent to the Lake Remle System, a water supply for irrigation and aesthetic amenities in the Las Colinas development used by the DCURD. The discharge to Lake Remle was not a permitted discharge. This section also required TRA to perform an assessment of uses and characteristics of the Lake Remle System.

Plummer assisted TRA in preparing a Work Plan, securing TCEQ approval of the plan, implementing the plan, and preparing a report on the results of the assessment. Following submittal of the report, there were extensive discussions involving TRA, Plummer, DCURD, TCEQ, and USEPA to determine whether a discharge to the Lake Remle System must be considered a discharge to waters of the U.S. (WOTUS) and, if so, what would be the appropriate Aquatic Life Use classifications of each component of the Lake Remle System. It was agreed that the Lake Remle System was WOTUS, requiring a permitted outfall in the CRWS permit.

Plummer prepared the major amendment permit application. Plummer's understanding of applicable rules and requirements, our outstanding working relationship with TCEQ, and the technical expertise of the Plummer Team were key to the success of this project.