HomeMy WebLinkAbout06.a.3) Businesses in Significant Non-Compliance for 2010Central Contra Costa Sanitary District
a .
January 27, 2011
TO: BOARD OF DIRECTORS
VIA: JIM KELLY, GENERAL MANAGER
ANN FARRELL, DIRECTOR OF ENGINEERING
FROM: TIM POTTER, ENVIRONMENTAL COMPLIANCE SUPERINTENDENT
SUBJECT: BUSINESSES IN SNC FOR 2010
BACKGROUND
Federal pretreatment regulations require the District to report businesses permitted under the
Source Control Program if they are issued a Notice of Violation during the calendar year. The
regulations also establish criteria for agencies such as the District to use to determine if the
violations of a permitted business are classified as Significant Non - Compliance (SNC). If a
business is determined to be in SNC, the District is required to publish certain information
about the violation in the newspaper at least annually.
In 2005, Source Control staff initiated a program, at the Board's request, to work more closely
with the regulated businesses to understand the actions they could take to minimize the
events when they would meet the SNC criteria. This program has been very successful and
the number of businesses reported in SNC has been significantly reduced. This year the
program assisted one Significant Industrial User quickly return to compliance for two separate
potential SNC violations.
BUSINESSES IN SNC FOR 2010
Unfortunately, two businesses were determined to meet the SNC criteria during calendar
year 2010:
• BART Concord Maintenance for phenol limit violation
• St. Mary's College for mercury limit violations
The information that will be published in the Contra Costa Times is included in the enclosed
document.
The BART maintenance facility was published for being in SNC last year but for copper limit
violations. BART has not had phenol in significant concentrations during prior sampling
events so they investigated potential sources within the shop operations. A potential source
was identified from a contractor applying an epoxy coating to the shop floors because they
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used a product that contained phenolic compounds. The results from subsequent sampling
are pending to document BART has returned to compliance.
St. Mary's College has been published in SNC in past years for mercury limit violations.
District staff met with St. Mary's College staff to discuss measures that can be taken to
control mercury sources to the sanitary sewer. Although they identified challenges for
controlling all mercury sources from the diverse operations of the science buildings, they did
state a commitment to work with the faculty and staff to prevent future violations. Monthly
mercury monitoring will be conducted by St. Mary's College for at least 2011 to provide more
timely information should elevated mercury concentrations be documented. Subsequent
sampling and the compliance sampling conducted in October documented the St. Mary's
discharge to be in compliance with the mercury limit.
TPlmvp
Enclosure
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PUBLIC NOTICE
CENTRAL CONTRA COSTA SANITARY DISTRICT
NOTICE OF SIGNIFICANT NONCOMPLIANCE FOR 2010
Notice is hereby given that pursuant to the federal regulations contained in 40 CFR
403.8.f(2)(vii), the Central Contra Costa Sanitary District (District) is required to publish the
names of all Industrial Users (IU) of the District's public sewer system that were considered to
be in significant noncompliance (SNC) with applicable pretreatment standards or other
pretreatment requirements during the 2010 calendar year. Federal regulations establish
objective criteria for the District to use to determine if an IU is in SNC.
Discharge Quality Violations
The following l Us were found to be discharging process wastewater in violation of the
District's Local Discharge Limits in a manner that met the definition of SNC:
Industrial User Nature of Violation
Follow -up Action Taken
Bay Area Rapid Transit- Limit violations for Phenol from
The District issued a Notice of Violation
Concord Maintenance the discharge from the
(NOV) for the violation. The IU investigated
1045 San Miguel Road maintenance buildings.
potential sources of phenol within the
Concord, CA
maintenance shop operations since
elevated concentrations of this pollutant
have not been recorded during prior
sampling events. A potential source was
identified from a contractor applying an
epoxy coating to the shop floors because
they used a product that contained phenolic
compounds. Results from the re- sampling
to demonstrate that the IU returned to
compliance are pending.
St. Mary's College Limit violations for mercury
The District issued a NOVs for the
1928 St. Mary's Road from the discharge from the
violations. The IU investigated potential
Moraga, CA laboratory buildings. The
sources of mercury within the laboratory
mercury LDL was significantly
operations and reported that although
reduced effective 9/11/07. The
experiments involving mercury in the labs
IU also violated the LDL for
have been significantly reduced, one was
copper that did not meet the
conducted before the violation was
SNC criteria.
documented and could have contributed to
the higher than normal concentrations. Re-
sampling demonstrated that the lU returned
to compliance.
Reporting Violations
No IUs were found to have violated reporting requirements of the District's Source Control Program in
a manner that met the definition of SNC.
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