HomeMy WebLinkAbout03. Update on State Water Resources Control Board order for non-potable recycled water use3.
tSD
amilimmilms Central Contra Costa Sanitary District
May 31, 2016
TO: BOARD ADMINISTRATION COMMITTEE
VIA: ROGER S. BAILEY, GENERAL MANAGER
DANEA GEMMELL, PLANNING & DEVELOPMENT SERVICES
DIVISION MANAGER
FROM: MELODY LABELLA, ASSOCIATE ENGINEER q`)IX
SUBJECT: STATE WATER RESOURCES CONTROL BOARD DRAFT GENERAL
ORDER FOR NON -POTABLE RECYCLED WATER USE
Background
On January 21, 2016, the State Water Resources Control Board (State Board) issued a
Notice of Public Hearing and Opportunity for Public Comment on a proposed General
Order (Order) for Recycled Water Use for non -potable recycled water projects. The
hearing was initially set for April 19, 2016, and the deadline for public comments was
set at February 22, 2016. After several postponements and issuance of a revised
Order, the ultimate date of the public hearing has been set at June 7, 2016, and the
public comment period was extended to May 13, 2016.
The stated intent of the draft Order is to:
1. Streamline the permitting of recycled water uses that are relatively low threat to
water quality.
2. Further encourage recycled water projects by:
a. Acknowledging recycled water as a resource through water reclamation
requirements, and
b. Allowing recycled water programs that are implemented in multiple Regional
Water Board boundaries to be permitted by the State Water Board.
Association Positions
Both WateReuse California and the California Association of Sanitation Agencies
(CASA) have been actively engaged on this draft Order, having met with State Board
members and staff to discuss the best path forward for this statewide permit. The Bay
Area Clean Water Agencies (BACWA) also weighed in with written comments.
Board Administration Committee
May 31, 2016
Page 2 of 2
The written comments submitted from all three Associations cover the concerns that
District staff has on this draft Order and are as follows:
1. Coverage is mandatory — unlike the previous statewide permit for non -potable reuse
projects, issued in 2014, this new draft Order does not include language that allows an
agency to opt -in to coverage under this permit. This means that all existing Recycled
Water Programs must transition to coverage under the new statewide permit. The draft
Order requires Regional Boards to transition all existing Recycled Water Programs to
coverage under the Order within three years of adoption. This will require water
recycling agencies to re -apply and re -submit Engineering Reports and Operations and
Maintenance Plans to the Regional Board to obtain coverage under the new Order.
District impact: if this requirement is adopted into the final Order, the District will have to
reapply to our Regional Board for coverage of our existing Recycled Water Program
under the new Order.
2. Mandatory Priority Pollutant Monitoring — for agencies that produce more than 1
million gallons of recycled water per day, the draft Order requires mandatory priority
pollutant monitoring once per year. BACWA recently collaborated with the Bay Area's
Regional Board to adopt an Alternate Monitoring Plan that allows municipal dischargers
to reduce monitoring frequencies for priority pollutants that, in recent years, have been
detected rarely and/or at levels lower than would pose an active threat to water quality.
If monitoring of these priority pollutants is not beneficial in treated effluent, the same
would hold true for recycled water. BACWA's position is that Regional Boards should
be given the authority to wave monitoring requirements when the data is found to be of
little value.
District impact: if this requirement isn't modified in the final Order, the District will have
to conduct priority pollutant monitoring of our recycled water once per year, since we
produce more than 1 million gallons per day.
Resources
The following webpage on the State Board's website provides a wealth of information
on the draft Order, including copies of the public notices, draft Orders, and public
comments received.
http://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/reguirements.shtml