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HomeMy WebLinkAbout05. Regulatory UpdatesItem No. SIGNIFICANT REGULATORY UPDATES November 22, 2016 Real Estate, Environmental and Planning Committee Meeting Lori Schectel Environmental and Regulatory Compliance Division Manager SIGNIFICANT REGULATORY ISSUES • Air • Wastewater • Household Hazardous Waste 1 11/15/2016 AIR -RELATED ISSUES Clean Air Act Section 129: 40 -CFR -60 Sewage Sludge Incinerator Regulations Effective March 2016 - New emissions limits, minimum operating limits, enhanced visible emissions from ash handling, operator training, annual source tests Annual operator training completed Both furnaces passed initial 129 compliance demonstration source tests Awaiting EPA's response on proposed minimum operating limits • Title V Authority to Construct permit application submitted to BAAQMD in November 2016 for Headworks Improvement Project AIR -RELATED ISSUES • Global Warming Solutions Act of 2006 Cap and Trade Program inclusion threshold: 25,000 MTCO2e Verified calendar year 2015 anthropogenic emissions: 23,142 MT CO2e Projected calendar year 2016 anthropogenic emissions: <24,000 MT CO2e • Portable Diesel Engine Regulation GARB Air Toxics Control Measure Two engines were replaced in 2016 Replace or decommission five engines by 2020 1111111101404444• Soil Cap Enforceable Agreement with DTSC Maintain integrity of soil caps (Basin A South; Surcharge Fill Area) DTSC no longer performs annual inspections • Reporting: Semi-annual and five -years; notice and reporting on excavation projects AIR -RELATED ISSUES • BAAQMD Draft Rea 11-18: Reduction of Risk from Air Toxic Emissions at Existing Facilities Facilities with incremental cancer risk > 10 in a million will be required to: Reduce facility incremental cancer risk to < 10 in a million and/or; Add TBARCT to any single source with an incremental cancer risk 1 in a million. Aggressive schedule for high-risk facilities to reduce facility risks BAAQMD public workshop - November 2016 Rule adoption - Summer 2017 Internal evaluation of health risks for Treatment Plant AIR -RELATED ISSUES • BAAQMD Revised Reg 2-1: General Requirements and Rea 2-2: New Source Review Amendments to existing regulations to include new definition of particulate matter State and federally enforceable Bay Area is officially non -attainment for PM2.5 Applicable to new and modified sources Applies BACT for PM2.5 if NSR is triggered Revisions effective August 31, 2016 • BAAQMD Proposed Revisions to Rea 2-5: New Source Review, of Toxic Air Contaminants Applicable to new and modified sources Applies TBACT for toxic air contaminants if NSR is triggered BAAQMD public hearing — December 2016 11/15/2016 3 WASTEWATER -RELATED ISSUES • Treatment Plant NPDES Discharge Permit, Expires March 2017 Renewal application (ROWD) submitted by September 30. 2016 Administrative draft permit expected in January 2017 • Nutrient Watershed Permit Meet regional permit expectations (monitoring, reporting, evaluation) Collaborate with BACWA, SFEI, RWOCB, consultants Second annual report submitted in October 2016 Expires June 2019; renew December 2018 ▪ Optimization and Upgrade Study — drafts completed for 17 out of 37 plants • WASTEWATER -RELATED ISSUES • Test of Significant Toxicity (Draft State Policy) Numeric limits for chronic toxicity Statistical method to determine chronic toxicity Monthly testing frequency Revised public draft expected in early 2017 with adoption in Summer 2017 • Federal Dental Amalgam Rulp.(ProDosed) CCCSD developed program based on Regulation 2 Mercury Watershed Permit Proposes new category — Dental Industrial User (DIU) Additional regulatory oversight on non-compliant DIU Additional sampling and administrative requirements EPA's target adoption date — December 2016 11/15/2016 WASTEWATER -RELATED ISSUES • Environmental Laboratory Accreditation Proaram (ELAP1 Laboratory accreditation for NPDES self-monitoring will be held to the new accreditation standard Additional documentation without improvement in data quality BAAQMD and CCCSD commented on draft regulation Fall 2016 Adoption is anticipated end of 2017/early 2018 HOUSEHOLD HAZARDOUS WASTE - RELATED ISSUES • Lead -Acid Batten/ Recyclina Act of 2016 (AB 2153) New bill chaptered in September 2016 Requires advance recycling fee of $1 per lead -acid, automotive battery at the time of purchase Fee will increase to S2 per battery in 2022 Retailers will be required to take these batteries back HHWCF currently collects lead -acid batteries as a source of revenue Should reduce number of lead -acid batteries received by CCCSD; CCCSD should save on handling cost • ALitornotive Repair: Oil Chanues: Notification to Customers (S13778) Requires automotive repair dealers or maintenance providers to follow manufacturer's published oil drain schedule Vetoed by Governor in September 2016; remains in Senate pending consideration 11/15/2016 AIR -1 AIR -2 Subject 129 Sewage Sludge Incinerator Regulations Effective March 21, 2016, the 129 Sewage Sludge Incinerator (SSI) regulations established new reporting, operating and emission Iimits for NOx, CO3 502, PM, HCI, cadmium, mercury, lead, and dioxin/furan. Major components of the 129 regulations include: 1) Minimum operating limits for continuous parametric monitors a) Top Hearth Temperature b) Wet scrubber inlet flow rate c) Wet scrubber outlet pH d) Wet scrubber Differential Pressure (dP) drop 2) Enhanced limits on visible emissions from ash handling 3) Enhanced OperatorTraining Program with annual refresher training and certification 4) Annual compliance source testing 5) Use of bypass damper allowable in certain circumstances, e.g. prevent Ioss of Iife, personal injury, or severe property damage, though must be reported. Breakdown relief may be granted. AB 32 Global Warming Solutions Act First state legislation in the nation to regulate greenhouse gas emissions and establishes targets for future statewide GHG emissions. Rules developed and enforced by the California Air Resources Board (CARB). 1) Required reductions for the State of California a) Reduce to199Oemissions levels by2OZO b) Reduce to 40% below 1990 emissions Ievels by 2030 d Reduce to 80% below 1990 emissions Ievels by 2050 2) Cap and Trade Program a) State-wide regulatory frame work for reducing GHG emissions b) >25,000 MT CO2e anthropogenic emissions trigger c) Triennial submittal of allowances to CARB for actual GHG emissions d) Triennial reduction in allowance available for purchase ortrade byCARB Central Contra Costa Sanitary District Regulatory Updates -U ;�� ^�� Significant Issues�� November 22, 2016 Relevance to the District 1) Annual source testing is required to demonstrate comp|ianceandisapproximatehS12O'l4Okperyear, not including stafftime. 2) Potential for more frequent Reportable Cornpliance Activities. Increased risk for violations with new emission limits. 3) Four additional process parameters as compliance monitors. The new minimum operating ?imits may reduce operational fiexibility. 4) Additional reporting requirements for Title V Permit. 5) Modifications to existing equipment to comply with 129 requirements, i.e. caustic system and ash loading station modifications. 1) CCCSD is required to complete mandatory annual reporting and verification of the Treatment Plant's annual GHG emissions inventory. 2) Added costs for future expansion if over the 25,000 MT CO2e Cap and Trade trigger. 3) Cap and Trade triggers reduction to meet future GHG reduction goals. Current Status 1) Completed Furnace No.1 Compliance Demonstration Source Test in October 2015. Results were in compliance with 129 emission limits. 2) Completed Furnace No.2 Compliance Demonstration Source Test in July 2016. Results were in compliance with 129 emission limits. 3) Completed caustic injection system pilot in 2015. 4) Collaborating with Capital Projects on the MHF Burner improvements. 5) Completed annual 129 operator training for Operations staff. 6) Awaiting EPA response on minimum operating 1) Actively manage natural gas use at the Treatment Plant to remain under the Cap and Trade Program trigger of 25,000 MT CO2e anthropogenic emissions. This saves CCCSD annual avoided costs of $250,000 per year by not being in the Cap and Trade Program. 2) Prepare, submit, and verify annual GHG inventories. 3) Calendar year 2015 anthropogenic emissions: 23,242MTCO2e. 4) Projected calendar year 2016 anthropogenic emissions below 24,OOOMT[Oze. Next Steps 1) Continue our efforts on emission testing, caustic injection testing, ash loading improvements, and operator training. 2) Staff will work with the Environmental Protection Agency to establish process operating Iimits for scrubber pressure drop, scrubber outlet pH, scrubber inlet flowrate, and top hearth temperature. 1) Track development of state and federal GHG regulations routinely to ensure compliance. 2) Staff will continue to work with CASA Climate Change Group and Bay Area Clean Water Agency's AIR Committee to obtain regulatory updates and provide comments through BACWA AIR Committee as necessary. AIR -3 AIR -4 AIR -5 (New) AIR -6 (New) Subject Title V Compliance TitIe V 15 d national Federal air permitting program under the Clean Air Act. The Treatment Plant's Title V permit lists all applicable regional, state, and Federal air requirements. All submitted Title V compliance documentsarecertdiedbv"responsib|eofficial". Title V permit holder responsible for compliance with all applicable regulations even if not in Title V permit. Title V Permit renewed every 5 years, and the Iast renewal in March 2015. Bay Area Air Quality Management District (BAAQMD) is the delegated enforcement authority. Portable Diesel Engine Regulation Per the California Air Resources Board (CARB) Air Toxics Control Measure (ATCM), all portable diesel engines > 50 horsepower be certified to EPA Tier 4. Final standards for emissions of particulate, NOx, and organics. The regulations were adopted in February 2011. Proposed BAAQMD Reg 11-18: Reduction of Air Toxic Emissions from Existing Facilities BAAQMD has published proposed Rule 1148 to reduce air toxic emissions from existing facilities. Facilities with incremental cancer risk greater than (>) 10 in a million would be required to reduce facility incremental cancer risk to < 10 in a million and/or add TBARCT to any single source with an incremental cancer risk» 1 in a million. Adoption is scheduled for Summer 2017. Revised BAACWID Reg 2-1: General Requirements and Reg 2-2: New Source Review Revised regulations effective August 31, 2016 that incorporate the new definition of particulate matter. Page |2 Relevance to the District 1) CCCSD is subject to increased process monitoring, reporting, and data retention requirements. 2) DuaI permit action for any significant changes: a) Title VPermit b) BAAQMDannual Pemnit-To-Operate 3) Increased annual permit fees every year. 4) Reportable Compliance Activities (RCA's) for communicating permit excursions or exceedances. 5) 5 -year recordkeeping requirements. 1) Eight portable diesel engines in District Fleet were not EPA Tier 4 certified as of November 2016: once replaced, will become Tier 4. 2) Increased equipment budget to replace these engines. 1) Treatment plant facility risk is likely> 10 in a mililon. 2) OnIy three years to install equipment to reduce facility risk to less than (<) 10 in a million, if draft regulations stay intact. 3) Could influence the selection of future projects under the Master PIan. 1) New definition of particulate matter includes condensable particulates. This can significantly increase furnace's particulate rnatter emissions over baseline emissions. 2) If new or modified source status is triggered for the furnace, CCCSD would be required to install BACT for PM2.5. Current Status 1) Regulatory Compliance staff works closely with Operations staffto ensure full compliance with all Title V permit requirements. 2) Monitoring and analysis of process data to ensure permit limits. 3) Prompt and accurate reporting (monthly, quarterly, semi-annuaLand annual) to8AA[lMD. 4) Preparation for routine site inspections. 5) Permit renewal is completed every 5 years. 6) Continue to develop positive working relationships with the regulatory agency. 7) Submitted Authority to Construct permit application to BAAQMD for Headworks Improvement Project. 1) Two portable diesel engines at the Treatment Plant have been taken out -of -service and replaced with portable diesel engines < 50 hp. 2) One portable diesel engine at Orinda Crossroads Pumping Station will be taken out -of -service and/or replaced by January 1, 2017. 3) Two diesel engines at CSO will be taken out -of - service and/or replaced by January 1, 2017. ut-of-sen/iceand/orrep1acedbv]anuaryl,ZOl7. 1) Rule is in draft stage. 2) BAAQMD soliciting input on draft rule. Will not impact District's operations unless a new or modified source status is triggered. Regulatory Updates - List of Significant Issues Next Steps Regulatory Compliance staff continues to work closely with Operations staff and BAAQMD officials to ensure full compliance with all Title V permit requirements. Remaining five engines to be taken out -of -service and/or replaced by January 1, 2020. 1) Attend public workshops and hearings on rule development. 2) Submit written comments on draft rule (December 2016) AIR -7 (New) AIR -8 CEC-1 Subject Potential Revisions to BAAQMD Reg 2-5: New Source Review of Toxic Air Contaminants Proposed revisions to Regulation 2, Rule 5 would require new and modified sources to impiement Toxic Best Available Control Technology (TBACT) for toxic air contaminants. Enforceable Agreement with Department of Toxic Substances Control (DTSC) for Soil Cap CCCSD has a written agreement with DTSC to maintain the soil cap onBasin ASouth and Surcharge fill area. The agreement requires periodic inspections and repairs as needed. Reportingnequirementsinc1udesemi'annuaL5' year summary report, and reports on any excavation work on Treatment Plant site. Microplastics Regional monitoring program microplastics strategy. Looking to determine microplastics pollution in the San Francisco Bay. Relevance to the District 1) If new or rnodified source status is triggered for the furnace, CCCSD would be required to install TBACT to reduce toxic air contaminants. 1) Staff time is utiiized to conduct inspections, repairs, and reports. 2) Limitation on the use ofthe soil cap area. Large remediation cost added to any expansion into soil cap area. 3) CCCSD is required to ensure compliance with current hazardous material regulations when/if soll cap area is ever excavated. 1) CA Cornprehensive Microbead Ban in consumer products. 2) SFEI Poster at State of the Estuary Conf showing results of preliminary survey in Bay Area wastewater effluent and surface waters. 3) Bay Area POTWs w/ filtration have similar Ievels of microplastics in their effluent as facilities w/out filtration. 4) Control at the source — how do we do this? Current Status Next Steps Will not impact District's operations unless a new or Staff will attend pub?ic hea ring in December 2016. modified source status is triggered. 1) Complete monthly and quarterly inspections, necessary repairs, and reports as needed. 2) Coordinate with Capital Projects on Treatment Plant projects. Provide proper notification and follow-up report to DTSC on any Treatment Plant excavation projects. 3) DTSC no Ionger performs annual inspections because District has been in full compliance with internal inspection requirements. 1) Governor signed bill lO/1S- Z> Manufacturers must comply by 2020. 3) BACWA met with Feinstein's staff to discuss increased funding to study issue through SFEI. Regulatory Updates - List of Significant Issues Continue to maintain the integrity of the soil cap by conducting routine inspections and making necessary repairs. 1) BACWA working w/ SFEI to better understand the issue. 2) Participate in future studies. 3) 2016 SFEI Draft Strategy — scope and cost to be refined. CEC-2 HHW-1 (NEW) HHW-2 (NEW) NPDES-1 Subject Pesticides The current EPA Office of Pesticide Programs (OPP) new registration and registration review processes for pesticides does not take into account the POTW pathway in evaluating fate and transport of pesticides to waterways. As a result, pesticides are being registered for indoor uses that result in discharges to POTWs. The Lead -Acid Battery Recycling Act of 2016. (AB 2153, CA Leg.) Bill requires an advance recycling fee of $1 per Iead-acid (auto) battery at the time of purchase in order to fund proper battery disposal and recycling efforts. The fee will increase to $2 per battery in April 2022. Automotive Repair: Oil Changes: Notification to Customers. (SB 778, CA Leg.) The bill would require an automotive repair dealer or an autornotive maintenance provider performing oiI change services to use the manufacturer's published oiI dram schedule when recommending an oil change to a customer. Treatment Plant Discharge Permit page/4 Relevance to the District 1) Pesticides of emerging concern (Fipronil and Pyrethroids, in particular) are being detected in the infiuent and effluent of POTWs, including CCCSD. 2) This is a concern both due to the potential for future 303(d) listings ofthese pesticides in SF Bay and due their potential to contribute to toxicity, in light of the State's efforts to develop and implement a statewide Toxicity Currently, the lead -acid batteries the HHW Program collects are a source of revenue that offset some of the costof waste management. This new bill should reduce the number lead -acid batteries received by the HHW program, which could reduce overall costs. Retailers will be required to take these batteries back. 1) If enacted, the hill would help reduce unnecessary oil changes by recommending the manufacturers service schedule, instead of using an industry standard of 3,500 miles. 2) A reduction in the amount of used motor oil generated by "Do-it-Yourselfer's" may also occur. 1) Permits discharge oftreated effluent into the Bay. 2) Monitoring and Reporting required; enforceable limits. 1) 2) Current Status BAppG'sPesticide Worheroupis continuing to raise wastewater considerations and provide comment letters on registration and reregistration decisions by both EPA OPP's and the California Department of Pesticide Regulations' processes to consider fate and transport through POTWs. This work is being coordinated with NACWA's Emerging Contaminants Workgroup. CASA's Statewide Pesticides Steering Committee, which 15 managing the work of consultant Larry VVa|ker& Associates (LWA), is focused on evaluating and commenting on Central Valley Water Board (Region V) pesticide actions, including the BPA and TMDL for pyrethroid pesticides, and for water quality criteria development for fipronil by UC Davis. This bill was chaptered September 2016. This hill was vetoed by the Governor on 9/30/16 and remains in Senate pending consideration. 1) Expires 3/31/17. 2) New permit expected 4/17. 3) Submitted ROWD by the 9/30/16 deadline. 4) Expected draft administrative order in January 2017. Regulatory Updates - List of Significant Issues Next Steps 1) Central Val!ey Regional Board (CVRB) hearing set for Feb 2017. Board to hear public comments on Amendment to the Water quality Control Plan for Sacramento and San Joaquin River Basins for coritrol of Pyrethroids Pesticide Discharges. 2) SWRCB hearing to consider adoption (of Pyrethroid BPA and TMDL) scheduled for April 2017. None Watch and support as needed. Review draft permit and provide comments to the NPDES-2 NPDES-4 Subject North SF Bay (NSFB) Selenium TMDL Total maximum daily load ofl7 arforthe0strict- Testmf Significant Toxicity (TST) (Draft State Policy) New statistical method to determine whether effluent 15 toxic. c. Federal Electronic Reporting Rule Page 15 Relevance to the District 1) NSFBwas 3O3dlisted for Seinthe early 2OO8s 2) RVVO[Bstaff developed waste load allocation (WLA)for CCCSD; set at current performance, with anticipation that Ioads would be exceeded 50% of time 3) Selenlum Total Maximum Daily Load once a permit to evaluate selenium Ioads to demonstrate consistent loads with WLA 4) No enforceable mechanism; potential for WQBEL in future 1) Policy that EPA and SWRCB support 2) Numeric limits for chronic toxicity 3) Use of TST as statistical method to determine chronic toxicity 4) RVVCC8 Discretion on inclusion of acute toxicity in permits and whether to allow for dilution (test whole effluent at receiving water dilution)(recent internal draft indicate allowance for dilution) 5) Testing frequency for CCCSD t from 1/0 to 1/M 1) Subrnit all NPDES reports electronically 2) Phased in over the next 5 years 3) CA already reports electronically, but must show federal gov't that the system is compliant 1) 2) 3) 4) 5) 6) Current Status CCCSD submitted comments on WLA 9/8/15; Ioad allocated to CCCSD did not account for current method of analysis; Lori and Mary Lou discussed this with RWOCB staif prior to commenting. RWOCB staff reviewing cornments and making revisions as appropriate. Public Hearing l2/1A/15. RWOCB Approved November 2015. SWRC Approved March 2016. EPA approved TMDL August 2016. 1) Draft issued 2012. 2) Revised Draft developed 2015, but not made public. 3) Revised Draft shared with Regional Water Boards, Fall 2016. 4) Revised Public Draft expected to be released early 2017 with adoption in summer of 2017. 5) BACWA worng with RWQCB to secure desired outcome. 1) Effective 8/15 with r implementation schedule broken into 2 phases: 2) Phase 1: Authorized NPDES programs required to submit implementation plan to EPA by I2/21/2016. 3) Phase 11 Electronic reporting of Sewage Sludge/biosolids annual report, MS4 storm water annual reports, Pre -Treatment reports etc. Regulatory Updates - List of Significant Issues Next Steps CCCSD (Lori and Mary Lou) keeping apprised of any potential issues that may arise due to new EPA criteria. 1) POTWs/BACWA to petition for reduced testing frequency based on past performance (from 1/M to 1/0). 2) If TST becomes effective, CCCSD will train staif for proficiency in chronic toxicity versus sending out if have organism we can work with easily. AaofNovember 2O26CAhas limited approval, Cross - Media Electronic Reporting Rule (CROMERR) compliant, and with the addition of a "simple Supplementary statementbvthestateAttorneyGenena|"vviUqua|ifvas "broadly applicable" aka: CROMERR compliant. No NPDES-5 NPDES-6 Water -1 Subject SF Bay Basin Plan Triennial Review Waters of the US Rule (fed. reg.) Rule would establish new standards to determine when waters are subject to regulation under the Clean Water Act. USEPA officially finalized the rule in 5/15 after reviewing more than one million public comments. Nutrient Watershed Permit Regional permit directing POTWs to monitor and report nutrient concentrations and loads; calls for regional effort to evaluate potential nutrient discharge reductions by treatment plant optimization, side -stream treatment, treatment plant upgrades, or other means. PCB and Hg Watershed Permit Regional permit directing POTWs to monitor and reduce Water -2 discharges of PCBs and Hg. Page |G Relevance to the District RWQCB determines where updates need to be made to Basin PIan and prioritizes where resources witi be used every 3 years. CCCSD required to meet permit expectations; working with BACWA, SFEI, Consultants, and others to meet permit expectations. 1) Final Hg TMDL allocation (llkg/yr.) was reached within the first five years of implementation; source control activities were instrumental in meeting the TMDL objective so rapidly. 2) PCB aggregate aUocation of 2.9kg/yr. was met as ofthe last renewal. Current Status 1) RWQCB approved the 2015 Triennial Review in December 2015. Project ranking remains as in the Staif Report issued 10/15. Resources will be allocated to projects according to ranking shown below: 2) Review and Refine Dissolved Oxygen Objectives for San Francisco Bay (*CCCSD proponent of this project along w/ BACWA, Palo Alto, Santa Clara, U.S- EPA, and SFPUC) 3) Climate Change and Water Resources Policy 4) Develop Numeric Nutrient Endpoints (NNEs) in Freshwater Streams and Estuaries 5) Develop Nutrient Water Quality Objectives for San Francisco Bay Estuaries 6) Using Wastewater to Create, Restore, and Enhance Wetlands 7) Lake Merced Dissolved Oxygen and pH Objectives (this project can only be accomplished with additional resources). 10/9/15 U.S. Court of Appeals for the 6th Circuit Next Steps CCCSD to stay current on issues related to RWQCB's progress on priority issues. CASA tracking the status of litigation pertaining to this rule issued an order temporarily blocking implementation. as well as any related federal legislative efforts. In limbo the courls will decide if EPA and Army Corps have followed the directions Iaid out by the U.S. Supreme Court. 1) First annual report submitted in November 2015 (group report; extension received from 10/1/15 deadline in permit 2) Second annual report submitted in October 2016 3) Expires 6/30/19; Renewal 12/30/18 4) Nutrient Watershed Permit Plant Optimization Study drafts completed for 17/37 plants Expires 12/31/17 Regulatory Updates - List of Significant Issues Continue to work with BACWA, SFEI, Consultantsand others to meet permit expectations. 1) Continue to comply with permit requirements. 2) Renewal activities TBD may include: a. Support BACWA's proposal to reduce monitoring. b. Comment on the planned recalculation of the POTW Ioad allocation as needed. Water -3 Water -4 Water -5 (NEW) Water -6 Subject Federal Dental Amalgam Rule Municipal Regional (Stormwater) Permit (MRP) Environmental Laboratory Accreditation Program (ELAP) The Environmental Laboratory Accreditation Program is in the process of updating its laboratory accreditation standard. RWQCB Order No. 96-011 Regional recycled water permit for the San Francisco Bay Area. Page 17 Relevance to the District 1) EPA Proposed Rule 10/14. 2) Proposed Rule creates new category — Dental Industrial User (DIU). 3) Proposed Rule provision to convert non-compliant DIU to Significant Industrial User, requiring full oversight by CCCSD. 4) CCCSD has a mandatory amalgam separator program in place. 1) Environmental Compliance conduct inspections under interagency service agreement with Contra Costa Clean Water Program (CWP) to support 10 cities in CCCSD service area; support administrative work of agreement for Delta Diablo and WCWD for their services. 2) RWQCB views services as valuable watershed protection strategy. 3) Services provided using billable hours that include charging for the CCCSD approved overhead rate. The District maintains laboratory accreditation for NPDES self-monitoring and will be held to the new accreditation standard. Many ofthe requirements within the Standard do not improve the quality of data while adding a significant amount of documentation. 1) The permit comprises CCCSD's Treatment Plant, Filter Plant, and Zone 1 customers. 2) CCCSD's residential fill station and truck fill stations. 1) 2) 3) 4) 1) 2) Current Status NACWA, CASA and BACWA commented on proposed rule in February 2015. EPA communicated with NACWA workgroup to review comments; EPA indicated intent to modify rule to address certain comments regarding impacts to Iocal agencies. Final Rule sent to Office of Management and Budget in September 2016. EPA targeting December 2016 to adopt Final Rule. Reissued MRP adopted 11/18/15. Services under agreement used to comply with updated standards for trash management (during inspections), mobile cleaners, facilities subject to the lndustrial General Permit, and identifying potential PCB sources. October 6, 2016 State Water Resources Control Board Public Workshop 1) Recommendation for Laboratory Standard. ELAP's preliminary recommendation on 1O/6/2O1Gwas touse the NELACInstitute (TNI) 2016 accreditation standard for the state of CA. 2) SVVR[Badvised ELAP staff to work with Iabs to develop list of "minus" provision so that the task of complying with the standard is not so onerous. 3) Three year implementation is planned. 4) Staff attended ISO 17025 audit training for TN1 October 2016. BAAQMD and CCCSD commented on draft regulation Fall 2016 Regulatory Updates - List of Significant Issues Next Steps 1) Continue to monitor adoption process. 2) Contents of final rule not known; range of impact to CCCSD's current mandatory amaigam separator program from negligible to significant. Continue to work with CWP to modify level of service to help cities comply with certain MRP elements. 1) Participate through the Environmental Laboratory Technical Advisory Committee (ELTAC) and BACWA to remove standards that are irrelevant/unnecessary for the operation of a POTW |aboretory. 2) Participate ELAP/SWRCB meetings. 3) Staff are working to implement portions of the standard that make sense to Iessen the burden when Standard becomes effective. 4) ELAP to prepare the DRAFT text for regulation by Jan 2017. 5) Final adoption is anticipated in end of 2017. Working with Contra Costa Water District on a potential