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Home My WebLink AboutREAL ESTATE, ENVIRONMENTAL & PLANNING MINUTES 11-22-168.d.1)d) Central Contra Costa Sanitary District ‘q116 2016 SPECIAL MEETING OF THE CENTRAL CONTRA COSTA SANITARY DISTRICT REAL ESTATE, ENVIRONMENTAL & PLANNING COMMITTEE MINUTES Tuesday, November 22, 2016 3:00 p.m. 2nd Floor Conference Room 5019 Imhoff Place Martinez, California Committee: Chair Mike McGill Member Jim Nejedly BOARD OF DIRECTORS: TAD J. PILECKI President PAUL H. CA USEY President Pro Tem MICHAEL R. MC GILL JAMES A. NEJEDLY DAVID R. WILLIAMS PHONE: (925) 228-9500 FAX: (925) 372-0192 www.centralsan.org Staff: General Manager Roger S. Bailey Director of Engineering and Technical Services Jean -Marc Petit Communication Services & Intergov. Relations Manager Emily Barnett Planning & Development Services Division Manager Danea Gemmel! (left after Item 4.) Program Manager Melody LaBella Environmental and Regulatory Compliance Division Manager Lori Schectel Laboratory Superintendent Mary Lou Esparza (left after Item 5.) Associate Engineer Rita Cheng Heft after Item 5.) Household Hazardous Waste Supervisor David Wyatt (left after Item 5.) Assistant Engineer Robert Hess (left after Item 5.) Engineering Assistant 111 Russ Leavitt (left after Item 4.) Environmental Compliance Inspector li Jeremy Talarico (left after Item 4.) Senior Administrative Technician Cindy Granzella 1. Call Meeting to Order Chair McGill called the meeting to order at 3:00 p.m. 2. Public Comments None. Real Estate, Environmental & Planning Committee Minutes November 22, 2016 Page 2 3.* Review draft Position Paper for public hearing to receive comments on renewal of lease with Contra Costa Water District (CCWD) of Alum Pond drying Mr. Petit distributed presentation slides which summarized the current lease with CCWD (attached). Ms. Gemmell explained that CCWD may forego one basin and only renew two. COMMITTEE ACTION: Discussed and recommended Board approval. 4. Receive status update on California Environmental Quality Act (CEQA) process for Diablo Country Club (DCC) Satellite Water Recycling Facility (SWRF) Ms. LaBella explained that DCC already had an environmental consultant under contract to support the CEQA process. Staff evaluated the consultant, and determined that the consultant could perform CEQA work for the project, so as to not delay the process. The consultant is working to prepare the preliminary CEQA analysis and should have a draft of their Initial Study in late December 2016 for Central San staff to review. Central San will be the lead agency and control and direct the work of the consultant. DCC will fund the CEQA consultant. In terms of the overall CEQA schedule, current estimate is completion of the CEQA process in October 2017. COMMITTEE ACTION: Received the update. 5.* Annual update on Regulatory Compliance Ms. Schectel stated that this update will also cover the updates for Item 6 below. Mr. Petit distributed a revised list of significant issues, pointing out that additional information has been added in blue print (see attached). Mr. Hess gave a brief update on the District Permit Matrix, which is now complete and available for all employees to view on the Central San Intranet. He explained that the information is up to date, and staff will be working with a consultant to develop an automated system to generate reports or determine when renewals are due. Ms. Schectel reviewed the information included in the agenda materials. She referred to slide 3, which had one additional bullet listed (attached). COMMITTEE ACTION: Received the update. Real Estate, Environmental & Planning Committee Minutes November 22, 2016 Page 3 6. Update/debrief on meetings of Bay Area Clean Water Agencies (BACWA) Ms. Scheele' explained that the updates were included in the annual update on Regulatory Compliance. COMMITTEE ACTION: Received the update. 7. Announcements a. Future scheduled meetings: Tuesday, December 13, 2016 at 3:00 p.m. b. Mr. Petit announced that RMC Water and Environment, the consultant for the District's Recycled Water Wholesale Opportunities Study, has sold to Woodard & Curran. 8. Suggestions for future agenda items a. Mr. Bailey suggested discussing the concept of gasification at the next Committee meeting. b. Chair McGill requested an update from Ms. LaBella on the projects that she is currently working on. 9. Adjournment — at 3:53 p.m. * Attachment Item 3. (Committee Handout) PUBLIC HEARING FOR RENEWAL OF CONTRA COSTA WATER DISTRICT LEASE OF ALUM DRYING PONDS Danea Gemmell Planning & Development Services Division Manager November 22, 2016 MAP OF CCWD DRYING BASINS Att. s. Gat 1 CCWD ALUM DRYING POND LEASE • Renewal for lease that originated in 1997. • Lease is for 5 years with option for additional years not to exceed 10 total. • Staff monitors the operation via Class II kli1)Industrial User Permit. 4, • Rental Rate is $20,700/acre. Total annual lease amount will be between $126,270 and $195,000 depending on 3rd basin use. -I* ' CURRENT LEASE VALUES Rent/Year Acres Escalation 5/Acre Notes: County Quarry 5259,776 7 3% 537,111 Annually adjusted Top Soil 571,540 5.22 3% 513,724 Three year adjustment pending 7/1/17 No escalation clause. This is a 3 year Right of Granite 524,000 1 $24,000 Entry. CCWD Basins(OId) 5171,000 9.5 3% 518,000 CCWD Basins (Proposed) 5195,650 3% 520,700 15% Adjustment, Two basins rent = 5125,000 2 QUESTIONS, COMMENTS, DISCUSSION 3 Item 5. (Revised) 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 • Use of bypass dampener • Title V • Authority to Construct permit application submitted to BAAQMD in November 2016 for Headworks Improvement Project 1 Subject 129 Sewage Sludge Incinerator Regulations Effective March 21, 2016, the 129 Sewage Sludge Incinerator (551) regulations established new reporting, operating and emission Iimits for NOx, CO, SO2,PM, HCI, cadmium, mercury, Iead, 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 Operator Training 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 rnust 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 1 California Air Resources Board (CARB). 1) Required reductions for the State of California a) Reduce to199Oemissions levels bv2O2O b) Reduce to 40% below 1990 emissions Ievels by 2030 c) 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 or trade by CARB Central Contra Costa Sanitary District Regulatory Updates - List of Significant Issues November 22^ 2016 Relevance to the District 1) Annual source testing is required to demonstrate comp|ianceandisepproximatehSl2O'l4Okperyeer, not including staff time. 2) Potential for more frequent Reportable Compliance Activities. Increased risk for violations with new emission limits. 3) Four additional process parameters as compliance monitors. The new minimum operating Iimits 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 sysem 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 �� Item �� (Committee Handout) 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 limits for scrubber pressure drop, scrubber outlet pH, scrubber inlet flowrate, and top hearth temperature. 1) Actively manage natural gas use at the Treatment 1) Plant to remain under the Cap and Trde Program trigger of 25,000 MT CO2e anthropogenic 2) 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: 23,142 MTCOze. 4) Projected calendar year 2016 anthropogenic emissions below 24'OOOMT[O,e. Track development of state and federal GHG regulations routinely to ensure compliance. 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. A1R-3 AIR -4 AIR -5 (New) AIR -6 (New) Subject Title V Compliance TitIe V is a national Federal air permitting program under the Clean Air Act. The Treatment Plant's TitIe V permit lists all applicable regional, state, and Federal air requirements. All submitted TitIe V compliance documents are certified by "responsible official". Title V permit holder responsible for compliance with all applicable regulations even if not in Title V permit. Title 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 pubiished proposed Rule 11-18 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 BAAQMD 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 1 2 Relevance to the District 1) CCCSD is subject to increased process monito ring, reporting, and data retention requirements. 2) DuaI permit action for any significant changes: a) Title V Permit b) BAAQMD annual Permit -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 million. 2) Only 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 offuture projects under the Master PIan. 1) New definition of particulate matter includes condensable particulates. This can significantly increase furnace's particulate matter emissions over baseline emissions. 2) If new or modified source status is triggered for the furnace, CCM would be required to install BACT for PM2.5. Current Status 1) Regulatory Compliance staff works closely with Operations staffto ensure full compliance with alt Title V permit requirements. 2) Monitoring and analysis of process data to ensure permit limits. 3) Prompt and accurate reporting (monthly, quarterly, semi-annual, and annual) to BAAQMD. 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- sen/iceand/ornep|acedbv]anuary1,2O17. 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 implement 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 on Basin A South and Surcharge fill area. The agreement requires periodic inspections and repairs as needed. Reportingrequirementsindudesemi'annua1'S- yearsummaryreport,andreportsonanyexcavadon work on Treatment Pant site. Microplast.cs Regional monitoring program microplastics strategy. Looking to determine microplastics pollution in the San Francisco Bay. Page 1 3 Relevance to the District 1) If new or rnodified source status is t'redforthe furnace, CCCSD would be required to install TBACT to reduce toxic air contarninants. 1) Staff time is utilized to conduct inspections, repairs, and reports. 2) Limitation on the use ofthe soll 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/ifsoi\ cap area is ever excavated. 1) CA Comprehensive 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 public hearing 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) Governors' edbUllO/l5. 2) Manufacturers must comply by 2020. 3) BACWA met with Feinstein's staif to discuss increased funding to study issue through SFEI. Regulatory Updates - List of Significant Issues Continue to maintain the integrity ofthe soll 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 (NEW) HHW-2 (NEW) NPDES-1 Subject Pesticides The current EPA Office of Pesicide Programs (OPP) new registration and registration review processes for pesticides does not take into accourtt 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 to52per battery inApril 2O22. Automotive Repair: OiI Changes: Notification to Customers. (SB 778, CA Leg.) The bill would require an automotive repair dealer or an automotive maintenance provider performing oil change services to use the manufacturer's published oil drain schedule when recommending an oiI change to a customer. Treatment Plant Discharge Permit Page 14 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 Hght ofthe State's efforts to develop and implement a statewide Toxicity Plan. Currently, the Iead-acid batteries the HHW Program collects are a source of revenue that offset some of the costs of waste management. This new hill should reduce the number !ead'addba1teriesneceivedbytheHHVVprognam,vvhich could reduce overall costs. Retailers will be required to take these batteries back. 1) If enacted, the bill 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 BACWA/BAPPG's Pesticide Workgroup is continuing to raise wastewater considerations and provide comment letters on registration and reregistration decisions by both EPA OPP's and the California Depa rtment 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 is managing the work of consultant Larry Waiker & 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 9/30/26 deadline. 4) Expected draft administrative order in January 2017. Regulatory Updates - List of Significant Issues Next Steps 1) Central Va!iey 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 control 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-3 NPDES_4 Subject North SF Bay (NSFB) Selenium TMDL Total maximum daily load of 17ar for the District. Test of Significant Toxicity (TST) (Draft State Policy) New statistical method to determine whether effluent is toxic. Federal Electronic Reporting Rule Page 1 5 Relevance to the District 1) NSFBwas 3C8dlisted for Seinthe early ZOOOs 2) RVVDCBstaff developed waste load allocation (WLA)for CCCSD; set at current performance, with anticipation that Ioads would be exceeded 50% oftime 3) Selenium Total Maximum Daily Load once a permit to evaluate selenium Ioads to demonstrate consistent Ioads with WLA 4) No enforceable mechanism; potential for WOBEL 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) RWQCB Discretion on inclusion of acute toxicity in permits and whether to altow for dilution (test who!e effluent at receiving water dilution)(recent internal draft indicate allowance for dilution) 5) Testing frequency for CCCSD from 1/0 to 1/M 1) 2) 3) 4) 5) 6) Current Status CCCSD submitted comments on WLA 9/8/15; load allocated to CCCSD did not account for current method of analysis; Lori and Mary Lou discussed this with RVVOCB staff prior to commenting. RWOCB staff reviewing comments and making revisions as appropriate. Public Hearing 11/18/15. RWQCB 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 working with RWOCB to secure desired outcome. 1) Submit all NPDES reports electronically 1) Effective 8/15 with five-year implementation 2) Phased in over the next 5 years schedule broken into 2 phases: 3) CA already reports electronicatly, but must show federal 2) Phase 1: Authorized NPDES programs required to gov't that the system is compliant submit implementation plan to EPA by 12/21/2016. 3) Phase 11 Electronic reporting of Sewage Sludge/biosolids annual report, M54 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. AsofNovember ZO16CAhas limited approval, Cross - Media BecLronicRepordngRu|e([ROMERR)comp|iant, and with the addition of a "simple Supplementary statementbythestateAttorneyGenera|"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 Ioads; calls for regional effort to evaluate potential nutrient discharge reductions by treatment plant optimization, side -stream treatment, treatment plarit 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 16 Relevance to the District RWQC8detennines where updates need to be made to Basin Plan and prioritizes where resources will 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 allocation 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 Staff 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 ofthis 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). Next Steps CCCSD to stay current on issues related to RWOCB's progress on priority issues. 10/9/15 U.S. Court of Appeals for the 6th Circuit 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 courts 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 Novernber 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 requirement . 2) Renewal activities TBD may include: a. Support BACWA's proposal to reduce monitoring. b. Comrnent on the planned recalculation ofthe 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 (ELAN 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 amaigam separator program in place. 1) Environmental Compliance conduct inspections under interagency servce 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. Current Status 1) NACWA, CASA and BACWA commented on proposed rule in February 2015. 2) EPA communicated with NACWA workgroup to review comments; EPA indicated intent to modify rule to address certain comments regarding impacts to local agencies. 3) Final Rule sent to Office of Management and Budget in September 2016. 4) EPA targeting December 2016 to adopt Final Rule. 1) Reissued MRP adopted 11/18/15. 2) Services under agreement used to comply with updated standards for trash management (during inspections), mobile cleaners, facilities subject to the Industrial 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 10/6/2016 was to use the NELAC Institute (TNI) 2016 accreditation standard for the state of CA. 2) SWRCB advised ELAP staif 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 |SOl7O25audit training for TN| October 2016. BACWAand CCM 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 amalgam separator program from negligible to significant. Continue to work with CWP to rnodify 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 laboratory. 2) Participate ELAP/SWRCB meetings. 3) Staff are working to implement portions of the standard that make sense to lessen 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