HomeMy WebLinkAbout04.c. Receive annual update on Regulatory CompliancePage 1 of 12
Item 4.c.
S
Central Contra Costa Sanitary District
November 27, 2017
TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE
FROM: LORI SCHECTEL, ENVIRONMENTAL AND REGULATORY COMPLIANCE
DIVISION MANAGER
REVIEWED BY: JEAN -MARC PETIT, DIRECTOR OF ENGINEERING AND TECHNICAL
SERVICES
ROGER S. BAILEY GENERAL MANAGER
SUBJECT: RECEIVE ANNUAL UPDATE ON REGULATORY COMPLIANCE
The Regulatory Compliance group will provide an annual update on pertinent regulatory issues. Attached
is the chart supporting the discussion.
ATTACHMENTS:
1. Regulatory Compliance Chart
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 13 of 25
Central Contra Costa
Sanitary district
Page 2 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Clean Air Act Section 129
1) Annual source testing is required to demonstrate
1) Completed 129 annual Furnace No.1 Compliance
1) Continue process optimization work to maintain
Sewage Sludge Incinerator Regulations
compliance and is approximately $120-140k per year,
Demonstration Source Test in April 2017
compliance with 129 requirements
not including staff time.
2) Internal bypass reduction strategies have
2) Staff will continue to work with the Environmental
Effective March 21, 2016, the 129 Sewage Sludge
2) Potential for more frequent Reportable Compliance
successfully reduced bypass -related RCAs.
Protection Agency to establish process operating
Incinerator (SSI) regulations established new reporting,
Activities (RCAs). Increased risk for violations with new
3) Completed annual 129 operator training for
limits for scrubber pressure drop, scrubber outlet pH,
operating and emission limits for NOx, CO, SOz, HCI,
emission limits.
Operations staff.
scrubber inlet flowrate, and top hearth temperature.
cadmium, mercury, lead, and dioxinfuran. Majoorr
3) Four additional process parameters as compliance
4) Awaiting EPA response on minimum operating
3) Working with the Solids Handling Team on the pre -
s
components of the 129 regulations include:
monitors. The new minimum operating limits may
limits.
design of a new scrubber system to improve HCl
1) Minimum operating limits for continuous parametric
reduce operational flexibility.
emissions control and capture of furnace exhaust
4) Additional reporting requirements for Title V Permit.
during bypass operation
monitors
5) Modifications to existing equipment to comply with 129
a) Top Hearth Temperature
requirements, i.e. caustic system and ash loading station
b) Wet scrubber inlet flow rate
modifications.
AIR -1
c) Wet scrubber outlet pH
6) Use of bypass stack must be reported to the Bay Area
d) Wet scrubber Differential Pressure (0) drop
Air Quality Management District.
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 loss of life, personal
injury, or severe property damage, though must be
reported. Breakdown relief may be granted.
Title V Compliance
1) Central San is subject to increased process monitoring,
1) Completed Title V 5 -Year Compliance Source Test
Continue to work closely with Operations staff and
reporting, and data retention requirements.
on Furnace No.1 in April 2017.
BAAQMD officials to ensure full compliance with all Title V
Title V is a national Federal air permitting program under
2) Dual permit action for any significant changes:
2) Monitoring and analysis of process data to ensure
permit requirements.
the Clean Air Act. The Treatment Plant's Title V permit
a) Title V Permit
permit limits.
lists all applicable regional, state, and Federal air
b) BAAQMD annual Permit -to -Operate
3) Prompt and accurate reporting (monthly,
requirements. All submitted Title V compliance
3) Permit renewal is completed every 5 years.
quarterly, semi-annual, and annual) to BAAQMD.
documents are certified by "responsible official". Title V
4) Increased annual permit fees every year.
4) Preparation for routine site inspections.
AIR -2
permit holder responsible for compliance with all
5) Reportable Compliance Activities (RCA's) for
5) BAAQMD issued Authority to Construct permits
applicable regulations even if not in Title V permit. Title
communicating permit excursions or exceedances.
for Headworks Improvement Project, Scrubber
V Permit renewed every 5 years, and the last renewal in
6) 5 -year recordkeeping requirements.
Pilot Plant, and Cogen CO Catalyst.
March 2015. The Bay Area Air Quality Management
District (BAAQMD) is the delegated enforcement
authority.
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 14 of 25
Central Contra Costa
Sanitary District
Page 3 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
AB 32 Global Warming Solutions Act
1) Central San is required to complete mandatory annual
1) Actively manage natural gas use at the Treatment
1) Continue to track development of state and federal
reporting and verification of the Treatment Plant's
Plant to remain under the Cap and Trade Program
GHG regulations to ensure compliance.
First state legislation in the nation to regulate
annual GHG emissions inventory.
trigger of 25,000 MT CO2e anthropogenic
2) Staff will continue to work with CASA Climate Change
greenhouse gas emissions and establishes targets for
2) Added compliance costs and obligations for future
emissions. This saves Central San a minimum of
Group and BACWA AIR Committee to obtain
future statewide greenhouse gas (GHG) emissions. Rules
expansion if anthropogenic GHG emissions exceed the
$300,000 per year.
regulatory updates and provide comments through
developed and enforced by the California Air Resources
25,000 MT CO2e Cap and Trade trigger.
2) Prepare, submit, and verify annual GHG
Committee as necessary.
Board (CARE). AB32 Scoping Plan outlines the approach
3) CARB states POTWs are part of the solution for methane
inventories.
for the State to meet its GHG emissions reduction targets
reduction, and encourages diversion of organics to
3) Calendar year 2016 anthropogenic emissions:
through 2020 and goals through 2050.
POTWS to use excess digester capacity and produce
22,389 MT CO2e.
biogas for use as transportation fuel.
4) Projected calendar year 2017 anthropogenic
1) Required reductions for the State of California
4) POTWs are exploring energy generation opportunities;
emissions: below 24,000 MT CO2e.
a) Reduce to 1990 emissions levels by 2020
however, competing toxic air emissions regulations
5) CARB released the updated 2017 Climate Change
AIR -3
b) Reduce to 40% below 1990 emissions levels by
proposed make waste -to -energy programs more
Scoping Plan in October 2017. Updated reflects
2030
expensive.
Governor's Executive Order B-30-15 and Senate
c) Reduce to 80% below 1990 emissions levels by
Bill 32, which establish a mid-term greenhouse gas
2050
(GHG) emission reduction target for California of
2) Cap and Trade Program
40 percent below 1990 levels by 2030.
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
AB 398• Cap and Trade Bill
No immediate effect on Central San unless Cap and Trade
1) The proposed Draft 2030 Target Scoping Plan
Staff will continue to work with CASA Climate Change
threshold is triggered. Future Treatment Plant projects
Update was released in January 2017 for public
Group and BACWA AIR Committee to obtain regulatory
Bill signed into State law on July 25, 2017, and officially
should evaluate potential GHG impacts.
comment. Describes CA's approach to reduce GHG
updates and provide comments as necessary.
extends the Cap and Trade Program to 2030, and
emissions: 1990 levels by 2020; 40% below 1990
requires CARB to:
levels by 2030; and 80% below 1990 levels by
2050.
1) Establish a price ceiling on GHG emission allowances
2) CASA drafted comment letter
AIR -4
2) Add conditions governing the management and
(NEW)
allocation of allowances
3) Reduce limits on compliance offsets
4) Update the scoping plan by January 1, 2018
5) Prohibit an air district from adopting or implementing
an emission reduction rule for carbon dioxide from
stationary sources that are subject to the cap -and -
trade regulation
Page 1 2
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 15 of 25
Central Contra Costa
Sanitary District
Page 4 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Portable Diesel Engine Regulation
1) 11 portable diesel engines in District Fleet were not EPA
1) Two portable diesel engines at the Treatment
Remaining six engines to be taken out -of -service and/or
Final Tier 4 certified as of November 2016: once
Plant have been taken out -of -service and replaced
replaced by January 1, 2020.
Per the California Air Resources Board (CARB) Air Toxics
replaced, will become Final Tier 4.
with portable diesel engines < 50 hp.
Control Measure (ATCM), all portable diesel engines > 50
2) Increased equipment budget to replace these engines.
2) One portable diesel engine at Orinda Crossroads
horsepower be certified to EPA Tier 4. Final standards for
Pumping Station was taken out -of -service.
emissions of particulate, NOx, and organics. The
3) Two diesel engines at CSO were taken out -of -
AIR -5
regulations were adopted in February 2011.
service.
In addition, the average emissions from the fleet
(includes new and existing portable diesel engines) must
meet the January 2013 fleet particulate standards. CARB
plans to amend the portable diesel engine fleet average
particulate standards in late 2017.
BAAQMD Reg 11-18: Reduction of Air Toxic
1) Treatment plant facility risk is likely > 10 in a million.
1) Public comment on final draft rule due by October
1) Working with Black & Veatch to determine baseline
Emissions from Existing Facilities
2) Will influence the selection of future air pollution
16, 2017. BACWA and Central San provided
health risks for treatment plant and strategize risk
controls projects under the Solids Handling Project.
comments to BAAQMD, supporting the revisions
reduction measures.
BAAQMD has published proposed Rule 11-18 to reduce
3) Facilities with only one or more stationary diesel
in the draft rules.
air toxic emissions from existing facilities that would pose
engines for emergency -use (e.g. pump stations), and
2) Rule adopted on November 15, 2017.
unacceptable health risk to nearby residents and off-site
non -routine sources (e.g. wet -weather holding basins)
4) BAAQMD has moved all POTWs to Phase 2 for
AIR -6
workers. Facilities with incremental cancer risk greater
are exempt.
implementation of the rule. (Phase 2 begins in
than (>) 10 in a million would be required to reduce
2019 with the development of HRA followed by 5 -
facility incremental cancer risk to < 10 in a million and/or
year implementation of TBARCT, if the facility
add Best Available Retrofit Control Technology for Toxics
triggers risk reduction requirements).
(TBARCT) to any single source with an incremental cancer
risk > 1 in a million, and submit a Risk Reduction Plan to
BAAQMD outlining implementation details of risk
reduction measures.
Page 1 3
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 16 of 25
Central Contra Costa
Sanitary District
Page 5 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Amended BAAQMD Regulations
1) New or modified sources at the treatment plant that are
1) BACWA submitted comment letter to BAAQMD in
BAAQMD will submit rule amendments to the USEPA to
Rule 2-1• General Requirements,
'
subject to New Source Review, could be required to
June 2017.
revise the California State Implementation Plan as
install Best Available Control Technology (SACT) if
2) Public hearing held and amendments adopted on
required by the federal Clean Air Act. This would allow
Rule 2-2: New Source Review, and
emissions increase is > 10 pounds per day.
October 18, 2017.
USEPA to approve BAAQMD's New Source Review
Rule 2-6: Major Facility Review
2) Larger emission increases for new project due to change
program under the federal Clean Air Act.
in the way emissions increases for New Source Review
AIR -7
The amendments to these three rules are meant to
projects are determined:
(NEW)
1) to address certain "deficiencies" identified by EPA in
a) Potential -to -Emit is based on facility operating at
order to allow EPA to fully approve the Air District's
100% of capacity
NSR program under the federal Clean Air Act;
b) Prior to amendments - Potential -To -Emit of new
2) to address certain other areas where further
project minus Potential -To -Emit of existing project
revisions and clarifications of the NSR regulations are
c) After amendments - Potential -to -Emit of new
needed;
project minus actual emissions from existing project
3) align BAAQMD's programs with the US Supreme
averaged over past three years.
Court's ruling in Utility Air Regulatory Group v. EPA
Amended BAAQMD Reg 2-5• New Source
If new or modified source status is triggered for the furnace,
Will not impact District's operations unless a new or
Review new projects to see if TBACT is triggered.
Review of Toxic Air Contaminants
Central San would be required to install TBACT to reduce
modified source status triggered.
toxic air contaminants.
AIR -8
Effective December 7, 2016, amendments to Regulation
2, Rule 5, applies to preconstruction permit review to
new and modified sources of toxic air contaminants and
may require implementation of Toxic Best Available
Control Technology (TBACT).
Revised Amendments to BAAQMD
1) New definition of particulate matter includes
1) Central San staff is working closely with BAAQMD
Continue to engage BAAQMD rule developer and track the
Particulate Matter Regulation 6 and 6-1
condensable particulates. This can significantly increase
rule developer to address the short
status of the draft amendments.
furnace's particulate matter emissions over baseline
implementation timeframe of the proposed
AIR -9
Proposed amendments to Regulation 6 incorporate the
emissions.
2) More stringent total suspended particulate limits may
amendments.
2) BAQMD staff has indicated that the potential
(NEW)
new definition of particulate matter categories.
require the installation of new air pollution control
replacement of Central San's scrubber would
Amendments to Regulation 6, Rule 1: Particulate Matter -
technology on the furnaces.
exceed BAAQMD's economic feasibility threshold,
General Requirements would update particulate
potentially exempting Central San from the rule.
emissions limits from general sources to reflect the most
stringent levels achievable.
Page 14
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 17 of 25
Central Contra Costa
Sanitary District
Page 6 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Enforceable Agreement with Department of
1) Staff time is utilized to conduct inspections, repairs, and
1) Complete monthly and quarterly inspections,
Continue to maintain the integrity of the soil cap by
Toxic Substances Control (DTSC) for Soil Cap
reports.
necessary repairs, and reports as needed.
conducting routine inspections and making necessary
2) Limitation on the use of the soil cap area. Large
2) Coordinate with Capital Projects on Treatment
repairs.
remediation cost added to any expansion into soil cap
Plant projects. Provide proper notification and
Central San has a written agreement with DTSC to
area.
follow-up report to DTSC on any Treatment Plant
maintain the soil capon Basin A South and Surcharge Fill
3) Central San is required to ensure compliance with
excavation projects.
Area. The agreement requires periodic inspections and
current hazardous material regulations when/if soil cap
3) DTSC no longer performs annual inspections
repairs as needed. Reporting requirements include semi-
area is ever excavated.
because District has been in full compliance with
SOIL -1
annual, 5 -year summary report, and reports on any
internal inspection requirements.
excavation work on Treatment Plant site. As part of
4) Prepared contract to repair petroleum seeps in
agreement, the entire Treatment Plant site was
Basin A South.
designated a single waste management unit. As a single
5) Working with Geosyntec to evaluate remedial
waste management unit, CCCSD does not require a
alternatives for treating contaminated soil in
Treatment, Storage, and Disposal (TSD) permit to manage
Surcharge Fill Area.
existing hazardous waste in the single waste
management unit.
Microplastics
1) CA Comprehensive Microbead Ban in consumer
1) Governor signed bill in October 2015.
1) BACWA working w/ SFEI to better understand the
products.
2) Manufacturers must comply by 2020.
issue.
The Regional Monitoring Program is currently engaged in
2) SFEI Poster at State of the Estuary Conference showing
3) BACWA met with Feinstein's staff to discuss
2) Participate in future studies and RMP CEC Workgroup.
a study on microplastics. Looking to determine
results of preliminary survey in Bay Area wastewater
increased funding to study issue through SFEL
3) 2016 SFEI Draft Strategy—scope and cost to be
microplastics pollution in the San Francisco Bay with
effluent and surface waters.
refined.
CEC-1
POTW participation from the BACWA community.
3) Bay Area POTWs with filtration have similar levels of
microplastics in their effluent as facilities without
filtration.
4) Control at the source — how do we do this?
Page 1 5
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 18 of 25
Central Contra Costa
Sanitary District
Page 7 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Pesticides
1) Pesticides of emerging concern (Fipronil and
1) EPA has been reviewing the registration of several
1) The SWRCB is currently accepting comments (through
Pyrethroids, in particular) are being detected in the
key pesticides over the last two years, a task it
November 2, 2017) on the CVRB's BPA and TMDL for
Pesticides are regulated via FIFRA, and not the Clean
influent and effluent of POTWs, including Central San.
conducts once every 15 years. BACWA/BAPPG's
Pyrethroid Pesticide Discharges in the Sacramento and
Water Act. POTWs do not have the authority to regulate
2) This is a concern both due to the potential for future
Pesticide Workgroup has continued to raise
San Joaquin River Basins, with an adoption hearing
pesticide use in their service area, but may be
303(d) listings of these pesticides in SF Bay and due their
wastewater considerations and has provided
anticipated in early 2018.
responsible for pesticide impacts to their treatment
potential to contribute to toxicity, in light of the State's
comment letters on registration and reregistration
2) Continue to work with BACWA and BAPPG to
processes or to surface water.
efforts to develop and implement a statewide Toxicity
decisions by both EPA OPP's and the California
comment, as necessary, on new pesticide registrations
Plan.
Department of Pesticide Regulations' processes to
and pesticide registration reviews.
Through BAPPG, BACWA supports a scientifically -sound
consider fate and transport through POTWs. This
CEC-2
pesticide management program that will not impact
work is being coordinated with NACWA's
POTWs' primary functions of collection and treating
Emerging Contaminants Workgroup.
wastewater, recycled water, and managing biosolids.
2) On June 8, 2017, the Central Valley Regional Board
(CVRB) adopted a Basin Plan Amendment to the
The current EPA Office of Pesticide Programs (OPP) new
Water Quality Control Plan for the Sacramento
registration and registration review processes for
and San Joaquin River Basins for control of
pesticides does not take into account the POTW pathway
Pyrethroid Pesticides Discharges, which included
in evaluating fate and transport of pesticides to
favorable language for the covered POTW
waterways. As a result, pesticides are being registered for
dischargers.
indoor uses that result in discharges to POTWs.
NPDES Treatment Plant Discharge Permit
1) NPDES Treatment Plant Discharge Permit regulates
1) New Treatment Plant Discharge Permit Order No.
Continue to work closely with Operations staff and
discharge of treated effluent into the SF Bay. Includes
R2-2017-0009 was issued. Effective until May 31,
RWQCB officials to ensure full compliance with all NPDES
enforceable limits and monitoring and requirements.
2022.
permit requirements.
2) Prepared Toxicity Reduction Evaluation workplan
NPDES-1
in August 2017, within 90 days of the issuance of
the new Permit.
North SF Bay (NSFB) Selenium TMDL
1) NSFB was 303d listed for Se in the early 2000s
1) Central San submitted comments on WLA
Central San keeping apprised of any potential issues that
2) RWQCB staff developed waste load allocation (WLA) for
September 8, 2015; load allocated to Central San
may arise due to new EPA criteria.
Total maximum daily load of 17.4kg/year for Central San.
Central San; set at current performance, with
did not account for current method of analysis;
anticipation that loads would be exceeded 50% of time
2) RWQCB approved November 2015.
3) Selenium Total Maximum Daily Load once a permit to
3) SWRCB approved - March 2016.
NPDES-2
evaluate selenium loads to demonstrate consistent
4) EPA approved TMDL - August 2016.
loads with WLA
4) No enforceable mechanism; potential for WQBEL in
future
Page 1 6
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 19 of 25
Central Contra Costa
Sanitary District
'd - -, �Jck,
Page 8 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Draft State Toxicity Plan —Test of Significant
1) Policy that EPA and SWRCB support
1) BACWA to comment on revised Draft Toxicity
If TST becomes effective, Central San will train staff for
Toxicity (TST)
2) Testing frequency for Central San may increase from
Plan expected to be released in 2018 (tentatively
proficiency in chronic toxicity versus sending out if have
quarterly to monthly
end of January)
organism we can work with easily.
3) High rate of false positives could result in violations
2) BACWA working with RWQCB to discuss key issues
Draft State Toxicity Policy Plan Policy issued in April 2017
depending on how in -stream waste concentrations
such as enforceable limits, monitoring frequency,
would establish/require:
(IWC) are determined in Plan. SF Bay RWQCB staff
reasonable potential analysis methodology,
■ Numeric chronic toxicity limits to agencies with
indicate they intend to work with POTWs to allocate
sensitive species screening requirements, and
Reasonable Potential
appropriate IWC
IWC.
NPDES-3
Use of Test of Significant Toxicity (TST) as
3) CASA provided comments on a draft toxicity plan
statistical method to determine toxicity in
staff report and met with SWRCB staff to discuss
effluent;
issues and strategies to address.
■ RWQCB discretion on inclusion of acute toxicity
in permits and whether to allow for dilution (test
whole effluent at receiving water dilution)
(recent). Recent internal draft indicate allowance
for dilution)
Federal Electronic Reporting Rule
1) Submit all NPDES reports electronically
1) Effective August 2015 with five-year
As of November 2016, CA has limited approval, Cross -
2) Phased in over the next 5 years
implementation schedule broken into two phases:
Media Electronic Reporting Rule (CROMERR) compliant,
3) CA already reports electronically, but must show federal
2) Phase I: Authorized NPDES programs required to
and with the addition of a "simple Supplementary
government that the system is compliant
submit implementation plan to EPA by December
statement by the state Attorney General" will qualify as
NPDES-4
21, 2016.
"broadly applicable" aka: CROMERR compliant. No
3) Phase II: Electronic reporting of Sewage
timeline available for statement by Attorney General.
Sludge/biosolids annual report, MS4 storm water
annual reports, Pre -Treatment reports etc.
Waters of the US Rule
October 8, 2015 - U.S. Court of Appeals for the 6th
CASA tracking the status of litigation pertaining to this rule
Circuit issued an order temporarily blocking
as well as any related federal legislative efforts.
Rule would establish new standards to determine when
implementation.
waters are subject to regulation under the Clean Water
Act. USEPA officially finalized the rule in May 2015 after
Still in limbo. USEPA and Army Corps are proceeding
reviewing more than one million public comments.
with rulemaking. Stakeholder listening sessions were
held with the water/wastewater session held on
NPDES-6
11/14/17. EPA and Army Corps proposing to amend
the effective date of the rule for two years to give
them time to reconsider the definition of WOTUS.
Written comments are also being accepted to assist
the agencies with developing the next regulations
which are intended to comply with the Supreme Court
decision on the prior regulations.
Page 1 7
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 20 of 25
Central Contra Costa
Sanitary District
Page 9 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Page 18
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 21 of 25
Subject
Relevance to Central San
Recent Status
Next Steps
Nutrient Watershed Permit
1)
Central San required to meet permit expectations;
1)
BACWA Group Nutrient Annual Report submitted
1)
Continue to work with BACWA, SFEI, Consultants, and
working with BACWA, SFEI, Consultants, and others to
in October 2017
others to meet permit expectations.
Effective July 1, 2014, the Regional permit:
meet permit expectations.
2)
Central San funded Suisun Bay modeling in
2)
Continue to report nutrient monitoring to the Water
2)
The watershed permit specifies $880k/year of funding
FY2016-17.
Boards through CIWQS and to BACWA via data sheet
1) Directs POTWs to monitor and report nutrient
from POTWs to the Regional Monitoring Program, which
3)
For 2018, BACWA is voluntarily contributing an
developed by BACWA consultant.
Water -1
concentrations and loads in effluent;
BACWA has provided for 2017.
additional $200k to the science program.
3)
The RWQCB issued a Letter of Intent specifying the
2) Calls for regional effort to evaluate potential nutrient
4)
BACWA has prepared and submitted 28 draft
next Watershed Permit will not include any nutrient
discharge reductions by treatment plant
facility reports on optimization and upgrades to
load caps, but will require an increase in funding for
optimization, side -stream treatment, treatment plant
agencies.
the science program and a regional study.
upgrades, or other means.
3) Requires BACWA to fund scientific studies associated
with SF Bay Nutrient Management Strategy.
Mercury and PCB Watershed Permit
1)
Aggregate PC and Mercury loads have been well below
1)
Current Watershed Permit expires December 31,
Continue
to comply with permit requirements
waste load allocations through 2016.
2017
Effective January 1, 2013, the Regional Watershed permit
2)
Final Hg TMDL allocation (11kg/yr) was reached within
2)
Tentative Order for 2017 Watershed Permit
directing POTWs to monitor and reduce discharges of
the first five years of implementation; source control
Reissuance out for review. BACWA submitted
Water -2
PCBs and Hg based on the TMDLs for each pollutant. The
activities were instrumental in meeting the TMDL
comments.
permit requires continued risk reduction program
objective so rapidly.
3)
Watershed Permit adopted on 11/8/17 and is
funding and annual reporting of effort via BACWA.
3)
PCB aggregate allocation of 2.9kg/yr was met as of the
effective January 1, 2018.
last renewal.
4)
Monitoring frequency remains the same for
Central San.
Revised Attachment G
4)
Removes storm water monitoring.
5)
New tentative order adopted Nov 8.
Comply
with averaging requirements.
Water board staff updated the attachment
5)
Consolidates D and G making permit easier to follow.
6)
Effective Jan 12018
(Requires averaging of laboratory duplicate analysis- not
to combine Attachment D and G and pull
a problem. )
Water -2a
out storm water monitoring provision into
6)
new Attachment S.
Federal Dental Amalgam Rule
1)
Final Rule creates new category— Dental Industrial User
1)
EPA Proposed Rule October 2014. NACWA, CASA
1)
BACWA Pretreatment Committee to provide Dental
(DIU) that is not a traditional categorical standard and is
and BACWA commented on proposed rule in
Amalgam Training in December 2017.
Effective July the EPA's Dental Amalgam Rule
not a Significant IU.
February 2015.
2)
Support NACWA in effort to clarify POTW
requires all denentaltal offices to have dental amalgam
2)
Central San has an existing mandatory amalgam
2)
Final Rule published in June 2017 and became
Pretreatment Program expectations.
separator program that exceeds standards in Final Rule.
effective in July 2017.
3)
Complete revisions to one-time certification form,
Water -3
separators by July 2020. the de to collect , but time
certification report from the dental offices, but not
Central San will need to have DIUs re -submit one-time
3)
NACWA working with USEPA Headquarters staff to
provided to DIUs in Central San service area, process
responsible for compliance enforcement.
certifications to ensure they comply with Final Rule
clarify intentions of rule as they relate to
receipt of completed forms.
standards.
expectations of POTW pretreatment programs.
3)
Local agencies are not required to permit, inspect, or
FAQ document being developed.
sample dental offices unless they choose to do so under
their local programs.
Page 18
November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 21 of 25
Central Contra Costa
Sanitary District
Page 10 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
Municipal Regional (Stormwater) Permit
1) Environmental Compliance conduct inspections under
1) Reissued MRP adopted November 18, 2015.
Continue to work with CWP to modify level of service to
(MRP)
interagency service agreement with Contra Costa Clean
2) Services under agreement used to comply with
help cities comply with certain MRP elements.
Water Program (CWP) to support 10 cities in Central San
updated standards for trash management (during
service area; support administrative work of agreement
inspections), mobile cleaners, facilities subject to
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for Delta Diablo and WCWD for their services.
the Industrial General Permit, and identifying
2) RWQCB views services as valuable watershed protection
potential mercury and PCB sources.
strategy.
3) Services provided using billable hours that include
charging for the Central San approved overhead rate.
Environmental Laboratory Accreditation
The District maintains laboratory accreditation for NPDES
1) New ELAP standard selected- TNI 2016
1) Final adoption is anticipated in the summer of 2018
Program (ELAP)
self-monitoring and will be held to the new accreditation
2) Draft regulations released July 24, 2017,
2) Full TNI by January 1, 2019 or Partial TNI by January 1,
standard. Many of the requirements within the proposed
comments submitted September 7, 2017. No
2019 with quarterly QC reports until fully TNI
In August 2015, SWQCB contracted with Southern
standards do not improve the quality of data while adding a
response to comments yet.
compliant in January 1, 2022.
California Coastal Water Research Project to establish
significant amount of documentation.
3) Second set of draft regulations anticipated Dec
3) Hire consultant to assist with implementation of New
and facilitate an Expert Review Panel to examine
2017, and will include changes based on the Sept
Standard (TNI 2016). Contract in progress.
California's laboratory certification body, Environmental
7 comments.
4) Attend CWEA or other trainings to learn how others
Laboratory Accreditation Program (ELAP). The Panel
are streamlining implementation. Attendance in
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determined that ELAP's current regulations are
progress.
inadequate. And recommended that ELAP adopt the
laboratory standard established by the NELAC Institute
(TNI).
The Environmental Laboratory Technical Advisory
Committee (ELTAC) was established to assist ELAP in
technical matters that impact the laboratory community.
The committee has represented the POTW laboratory
community during his process.
Methods Update Rule (MUR 2017)
Central San must produce data for Self-monitoring report
1) EPA published the methods rule update (MUR)
Central San will comply with the new procedure for
using methods listed in 40CFR136.
August 27, 2017.
calculating the MDL.
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2) MUR became effective September 28, 2017.
(NEW)
3) Central San has updated affected SOPS to comply
with MUR changes.
RWQCB Recycled Water
This regional permit covers distribution of recycled water to
Continue to comply with the requirements contained in
General Order No. 96-011
Central San's Zone 1 customers, including Central San's
the General Order.
Residential Fill Station and Truck Fill Program.
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Regional recycled water permit for the San Francisco Bay
Area.
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November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 22 of 25
Central Contra Costa
Sanitary District
Page 11 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Subject
Relevance to Central San
Recent Status
Next Steps
SWQCB Recycled Water State General Order
The new State General Order will impact new or expanded
1) The next anticipated Central San recycled water
recycled water projects and is more onerous than the
project that will be subjected to this new order is the
In response to the Governor's proclamation of a Drought
RWQCB General Order No. 96-011.
Diablo Country Club Satellite Water Recycling Facility
State of Emergency in 2014, the SWQCB adopted a
Project.
2) The SWQCB plans to update the State General Order
General Order to streamline permitting for recycled
within the next three years subsequent to its revision
water. The General Order was reissued on June 7, 2016.
of the State Recycled Water Policy. One of the
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anticipated changes to both documents is a reduction
Although the SWQCB is intended to make enrollment
in priority pollutant monitoring.
mandatory for Regional Permittees by June 2019, the
3) Consider commenting on 2017 State Recycled Water
RWQCB only intends to enroll agencies with new or
Policy update through WateReuse. Proposed revision
expanded recycled water projects.
is expected in March 2018.
AB 967 (Alkaline Hydrolysis/Biocremation)
1. Sanitary sewer agencies can prohibit these
No Bay area agencies have a current operation in their
Decide if prohibition of such operations will be the Central
Passed
discharges; primary concern is over potential
service area.
San policy.
impacts to recycled water programs.
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2. Pretreatment systems are available for most
Monitor potential applications for this type of operations
(NEW)
Primary objective of bill to create licensing standards
pollutants expected to be present.
in Central San service area.
specific to alkaline hydrolysis (bio -cremation) facilities.
3. High strength discharges have been reported
Standards require operations to obtain permit or
from currently operating facilities.
authorization to discharge process wastewater to
sanitary sewer agencies.
Cannabis Grow Operations (SWRCB General
None
Continue program to provide oversight of indoor grow
Permit -Pending)
operations in Central San service area.
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SWRCB processing General Order to address cannabis
(NEW)
grow operations. Primary focus is on water rights and
protection of water quality from outdoor grow
operations. Indoor grow operations subject to local
program oversight for permitting and authorizing
discharges to sanitary sewer.
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November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 23 of 25
Central Contra Costa
Sanitary District
Contents
AIR 1: Clean Air Act Section 129 Sewage Sludge Incinerator Regulations
AIR 2: Title V Compliance
AIR 3: AB 32 Global Warming Solutions Act
Page 12 of 12
2017 ANNUAL SUMMARY OF KEY REGULATORY ISSUES
Page
1
1
2
AIR 4: AB 398 Cap and Trade Bill 2
AIR 5: Portable Diesel Engine Regulation 3
AIR 6: Proposed BAAQMD Reg 11-18: Reduction of Air Toxic Emissions from Existing Facilities 3
AIR 7: Revised BAAQMD Reg 2-1: General Requirements, Reg 2-2: New Source Review,
and Rule 2-6: Major Facility Review 3
AIR 8: Amended BAAQMD Reg 2-5: New Source Review of Toxic Air Contaminants 4
AIR 9: Revised Amendments to BAAQMD Particulate Matter Regulations 6 and 6-1 4
SOIL 1: Enforceable Agreement with Department of Toxic Substances Control (DTSC) for Soil Cap 4
CEC 1: Microplastics
5
CEC 2: Pesticides
5
NPDES 1: NPDES Treatment Plant Discharge Permit
6
NPDES 2: North SF Bay (NSFB) Selenium TMDL
6
NPDES 3: Draft State Toxicity Plan —Test of Significant Toxicity (TST)
6
NPDES 4: Federal Electronic Reporting Rule
7
NPDES 5: San Francisco Bay Basin Plan Triennial Review
7
NPDES 6: Waters of the US Rule
7
WATER 1: Nutrient Watershed Permit
8
WATER 2: Mercury and PCB Watershed Permit
8
WATER 3: Federal Dental Amalgam Rule
8
WATER 4: Municipal Regional (Stormwater) Permit (MRP)
9
WATER 5: Environmental Laboratory Accreditation Program (ELAP)
9
WATER 6: Methods Update Rule (MUR 2017)
10
WATER 7: RWQCB Recycled Water Order No. 96-011
10
WATER 8: SWQCB Recycled Water State General Order
10
WATER 9: AB 967 (Alkaline Hydrolysis/Biocremation) Passed
10
WATER 10: Cannabis Grow Operations (SWRCB General Permit -Pending)
10
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November 27, 2017 Special REEP Committee Meeting Agenda Packet - Page 24 of 25