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Home My WebLink About11.a. Update on Pollution Prevention (P2) Program Page 1 of 31 Item II.a. Central Contra Costa Sanitary District March 15, 2018 TO: HONORABLE BOARD OF DIRECTORS FROM: COLLEEN HENRY, SENIOR ENVIRONMENTAL COMPLIANCE INSPECTOR REVIEWED BY: LORI SCHECTEL, ENVIRONMENTAL & REGULATORY COMPLIANCE DIVISION MANAGER JEAN-MARC PETIT, DIRECTOR OF ENGINEERINGAND TECHNICAL SERVICES ROGER S. BAILEY, GENERAL MANAGER SUBJECT: UPDATE ON POLLUTION PREVENTION (P2) PROGRAM Central San is required to prepare and submit an Annual Pollution Prevention (P2) Report to the Regional Water Quality Control Board (Regional Board) by the end of February every year. The report details the performance of Central San's P2 Program and includes a summary of Central San's efforts to expand P2 awareness. The 2017 Annual Pollution Prevention Report was submitted to the Regional Board via the California Integrated Water Quality System on February 27, 2018. The P2 Program presentation and the Executive Summary from the report are attached. Please contact the Secretary of the District if you wish to receive a copy of the full 99-page report. Strategic Plan re-In GOAL TWO: Strive to Meet Regulatory Requirements Strategy 1 - Strive to Achieve 100% Permit Compliance in Air, Water, Land and Other Regulations ATTACHMENTS: 1. Presentation 2. Executive Summary- 2017 Annual Pollution Prevention Report March 15, 2018 Regular Board Meeting Agenda Packet- Page 199 of 275 Page 2 of 31 ANNUAL UPDATE ON CENTRAL SAN'S POLLUTION PREVENTION PROGRAM Colleen Henry - Senior Environmental Compliance Inspector 4»p. i Board Meeting March 15, 2018 1 2017 PRIORITY POLLUTANTS OF CONCERN • National Pollutant Discharge Contribute to Sanitary Sewer Elimination System Permit Limits Overflows • Acrylonitrile • Ammonia • Fats, Oils& Grease (FOG) • Bis-2(ethyl-hexyl)phthlate • Flushable & Non-Dispersible • Dioxins Products • Regional Requirements • Copper • Cyanide • Mercury • PCBs • Selenium 1 March 15, 2018 Regular Board Meeting Agenda Packet- Page 200 of 275 Page 3 of 31 Comm-nitly I Outreach L— Household Hazardous Waste Program W) F" Pollution \ PreventionLegislative i / Program F'Regulatory a' �c 'I ollaborative 4Efforts Relationships r � - HHW COLLECTION PROGRAM Collected over 2 million pounds (lbs) of HHW Collected over 100 lbs of mercury waste 416,701 feet of fluorescent lamps 814 thermometers Collected over 24,000 lbs of pesticides Collected about 16,680 lbs of pharmaceuticals Over 110,000 lbs since program inception (2009) z March 15, 2018 Regular Board Meeting Agenda Packet- Page 201 of 275 Page 4 of 31 PRETREATMENT PROGRAM Conducted 1 ,328 inspections at 1 ,018 businesses Issued or administered 765 discharge permits Continued monitoring pollutants in our collection system Continued implementing our Mandatory Dental Amalgam Program COMMUNITY OUTREACH Included P2 articles in the two issues of the Pipeline mailed to all customers Reached over 6,300 students through our student education programs Water Wizards, Sewer Science & Delta Discovery Public Service Announcements Pesticides, pharmaceuticals & FOG _.. Afth- t' 3 March 15, 2018 Regular Board Meeting Agenda Packet- Page 202 of 275 Page 5 of 31 COLLABORATIVE PARTNERSHIPS Contra Costa Green Business Program 2 new businesses certified (335 total) Contra Costa Clean Water Program 1 ,040 inspections at 883 businesses Sustainable Contra Costa Visionary partner P2 Awards L REGULATORY & LEGISLATIVE EFFORTS As a member of the Bay Area Pollution Prevention Group Track and comment on pesticide registration to ensure consideration of water quality concerns Dialog with EPA and DPR about pet flea control treatments Ensure EPA requires proper labeling on swimming pool products 4 March 15, 2018 Regular Board Meeting Agenda Packet- Page 203 of 275 Page 6 of 31 2018 P2 PLt Pollutants of Emerging Concern Pesticides Flame retardants Nanotechnology Nonylphenol Ethoxylates Pharmaceuticals and Personal-care products Microplastics Air toxics .41 ACKNOWLEDGEMENTS P2 Small Workgroup • Communication Services • Environmental Compliance • Household Hazardous Waste Laboratory Regulatory Compliance 5 March 15, 2018 Regular Board Meeting Agenda Packet- Page 204 of 275 Page 7 of 31 QUESTIONS? [jam 6 March 15, 2018 Regular Board Meeting Agenda Packet- Page 205 of 275 Page 8 of 31 Central Contra Costa Sanitary District Annual Pollution Prevention Report (For Calendar Year 2017) February 2018 Prepared By: Randy Schmidt, P.E. Central Contra Costa Sanitary District March 15, 2018 Regular Board Meeting Agenda Packet- Page 206 of 275 Page 9 of 31 TABLE OF CONTENTS I. ACKNOWLEDGMENTS ....................................................................................... 1 II. EXECUTIVE SUMMARY...................................................................................... 2 A. Central San's Wastewater Treatment Facilities ......................................... 2 B. Central San's Pollution Prevention Program.............................................. 2 C. Central San's 2017 Pollutants of Concern ................................................. 3 D. Central San's 2017 Summary of Pollution Prevention Activities ................ 5 E. Central San's 2018 Pollution Prevention Plan ......................................... 16 III. REQUIRED STATUS REPORTS ....................................................................... 22 A. Cyanide Control Program ........................................................................ 22 B. Copper Control Program.......................................................................... 23 C. Polychlorinated Biphenyls........................................................................ 25 IV. DETAILED DISCUSSION OF 2017 P2 ACTIVITIES.......................................... 26 A. Household Hazardous Waste Collection Program................................... 26 B. Pretreatment Program ............................................................................. 32 C. Dental Amalgam Program........................................................................ 33 D. Stormwater Inspection Program .............................................................. 33 E. Integrated Pest Management Program.................................................... 34 F. Student Education ................................................................................... 34 G. Business Outreach .................................................................................. 38 H. Community Outreach............................................................................... 39 I. Employee Outreach .................................................................................41 J. Cooperative Partnerships ........................................................................41 APPENDIXA.................................................................................................................44 March 15, 2018 Regular Board Meeting Agenda Packet- Page 207 of 275 Page 10 of 31 2017 POLLUTION PREVENTION ANNUAL REPORT I. ACKNOWLEDGMENTS Central Contra Costa Sanitary District's (Central San's) Pollution Prevention (P2) Program is the result of the combined efforts of every employee and Board member, as it works toward its mission of protecting the environment. The following staff members deserve special recognition for their contributions to this report: • Colleen Henry, Senior Environmental Compliance Inspector • Chris Carpenter, Community Affairs Representative • Tim Potter, Environmental Compliance Superintendent • Jeff Skinner, Senior Environmental Compliance Inspector • David Wyatt, Household Hazardous Waste Supervisor • Khang Nguyen, Staff Engineer • Adrianna Mendoza, Administrative Assistant Central San 2017 Pollution Prevention Annual Report Page 1 March 15, 2018 Regular Board Meeting Agenda Packet- Page 208 of 275 Page 11 of 31 II. EXECUTIVE SUMMARY A. Central San's Wastewater Treatment Facilities Central San owns and operates a municipal wastewater collection system and a secondary wastewater treatment plant rated for 53.8 million gallons per day. Central San collects, treats, recycles, and discharges wastewater from 484,200 residents and more than 3,000 businesses within ten cities and four unincorporated communities in central Contra Costa County. The collection area covers 145 square miles and includes over 1,500 miles of sewer pipelines. Central San's treatment plant consists of screening, pre-aeration, grit removal, primary sedimentation, anaerobic selection, biologically activated sludge secondary treatment, secondary clarification, and ultraviolet disinfection. Each year, Central San sends approximately 600 million gallons of treated effluent to a dual-media tertiary treatment plant to produce recycled water. The treatment plant uses about 400 million gallons of recycled water with the balance of 200 million gallons of recycled water sent to a portion of Central San's service area primarily for landscape irrigation. The remaining treated effluent discharges via a deep-water outfall to Suisun Bay. B. Central San's Pollution Prevention (P2) Program Central San has conducted several award-winning P2 programs in the service area and beyond, including: • Our Water Our World Integrated Pest Management Program • Sewer Science for high school students • Water Wizards for 3rd and 5t" grade students • Delta Discovery Voyage for 5t" grade students P2 activities are often multifunctional programs, requiring coordination among several operating units at Central San which, when taken together, contribute to an effective P2 Program: • The Household Hazardous Waste Collection Program (HHWCP) provides a solution for proper disposal of toxic household products and chemicals. • Communication Services staff provides regular outreach and educational materials to the public and Central San employees about how to keep toxics out of sewers and storm drains, tips for "going green", and other information to encourage less toxic choices and purchases. • Environmental Compliance staff performs wastewater inspections, stormwater inspections, and P2 audits at businesses and industries in Central San's service area. • Laboratory staff samples and analyzes constituents to identify and monitor pollutants of concern and determine the effectiveness of P2 efforts. Central San 2017 Pollution Prevention Annual Report Page 2 March 15, 2018 Regular Board Meeting Agenda Packet- Page 209 of 275 Page 12 of 31 • Central San staff provides representation, leadership, project management, and technical support on local, regional, statewide, and national committees to collaborate on P2 campaigns, projects, and issues. Central San works with the following agencies and organizations to take advantage of local, regional, statewide, and national efforts for reducing wastewater pollution and protecting water quality: • Bay Area Clean Water Agencies (BACWA) • Bay Area Pollution Prevention Group (BAPPG) • California Association of Sanitation Agencies (CASA) • Central Contra Costa Solid Waste Authority • Contra Costa Clean Water Program (CCCWP) • Contra Costa County Hazardous Materials Commission • Contra Costa Environmental Health • Contra Costa Green Business Program (CCGBP) • National Association of Clean Water Agencies (NACWA) C. Central San's 2017 Pollutants of Concern Central San's pollutants of concern for 2017 are comprised of three groups of pollutants, described below. 1. Priority Pollutants Pollutants with effluent limits in Central San's 2012 and 2017 National Pollutant Discharge Elimination System (NPDES) Permits or in the San Francisco Bay Mercury and Polychlorinated Biphenyls (PCBs) Watershed Permit are classified as priority pollutants. Fats, oils, grease (FOG), and flushable products are also classified as priority pollutants because of their significant contribution to sanitary sewer overflows. Although Central San does not have a Selenium effluent limit in the current NPDES permit, a Total Maximum Daily Load (TMDL) has been established for Selenium in the North San Francisco Bay. Central San's Priority Pollutants for 2017 were: • Mercury • PCBs • Dioxins • Ammonia • Cyanide • FOG • Copper • Flushable and Non-dispersible Products • Acrylonitrile • Selenium • Bis (2-ethylhexyl) phthalate 2. Watch List Pollutants Central San's Watch List pollutants appeared in previous NPDES Permits, but do not have effluent limits in the 2012 and 2017 NPDES Permits. Pollutants are removed from the Watch List if they have not had effluent limits in Central San 2017 Pollution Prevention Annual Report Page 3 March 15, 2018 Regular Board Meeting Agenda Packet- Page 210 of 275 Page 13 of 31 Central San's NPDES Permit for two permit cycles. Lead was the only Watch List Pollutant for 2017. 3. Pollutants of Emerging Concern This category includes chemicals and products emerging as pollutants of concern to water quality. It also includes pollutants for which Total Maximum Daily Loads are being developed. The following were Central San's Pollutants of Emerging Concern for 2017: • Pesticides • Pharmaceuticals and • Flame retardants personal-care products • Nanotechnology • Microplastics • Nonylphenol Ethoxylates • Air toxics Central San 2017 Pollution Prevention Annual Report Page 4 March 15, 2018 Regular Board Meeting Agenda Packet- Page 211 of 275 Page 14 of 31 D. Central San's 2017 Summary of P2 Activities The following table provides the results of the activities that Central San committed to complete in the 2017 P2 Plan. Table 1. Central San's 2017 P2 Accomplishments Section 1: Priority Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue evaluating P2 Conduct monitoring and report Sampling performed. Monthly effluent performance/impacts by any observed trends. and annual average effluent conducting targeted monitoring for concentrations continued to be low. mercury, as appropriate. Maintain Mandatory Amalgam Report compliance level of dental Continued issuing permits and Separator Program, including facilities. Report number of new processing certifications from new or permitting new practitioners. dental operations permitted and sold practices (325 practices currently Continue routine inspections. number of inspections conducted.permitted). Based on information in self-certifications, periodic compliance reports, and on-site inspections, all dental facilities achieved compliance with amalgam separator installation. One dentist was given a Warning Notice or an improperly maintained amalgam separator. 86 site visits were conducted at 83 dental practices. Continue sampling two existing Report any trends observed and Sewer monitoring results continued to mercury-monitoring sites any follow-up action taken. show positive results with some periodic downstream of dental offices, to variability. Results remain consistently track effectiveness of amalgam lower than the baseline data obtained separator installations and prior to the amalgam separator adherence to other dental installations. No targeted follow-up amalgam best management inspections were performed at the practices (BMP). Follow up with upstream dental practices in 2017. inspections of upstream dental practices, as necessary. Track development of the Federal Description of necessary program The United States Environmental Dental Amalgam Rule and changes, if any. Protection Agency(EPA)Administrator incorporate program changes, as signed the final Federal Dental necessary. Amalgam Rule on December 15, 2016, which was published on June 14, 2017 with an effective date of July 14, 2017. Central San does not need to make significant changes to its program to comply with the final rule. The initial certification form used to document the installation and maintenance of amalgam separators was modified to capture the detail required in the final rule. Central San 2017 Pollution Prevention Annual Report Page 5 March 15, 2018 Regular Board Meeting Agenda Packet- Page 212 of 275 Page 15 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue collecting, tracking, and Track the amount of elemental The HHWCP collected over 91 pounds properly disposing of elemental mercury and mercury-containing of elemental mercury and 11.2 pounds mercury and mercury-containing products collected and properly of mercury-containing products for a products via Central San's disposed of by the HHWCP. total of almost 102.6 pounds of HHWCP. mercury-containing wastes. This included 416,701 feet of fluorescent lamps. Continue the Mercury Track the number of mercury 814 mercury-filled, fever-grade Thermometer Exchange Program thermometers exchanged for thermometers were exchanged for 132 or residents and schools digital (residents)and spirit-filled digital thermometers. (chemistry laboratories)via the (schools)thermometers. HHWCP. Continue recycling the mercury- Track the number of lamps Central San recycled approximately : containing lamps used in the properly recycled. 5,017 spent ultraviolet mercury lamps. 4) Ultraviolet Disinfection Facility in Central San's treatment plant. o Continue partnerships with local List of partner stores and No new retail locations were hardware stores in Central San's outreach materials prepared. established. However, fluorescent lamp service area to provide in-store Report amount of mercury- and household battery collection Loutreach on proper disposal of containing waste collected continued at the seven existing Ace W mercury-containing items. through these partnerships. Hardware stores in the service area. These retail partners collected over 68,300 feet of fluorescent lamps and over 15,965 pounds of household batteries, which were disposed through the HHWCP. Continue to enforce the tiered Report number of businesses 325 dental offices in Central San's local discharge limits (LDL)for permitted under the tiered service area were permitted under the mercury, as adopted in February mercury LDL. mercury LDL as of December 2017. In 2007. addition, all of Central San's permitted industries have the mercury LDL included in their permits. No new industries classified as Significant Industrial Users (SIU)were permitted in 2017. Continue evaluating P2 Conduct monitoring and report Sampling performed. Results for performance/impacts by any observed trends. dioxins were consistent with previous conducting targeted monitoring for years. dioxins, as appropriate. Continue collecting, tracking, and Track the amount of dioxin- The HHWCP collected 479 pounds of properly disposing of dioxin- containing wastes collected and dioxin-containing wastes. 'o containing wastes via the properly disposed of by the o HHWCP. Tracked substances HHWCP. include pentachlorophenol, 2,4,5-T, and trichlorophenol. Continue to enforce the discharge Continue enforcement of the Facility inspections continued. No prohibition for dioxin compounds, discharge prohibition for dioxin significant sources of dioxins were as adopted in February 2007. compounds. identified. Central San 2017 Pollution Prevention Annual Report Page 6 March 15, 2018 Regular Board Meeting Agenda Packet- Page 213 of 275 Page 16 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue evaluating P2 Conduct monitoring and report Sampling performed. Results for performance/impacts by any observed trends. cyanide were consistent with previous conducting targeted monitoring for years. See the Cyanide Action Plan cyanide, as appropriate. section of this report for additional details. Continue collecting, tracking, and Track the amount of cyanide- The HHWCP collected 41 pounds of properly disposing of cyanide- containing wastes collected and cyanide-containing wastes. containing wastes via the properly disposed of by the HHWCP. HHWCP. Continue to implement the Description of appropriate Central San continued to implement the Cyanide Action Plan of the Cyanide Action Plan Cyanide Control Program elements, Cyanide Site Specific Objective, requirements completed. including inspection of the two off-site •Ewhich includes: facilities identified in the original �, 0 Maintain inventory of inventory of significant cyanide sources. v significant cyanide sources Central San continued to monitor these • Conduct required monitoring of facilities for cyanide to determine if their identified cyanide sources discharges are a significant source of • Investigate any cyanide cyanide to Central San's system. No excursions that occur in cyanide excursions were identified treatment plant monitoring during routine plant monitoring in 2017. Continue to enforce the tiered Report number of businesses Facility inspections continued. No new LDL for cyanide, including permitted under the cyanide LDL. industries were permitted under the discharge prohibition for cyanide LDL. All of Central San's unpermitted Central San permitted industries received the businesses, as adopted in cyanide LDL in their permits. February 2007. Continue evaluating P2 Conduct monitoring and report Sampling performed. Results for performance/impacts by any observed trends. copper were consistent with previous conducting targeted monitoring for years. copper, as appropriate. Continue collecting, tracking, and Track the amount of copper- The HHWCP collected 3,501 pounds of properly disposing of copper- containing wastes collected and copper-containing wastes. CL containing wastes via the properly disposed of by the Q. HHWCP. HHWCP. 0 Continue Pretreatment Program, Track the number of pretreatment Central San's Environmental which includes inspection of inspections conducted at radiator Compliance staff completed 283 radiator shops and auto repair shops and auto repair facilities. inspections at 205 vehicle service facilities, including permitting new facilities. Citations (24 Notice of acilitie Violations (NOVs) and 19 Warning Notices)were issued as a result of these inspections. Central San 2017 Pollution Prevention Annual Report Page 7 March 15, 2018 Regular Board Meeting Agenda Packet- Page 214 of 275 Page 17 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue implementation of the Continue implementation and • BAPPG contractor Stephanie Copper Action Plan, which report results. Hughes provided one presentation in includes the following elements: 2017, reaching 15 student • Support of the BAPPG's apprentices. Regional Copper Project • 34 Special Discharge Permits were • Central San's Pool and Spa issued to authorize the discharge of Permitting Program pool, spa, and fountain water to • Communication with water Central San's collection system. purveyors in Central San's • Central San periodically service area regarding copper communicates with water purveyors algaecide dosing of reservoirs regarding corrosion control practices M and corrosion control and copper algaecide dosing of practices. reservoirs. No significant changes o reported in the corrosion control —"- practices and no correlation with CL copper algaecide dosing contributing o to elevated copper concentrations in v Central San's influent. Continue implementation of tiered Track the number of businesses Applications for Class III BMP permits LDL for copper as adopted in permitted under the tiered copper continued to be sent to vehicle service February 2007. LDL. facilities that could potentially have elevated copper in their discharge. There were 277 facilities with BMP Permits as of December 2017. Eight businesses were issued Class III Industrial User(IU) Permits as of December 2017 due to engine degreasing activities. Continue evaluating P2 Conduct monitoring and report Sampling performed. Results for performance/impacts by any observed trends. acrylonitrile were consistent with conducting targeted monitoring for previous years. acrylonitrile, as appropriate. L c Continue accepting, tracking, and Since acrylonitrile is an Central San's HHWCP collected o properly disposing of acrylonitrile- occasional component of paint- 252,350 pounds of paint-related containing products, e.g. related material, the material. Q adhesives, auto-finishing paints, measurement will be the amount and wood surface products, via of paint-related materials the HHWCP. collected and properly disposed of by the HHWCP. Continue evaluating P2 Conduct monitoring and report Sampling performed. Results for bis >% performance/impacts by any observed trends. (2-ethylhexyl) phthalate were consistent conducting targeted monitoring for with previous years. 5,.T bis (2-ethylhexyl) phthalate, as r appropriate. N � N m Central San 2017 Pollution Prevention Annual Report Page 8 March 15, 2018 Regular Board Meeting Agenda Packet- Page 215 of 275 Page 18 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue evaluating P2 Conduct monitoring and report Sampling performed. PCBs were not performance/impacts by any observed trends. detected in Central San's influent or conducting targeted monitoring for effluent when using the EPA-approved m PCBs, as appropriate. method. L) Continue collecting, tracking, and Track the amount of PCB- The HHWCP collected 2,800 pounds of a y properly disposing of PCB- containing wastes collected and PCB-containing wastes. >, containing wastes (less than properly disposed of by the 50 ppm) via the HHWCP. HHWCP. a Continue investigating potential Summarize potential PCB Inspections of facilities within Central m significant sources of PCBs in sources. San's service area did not identify any m Central San's service area. significant sources of PCBs. Coordinate with CCCWP efforts to .o identify and inventory PCB 7 sources, as required under the newly adopted Municipal Regional Z Stormwater Permit. a Perform outreach encouraging Describe outreach. Outreach included in HHWCP list of proper disposal of PCB-containing accepted materials. light ballasts at the HHWCP. Continue surveying/researching Report any significant sources Central San has not identified any potential significant sources of found and summarize any follow- manufacturers that generate ammonia ammonia to Central San's up programs created. in significant quantities. Staff continued wastewater, aside from human to conduct limited surveys of potential waste. operations with potential large quantities of ammonia. No controllable sources 0 E were identified. E a Continue to collect and properly Track the amount of ammonia- The HHWCP collected 1,625 pounds of dispose of ammonia-containing containing wastes collected and ammonia-containing products. wastes at the HHWCP. properly disposed of by the HHWCP. Continue collecting, tracking, and Track the amount of residential The HHWCP collected about 3,912 properly disposing of residential FOG collected and properly gallons of residential FOG. Collected FOG wastes via the HHWCP. disposed of by the HHWCP. FOG was sent to a biofuel refining company. O u. a� W Continue inspecting and enforcing Track the number of inspections Environmental Compliance staff existing standards for controlling completed at food service completed 535 FOG inspections at 399 discharges of FOG wastes to facilities and number of food service facilities. Due to these Central San's sewer system using enforcement actions taken. inspections, 21 NOVs and 26 Warning O a targeted frequency based on Notices were issued. potential for FOG discharges. N Continue outreach on proper FOG Description of outreach. Proper FOG disposal was covered in LL disposal. Central San's Fall 2017 Pipeline newsletter (see Appendix A). It was also requently mentioned on social media accounts. Central San 2017 Pollution Prevention Annual Report Page 9 March 15, 2018 Regular Board Meeting Agenda Packet- Page 216 of 275 Page 19 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue making presentations at Number of presentations given by Environmental Compliance staff m Contra Costa County Food Safety Central San staff. presented information on proper E Classes and other forums to disposal of FOG at seven Contra Costa u- c educate Food Service staff about County Food Safety Classes. �j proper FOG disposal. Continue outreach to encourage Description of outreach. This topic was covered in Central San's all customers not to flush wipes Spring 2017 Pipeline newsletters (see 3 and other products labeled as Appendix A). Wipes were also o lushable. discussed at all community events and a speaking engagements. Continue outreach program, Report number of outreach Central San's Collection System targeting neighborhoods with high pieces sent. Planner mailed out 182 Wipes Clog accumulations of wipes with direct Pipes!postcards in 2017. LL mailers to encourage behavior change. M Continue to track opportunities to Continue tracking opportunities. NACWA and the Water Environment Lweigh in on the development of Include any comment letters Federation (WEF) continued to facilitate Q. lushability standards and submit written. efforts between the two national An comments when appropriate. workgroups comprised of wastewater and wipes industry representatives. o Central San discontinued participation Z on the wipes Product Stewardship Initiative workgroup prior to 2017. Continue evaluating P2 Conduct monitoring and report Monitoring performed. Results for performance/impacts by any observed trends. selenium were consistent with previous conducting targeted monitoring for years. selenium, as appropriate. N Continue investigating potential Summary of potential selenium Facility inspections continued. No sources of selenium in Central sources. significant sources of selenium were San's service area. identified. Central San 2017 Pollution Prevention Annual Report Page 10 March 15, 2018 Regular Board Meeting Agenda Packet- Page 217 of 275 Page 20 of 31 Section 2: Watch List Pollutants Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue evaluating P2 Conduct monitoring and report Sampling performed. Results for performance/impacts by any observed trends. lead were consistent with previous conducting targeted monitoring years. or lead, as appropriate. Continue collecting, tracking, and Track the amount of lead- The HHWCP collected 53,571 properly disposing of lead- containing wastes collected and pounds of lead-acid batteries,174 containing wastes via Central properly disposed of by the pounds of lead compounds, and 284 San's HHWCP. HHWCP. pounds of metallic lead that was recycled. Continue Pretreatment Program, Track the number of Environmental Compliance staff which includes inspections of pretreatment inspections completed 283 inspections at 205 radiator shops and auto repair conducted at radiator shops and vehicle service facilities. Citations facilities, including permitting auto repair facilities. (24 NOVs and 19 Warning Notices) new facilities. were issued as a result of these inspections. Continue implementation of Track the number of businesses Applications for Class III BMP tiered LDL for lead as adopted in permitted under the tiered LDL. permits continued to be sent to February 2007. vehicle service facilities that could potentially have elevated lead in their discharge. In 2017, 277 facilities were issued BMP Permits to control lead and other metals. Eight businesses were issued Class III Industrial User Permits as of December 2017 due to engine degreasing activities. Section 3: Pollutants of Emerging Concern Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue collecting, tracking, and Track the amount of pesticides The HHWCP collected 24,565 properly disposing of pesticides collected and properly disposed pounds of pesticides, which included via the HHWCP. of by the HHWCP. 12,670 pounds of pyrethroid pesticides. Continue outreach on pesticide Description of outreach. Outreach included in HHWCP list of reduction and proper disposal. accepted materials. Continue providing support for Description of support provided, Central San supported ongoing future research studies related to if applicable. pesticide research, conducted by the y pesticides of emerging concern. San Francisco Estuary Institute a (SFEI), with its participation in the Alternate Monitoring and Reporting Permit (R2-2016-0008). Fees associated with the permit went to SFEI's Regional Monitoring Program (RMP). Central San 2017 Pollution Prevention Annual Report Page 11 March 15, 2018 Regular Board Meeting Agenda Packet- Page 218 of 275 Page 21 of 31 Section 3: Pollutants of Emerging Concern Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue leading and supporting Support and describe efforts by Central San continued to employ a BACWA/BAPPG's efforts to track BACWA/BAPPG. landscaping company that utilizes a and comment on Federal and Integrated Pest Management in their 5 pesticide registration maintenance of Central San's c State g� c activities in support consideration grounds. Central San continued to aa. of water quality concerns and explore ways to reduce pesticide reduce pesticide discharges at usage in structural pest control heir source. applications. Continue to maintain and Track the amount of Over 16,600 pounds of unwanted promote our Pharmaceutical pharmaceutical waste collected medications were collected and Collection Program, which and proper disposal. properly disposed of at 13 collection includes collection sites at 13 law sites. enforcement agencies throughout our service area. Continue participation and Continued participation and Central San staff continued to support of regional, statewide, description of support activities participate in the dialogues on and national projects on the by Central San staff. establishing collection programs for establishment of pharmaceutical unwanted medications. In addition, collection programs that are Central San supported a regional funded by the product chain research project by quantifying 104 (manufacturers and retailers). pharmaceutical and personal care products in Central San's treatment plant influent, primaries, pre-UV, and effluent. A total of 13 samples were collected in April and July 2017. The 0 3 samples were sent to Axys oAnalytical for analysis. The CL analytical data was shared with SFEI staff who will compile Central San's U v data with those of other treatment M E plants and inform the Regional M c Board staff of any specific a m pharmaceutical or class of a pharmaceuticals that nears published effect levels for aquatic organisms. Continue accepting and properly Continued acceptance and The HHWCP continued to collect disposing of personal care proper disposal of personal care personal care products from products via Central San's products by the HHWCP. residents, although the amount HHWCP. collected was not tracked. Continue outreach to encourage Description of outreach. Proper pharmaceutical disposal (with customers to dispose of list of collection sites)was covered in pharmaceuticals and personal each issue of the Pipeline newsletter care products properly. (see Appendix A). Central San 2017 Pollution Prevention Annual Report Page 12 March 15, 2018 Regular Board Meeting Agenda Packet- Page 219 of 275 Page 22 of 31 Section 3: Pollutants of Emerging Concern Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness r Continue accepting and properly Continued acceptance and The HHWCP collected five pounds disposing of flame retardants via proper disposal of flame of flame retardants. he HHWCP. retardants by the HHWCP. Continue to track developing Continue to track information. Central San staff relies on regional information on the sources and programs studying flame retardants M control of flame retardants. in the San Francisco Bay(e.g. RMP LL and BAPPG). Continue supporting Continue support. Central San supports >% BACWA/BAPPG and CASA BACWA/BAPPG and CASA projects efforts to track developing to monitor EPA and Department of information on nanotechnology Pesticide Regulation registrations for and comment in support of water products containing nanomaterials. oquality concerns on any federal regulatory action on products z and chemicals that use nanotechnology. o w Evaluate any potential sources of Summary of potential sources Inspections did not identify any nonylphenol ethoxylates in the found and follow-up actions significant sources of nonylphenol commercial laundries within taken. ethoxylates in Central San's service cCentral San's service area. area. c � oW z 0 Continue outreach on Description of outreach. Central San did not conduct direct microplastics. outreach in 2017, but relied on f° BACWA-supported studies and 0 outreach on microplastics. Central San 2017 Pollution Prevention Annual Report Page 13 March 15, 2018 Regular Board Meeting Agenda Packet- Page 220 of 275 Page 23 of 31 Section 3: Pollutants of Emerging Concern Pollutant Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue providing support for Description of support provided, Central San provided staff time in future research studies related to if applicable. support of BACWA's effort to microplastics. improve the microplastics method. Staff carried out experiments evaluating different sample digestion procedures. : Staff worked through BACWA to 4) submit comments on the sampling 3 plan and microplastics Standard c Operating Procedure (SOP) developed by the 5-Gyres institute. N `—' The BACWA microplastics orkgroup held to the previous Q- year's goals for an SOP: 0 v • Routinely performed Not too expensive • Not too complex • Robust Quality Assurance/Quality Control criteria • Inter-laboratory reproducibility • Complete documentation and transparency Monitor development of the Bay Description of regulation The BAAQMD adopted Regulation Area Air Quality Management development progress and 11: Rule 18 on November 15, 2017. District's (BAAQMD's) proposed identification of pollutants of The purpose of the rule is to ensure Regulation 11: Rule 18 air toxics concern. that emissions of toxic air regulations to identify potential contaminants from existing facilities pollutants of concern with cross- do not pose an unacceptable health media impacts and potential risk to people living and working 0 reduction through P2 efforts. nearby. The BAAQMD will conduct L a Health Risk Assessment (HRA)to Q quantify the health risk associated with Central San's Treatment Plant. Central San is working with a contractor to develop an internal HRA to strategize different scenarios to reduce the associated cancer risk. Central San 2017 Pollution Prevention Annual Report Page 14 March 15, 2018 Regular Board Meeting Agenda Packet- Page 221 of 275 Page 24 of 31 Section 4: Continuous P2 Efforts Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue the operation and Track the total amount of The HHWCP completed its 20th promotion of Central San's Household Hazardous Waste year of operation and collected HHWCP to keep pollutants out of (HHW)collected and properly 2,260,330 pounds of hazardous the wastewater stream. disposed of by the HHWCP. waste in 2017. Three videos produced to promote HHW's 20th Anniversary Collection Week. See Community Outreach section for links. Continue Pretreatment and Track the number of inspections These programs were continued. Stormwater Inspection Programs. conducted and enforcement 1,328 pretreatment inspections Continue student education actions taken. were conducted at 1,018 facilities programs (Water Wizards, Sewer Track the number of students with 48 NOVs and 38 Warning Science, and Delta Discovery participating in each program. Notices issued. 1,040 stormwater Voyage). inspections were completed at 883 facilities with 25 NOVs and 28 Warning Notices issued. 955 students participated in the Water Wizards Program. 1,584 students participated in the Sewer Science Program. 4,000 students participated in the Delta Discovery Voyage Program. aContinue attendance at Description of events. Central San shared P2 messages N environmental/community events. with more than 4,750 people at 11 CL environmental/community events. N 3 Continue Treatment Plant and Track number of people given Central San conducted plant tours Household Hazardous Waste tours. for 300 people. P Collection Facility tours to o educate people about P2. L) Continue conducting Annual Description of program. Central San chose four businesses Pollution Prevention Awards to receive Pollution Prevention Program to recognize local Awards in 2017. Central San also businesses for achieving recognized 41 "Water Quality excellence in P2 and Community Partners" and two sustainability. "Recycled Water Champions." Continue education and outreach Description of outreach and Central San's website received through Central San's website, relevant statistics. 80,084 visitors in 2017. Video television (TV) ads, social media, ads/Public Service Announcements and various publications. aired on TV more than 1,400 times. Multiple posts were made on our Facebook, Twitter, YouTube, and blog sites. Maintain green business Maintain green business Central San maintained its green certification standards and certification. Description of any business certification in 2017. continue making green green measures added or improvements in Central San's improvements made. operations that will ensure the next green business recertification. Central San 2017 Pollution Prevention Annual Report Page 15 March 15, 2018 Regular Board Meeting Agenda Packet- Page 222 of 275 Page 25 of 31 Section 4: Continuous P2 Efforts Plan Activity for 2017 Measurement of Activity 2017 Accomplishments Effectiveness Continue tracking and supporting Provide an update on progress Central San supports the BAPPG the development of the and include copies of any and CASA projects that track Department of Toxic Substances comment or support letters developments under this program. Control's (DTSC) Green submitted. = Chemistry Initiative. Continue active participation, Continued active participation, Central San staff continued active ° membership, and support (where membership, and support of the participation and/or financial U appropriate) of various regional, various organizations/programs support of the various d statewide, and national listed. organizations committed to in organizations/programs that serve 2017. as a conduit for P2 information, Q such as BACWA, BAPPG, a CCCWP, California Water Environment Association, CASA, o Household Hazardous Waste c Information Exchange (HHWIE), c California Product Stewardship ° Council, NACWA, and the North U American Hazardous Materials Management Association (NAHMMA). E. Central San's 2018 P2 Plan Central San's 2018 P2 Plan reflects continued efforts to mitigate pollutants of concern. For many pollutants, there are no reasonable methods to assess the effectiveness of Central San's P2 efforts. In these cases, success is measured by the number of events conducted, the amount of flyers distributed, the number of participants using the HHWCP, etc. Table 2 on the following pages outlines Central San's P2 Plan for 2018. Central San 2017 Pollution Prevention Annual Report Page 16 March 15, 2018 Regular Board Meeting Agenda Packet- Page 223 of 275 Page 26 of 31 Table 2. Central San's 2018 P2 Plan Section 1: Priority Pollutants Pollutant Plan Activity for 2018 Measurement of Activity Effectiveness Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any targeted monitoring for mercury, as appropriate. observed trends. Maintain Mandatory Amalgam Separator Program, including Report compliance level of dental facilities. permitting new practitioners. Continue routine inspections. Report number of dental operations permitted (existing and new) and number of inspections conducted. Continue sampling two existing mercury-monitoring sites Report any trends observed and any downstream of dental offices, to track effectiveness of amalgam follow-up action taken. separator installations and adherence to other dental amalgam BMPs. Follow up with inspections of upstream dental practices, as necessary. Implement the Federal Dental Amalgam Rule provisions, and Description of necessary program incorporate program changes as necessary. changes, if any. L Track development of the statewide objectives for mercury Description of necessary program water quality. Monitor effect on San Francisco Bay Watershed changes, if any. Permit to determine if changes will be driven by addition of subsistence consumption of fish. Continue collecting, tracking, and properly disposing of Amount of elemental mercury and elemental mercury and mercury-containing products via Central mercury-containing products collected and San's HHWCP. properly disposed of by the HHWCP. Continue the Mercury Thermometer Exchange Program for Number of mercury thermometers residents and schools (chemistry laboratories)via the HHWCP. exchanged for digital (residents) and spirit- filled (schools). Continue recycling the mercury-containing lamps used in the Number of lamps properly recycled. Ultraviolet Disinfection Facility in Central San's treatment plant. Continue partnerships with local hardware stores in Central Report number of partner stores and San's service area for proper disposal of mercury-containing amount of mercury-containing waste lamps. collected through these partnerships. Continue to enforce the tiered LDL for mercury, as adopted in Report number of businesses permitted February 2007. under the tiered mercury LDL. Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any targeted monitoring for dioxin, as appropriate. observed trends. Continue collecting, tracking, and properly disposing of dioxin- Amount of dioxin-containing wastes containing wastes via the HHWCP. Tracked substances include collected and properly disposed of by the pentachlorophenol, 2,4,5-T and trichlorophenol. HHWCP. = Continue to enforce the discharge prohibition for dioxin Continue enforcement of the discharge acompounds, as adopted in February 2007. prohibition for dioxin compounds. O Central San 2017 Pollution Prevention Annual Report Page 17 March 15, 2018 Regular Board Meeting Agenda Packet- Page 224 of 275 Page 27 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2018 Measurement of Activity Effectiveness Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any targeted monitoring for cyanide, as appropriate. observed trends. Continue collecting, tracking, and properly disposing of cyanide- Amount of cyanide-containing wastes containing wastes via Central San's HHWCP. collected and properly disposed of by the HHWCP. Continue to implement the Cyanide Action Plan of the Cyanide Description of appropriate Cyanide Action .E Site Specific Objective, which includes: Plan requirements completed in 2017. v Maintaining inventory of significant cyanide sources Conducting required monitoring of identified cyanide sources Investigating any cyanide excursions that occur in treatment plant monitoring Continue to enforce the tiered LDL for cyanide, including Report number of businesses permitted discharge prohibition for unpermitted Central San businesses, under the cyanide LDL. as adopted in February 2007. Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any targeted monitoring for copper, as appropriate. observed trends. Continue collecting, tracking, and properly disposing of copper- Amount of copper-containing wastes containing wastes via Central San's HHWCP. collected and properly disposed of by the HHWCP. Continue Pretreatment Program, which includes inspection of Number of pretreatment inspections radiator shops and auto repair facilities, including permitting new conducted at radiator shops and auto a facilities. repair facilities. vContinue implementation of the Copper Action Plan, which Continue implementation and report includes the following elements: results. • Support of the BAPPG's Regional Copper Project • Central San's Pool and Spa Permitting Program • Communication with water purveyors in Central San's service area regarding copper algaecide dosing of reservoirs and corrosion control practices Continue implementation of tiered LDL for copper as adopted in Number of businesses permitted under the February 2007. tiered copper LDL. Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any targeted monitoring for acrylonitrile, as appropriate. observed trends. Continue accepting, tracking, and properly disposing of Since acrylonitrile is an occasional acrylonitrile-containing products, such as adhesives, auto component of paint-related material, the finishing paints, wood surface products, etc. via Central San's measurement will be the amount of paint- HHWCP. related materials collected and properly o disposed of by the HHWCP. Q Central San 2017 Pollution Prevention Annual Report Page 18 March 15, 2018 Regular Board Meeting Agenda Packet- Page 225 of 275 Page 28 of 31 Section 1: Priority Pollutants Pollutant Plan Activity for 2018 Measurement of Activity Effectiveness Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any targeted monitoring for PCBs, as appropriate. observed trends. Continue collecting, tracking, and properly disposing of PCB- Amount of PCB-containing wastes containing wastes (less than 50 ppm) via Central San's collected and properly disposed of by the HHWCP. HHWCP. Continue investigating potential significant sources of PCBs in Summary of potential PCB sources. our service area. Coordinate with CCCWP efforts to identify m and inventory PCB sources, as required under the Municipal U Regional Stormwater Permit. EL Perform outreach encouraging proper disposal of PCB- Description of outreach. containing light ballasts at Central San's HHWCP. Continue surveying/researching potential significant sources of Report any significant sources found and 2 ammonia to Central San's wastewater, aside from human summarize any follow-up programs 0 waste. created. E Continue to collect and properly dispose of ammonia-containing Amount of ammonia-containing wastes Qwastes at Central San's HHWCP. collected and properly disposed of by the HHWCP. Continue collecting, tracking, and properly disposing of Amount of residential FOG collected and residential FOG wastes via Central San's HHWCP. properly disposed of by the HHWCP. Continue inspecting and enforcing existing standards for Number of inspections completed at food controlling discharges of FOG wastes to Central San's sewer service facilities and number of Osystem using a targeted frequency based on potential for FOG enforcement actions taken. LL discharges. Continue outreach on proper FOG disposal. Description of outreach. Continue making presentations at Contra Costa County's Food Number of presentations given by Central Safety Class and other forums to educate Food Service staff San's staff. about proper FOG disposal. = w Continue outreach to encourage all customers not to flush wipes Description of outreach. and other products labeled as flushable. :5 o Continue outreach program, targeting neighborhoods with high Report number of outreach pieces sent. L a accumulations of wipes with direct mailers to encourage a� behavior change. Continue to track opportunities to give input on the development Identify support provided under these o of flushability standards and submit comments when opportunities. Include any comment letters Z ILL appropriate. submitted. Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any E targeted monitoring for selenium, as appropriate. observed trends. .E Continue investigating potential sources of selenium in our Summary of potential selenium sources. m cn service area. Central San 2017 Pollution Prevention Annual Report Page 19 March 15, 2018 Regular Board Meeting Agenda Packet- Page 226 of 275 Page 29 of 31 Section 2: Watch List Pollutants Pollutant Plan Activity for 2018 Measurement of Activity Effectiveness Lead was removed from the Watch List Pollutants list for the 2018 P2 Plan since the NPDES permit has not contained a lead effluent —J limit for two permit cycles. Central San will continue with its commitment to monitor and control sources of lead. Continue evaluating P2 performance/impacts by conducting Conduct monitoring and report any _ targeted monitoring for bis (2-ethylhexyl) phthalate, as appropriate. observed trends as needed. Per the 2017 NPDES Permit, "reasonable potential analysis shows 5'.2 that the discharge no longer demonstrates reasonable potential for s this pollutant to cause or contribute to exceedances of the c� a applicable Water Quality Orders. This Order, therefore, does not N retain these limitations". Bis (2-ethylhexyl) phthalate was moved out m of the Priority Pollutants section and into the Watch List pollutant for the 2018 P2 Plan. Section 3: Pollutants of Emerging Concern Pollutant Plan Activity for 2018 Measurement of Activity Effectiveness Continue collecting, tracking, and properly disposing of pesticides Amount of pesticides collected and via Central San's HHWCP. properly disposed of by the HHWCP. w Continue outreach on pesticide reduction and proper disposal. Description of outreach. a� :a Consider supporting future research studies related to pesticides of Description of support provided, if Nemerging concern. applicable. a Continue leading and supporting BACWA/BAPPG's efforts to track Support and describe efforts by and comment on Federal and State pesticide registration activities BACWA/BAPPG. in support consideration of water quality concerns and reduce pesticide discharges at their source. Continue to maintain and promote Central San's Pharmaceutical Amount of pharmaceutical waste Collection Program, which includes collection sites at 13 law collected and properly disposed of. enforcement agencies throughout the service area. Continue support of statewide and national projects on the Describe support activities by Central establishment of pharmaceutical collection programs that are San staff. funded by the product chain (manufacturers and retailers). N 2 Track implementation of the Contra Costa County Safe Drug Describe program implementation as it v a Disposal ordinance and support adoption by the cities in the Central affects Central San. San service area. � U v _ Continue accepting and properly disposing of personal care Continue acceptance and proper c o products via Central San's HHWCP. disposal of personal care products by N as m the HHWCP. a Continue outreach to encourage customers to dispose of Description of outreach. pharmaceuticals and personal care products properly. Central San 2017 Pollution Prevention Annual Report Page 20 March 15, 2018 Regular Board Meeting Agenda Packet- Page 227 of 275 Page 30 of 31 Section 3: Pollutants of Emerging Concern Pollutant Plan Activity for 2018 Measurement of Activity Effectiveness N Continue accepting and properly disposing of flame retardants via Continue acceptance and proper Central San's HHWCP. disposal of flame-retardants by the HHWCP. M Continue to track developing information on the sources and controlContinue to track information. E of flame retardants. R LL M>% Continue supporting BACWA/BAPPG and CASA efforts to track Identify support provided. _o developing information on nanotechnology and comment in support 0 of water quality concerns on any federal regulatory action on c s products and chemicals that use nanotechnology. L) m 0 c 0 z Evaluate any potential sources of nonylphenol ethoxylates in the Summary of potential sources found c r commercial laundries and other large laundry operations within and follow-up actions taken. Central San's service area. x � o c � oW Z Continue outreach on microplastics. Description of outreach. :r a 0 Continue providing support for future research studies related to Description of support provided, if 2 microplastics. applicable. W The BAAQMD adopted Regulation 11: Rule 18 air toxics Identify potential pollutants of concern •x regulations. Central San will continue to identify potential pollutants to ensure compliance with the new 0of concern with cross-media impacts and potential reduction regulation. L through P2 efforts. 'a Central San 2017 Pollution Prevention Annual Report Page 21 March 15, 2018 Regular Board Meeting Agenda Packet- Page 228 of 275 Page 31 of 31 Section 4: Continuous P2 Efforts Plan Activity for 2018 Measurement of Activity Effectiveness Continue the operation and promotion of Central San's HHWCP Total amount of HHW collected and o keep pollutants out of the wastewater stream. properly disposed of by the HHWCP. Continue Pretreatment and Stormwater Inspection Programs. Number of inspections conducted and enforcement actions taken. Continue student education programs (Water Wizards, Sewer Number of students participating in each Science, and Delta Discovery Voyage). program. Continue attendance at environmental/community events. Description and number of events attended. Continue Treatment Plant and HHWCP tours to educate people Number of people given tours. on the efforts to reduce pollution by the treatment of wastewater and the collection and proper disposal of HHW. a Continue conducting Central San's Annual Pollution Prevention Description of recognition program. N a wards Program to recognize local businesses for achieving 3 excellence in P2 and sustainability. Continue education and outreach through Central San's Description of outreach and relevant website, TV ads, social media, and various publications. statistics. o Continue partnership with CCGBP. Continue providing Continue partnership and green business L) environmental compliance inspection services to aid in certifying inspections. Report number of new and green businesses in Central San's service area. existing businesses certified in Central San's service area. Maintain green business certification standards and continue Maintain green business certification. making green improvements in Central San's operations that will ensure the next green business recertification. Continue active participation, membership, and support(where Continue active participation, membership, appropriate)of various regional, statewide, and national and support of the various organizations/programs that serve as a conduit for P2 organizations/programs listed. information, such as BACWA, BAPPG, CCCWP, CWEA, CASA, HHWIE, NACWA, and NAHMMA. III. REQUIRED STATUS REPORTS The San Francisco Bay Regional Water Quality Control Board (Regional Water Board) required reporting on the status of the following items by the various regulatory instruments noted below. A. Cyanide Control Program 1. Reporting Requirement The Cyanide Site-Specific Objective for San Francisco Bay (Order No. R2- 2006-0086) required the implementation of a Cyanide Control Program and a status report of the Program in the annual P2 Report. The Program requirements consisted of the following: • Inspect each potential source and assess the need to include that contributing source in the control program. Central San 2017 Pollution Prevention Annual Report Page 22 March 15, 2018 Regular Board Meeting Agenda Packet- Page 229 of 275