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Home My WebLink About04.b. Receive annual update on Regulatory Compliance Page 1 of 9 Item 4.b. CENTRAL SAN January 28, 2019 TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE FROM: LORI SCHECTEL, ENVIRONMENTALAND 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 Attached is the presentation for Regulatory Compliance's annual update. Strategic Plan Tie-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 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 18 of 29 Page 2 of 9 MW-. ., ANNUAL REGULATORY 1 . UPDATES F ,- January 28, 2019 Real Estate, Environmental and Planning Committee Meeting Lori Schectel Environmental and Regulatory Compliance Division Manager I SIGNIFICANT REGULATORY UPDATES • Air • Soil • Wastewater • Constituents of Emerging Concern (CECs) 1 CENTRALSAN 1 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 19 of 29 Page 3 of 9 AIR-RELATED UPDATES Clean Air Act Section 129 Sewaqe Sludqe Incinerator Regulations (2016) • Emissions limits, minimum operating limits, enhanced visible emissions from ash handling, operator training, and annual source tests • Working with EPA on proposed minimum operating limits • Hydrogen chloride emissions limit violation measured during 2018 Furnace 2 compliance source test • Two violations in 2018 related to furnace bypass Title V Compliance • BAAQMD issued Authority-to-Construct permits for Headworks Improvement Project • Central San accepted BAAQMD's settlement offer to settle six violations • One violation in 2018 related to furnace opacity exceedance CENTRALSAN ` 3 . . AIR-RELATED UPDATES AB 32: Global Warming Solutions Act of 2006 • Cap and Trade Program inclusion threshold: 25,000 MTCO2e • Pre-verification anthropogenic emissions calendar year 2018: 23,789 MT CO2e • Projected calendar year 2019 anthropogenic emissions: <24,500 MT CO2e AB 398: Cap and Trade Bill • Cap and Trade Program extension to 2030 Portable Diesel Engine Regulation • CARB Airborne Toxic Control Measure(ATCM)for portable diesel engines >50hp • Latest amendments to ATCM 2018: • Fleet emission standards exemption for emergency and low-use engines Z910 CENTRALSANh 2 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 20 of 29 Page 4 of 9 AIR-RELATED UPDATES BAAQMD Rule 11-18: Reduction of Risk from Air Toxic Emissions at Existing Facilities(2017) • Toxic emissions reductions requirements • BAAQMD tentatively plans to complete Health Risk Assessments for POTWs in 2019/2020 • 5-year implementation for risk reduction measures • Completed internal baseline health risk for Treatment Plant • Working with Black&Veatch to develop risk reduction strategies ` s CENTRALSAN a AIR-RELATED UPDATES Amendments to BAAQMD PM Regulation 6 and 6-1 (2018) • New limits effective for Central San 2025 • Applies to existing and new sources • Reg 6: clarifies definition of fine PM • Rule 6-1: more stringent limits on total suspended particulates • New scrubber will be able to meet new PM concentration limit (Procurement approved by Board on Dec. 20, 2018) AB 617—Non-Vehicular Air Pollution: CAPs and TACs (2017) • Requires CARB to develop statewide strategy for community air monitoring, reporting, and local emissions reduction programs • Enhanced air monitoring in high-risk communities • Reporting of Criteria Air Pollutants and Toxic Air Contaminants to CARB by July 2019 (likely from BAAQMD) CENTRALSAN 3 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 21 of 29 Page 5 of 9 SOIL-RELATED UPDATES Soil Cap Enforceable Agreement with DTSC • Maintain integrity of soil caps (Basin A South; Surcharge Fill Area) • DTSC no longer performs annual inspections • Reporting: Semi-annual and five-years; notice and reporting on excavation projects • Annual petroleum seeps repair work in Basin A South • Completed an evaluation of remedial alternatives for treating contaminated soil in Surcharge Fill Area CENTRALSAN CEC-RELATED UPDATES Microplastics • Regional Monitoring Program continuing a microplastics study to determine microplastics pollution in SF Bay with POTW participation • SFEI and the 5-GYRES Institute continuing with its SF Bay Microplastic Project that began in 2016. Preliminary data to be released in May 2019 Other CECs • SFEI released strategy for CECs of moderate concern such as: plasticizers,flea and tick insecticides, materials in cleaning products • Participating in state and regional monitoring efforts a C' -d, CENTRALSAN 4 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 22 of 29 Page 6 of 9 CEC-RELATED UPDATES Pharmaceutical Take-Back SB 212(State Program) • Passed in September 2018; implementation by 2022 • Requires manufacturers of pharmaceutical drugs and sharps to establish and fund a statewide take-back system for medications and sharps • CalRecycle is responsible for developing regulations and administering the program • Potential to reduce pharmaceuticals from Central San's influent • Will improve upon current CC County Safe Drug Disposal ordinance (began in September 2018)by including sharps Contra Costa County Safe Druq Disposal Ordinance Wed - Pro'ect • Currently 22 Med-Project collection sites in HHW service area (does not include Central San's 13 collection sites) 9 CENTRAL SAN WASTEWATER-RELATED UPDATES Draft State Toxicity Provisions -Test of Significant Toxicity(TST) • Numeric chronic toxicity limits • Statistical method to determine chronic toxicity • May increase testing frequency from quarterly to monthly • Draft"Statewide Toxicity Provisions"released in October 2018 • Board hearing held on November 2018 • Comments were submitted in December 2018 • February 7 meeting for CASA and State Board staff to discuss implementation and comments • BACWA has joined SCAP,CVCWA,and NACWA in a lawsuit alleging EPA did not follow proper procedure in requiring use of the TST in Southern California Clean Water Rule:Waters of the US Rule(WOTUS) • 2015 Rule now in effect in 22 states, D.C.,and US territories(CA included) • All waters that meet the definition of the WOTUS subject to the Clean Water Act; CA has its own waters of the state(broader) • December 2018 New definition proposed by EPA,Army Corps, DOD includes a narrower range of waterways subject to Clean Water Act CIENTRALSAN5 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 23 of 29 Page 7 of 9 WASTEWATER-RELATED UPDATES SF Bay Nutrient Watershed Permit • Regional permit that requires nutrient monitoring, reporting, evaluation, and support for scientific studies • Collaborate with BACWA, SFEI, RWQCB, consultants • Expires June 2019; BACWA engaged with RWQCB on second permit • Received first admin draft of permit Jan 2019; comments submitted by BACWA • Tentative Order expected March 2019;Adoption slated for May 2019 • For FY2019, BACWA is contributing an additional $200k to the science program • The last BACWA Group Nutrient Annual Report submitted in October IL 2018 BACWA submitted final report on Nutrient Treatment by Optimization and Upgrade in June 2018 CENTRALSANWASTEWATER-RELATED UPDATES Mercury and PCB Watershed Permit • Current permit became effective January 1, 2018 • No change for Central San • Monitoring frequency remains the same Sanitary Sewer Systems Waste Discharge Requirements (SSS WDR) • State Water Board plans to reissue the SSS WDR in 2019 and has sought out early stakeholder engagement through CASA • CASA provided redlines to the SSS WDR to the SWRCB • State Board workshop planned for February 2019 a `,= 6 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 24 of 29 Page 8 of 9 WASTEWATER-RELATED UPDATES Environmental Laboratory Accreditation Program (ELAP) • Laboratory accreditation for NPDES self-monitoring will be based on the NELAC institute 2016 standard • Additional documentation without improvement in data quality • Staff to continue working with consultant to prepare for implementation • Draft regulations released for ELTAC comment in June 2018; updated drafts have been released; comments to third draft February 2019 • POTW groups urging State Board to consider the financial impact of the new regulation on agencies ` 13 . . CENTRALSAN WASTEWATER-RELATED UPDATES Cannabis Grow Operations(SWRCB General Permit-Pending) • SWRCB processing General Order to address cannabis grow operations • Surveyed cities in Central San service area to determine if cannabis grow and manufacturing operations would be permitted • No cities have adopted rules to allow cannabis grow operations • Concord and Martinez are evaluating • Engaged SWRCB staff and local agencies to discuss Updates and strategies associated with cannabis grow operations aLI CENTRALSAN 7 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 25 of 29 Page 9 of 9 RECYCLED WATER-RELATED UPDATES SWQCB Recycled Water State General Order • May 2018 State Board released Recycled Water Policy • The Policy will terminate 96-011 three years from the effective date of the Policy amendments • Final Draft Policy amendments posted in December 2018 • Regional and State Board discussions on coverage are ongoing QUESTIONS? 8 January 28, 2019 REEP Committee Meeting Agenda Packet- Page 26 of 29