HomeMy WebLinkAbout08.a. Receive information on Industrial Users in Significant Non-Compliance for 2021 Page 1 of 3
Item 8.a.
CENTRALSAN
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CENTRAL CONTRA COSTA SANITARY DISTRICT
January 27, 2022
TO: HONORABLE BOARD OF DIRECTORS
FROM: TIM POTTER, ENVIRONMENTAL COMPLIANCE PROGRAM
ADMINISTRATOR
REVIEWED BY: LORI SCHECTEL, ENVIRONMENTALAND REGULATORY COMPLIANCE
DIVISION MANAGER
JEAN-MARC PETIT, ENGINEERINGAND TECHNICAL SERVICES
DEPARTMENT DIRECTOR
ROGER S. BAILEY, GENERAL MANAGER
SUBJECT: RECEIVE INFORMATION ON INDUSTRIAL USERS OF CENTRAL SAN'S
PUBLIC SEWER SYSTEM FOUND TO BE IN SIGNIFICANT NON-
COMPLIANCE FOR 2021
Federal pretreatment regulations establish standards that apply to wastewater agencies with approved
pretreatment programs. One of these standards is to use specified criteria to evaluate violations that are
documented at regulated businesses to determine if the business is in Significant Non-Compliance
(SNC). When a business is determined to be in SNC, Central San is required to report this status
in reports submitted to the Regional Water Quality Control Board and to publish information about the
violation in the newspaper at least annually.
For the calendar year 2021, one business was determined to be in SNC:
• Diablo Valley College conducted compliance sampling for the discharge from the Physical Science
Building that resulted in mercury being measured in concentrations that exceeded Central San's
Local Discharge Limit (LDL)four times during the second quarter reporting period. The level of
exceedance met the Technical Review Criteria established for SNC, and the frequency of violations
met the chronic criteria for SNC. Diablo Valley College resampled the discharge, which documented
compliance with the mercury LDL. These discharge violations occur with a history of other discharge
violations from previous years, representing a pattern of non-compliance. Diablo Valley College
conducted cleaning of the pretreatment unit and flushed the waste lines from the laboratory areas to
the pretreatment unit to clear out any legacy sources of mercury. Due to the pattern of non-
compliance, Environmental Compliance initiated a formal enforcement action against Diablo Valley
College that was successfully resolved in November 2021. A summary of the formal enforcement
action elements will be included in the Central San 2021 Annual Pretreatment Program Report.
January 27, 2022 Special Board Meeting Agenda Packet- Page 62 of 84
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Environmental Compliance staff will continue to work with this business to maintain compliance with the
pretreatment standards. Attached is the SNC notice that will be published in the Contra Costa Times in
early February 2022.
Strategic Plan Tie-In
GOAL TWO: Environmental Stewardship
Strategy 1—Achieve 100% compliance in all regulations
ATTACHMENTS:
1. Notice for Publication of Businesses in Significant Non-Compliance for 2021
January 27, 2022 Special Board Meeting Agenda Packet- Page 63 of 84
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PUBLIC NOTICE
CENTRAL CONTRA COSTA SANITARY DISTRICT
NOTICE OF SIGNIFICANT NON-COMPLIANCE FOR 2021
Notice is hereby given that pursuant to the federal regulations contained in 40 CFR
403.8.f(2)(vii), Central Contra Costa Sanitary District (Central San) is required to publish the
names of all Industrial Users (IUs) of Central San's public sewer system that were
determined to be in Significant Non-Compliance (SNC) with applicable pretreatment
standards or other pretreatment requirements during the 2021 calendar year. Federal
regulations establish objective criteria for Central San to use to determine if an IU is in SNC.
Discharge Quality Violations
The following IU was found to have discharged process wastewater in violation of Central
San's Local Discharge Limits in a manner that met the definition of SNC.
Industrial User Nature of Violation Follow-up Action Taken
Diablo Valley College Limit violations for mercury Central San issued Notices of Violation (NOVs)
321 Golf Club Road (4) in the discharge from the for the violations. The IU investigated potential
Pleasant Hill, CA 94523 Physical Science Building at sources of mercury within the laboratory
concentrations that met the operations and did not locate any significant
SNC criteria [Technical mercury sources. The IU cleaned the
Review Criteria (TRC)and pretreatment unit serving the Physical Science
chronic]. Building to improve the unit's ability to remove
regulated pollutants. Violations occurred after
this cleaning, so the IU conducted another
cleaning of the pretreatment unit and flushed the
waste lines from the laboratory areas to the
pretreatment unit to remove potential legacy
sources of mercury. Resampling demonstrated
that the IU returned to compliance after the
violations were recorded. Central San initiated a
formal enforcement action with this IU based on
the pattern of non-compliance. The formal
enforcement action was resolved in November
2021.
Reporting Violations
No IUs were in SNC for reporting violations in 2021.
January 27, 2022 Special Board Meeting Agenda Packet- Page 64 of 84