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Home My WebLink About05.a.3) Sacramento Regional Permit% eritral Contra Costa October 8, 2010 PHONE (925) 228-9500 FAX (925) 228-4624 www,centralsan.org JAMES M, KELLY Generat Manager Central Valley Region AtIlientilow. Ms. Kathleen Harde:r 1102:0 Sun Center Drive #200 Randho Gordo* CA 95:670-61 14 SENT VIA EMAIL: kh a rdeiCa wa terboards. ca, go v KENTON L. ALM Counsel tor the owfid (510) 808-2000 ELAINE R, 80FHMF secrelaty of the Daftid Subject: Tentative Waste Discharge Requirements Renewal (NPDES No, CA0077682) for Sacramento Regional County Sanitation District and Sacramento Regional Wastewater Treatment Plant, Sacramento County Dear Ms, Harder: CCCSD views this tentative permit as raising both complicated technical issues and extremely difficult Statewide policy issues, CC CSD understands that Regional Boards typically reject legal arguments that their NPDES related decisions require either evaluation of econornic considerations or CEQA review. However, the looming mega public policy issue which this Regional Board and other regulators face is how can our society successfully address both the requirements of specific existing environmental regulations and the daunting challenges of meeting requirements of AB 32? Moreover, h ow can these d u a I obj a cti ve s lie met without a fund amenta I mod ificatio n of the manner in which our State agencies evaluate the cost benefit of regulatory actions during this depressed economic cycle? Thf, issue is not whether the Regional Board may be able to lawfully avoid a thorough and ;s, th,�Z ound public policy deinands a fully integrated approach to these competing issues_ brief listing of our concerns is attached jr) 'Table format as requested, We ask that the Regional Water Board reconsider the proposed requirements arid release a revised permit for review and comment that is consistent with applicable law regulations, and accepted permitting p ractices, Sincerely, / James M. Kelly General Inee r Attachment 1525489.1 2 Sacramento Regional County Sanitation District Sacramento Regional Wastewater Treatment Plant Tentative NPDES Permit Renewal and Time Schedule Order Commenter: Central Contra Costa Sanitary District, 5019 Imhoff Place Martinez CA 94553 James M. Kelly, General Manager 925/229 -7386 jkelly@centralsan.org October 8, 2010 Comment No. Topic (i.e., ammonia, Title 22 tertiary, dilution, etc. Summarized Comment 1 Compliance with Title The requirement for full Title 22 treatment for contact 22 Standards for recreation to meet a 2.2 total coliform standard far Total Coliform exceeds the fecal coliform water quality objective specifically adopted by the Basin Plan to protect this beneficial use. While the RWQCB may choose, on a case -by -case basis, to develop a more stringent water quality objective, it must consider the economic impacts of doing so, in accordance with Water Code Sections 13241. Given the significant cost of providing the additional level of treatment required above the water quality objective, it does not appear that there was a consideration of cost versus benefit in applying this re uirement. 2 Ammonia Limits — The body of work on this topic is growing, as evidenced Requirement for by many of the citations in the permit renewal package. Nitrification There is ongoing work and analysis that will continue to inform the ammonia /nitrate /nitrite permitting process. As such, the studies cited do not provide a complete understanding of the impact of ammonia /nitrate and nitrite discharges on the aquatic system. We support the ongoing efforts to develop a more comprehensive understanding of these impacts, taken in context with all of the other stressors in the Delta and the Suisun Bay. These other stressors include, but are not limited to, variations in salinity caused by seasonal flow fluctuations and water exports, and seasonal changes in turbidity and clarity. We request the Water Board to look at this issue holistically and be convinced that the significant resources required for nitrification to the level proposed are justified in light of the expected water qua lit improvements. 3 Nitrate Limits — SRCSD effluent currently has a low concentration of Requirement for nitrates which will increase substantially if the plant is Denitrification required to fully nitrify in order to comply with the proposed ammonia limits. As a result of this increase, the draft permit concludes that reasonable potential exists for the discharge to cause or contribute to an exceedance of applicable water quality standards, and a numeric effluent limit is required. The basis for the Sacramento Regional County Sanitation District Sacramento Regional Wastewater Treatment Plant Tentative NPDES Permit Renewal and Time Schedule Order Commenter: Central Contra Costa Sanitary District, 5019 Imhoff Place, Martinez, CA 94553 James M. Kelly, General Manager 925/229 -7386 jkelly(M-centralsan.org October 8, 2010 Comment No. Topic (i.e., ammonia, Title 22 tertiary, dilution, etc.) Summarized Comment nitrate effluent limits, however, are questionable, consisting solely of preserving the current effluent ratio of nitrogen to phosphorous. We remind the Water Board to recognize that achieving these very low nitrate concentrations reliably is beyond the limits of current technology and will require the addition of substantial amounts of carbon, such as methanol, and significantly increase the greenhouse gas footprint of the SRCSD p lant with no demonstrated water quality benefits. 4 Denial of Mixing The basis for denying a dilution credit based on mixing Zone /Dilution Credit zone studies for ammonia is not well documented. for Ammonia and While regional water boards have discretion in Toxic Constituents determining the amount of dilution credit to be allowed, a permit can only limit or deny dilution credit if there is a defensible technical basis for the limitation. The State Water Board has affirmed that regional boards "must explain the denial of a mixing zone based on the facts of the discharge" (in the Matter of Yuba City, Order WQ 2005 -013 at p 10). It does not appear that this standard has been met. 5 Development of WET The tentative permit requires multiple special studies, testing using Hyalella including one intended to "develop procedures for azteca as Test conducting whole effluent toxicity (WET) testing using Species Hyalella azteca as the test species" (Tentative Permit at p. 28). The development of test procedures requires significant resources and expertise and is a role appropriately undertaken by large governmental agencies, e.g. USEPA. We are concerned that the Regional Water Board is requiring a permittee to single- handedly develop a test procedure that could have consequences for the entire POTW community. Requiring SRCSD to develop test procedures as described in the tentative permit is not practical nor is it justified. We are concerned that this sets a precedent and we request that this requirement be removed from the Tentative Permit. -2-