HomeMy WebLinkAbout06.a.2) Written AnnouncementsAgenda Item
•Q• 02)
Board Meeting of December 2, 2010
Written Announcements
General Updates
a) November 5, 2010 Regional Water Quality Control Board
Meeting
Staff met with Executive Officer Bruce Wolfe of the Regional Water Quality
Control Board (RWQCB) and two of his staff members. The purpose of the
meeting was to discuss the 2012 District NPDES permit renewal and the
RWQCB's Suisun Bay Nutrient Study. At this time, RWQCB staff anticipates our
NPDES Permit renewal to be routine.
The Suisun Bay Nutrient Study was funded solely by the RWQCB last year, and
this year will be funded by the RWQCB and by the State Water Contractors
(SWC). The SWC are funding an algae toxicity study in Suisun Bay. Staff
expressed concern about the SWC involvement and the lack of transparency of
how the SWC became involved. Staff also suggested that the RWQCB expand
the team to include the District and /or Bay Area Clean Water Agencies
(BACWA). District/BACWA funds for the Suisun Bay Nutrient Study would
expand to include the effect of water export and provide balance to the study.
Next year staff hopes to have the study included in the Regional Monitoring
Program.
The RMP monitors contamination in the Estuary. It provides water quality
regulators with information they need to manage the Estuary effectively. The
RMP is an innovative collaborative effort between the RWQCB and the regulated
discharger community. The RMP would be the natural choice in leading a
science study that could drive permit decisions such as nutrient removal. In the
coming years, District support of the RMP will be even more critical given the
potential impact of the regulations on the rate payers' cost to construct and
operate nutrient removal systems.
b) Cogeneration System Maintenance Contract
Since 1995, the District has maintained a contract with Solar Turbines for the
maintenance of the Cogeneration System. The Cogeneration System is used to
produce nearly all the electrical power for plant operations. Heat generated from
the unit is captured as steam and used to power the aeration blowers that
provide oxygen to the microbes in the biological treatment process. This contract
covers the entire power - generating package. The contract with Solar Turbines
expired on December 1, 2010. Our existing agreement with Solar Turbines has
been extended for 90 days to ensure uninterrupted mechanical maintenance
support of the Cogeneration System while a new contract is being negotiated.
c) Comment Letter to United States Environmental Protection
Agency on Pending Sewage Sludge Incinerator Rules
The United States Environmental Protection Agency (USEPA) released proposed
new standards for Multiple Hearth Furnaces on October 14, 2010. On October
29, 2010, the District commented on those standards in Research Triangle Park,
North Carolina. Written comments on the proposed new standards were due
November 29, 2010 and the District forwarded comments. Major highlights of
District concerns with the new regulation are as follows:
1. The District noted that since USEPA has emissions data from only
105 SSI units out of the 218 units, there is insufficient emissions
data to legally calculate the new emission limits.
2. The District's actual mercury mass emissions were only 56.6% of
the mercury mass emission estimated by USEPA.
3. USEPA is proposing a mercury emission limit lower than required
by the 129 standards. This lower mercury emission limit is not cost
effective and is therefore not authorized under Section 129. The
District provided information that the cost to treat mercury to the
very low levels suggested in the proposed regulation is
approximately $335,000 per pound of mercury removed versus the
$6,150 per pound of mercury removed stated in the proposed
ruling. Thus, the nationwide cost could be over $1 billion per year
not the $105 million suggested in the proposed regulation, therefore
making EPA's cost to benefit ratio not justifiable.
4. The District indicated that source control efforts were much more
cost effective than emission controls at the furnace stack. The
Household Hazardous Waste (HHW) Program and Dental
Amalgam programs reduced the amount of mercury in the plant
influent by 70% since 2004. The cost of the HHW program is
approximately $639 per pound of mercury removed and the cost of
the dental amalgam program is approximately $8,918 per pound of
mercury removed compared to emission control approximate cost
of $335,000 per pound of mercury removed. The District stated
that source control is a better mechanism for mercury removal.
5. USEPA did not consider the full impact of sewage sludge
incinerators that will be shut down because of the new rules. This
includes the loss of waste -to- energy programs, increased use of
limited landfill space, and increased greenhouse gas emissions
from sludge hauling to landfills.
6. USEPA made too many errors during the development of the rule
for the proposed rule to be valid under the 129 requirements.
In closing, the District acknowledged that USEPA is under court order to
promulgate emission standards under Section 7429 by January 16, 2011.
Even so, USEPA should not use this deadline to justify the use of insufficient
emission data, flawed emission calculations, and incorrect economic analysis
in determining limits. The District strongly urged USEPA to request an
extension of the court ordered deadline so the details and issues in the
comment letter could be addressed.