CHAPTER 4: IMPLEMENTATION PLANS (continued)SURFACE WATER PROTECTION AND MANAGEMENT — POINT SOURCE CONTROLSurface waters in the region consist of inland surface water (freshwater lakes, rivers, and streams), estuaries, enclosed bays, and ocean waters. Historical and ongoing wasteloads contributed to the surface water bodies in the region come from upstream discharges carried into the region via Delta outflow, direct input in the forms of point and nonpoint sources, and indirect input via groundwater seepage. A point source usually refers to waste emanating from a single, identifiable location, while a nonpoint source usually refers to waste emanating from diffuse locations. While legally considered point sources, stormwater sewer systems are discussed under the nonpoint source control because waste entering the systems is generated from diffuse sources. This section describes control measures for point source discharges. The Regional Board may control either type of discharge, but approaches may differ. TYPES OF POINT SOURCESWasteloads from point sources are those that are generally associated with pollutant discharges from an identifiable location to a specific receiving water body. Major types of point sources include:
WASTE DISCHARGE PERMITTING PROGRAMPoint source discharges to surface waters are generally controlled through waste discharge requirements issued under the federal National Pollutant Discharge Elimination System (NPDES) permits. Although the NPDES program was established by the federal Clean Water Act, the permits are prepared and enforced by the Regional Boards per California's delegated authority for the act. Issued in five-year terms, an NPDES permit usually contains components such as discharge prohibitions, effluent limitations, and necessary specifications and provisions to ensure proper treatment, storage, and disposal of the waste. The permit often contains a monitoring program that establishes monitoring stations at effluent outfall and receiving waters. Under the state's Porter-Cologne Water Quality Control Act, any person discharging or proposing to discharge waste within the region (except discharges into a community sewer system) that could affect the quality of the waters of the state is required to file a Report Of Waste Discharge (ROWD). The Regional Board reviews the nature of the proposed discharge and adopts Waste Discharge Requirements (WDRs) to protect the beneficial uses of waters of the state. Waste discharge requirements could be adopted for an individual discharge, or a specific type of discharges in the form of a general permit. The Regional Board may waive the requirements for filing a ROWD or issuing WDRs for a specific discharge where such a waiver is not against the public interest. NPDES requirements may not be waived. Acceptable control measures for point source discharges must ensure compliance with NPDES permit conditions, including the discharge prohibitions (Table 4-1) and the effluent limitations provided on the following pages. In addition, control measures must satisfy water quality objectives set forth in the Basin Plan unless the Regional Board judges that related economic, environmental, or social considerations merit a modification after a public hearing process has been conducted. Control measures employed must be sufficiently flexible to accommodate future changes in technology, population growth, land development, and legal requirements. EFFLUENT LIMITATIONSTECHNOLOGY- AND WATER QUALITY-BASED LIMITATIONSThe federal Clean Water Act (CWA) requires that NPDES permits include technology-based and, where appropriate, water quality-based effluent limitations. Technology-based effluent limitations are promulgated performance standards based on secondary treatment or best practicable control technology. When technology-based limitations fail to attain or maintain acceptable water quality (as measured by water quality objectives) or comply with water quality control plans, additional or more stringent effluent limitations will be required in order to attain water quality objectives. The more stringent limitations are known as water quality-based limits. Water quality-based effluent limitations will consist of narrative requirements and, where appropriate, numerical limits for the protection of the most sensitive beneficial uses of the receiving water. Establishing numeric limits takes into account the appropriate water quality objectives, background concentrations in the receiving water, and allowable dilution credit. In many cases, numerical water quality objectives are not available for various types of beneficial uses or for various constituents of concern. The U.S. EPA is expected to promulgate final water quality standards for California in late 1995. In these cases, best professional judgment will be used in deriving numerical effluent limitations that will ensure attainment and maintenance of narrative water quality objectives. SITE-SPECIFIC OBJECTIVESIn some cases, the Regional Board may elect to develop and adopt site-specific water quality objectives. These objectives will be based on reflect site-specific conditions and comply with the Antidegradation Policy. This situation may arise when:
In the above cases, the Regional Board may consider developing and adopting site-specific water quality objectives for the constituent(s) of concern. These site-specific objectives will be developed to provide the same level of environmental protection as intended by national criteria, but will more accurately reflect local conditions. Such objectives are subject to approval by the State Board, Office of Administrative Law, and U.S. EPA. There may be cases where the promulgated water quality standard or adopted objectives are practically not attainable in the receiving water due to existing high concentrations. In such circumstances, discharges shall not cause impairment of beneficial uses. BEST PROFESSIONAL JUDGMENTIn developing and setting water quality-based effluent limitations for toxic pollutants, best professional judgment will involve consideration of many factors. Factors that may be considered include:
While the conditions surrounding a waste discharge may vary from case to case, all attempts will be made to ensure consistency among permits when exercising best professional judgment. EFFLUENT LIMITATIONSThe effluent limitations described below have been established to help achieve the water quality objectives identified in Chapter 3. Numerical effluent limitations identified in this section may not contain a complete list of pollutants that have a reasonable potential to cause an adverse impact on water quality. Inclusion of such pollutants of concern into the NPDES permit will be evaluated on a case-by-case basis. The Regional Board will consider establishing more stringent limitations as necessary to meet water quality objectives and protect beneficial uses in particularly sensitive areas. Similarly, the Regional Board will consider establishing less stringent limitations, consistent with state and federal laws, for any discharge where it can be conclusively demonstrated through a comprehensive program approved by the Regional Board that such limitations will not result in unacceptable adverse impacts on the beneficial uses of the receiving water. Such a comprehensive program must evaluate the impact of other, nearby discharges as well as the discharge itself. The numerical limits identified in this section have been and will be applied on a gross rather than a net basis except for certain industrial waste discharges, which will be evaluated on a case-by-case basis. DISCHARGES TO OCEAN WATERSWithin the context of this Basin Plan, ocean waters of the region are all territorial marine waters of the state west of the coastline, except enclosed bays. All discharges to ocean waters must comply with the applicable quality requirements for waste discharges specified in the State Board's Ocean Plan and Thermal Plan. DISCHARGES TO INLAND SURFACE WATERS, ENCLOSED BAYS, AND ESTUARIESWithin the context of this plan, enclosed bays are the indentations along the coast that enclose an area of marine water (such as Tomales Bay and Drake's Estero) including San Francisco Bay; estuaries extend from a bay to points upstream where there is no significant mixing or fresh water or sea water (this includes significant portions of the main San Francisco Bay and the portions of streams draining to the Bay where salt and freshwater mix); and inland surface waters are all other waterbodies within the region (freshwater rivers, streams, lakes, and reservoirs). As described in Chapter 3, effluent limits for discharge into any surface water body within the region is based on salinity. These are defined in the State Enclosed Bays and Estuaries Policy, 1974. LIMITATIONS FOR CONVENTIONAL POLLUTANTSEffluent limitations for conventional pollutants are contained in Table 4-2 for discharges to inland surface waters and enclosed bays and estuaries within the region. LIMITATIONS FOR SELECTED TOXIC POLLUTANTSWater quality-based effluent limitations for shallow water and deepwater dischargers shall be calculated according to the methodology in the “Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bay, and Estuaries of California (SIP).” The Regional Board may adopt additional numerical standards for conservative constituents documented in discharges and/or documented to be of concern in receiving waters. WHOLE EFFLUENT TOXICITY LIMITS AND CONTROL PROGRAMThe narrative water quality objective for toxicity (see Chapter 3) protects beneficial uses against mixtures of pollutants typically found in aquatic systems. This approach is used because numerical objectives for individual pollutants do not take mixtures into account and because numerical objectives exist for only a small fraction of potential pollutants of concern. Effluent limits for acute toxicity are described below and were derived through the Effluent Toxicity Characterization Program (ETCP). A detailed description of the ETCP is presented later in this section. These limits define in specific terms how the Regional Board assesses whether waters are "maintained free of toxic substances in concentrations that are lethal to or that produce other detrimental responses in aquatic organisms" (the narrative objective in Chapter 3) and maintains waters free of "toxic substances in toxic amounts" (Clean Water Act). ACUTE TOXICITYThe acute toxicity effluent limitation states that the survival of organisms in effluent shall be a median value of not less than 90 percent survival, and a 90 percentile value of not less than 70 percent survival using tests as specified in Table 4-4 and Table 4-5. Compliance with the acute toxicity limitation is evaluated by measuring survival of test fishes exposed to effluent for 96 hours. Each fish species represents a single sample. Dischargers are required to conduct flow-through effluent toxicity tests, except for those that discharge intermittently and discharge less than 1.0 million gallons per day (average dry weather flow). Such small, intermittent dischargers are required to perform static renewal bioassays. All dischargers perform toxicity tests using fish species, according to protocols approved by the U.S. EPA or State Board or published by the American Society for Testing and Materials (ASTM) or American Public Health Association. Two fish species shall be tested concurrently. These shall be the most sensitive two species determined from concurrent screening(s) of three species: three-spine stickleback, rainbow trout, and fathead minnow. Tests completed within ten days of the initial test are considered concurrent. This three-species-screening requirement can be met using either flow-through or static renewal bioassays. The Regional Board may consider allowing compliance monitoring with only one (the most sensitive, if known) fish species, if the following condition is met: The discharger can document that the acute toxicity limitation, specified above, has not been exceeded during the previous three years, or that acute toxicity has been observed in only one of two fish species. The Regional Board may modify the flow-through bioassay requirements and the specific test species requirements on a case-by-case basis for discharges of once-through cooling water or excessively saline wastes, which make the implementation of these test requirements impractical. Such changes are not intended as a reduction in the acute toxicity limitation, but rather to account for the technical difficulties of performing the tests. In addition, for deep water discharges subject to marine effluent limitations, dischargers are not to be considered out of compliance with the acute toxicity effluent limitation under the following circumstances: the discharger documents that the only cause of acute toxicity is ammonia which rapidly decays in the receiving water, and demonstrates that ammonia in the discharge does not impact water quality or beneficial uses. CHRONIC TOXICITYChronic toxicity effluent limits are derived for individual dischargers based upon Best Professional Judgement. Some of the factors that may be considered in the development of these limits include: allowing credit for dilution comparable to those allowed for numeric chemical-specific objectives, effluent variability, and intent to protect against consistent chronic toxicity and severe episodic toxic events. Chronic toxicity limitations are contained in the permits of all dischargers that have completed or are currently participating in the Effluent Toxicity Characterization Program (ETCP). This includes all municipal facilities with pre-treatment programs, all major industrial facilities, and selected treated groundwater dischargers. Monitoring requirements for chronic toxicity, such as test species, effluent sampling procedures, dilution series, monitoring frequency, dilution waters and reference toxicant testing requirements, are specified in NPDES permits on a case-by-case basis. Monitoring requirements will be based on Effluent Toxicity Characterization Program data. Test species and protocols will be selected from those listed in Table 4-5. Dischargers with chronic toxicity limits in their permits monitoring quarterly or less frequently are required to accelerate the frequency to monthly (or as otherwise specified by the Executive Officer) when conditions such as those listed in Table 4-6 occur. TOXICITY IDENTIFICATION/REDUCTION EVALUATION (TIE/TRE)Permits shall require that if consistent toxicity is exhibited, then a chronic toxicity identification evaluation (TIE) and toxicity reduction evaluation (TRE) shall be conducted. Specific language in permits requires the development of workplans for implementing TIEs. TIEs will be initiated within 30 days of detection of persistent toxicity. The purpose of a TIE is to identify the chemical or combination of chemicals causing the observed toxicity. Every reasonable effort using currently available TIE methodologies shall be employed by the discharger. The Regional Board recognizes that identification of causes of chronic toxicity may not be successful in all cases. The purposes of a TRE are to identify the source(s) of the toxic constituents and evaluate alternative strategies for reducing or eliminating their discharge. The TRE shall include all reasonable steps to reduce toxicity to the required level. In addition, the Regional Board will review chronic toxicity test results to assess acute toxicity and consider the need for an acute TIE. Following completion of the TRE, if consistent toxicity is still exhibited in a discharge, then the discharger shall pursue all feasible waste minimization measures at a level that is acceptable to the Regional Board. The discharger must document that the acceptable level of participation is maintained by submitting reports on a specified schedule to the Regional Board. A Toxicity Reduction Evaluation may again be required in situations where chronic toxicity still exists and new techniques for identifying and reducing toxicity become available. Alternatively, the cause of effluent toxicity may change, so that existing techniques will enable identification and reduction of toxicity. Consideration of any enforcement action by the Regional Board for violation of the effluent limitation will be based in part on the discharger's actions in identifying and reducing sources of persistent toxicity. EFFLUENT TOXICITY CHARACTERIZATION PROGRAMThe Effluent Toxicity Characterization Program was initiated in 1986 with the goal of developing and implementing toxicity limits for each discharger based on actual characteristics of both receiving waters and waste streams. The Regional Board initiated the program as a means of implementing the narrative objective prohibiting toxic effects in receiving water. The first two phases of the program focused on developing methods for monitoring effluent toxicity (known as effluent characterization) and deriving the appropriate series of tests to ensure that each effluent and its immediate receiving waters are not toxic to aquatic organisms. Information from these phases is used to determine whether the narrative objectives are being met in each segment of the Bay and will support the development of site-specific water quality objectives and wasteload allocations. As the program progresses, the Regional Board may: (a) Modify existing effluent limits; (b) Specify different test organisms and methods for determining compliance with toxicity effluent limits; and/or (3) Require a toxicity reduction evaluation (TRE) to determine the cost-effectiveness of controlling toxicity or reducing concentrations of specific pollutants. This program is being implemented within the existing framework of the NPDES permitting program for municipal and industrial facilities. The purposes of effluent characterization are to:
Two rounds of effluent characterization have been completed by dischargers selected on the basis of the nature, volume, and location of discharge. The first round started characterization in 1988; the second round in 1991. The Regional Board adopted guidance documents for each round of characterization, with modifications made to the second round from knowledge gained during the first. Status reports were issued in July, 1989, March, 1990, and July, 1991. A summary report is scheduled upon completion of the second round in 1995. The need for a third round of characterization will be evaluated at that time. Thus far, no one test species has consistently been the most sensitive to all discharges. This strongly supports the current approach of requiring screening using several test species. Also, acute toxicity has been observed at several sites using the expanded range of test species. Although these sites can meet existing limits with test species currently used to determine compliance (fathead minnow, trout, and stickleback), they cannot meet the limits based on more sensitive species now available. Detailed technical guidelines for conducting toxicity tests and analyzing resulting data were compiled in "Modified Guidelines: Effluent Toxicity Characterization Program," San Francisco Bay Regional Water Quality Control Board, 1991, Resolution No. 91-083, after experience gained during the first round. This document is incorporated by reference into this plan. CALCULATION OF WATER QUALITY-BASED EFFLUENT LIMITATIONSDILUTION RATIOSThe allocation of dilution ratio depends on whether a discharge is classified as a deep water or a shallow water discharge. In order to be classified as a deep water discharge, waste must be discharged through an outfall with a diffuser and must receive a minimum initial dilution of 10:1, with generally much greater dilution. All other dischargers are classified as shallow water discharges. DEEP WATER DISCHARGESWhile it is recognized that the actual initial dilution of many deep water discharges is greater than ten, the Regional Board has taken a conservative approach to calculating effluent limitations for the following reasons. First, there is concern over the effects of the cumulative mass loadings of toxic pollutants from the numerous discharges into San Francisco Bay. Limiting the allocation of dilution credits is one means of limiting mass loadings. Second, recent Regional Board studies have detected toxicity in ambient waters throughout the Bay system based on laboratory toxicity tests. This calls for a cautious approach in allowing the discharge of toxic substances. Third, studies indicate that bioaccumulation of pollutants in San Francisco Bay biota is of concern to wildlife and human health. Fourth, it is difficult to either measure or predict actual dilution in the San Francisco Bay estuarine environment. In the Estuary, the direction of waste transport varies over the course of the tidal cycle, so it is difficult to determine the fraction of new water versus recirculated water mixing with the discharge. U.S. EPA has developed several models of initial dilution for discharge plumes, but none take into account transport due to tidal currents. The Regional Board will consider inclusion of an effluent limitation greater than that calculated from water quality objectives when the increase in concentration is caused by implementation of significant water reclamation or water reuse programs at the facility; the increase in the effluent limitation does not result in an increase in the mass loading; and water quality objectives will not be exceeded outside the zone of initial dilution. SHALLOW WATER DISCHARGESShallow water dischargersare subject to a discharge prohibition (Table 4-1, No. 1), which is intended to protect beneficial uses in areas that receive very limited, if any, dilution. When an exception to the prohibition is granted, it is generally not appropriate to allocate dilution credits for purposes of calculating effluent limitations, because these shallow aquatic environments are often biologically sensitive or critical habitats. However, dilution credit may be granted on a discharger-by-discharger and pollutant-by-pollutant basis based on provisions of the “Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bay, and Estuaries of California (SIP).” In making this determination, the Regional Board will grant dilution credit on a pollutant-by-pollutant basis, if the discharger demonstrates that an aggressive pretreatment and source control program is in place, including the following:
Any dilution credit granted must be consistent with the antibacksliding policy and may be granted only after very rigorous scrutiny of source control efforts and receiving water data. When dilution is granted, permits shall include provisions requiring continuing efforts at source control, targeting the substances to which the exceptions apply. For certain low volume, short duration, or one-time discharges, the requirements of pretreatment and source control programs may not be practical. The Regional Board may choose to waive such requirements for pollutants in low volume discharges determined to have no significant adverse impact on water quality. In addition, the Regional Board will consider the discharger's demonstration of compliance with water quality objectives, in accordance with the SIP. This demonstration shall address the following issues:
A study plan for conducting this work must be submitted to the Regional Board for approval by the Executive Officer. Results of the study or studies addressing these three points shall be submitted to the Regional Board. Effluent limitations based on either concentration or mass loading shall be developed for consideration by the Regional Board based on study results and any other available information. The goal in setting effluent limitations shall be to ensure that water quality objectives are met in the receiving water and that mass loadings are limited to a level that provides protection of beneficial uses. In no case shall effluent limitations impair the basis upon which exception to the prohibition against discharge to shallow water was granted. Continued ambient monitoring shall also be required to ensure that water quality objectives are met. FRESH WATER VS. MARINE WATERDue to the unique estuarine environment that exists in the region, the salinity characteristics (i.e., freshwater vs. marine water) of the receiving water shall be considered in establishing water quality objectives. Freshwater effluent limitations shall apply to discharges to waters both outside the zone of tidal influence and with salinities equal to or less than 1 part per thousand at least 95 percent of the time in a normal water year. Marine effluent limitations shall apply to discharges to waters with salinities equal to or greater than 10 parts per thousand at least 95 percent of the time, except for discharges to the Pacific Ocean, which are covered by the California Ocean Plan. For discharges to waters with salinities in between these two categories, defined as estuarine, effluent limitations shall be the lower of the marine or freshwater effluent limitation, based on ambient hardness, for each substance. The use of alternative marine or freshwater criteria may be approved if scientifically defensible information and data demonstrate that on a site-specific basis the biology of the water body is dominated by freshwater aquatic life; or conversely, the biology of the water body is dominated by marine aquatic life. BACKGROUND CONCENTRATIONSWhen dilution credit is granted, the background concentration of the substance is taken into account in calculating effluent limitations so that the dilution provided by mixing with receiving waters is not overestimated. Ambient background concentration means the median concentration of a substance, in the vicinity of a discharge, which is not influenced by the discharge. For the San Francisco Estuary, it is difficult to identify a location that is not influenced by a discharge. Furthermore, background concentrations should vary within the Estuary due to changing geochemistry of the waters as they travel downstream. However, in order to simplify the calculation of effluent limitations, it is desirable to use one background concentration throughout the region. The determination of ambient background concentration, for purposes of establishing NPDES effluent limitations for toxic pollutants, will be done in accordance with the provisions of the SIP, and amendments thereto. IMPLEMENTATION OF EFFLUENT LIMITATIONSIn incorporating and implementing effluent limitations in NPDES permits, the following general guidance shall apply: PERFORMANCE-BASED LIMITSWhere water quality objectives in the receiving water are being met, and an existing effluent limitation for a substance in a discharge is significantly lower than appropriate water quality-based limits, performance-based effluent limitations for that substance may be specified or the effluent limit revised. Any changes are subject to compliance with the state Antidegradation Policy. The performance-based effluent limitation may be either concentration- or mass-based, as appropriate. SITE-SPECIFIC OBJECTIVE INCORPORATIONOnce the Regional Board has adopted a site-specific objective for any substance, effluent limitations shall be calculated from that objective in accordance with the methods described above. AVERAGING PERIODSFor some substances there may be more than one effluent limitation with different averaging periods (e.g., daily average and 30-day average). In both cases, the effluent limitations shall apply to the mean concentration of all samples analyzed during the averaging period. If only one sample is taken during the averaging period, the effluent limitation applies to the concentration of that sample. METHOD DETECTION LIMITS, PRACTICAL QUANTITATION LEVELS (PQL), AND LIMITS OF QUANTIFICATION (LOQ)Method Detection Limits are defined in Title 40, Code of Federal Regulations, Part 136, Appendix B (revised June 30, 1986). Practical Quantitation Level is the lowest concentration of a substance within plus or minus 20 percent of the true concentration by 75 percent of the analytical laboratories testing in a performance evaluation study. If performance data are not available, the PQL is the MDL x 5 for carcinogens and the MDL x 10 for noncarcinogens. Limits of Quantification are ten standard deviations greater than the average measured blank values used in developing the MDL. These terms and concepts are useful when pollutant concentrations in waters are relatively low. However, these will be taken into account in determining compliance with, rather than in the calculation of, effluent limitations. SELECTION OF PARAMETERSEffluent limits are not necessary for substances that do not pose any risk to beneficial uses or are shown not to be present in discharge. However, a discharger must demonstrate to the satisfaction of the Regional Board that particular substances do not cause, or have the reasonable potential to cause or contribute to an excursion above numerical and narrative objectives. Dischargers must also demonstrate that pollutants of concern are (a) not in the waste stream, and (b) no change has occurred that may cause release of pollutants. This certification shall be supported, at a minimum, by monitoring results for such pollutants and process and treatment descriptions that demonstrate these substances are not expected to be present in the waste stream. At a minimum, this monitoring and certification is required prior to issuance and reissuance of WDRs. The Regional Board may choose to not require periodic monitoring and certification for pollutants in low volume discharges determined to have no significant adverse impact on water quality. COMPLIANCE SCHEDULESAs new objectives or standards are adopted, permits will be revised accordingly. Revised permits will distinguish between effluent limitations that are met by current performance, and effluent limitations not currently attained. Immediate compliance will be required for effluent limitations that are met by current performance. The Regional Board may consider dischargers' proposals for longer compliance schedules for newly adopted objectives or standards as NPDES permit conditions for particular substances, where revised effluent limitations are not currently being met and where justified. The primary goal in setting compliance schedules is to promote the completion of source control and waste minimization measures, including water reclamation. Justification for compliance schedules will include, at a minimum, all of the following:
Implementation of source control measures to reduce pollutant loadings to the maximum extent practicable shall be completed as soon as possible, but in no event later than four years after new objectives or standards take effect. Implementation of any additional measures that may be required to comply with effluent limitations shall be completed as soon as possible, but in no event later than ten years after new objectives or standards take effect. The issuance of the permit containing a compliance schedule should not result in a violation of any applicable requirement of the federal Clean Water Act or the California Water Code, including any applicable Clean Water Act statutory deadlines. STORMWATER DISCHARGESAs discussed in a later section titled "Urban Runoff Management," the Regional Board has initiated a program that regulates certain municipal, industrial, and construction stormwater discharges through NPDES permits. Since both the sources of pollutants in stormwater discharges and the points of discharge are diffuse, and the methods of reducing pollutants in stormwater discharges are in the development stage, water quality-based numerical effluent limitations are not feasible at this time. Instead, stormwater permits will include requirements to prevent or reduce discharges of pollutants that cause or contribute to violations of water quality objectives. Compliance with these requirements is expected to be achieved through implementation of control measures or best management practices identified in dischargers' stormwater management plans or stormwater pollution prevention plans. Instead, stormwater permits will include requirements to prevent or reduce discharges of pollutants that cause or contribute to violations of water quality objectives for receiving waters. Compliance with these requirements is expected to be achieved through implementation of control measures or best management practices identified in dischargers' stormwater management plans or stormwater pollution prevention plans. The Regional Board is taking a phased approach towards attainment of water quality objectives in waters that receive stormwater discharges from urban areas and certain industrial and construction activities. The Regional Board will first require entities subject to NPDES permits for stormwater discharges to complete implementation of technically and economically feasible control measures to reduce pollutants in stormwater to the maximum extent practicable. For industrial facilities, such control measures include those representing the best available technology that is economically achievable. NPDES permits for stormwater discharges will require completion of technically and economically feasible control measures as soon as possible. Specific schedules for implementing control measures may, at the discretion of the Regional Board, be included in permits (to the extent that such schedules are authorized by state or federal laws) either by reference to a stormwater management plan or by permit conditions. In no event will these schedules extend beyond the term of the permit. If this first phase does not result in attainment of water quality objectives, the Regional Board will consider permit conditions which may require implementation of additional control measures. In such circumstances, the Regional Board may consider dischargers' proposed schedules for identification and implementation of additional control measures designed to attain water quality objectives. Such schedules shall be as short as practicable and will only be considered for inclusion in permits when a discharger has demonstrated the following:
WET WEATHER OVERFLOWSDuring periods of heavy rainfall, large pulses of water enter sewerage systems. When these pulses exceed the collection, treatment, or disposal capacity of a sewerage system, overflows occur. This is especially problematic for sewer systems that combine both sanitary sewage and stormwater (Combined Sewer Systems or CSS), such as the City and County of San Francisco's system (discussed under the municipal discharger section). All other municipalities in the region operate two distinct sewer systems. Wet weather is also problematic for separate systems because more water infiltrates the pipes leading to treatment plants. This problem is commonly referred to as inflow/infiltration (I/I). In either case, pulses of water during wet weather may cause untreated or partially treated wastewater to be discharged directly to surface water bodies. Wet weather overflows of wastewater affect three types of beneficial uses: water contact recreation, non-contact water recreation, and shellfish harvesting. The water quality characteristics that can adversely affect these beneficial uses are pathogens, oxygen-demanding pollutants, suspended and settleable solids, nutrients, toxics, and floatable matter. FEDERAL COMBINED SEWER OVERFLOW CONTROL POLICYOn April 11, 1994, the U.S. EPA adopted the Combined Sewer Overflow (CSO) Control Policy (50FR 18688). This policy establishes a consistent national approach for controlling discharges from CSOs to the nation’s water. Using the NPDES permit program, the policy initiates a two-phased process with higher priority given to more environmentally sensitive areas. During the first phase, the permittee is required to implement the following 9 Minimum Controls. These constitute the technology-based requirements of the Clean Water Act as applied to combined sewer facilities (best conventional treatment (BCT) and best available treatment (BAT)). These minimum controls can reduce CSOs and their effects on receiving water quality:
Compliance with the minimum controls shall be as soon as practicable, but no later than January 1, 1997. The permittee is also required to initiate development of a long-term control plan to select CSO controls, based on consideration of the permittee's financial capability. The second phase of the process involves implementation of the long-term control plan developed in the first phase. Such implementation must provide for the attainment of water quality objectives and may result in additional site-specific technology-based controls, as well as water quality-based performance standards that are established based on best professional judgement. While numeric water quality-based effluent limits are not readily established due to unpredictability of a storm event and the general lack of data, the CSO Control Policy requires immediate compliance with water quality standards expressed in the form of a narrative limitation. The Regional Board intends to implement the federal CSO Control Policy for the combined sewer overflows from the City and County of San Francisco. The City and County of San Francisco has substantially completed implementation of the long-term CSO control plan (and is thereby exempted requirements to prepare a long-term control plan). Additionally, the following is the Regional Board's recommended approach to control the seasonal degradation of water quality that results from all wet weather overflows of wastewater, including POTWs with either combined and separate sewer systems, and industrial wastewater facilities. The overflow from San Francisco's combined sewer system is addressed by the CSO Control Policy described above. CONCEPTUAL APPROACHThe recommended approach to controlling wet weather overflows of wastewater that contains particular characteristics of concern to beneficial uses is a combination of designated alternative levels of maintenance (i.e., combination of treatment levels and beneficial use protection categories) and guidance for the design of overflow discharge structures. The Regional Board is not endorsing any specific control measures, but is presenting a conceptual framework that allows for the evaluation of costs and benefits. This framework can be used as guidance in adopting specific control measures. As with all of its programs, the Regional Board will implement this conceptual approach consistent with the national goal of "...water quality which provides for the protection and propagation of fish, shellfish, and wildlife and provides for recreation in and on the water." Maintenance and associated treatment and overflow requirements are detailed in Table 4-8. The following requirements should be met for all overflows:
Exceptions to (a) and (c) will be considered where an inordinate burden would be placed on the discharger relative to beneficial uses protected, and when an equivalent level of environmental protection can be achieved by alternative means, such as an alternative discharge site, a higher level of treatment, and/or improved treatment reliability. The conceptual approach described above will be used by the Regional Board in evaluating wet weather discharge conditions where polluted stormwater or process wastewater bypasses any treatment unit or units that are used in the normal treatment of the waste stream. Evaluation of such discharges must include identification of:
SURFACE IMPOUNDMENT OVERFLOW PROTECTIONIn providing protection of waste management units against wet weather overflows, Chapter 15 requires that surface impoundments must have sufficient freeboard to accommodate seasonal precipitation and precipitation conditions specified for each class of waste management unit. Those specified precipitation conditions are probable maximum precipitation for Class I units; and the 1000-year, 24-hour precipitation for Class II units. To guarantee the protection of water quality, the Regional Board will interpret seasonal precipitation to be the 100-year return period wet season for Class I units and the 10-year return period wet season for Class II units. The sources to be used for determining the applicable precipitation for a given return period and location are California Department of Water Resources Bulletin No. 195 (or any update by the Department), local water agency publications, or other sources approved by the Executive Officer. DISCHARGE OF TREATED GROUNDWATERCleanup of groundwater contamination sites often includes groundwater extraction, and thus creates the need for proper disposal of treated groundwater. The majority of the groundwater pollution cases of the region involve surface spills, pipeline breaks, or leakages from tanks, vaults, sumps, surface impoundments, or landfills. Toxic pollutants commonly found in groundwater range from solvents (including volatile and semi-volatile organic compounds), petroleum hydrocarbons, heavy metals, or a combination of these pollutants. In many cases, the treated groundwater is discharged to surface waters via storm drains. These direct discharges would normally require an exception to the prohibitions against discharge into shallow or non-tidal waters. To address this issue, the Regional Board adopted Resolution No. 88-160 (see Chapter 5). The Resolution urges dischargers of groundwater extracted from site clean-up projects to reclaim their effluent. When reclamation is not technically and/or economically feasible, discharges must be piped to a municipal treatment plant. Furthermore, as required in State Water Board Resolution 89-21 (see Chapter 5), the Regional Board recognizes the resource value of the extracted and treated groundwater and urges its utilization for the highest beneficial use for which applicable water quality standards can be achieved. The Regional Board will consider granting an exception to the discharge prohibitions only if (a) it has been demonstrated that neither reclamation nor discharge to a POTW is technically or economically feasible, and (b) beneficial uses of the receiving water are not adversely affected. Such an exception is based on the Regional Board's recognition that discharges allowed under the exception are an integral part of a program to clean-up polluted groundwater and thereby produce an environmental benefit. Dischargers shall demonstrate that their groundwater extraction and treatment systems and associated operation, maintenance, and monitoring plans constitute acceptable programs for minimizing the discharge of toxic substances and for complying with effluent limitations deemed necessary for protection of the beneficial uses of receiving waters. Applications for NPDES permits to discharge treated groundwater directly to surface waters will be evaluated on a case-by-case basis. However, the Regional Board has adopted general NPDES permits for the following two types of groundwater clean-up projects:
The general permits were intended to streamline a common regulatory process. The Regional Board may renew, revise, or rescind the permits if deemed appropriate. In establishing effluent limitations, no dilution credit was allowed in the general permits for primary pollutants of concern. However, ambient levels of heavy metals in groundwater may sometimes result in exceedances of effluent limitations that did not provide allowance for dilution. This is especially a concern for clean-up of groundwater polluted with VOCs when heavy metals were not contributed to the environment. The inadvertent discharge of background metals would be a result of the effort to extract groundwater for the removal of VOCs. A study conducted by Regional Board staff in 1993 concluded that metals concentrations in the effluent of these groundwater discharges would sometimes exceed effluent limitations with zero dilution credit, but would rarely exceed concentrations of twice of such limits. As a result, the general permit adopted for cleanup of VOCs-polluted groundwater (Order No. 94-087) sets heavy metals effluent limitations based on a 1:1 dilution credit. Consideration for allowing limited dilution credit in this case is based on reasons which are unique to the specific type of groundwater cleanup discharges which are temporary and are due to non-metal contamination. Metal mass loading to the Bay from these discharges is insignificant compared to other sources and the dischargers usually have no feasible way to reduce the loadings. However, special studies shall be required in the event of any chronic violations of such metals limits. MUNICIPAL FACILITIESTable 4-9 is a list of municipal wastewater treatment facilities (excluding wet weather facilities) within the Region that discharge directly into surface waters. Figure 4-1 shows where these facilities are located in the region. Under normal operational conditions, these POTWs provide a minimum of secondary treatment. In addition, with more than thirty percent of the total flow receives advanced treatment. Brief discussions of the issues specific to the City and County of San Francisco, South Bay dischargers, the Fairfield-Suisun Sewer District, the Livermore-Amador Valley, and the East Bay Municipal Utilities District are presented below. CITY AND COUNTY OF SAN FRANCISCOThe City and County of San Francisco collects the wastewater in a combined sewer system. That is, the domestic sewage, industrial wastewater, and stormwater runoff are all collected in the same pipes (combined sewer). Such system is subject to overloading during severe storms. Most other communities in California have a separated sewer system: one set of pipes for domestic sewage and industrial wastes and another set for stormwater. San Francisco is near completion of the primary components of its wastewater facilities master plan. This construction program began in 1974 with the publication of the Master Plan Environmental Impact Statement and Report. The integrated wastewater control system established by the master plan has been designed to provide control and treatment for both dry weather sewage and wet weather storm flows. All dry weather flows currently receive secondary level treatment. At program completion in 1996, all wet weather flows including stormwater runoff will be captured and will receive a specified level of treatment depending on the size of the storm. Pollutant removal from stormwater will be approximately 60 percent system-wide (measured as reduction in total suspended solids). San Francisco is one of the first municipalities in the nation to complete a comprehensive control program for a combined sewer system. The expenditures for completing the wastewater master plan is about $1.45 billion. The Southeast Water Pollution Control Plant is a major component of San Francisco's wastewater treatment system. The plant provides secondary level treatment for all dry weather domestic and industrial wastewater from the Bayside drainage area in San Francisco (approximately 75 percent of the total citywide flow). The Oceanside plant provides similar treatment on the Westside. The storage/transports around the periphery of the city store combined sewage for treatment after the storms subside. Additionally, northeast zone storm flows receive treatment at the Northpoint wet weather treatment plant. SOUTH BAY MUNICIPAL DISCHARGERS (SAN JOSE/SANTA CLARA, PALO ALTO, AND SUNNYVALE)The South Bay municipal dischargers consist of three sewage treatment facilities: the San Jose/Santa Clara Water Pollution Control Plant (WPCP), the Palo Alto Regional Water Quality Control Plant, and the Sunnyvale WPCP. These three plants serve all of the urban communities of Santa Clara County located in the region. The South Bay municipal dischargers, as shown in Figure 4-1, presently discharge effluent receiving tertiary treatment (secondary plus nitrification, filtration, and disinfection) to shallow sloughs contiguous with the Bay, south of the Dumbarton Bridge. Therefore, all three dischargers must meet shallow water effluent concentration limits for toxic pollutants. In 1988, the Regional Board identified the following issues that needed further study in the South Bay. As part of the reissuance of the South Bay NPDES permits, the Regional Board required the three South Bay dischargers to address these issues.
Based on the results of these studies the Regional Board amended the NPDES permits for the three South Bay dischargers on several occasions. In 1989, San Francisco Bay south of the Dumbarton Bridge (South Bay) was designated by EPA as an impaired water body under Section 304(l) of the Clean Water Act due to anthropogenic inputs of seven metals. The three municipal plants and stormwater runoff were designated as sources contributing to the impairment. As of 1994, the wastewater effluents of the three plants routinely exceed the concentration limit for copper and occasionally exceed the limits for other metals such as nickel. South Bay monitoring data collected by the dischargers from 1989 to 1992 indicate that U.S. EPA water quality criteria for copper, nickel, and mercury were regularly violated in the receiving waters south of the Dumbarton Bridge. The beneficial uses of San Francisco Bay, South Bay (south of the Dumbarton Bridge) and contiguous water bodies are defined in the to be: Contiguous water bodies of the South Bay in the vicinity of the discharge include freshwater and saltwater sloughs such as Artesian Slough, Coyote Slough, Mud Slough and Coyote Creek. Beneficial uses of the sloughs have been established based on the beneficial uses formally identified for the South Bay. However, beneficial uses specific to the sloughs need to be assessed to determine which uses exist or potentially could exist. Until such determination is made, Regional Board policy has been to use the tributary rule to interpret which beneficial uses are currently or potentially supported where beneficial uses have not been specifically designated. The existing discharge locations for Lower South SF Bay municipal wastewater dischargers are contrary to Basin Plan policy concerning discharge prohibitions (listed in Table 4-1). Exceptions to the first three of these prohibitions are discussed in the later section “Discharge Prohibitions Applicable Throughout the Region.” State Board Order WQ 90-5 (1990) found that a net environmental benefit exception to these prohibitions could not be made for the three South Bay municipal discharges. However, the Order found that a finding of equivalent protection can be made if water quality based concentration limits for metals and revised mass loading limits for metals are placed in the dischargers' NPDES permits, if Sunnyvale and San Jose/Santa Clara continue avian botulism control programs, and if San Jose/Santa Clara implements mitigation for loss and degradation of endangered species habitat. Order 90-5 also included provisions that would prevent increases in flows that would adversely impact endangered species habitats. In an effort to demonstrate net environmental benefit, the three South Bay municipal dischargers participated in a five-year Water Quality Monitoring Study conducted by the South Bay Dischargers Authority. Based on that study, the Regional Board found that water quality enhancement occurs due to localized increase of receiving water dissolved oxygen and the flushing effects of the discharge. These effects enhance beneficial uses of non-contact recreation, estuarine habitat, commercial and sport fishing. A finding of net environmental benefit was denied by the State Board, however, based on the impacts of fresh water flow on salt marsh habitat and the uncertainties of the impacts of nutrient and metals loading on beneficial uses. The conversion of salt marsh to brackish or fresh water marsh threatens the habitat of two endangered species (California clapper rail and salt marsh harvest mouse). State Board Order WQ 90-5 directed the San Jose/Santa Clara treatment plant to mitigate for degradation of endangered species habitat. As of December 2001, the three principal issues of WQ 90-5 have been addressed in the following fashion. WATER-QUALITY BASED EFFLUENT LIMITSThe Regional Board has amended and reissued permits to the South Bay municipal dischargers to provide equivalent protection. On April 17, 1991, the NPDES permits of the three South Bay Municipal Dischargers were amended to include water quality based concentration limits and revised mass loading limits for metals, as directed by State Board Order WQ 90-5. AVIAN BOTULISMAnnual avian botulism control program reports are provisions of the Sunnyvale and San Jose/Santa Clara permits. These two dischargers have conducted an avian botulism control program by monitoring Artesian Slough, Guadalupe Slough, Coyote Creek, and Alviso Slough for the presence of avian botulism since 1982. Outbreaks of avian botulism as well as other diseases have been controlled by the prompt removal of sick and dead vertebrates. The discharger also supports the collection of bird and other wildlife data, in conjunction with the avian botulism program, to better understand the potential beneficial and detrimental impacts of the discharge on the associated habitat. MITIGATION FOR LOSS OF ENDANGERED SPECIES HABITAT AND PREVENTION OF FLOW INCREASESOn March 6, 1991 the San Jose/Santa Clara treatment plant submitted an "Action Plan", with a request that the Action Plan be accepted by the Regional Board as fulfillment of the State Board requirement for a discharge flow limit. In Resolution 91-152, the Regional Board stated that the Action Plan (revised), dated September 30, 1991, fulfilled the intent of the State Board Order WQ 90-5 requirement to limit flows from the San Jose/Santa Clara Water Pollution Control Plant to a level that will halt any further loss or degradation of endangered species habitat. The Resolution contained a provision requiring a Regional Board hearing to consider adopting a 120 million gallon per day average dry weather effluent flow (MGD ADWEF) discharge limit if delays occur that threatened the timely completion or implementation of reclamation projects, or if ADWEF exceed 120 MGD. By letter dated November 26, 1991, the State Board found Resolution 91-152 to be consistent with Order WQ 90-5. On September 18, 1996 the Regional Board adopted Resolution 96-137, which accepted the discharger’s proposal for wetland loss mitigation as required by Provision 6.1 of Order No. 93-117 and requested State Board concurrence that the proposal fulfilled mitigation requirements contained in WQ 90-5. By letter dated October 10, 1996, the State Board concurred that the proposal satisfied requirements of Order WQ 90-5 pertaining to salt marsh conversion. In 1996, the ADWEF of 132 MGD triggered the requirement in Resolution 91-152 for the Regional Board to hold a hearing. On December 18, 1996 the Regional Board held a hearing on this issue. It considered three options: 1) amend the NPDES permit to limit flows to 120 MGD ADWEF; 2) direct the discharger to propose an alternative solution by June 1997; and 3) no action. The Regional Board adopted the second option (Order No. 97-111). Also at the December 1996 hearing, the Regional Board directed the discharger to conduct a wetland conversions assessment in 1997. Responding to the 120 MGD ADWEF flow limit, On May 28, 1997, the San Jose/Santa Clara treatment plant submitted the South Bay Action Plan (SBAP) to the Regional Board. The SBAP proposed both near and long-term solutions to reduce the discharge: 1) two projects to begin in the near term (1997-98), (i.e. public education aimed at water conservation and on-site reuse); 2) A third near term project of wastewater diversion to the Sunnyvale treatment plant is under investigation; 3) Seven long-term projects to be completed between 1997 and 2002: indoor water conservation, two expanded water recycling projects, industrial water recycling, inflow/infiltration reduction, and two environmental enhancement projects. Total costs of these projects were estimated to be $150 million and were expected to reduce effluent flows by up to 60 MGD. The results of a wetlands conversions assessment were submitted on November 30, 1997. The assessment indicated that there were no significant additional salt marsh conversions between 1996 and 1997 and if data are compared to the baseline period of 1989-1991, an increase of 1.3 acres of salt marsh conversion had occurred. It is the intent of the Regional Board to require appropriate mitigation for any wetland losses due to the discharge. Appropriate mitigation shall be determined after consultation with appropriate resource agencies and other interested parties. RECENT DEVELOPMENTS FOR COPPER AND NICKELStarting in 1998, technical studies were initiated to assess the impairment status of South San Francisco Bay south of the Dumbarton Bridge with respect to copper and nickel and determine appropriate site-specific objectives for dissolved ambient concentrations of these two metals. It was determined that impairment of beneficial uses due to these metals is unlikely and recommended ranges of site-specific objectives were established. The site-specific objectives resulting from this work are given in Table 3-3A, and the Water Quality Attainment Strategy to support these objectives is described earlier in this Chapter. FAIRFIELD-SUISUN SEWER DISTRICT (FSSD)The FSSD's tertiary wastewater treatment plant has a dry weather treatment capacity of 17.5 million gallons per day (mgd), a wet weather capacity of 40 mgd, and 45 million gallons of off-line storage capacity. The District is currently treating 13 mgd (1993 dry weather data) from a service population of about 111,000. In order to comply with the Regional Board's prohibition against dry weather discharges to the Suisun Marsh, FSSD operates a reclamation project in cooperation with the Solano Irrigation District. However, due to various contractual, legal and economic constraints, only about 40 percent of the treatment plant's annual effluent flow is reclaimed for agricultural irrigation. The remainder is discharged to Boynton Slough in Suisun Marsh. The Regional Board required FSSD to conduct an investigation to evaluate the discharge’s impact on water quality conditions and beneficial uses of the receiving waters. This investigation was completed in 1987 and found that the discharge has some measurable local effects on water quality in Boynton Slough, but that beneficial uses are not impaired by the discharge. The study concluded that, overall and on a year-round basis, the discharge affords a net environmental benefit to Boynton Slough and the Suisun Marsh. Given the findings of this study, the plant's high degree of operational redundancy and emergency storage capacity, and continued efforts by FSSD to maximize the use of reclaimed water, the Regional Board has granted FSSD an exception to the Basin Plan prohibition. The Regional Board allows, through the NPDES permit issued to FSSD, that portion of FSSD's tertiary effluent which cannot be reclaimed to be discharged to Boynton Slough on a year-round basis. LIVERMORE-AMADOR VALLEYThe primary Board concern in the Livermore-Amador Valley is that an integrated water/wastewater resource operational plan be implemented to protect the main groundwater basin from increased salt (TDS) loading. Existing natural saline sources and basin management practices, with minimal water recycling, result in a net salt loading of approximately 5,000 tons/year. The Regional Board supports efforts to concurrently improve the salt balance in the main basin, to increase the local water supply, and to reduce the need for wastewater export through recycled water irrigation and groundwater recharge and other basin management practices. In 1993, the Regional Board approved a Master Water Reuse Permit for the water and wastewater agencies in the valley that provides the framework (described below) within which these goals can be accomplished. A Salt Management Program being developed by the permittees prior to implementation of valley-wide recycling projects will provide updated water quality management policies and objectives. The Regional Board will consider permittee requests for future modifications to Basin Plan policies and objectives as appropriate to facilitate implementation of beneficial reuse projects. BACKGROUNDThe Livermore-Amador Valley is a closed groundwater basin within the Alameda Creek Watershed with multiple groundwater sub-basins of variable water quality. The main portion of the Main Basin (that portion underlying Livermore and Pleasanton) has the highest water quality, supplies most of the municipal wells in the area, and is used to store and distribute high quality imported water. Alameda Creek and its tributaries recharge the Livermore-Amador Valley groundwater basin and serve as a channel to convey water released from the South Bay Aqueduct (SBA) to the Niles Cone groundwater basin for recharge. During dry weather, creek flow consists primarily of SBA release water. The Zone 7 Water Agency is the potable water wholesaler for the most of Livermore-Amador Valley area and operates facilities to import and treat surface water from the State Water Project, groundwater wells, and distribution pipelines. Zone 7 serves as the overall water quality management planning agency for the Alameda Creek Watershed above Niles and is responsible for management of the valley's surface water and groundwater resources. Dublin-San Ramon Services District (DSRSD) distributes potable water and treats wastewater in the western portion of the valley, including parts of Contra Costa County. The City of Livermore distributes potable water to about one-fourth of Livermore and treats wastewater from the city and adjacent national laboratories. Livermore and DSRSD are member agencies of the Livermore-Amador Valley Water Management Agency (LAVWMA). Since 1980, wastewater has been exported from the valley via LAVWMA-operated facilities that connect to an East Bay Dischargers Authority interceptor in San Leandro. These waters are ultimately discharged through the East Bay Dischargers Authority outfall into south San Francisco Bay west of the Oakland Airport. The current surface water quality objectives for the Alameda Creek Watershed above Niles (Table 3-7) were adopted in 1975. They were set primarily to prevent degradation by wastewater discharge during dry weather periods. The Table 3-7 groundwater quality objectives and basin boundary definitions for the Valley were developed by Zone 7 in its May, 1982 "Wastewater Management Plan for the Unsewered, Unincorporated Area of Alameda Creek Above Niles." This plan was prepared when wastewater demineralization and reuse was not considered cost-effective in comparison to export; the LAVWMA export project had only recently become operational; the safety of reuse was less widely accepted; and extensive development with on-site systems remained a possibility. The policies in the 1982 plan consist of a general policy, community wastewater system policies, individual on-site wastewater system policies, and local area policies for known problem areas at that time. The policies were intended to discourage small community wastewater systems and septic tanks in favor of connection to existing large community systems. They also encourage export of wastewater, rather than beneficial reuse via irrigation or groundwater recharge. Since adoption of the wastewater management plan, Zone 7, DSRSD and Livermore's interest in water recycling has been increased by droughts, continuing scarcity of new water supplies, institutional barriers to increasing wastewater export capacity from the valley, and increasing public acceptance of water recycling throughout California. Technological advances and reduced costs of demineralization also now make groundwater recharge with demineralized wastewater a viable tool for managing salt concentrations in the basin. WATER RECYCLING FOR VALLEY WATER - WASTEWATER MANAGEMENTZone 7 has projected a need for 10,000-25,000 acre-feet per year of additional water supply within the next 10-15 years. Livermore-Amador Valley Water Management Agency wastewater export disposal capacity is currently limited to 21 million gallons per day. This capacity is projected to be exceeded within the next 10-15 years. Wet weather disposal capacity may be exceeded sooner. Additional effluent storage may achieve marginal increases in effective capacity, but will not meet projected disposal demand at buildout. The water and wastewater agencies of the Livermore-Amador Valley have studied water recycling as an alternative to import of new water supplies and export of wastewater for over 20 years. While LAVWMA continues to investigate export alternatives, the agencies have also developed a strategy for implementing large-scale water recycling. Valleywide water recycling is consistent with the Regional Board's policy on Reclamation, which states in part that disposal of wastewater to inland, estuarine, or coastal waters is not considered a permanent wastewater disposal solution where the potential exists for conservation and reclamation. As directed by Water Code Sections 13511 and 13512, the Regional Board strongly supports the use of recycled water to supplement existing surface and groundwater supplies and will work with agencies to facilitate development of water reclamation facilities. An important Valley water recycling milestone was the City of Livermore's study, "Advanced Treatment and In-Valley Effluent Reuse/Disposal" (October, 1989). The study recommended installing advanced treatment (reverse osmosis demineralization) facilities at the Livermore Water Reclamation Plant to provide recycled water for irrigation and groundwater recharge. The agencies then formed the Tri-Valley Water Recycling Task Force and held several public meetings in 1990 and 1991 to present the findings. The agencies then jointly sponsored the "Livermore-Amador Valley Water Recycling Study" (May 1992), a comprehensive investigation of water recycling options. The study documented the area's hydrogeology. It also identified and analyzed potential projects throughout the valley, including irrigation with non-demineralized effluent, groundwater recharge with demineralized effluent, and export of brine. The report included a discussion of how water recycling could be implemented in conformance with Basin Plan requirements and Zone 7 policies. The report also detailed a strategy for developing a water recycling program incrementally, beginning with small demonstration projects to gain experience and public acceptance and building up to full-scale projects that could contribute substantially to water supply and wastewater disposal needs in future years. The 1992 study documented that between 19,000 and 38,000 acre-feet per year of recycled water could be beneficially reused within the Livermore-Amador Valley via irrigation and groundwater recharge. Well-established technologies and procedures exist for accomplishing such uses and could be in full compliance with Basin Plan and Title 22 requirements. The long-operating Orange County Water District Water Factory 21 project has served as a model for many recycled water groundwater recharge facilities. A key element of proposed valley-wide water recycling is a salt management program for the groundwater basin. This program includes further characterization of basin hydrogeology, refinement of salt balance calculations, selection of TDS targets and examination of alternative ways to offset natural salt loadings. (These measures might include wellhead demineralization of pumped groundwater or diversion of natural salt inflows to export facilities.) The Salt Management Program addresses the Basin Plan objectives for the Alameda Creek Watershed that wastewater disposal/reuse projects be part of an "overall water-wastewater resource operational program developed by the agencies affected and approved by the Regional Board." MASTER WATER REUSE PERMITAs recommended in the study, the agencies jointly applied for a master water reuse permit to cover proposed water recycling activities throughout the Valley. The permit was issued by the Regional Board in December, 1993 (Order No. 93-159). The permit specifies the various technical reports that are required to be submitted for review by the Executive Officer, and approval before projects can commence operation. In this manner, the master permit fully addresses the regulatory requirements that projects must comply with, while facilitating the approval process for individual projects in this long-term, valley-wide program. This permit identifies two phases and three categories of water recycling projects. During Phase I of the water recycling program, the agencies have proposed first to construct a few small-scale irrigation projects (Group A). This would be followed by startup of a 0.75 MGD demonstration demineralization facility or possibly other salt management projects (Group B). The Phase I projects would be accompanied by a thorough groundwater monitoring program to assess any potential impacts. As specified in the master permit, during the first three years of small-scale project operation, the agencies would complete the salt management plan, as well as the complex engineering reports, design studies and other documentation the Executive Officer will require before approval of any Phase II full-scale, valley-wide irrigation and groundwater recharge projects (Group C). Within five years of start-up of the first new small-scale (Phase I) project, the salt management plan would be implemented to achieve 100 percent mitigation of impacts on groundwater quality from water recycling activities. The salt management plan will be developed beginning in 1995 based on the concept that the effect of each individual project on the main basin groundwater resource is best assessed in the context of the cumulative effects of all such projects, as well as the effects of groundwater management policies and natural conditions. The relative geological homogeneity of the Main Basin lends itself to a mass-balance approach for assessing cumulative impacts. For a planning horizon of 10 years, the salt management plan will define a project or set of projects that will:
The Salt Management Plan will also provide a technical basis for estimating and allocating salt loading or removal among existing sources and new projects. Accordingly, the SMP includes development of a basin-wide model of salt sources and sinks. Numerical factors, representing (for example) connectivity between groundwater basins and effects of filtering through the soil mantle, will be estimated using the preparer's best professional judgement. The SMP will also provide information needed to support the DHS engineering report for full-scale groundwater recharge projects. Groundwater recharge or conveyance via ephemeral streams or waters of the state is an essential component of the proposed valley-wide, year-round water recycling and groundwater quality management program. Projects subject to NPDES requirements are not authorized under the master water reuse permit. The permit solely identifies the technical reports necessary to support a future NPDES permit application. The Regional Board will consider issuing a separate NPDES permit to the permittees following receipt of a complete NPDES application. IMPLEMENTATION POLICIESThe Regional Board supports the concept that water recycling is an essential component for planning the valley's future water supply. Water recycling is particularly important in areas that are dependent on imported water, such as the valley. The Regional Board supports managing the basin-wide salt balance can best be managed through an integrated water-wastewater resource operational plan. Such a plan should combine management of the groundwater basin, water conservation, salt management projects, and water recycling, with and without demineralization. The Regional Board supports the concept of transport and recharge through the valley's ephemeral streams. Recharge of the groundwater basin may be accomplished with imported water, as is done now, or with high-quality recycled water under a future NPDES permit. The year-round, dependable recycled water resource may be appropriate for streamflow augmentation to enhance beneficial uses of the valley's ephemeral streams. EAST BAY MUNICIPAL UTILITY DISTRICT (EBMUD) AND LOCAL AGENCIESThe sewer systems of the seven local agencies in the East Bay communities (Alameda, Albany, Berkeley, Emeryville, Oakland, Piedmont, and Stege Sanitary District) have had a serious problem with infiltration/inflow (I/I) during the wet weather season. During major storms, the community's sewers receive up to 20 times more flow than in dry weather. As a result, the communities' sewers overflowed to streets, local watercourses, and the Bay, creating a risk to public health and impairing water. The seven local agencies discharging sanitary sewage deliver sewage to EBMUD's facilities, and thus, EBMUD's interceptors and treatment facilities also subject to overflows during storm events. The Regional Board approved a regional approach -- a combination of community collection system improvements and EBMUD capacity improvements - for correcting wet weather overflows. Following the Basin Plan, EBMUD and the agencies established the following priorities to correct this problem:
In 1985, the East Bay communities completed a multi-year infiltration/inflow (I/I) study, which proposed a $300 million (1985 dollars) comprehensive sewer rehabilitation and relief line program known as the East Bay Infiltration/Inflow Correction Program (ICP), it required 20 years to implement. In a 1986 enforcement order, the Regional Board accepted the proposed approach and directed the ICP Program to focus on high public health problems. In 1986, all agencies submitted Compliance Plans in response to the cease-and-desist orders issued by the Regional Board. These plans set forth the design and implementation requirements of each agency's I/I Correction Program. EBMUD's and the collection system agencies' programs are designed to handle wastewater and I/I flows for up to a 5-year wet weather event. For rainfall events that have a return frequency greater than 5 years, overflows from the sanitary collection and treatment systems may occur. This approach is consistent with the Basin Plan wet weather overflow requirements (Maintenance Level C) adopted for the I/I Correction and the Wet Weather Facilities Program. The communities have made good progress implementing their ICP eliminating about 60 percent of the high public public health risk overflows. They have also gained a better understanding of how to implement their ICP. This experience has revealed that some of the original planning assumptions underestimated sewer rehabilitation and replacement costs. As a result, the communities revised their programs and the Cities of Alameda, Albany, Berkeley, Oakland, and Piedmont requested extensions to their compliance schedules by 5 to 10 years. In 1993, the Regional Board amended its enforcement order giving extensions to some communities' compliance schedules. The amended enforcement order also contains revised compliance reporting requirements. As part of the regional approach, EBMUD's contribution is a $145 million (1985 dollars) Wet Weather Program, designed to increase treatment capacity to match the communities' flows. The Wet Weather Program includes an expansion of the main wastewater treatment plant, new storage basins, four new remote wet weather treatment plants, new and ungraded pumping stations, and 7.5 miles of new interceptors. This program will increase EBMUD's peak transport and treatment capacity, without which community sewers would continue to overflow. It will also provide treatment for wet weather discharges and meet or exceed Basin Plan requirements. As of 1995, EBMUD has completed the expansion of the main wastewater treatment plant, all interceptor improvements, construction of the main plant storage basin, and construction of the two principal wet weather treatment facilities (Oakport and Point Isabel). The work remaining includes two pump station improvements, a storage basin, and two wet weather treatment plants. The Wet Weather Program is scheduled for completion in 1998. INDUSTRIAL FACILITIESThis section discusses industrial waste discharges to surface waters under the NPDES program. Other industrial waste disposal practices are discussed in a later section entitled "Hazardous and Nonhazardous Waste Disposal" under Groundwater Protection and Management. The Regional Board has permitted over 320 industrial discharges in the region. They can be separated into two general types: process-related wastewaters and groundwater from cleanup activities. There are about 50 discharges of process wastewater; of these, 15 are classified as major discharges and the rest are mostly small discharges of non-contact cooling water and/or runoff. About 270 of the 320 discharges consist solely of treated groundwater from remediation activities at solvent and/or fuel contamination sites. These are minor in flow relative to the major discharges, and are discussed in more detail in an earlier section entitled "Discharge of Treated Groundwater." Additionally, there are over 1,500 industrial facilities discharging only stormwater runoff. The regulation of these discharges is discussed in a later section entitled: "Urban Runoff Management." The 15 major discharges are the most significant individual sources of pollutant loadings from industrial discharges. They are identified and described in Table 4-11, and their locations are shown in Figure 4-2. These industries have all installed treatment facilities that can be considered to provide "best available treatment economically achievable" (BAT), and are in compliance with available BAT standards promulgated by the U.S. EPA for each industrial classification. The Regional Board's goal for regulation of industrial discharges is to continue to move beyond treatment technology-based standards to water quality-based standards. With this shift, the industries are challenged to improve existing or develop new treatment and control technologies to achieve higher levels of protection of receiving waters' beneficial uses. The effect of the Regional Board's regulation has been to drastically reduce the pollutant loadings from industrial sources. But with the focus shifting to water quality-based standards, concerns still do exist in certain areas. For example, a major concern is discharge of selenium from oil refineries. Water quality data from the Regional Monitoring Program and other studies will be necessary to identify areas of most concern and help target future pollutant reduction efforts. PRETREATMENT AND POLLUTION PREVENTIONThe Waste Discharge Permitting Program described above focuses on limiting pollutant discharge to the Bay from industrial and municipal treatment systems. In most situations, however, the overall effectiveness of treatment depends on the type and amount of pollutants that enter these POTW or industrial treatment system. Some pollutants may cause upset to or interference with the operation of the treatment plant, sludge contamination, or harm to treatment plant workers and the public if discharged into sewer systems. In general, it is often more economical to reduce overall pollutant loading into treatment systems than to install complex and expensive technology at the plant. The goal of pretreatment is to protect treatment plants, worker health and safety, and the environment from the impact of discharges of certain toxic wastes (eg., explosive and corrosive materials) into sewer systems. The goals of pollution prevention expand beyond the original pretreatment goals and are to:
CALIFORNIA PRETREATMENT PROGRAMEach POTW regulates the types of waste discharged into sewer systems leading to its treatment plant. General standards for discharge to POTWs are set by the U.S. EPA for certain types of waste and industrial categories. Each POTW receiving a large amount of industrial waste and/or with a design flow greater than 5 million gallons per day (MGD) is required to develop and implement a pretreatment program, including enforce its own local discharge limits. The goal is to both protect treatment plants and ensure that the POTW is in compliance with its own discharge permit. The Regional Board oversees the implementation of the California Pretreatment Program under the California Water Code and federal Clean Water Act although EPA retains its oversight role and is still actively involved in inspections and enforcement activities. POTW pretreatment programs must include components as specified in federal regulations and program descriptions incorporated into the NPDES permit for each POTW. Specific monitoring and reporting requirements for the 27 POTWs in the San Francisco Bay Region with approved pretreatment programs are contained in one "blanket" NPDES Permit Amendment. This blanket amendment was first issued by the Regional Board in 1980, and later revised in 1984, 1989, and 1995. Major budgeted program tasks for the Regional Board's oversight activities include pretreatment compliance inspections and audits; annual and semiannual report reviews; program modifications, particularly local limits revisions; and enforcement activities. POLLUTION PREVENTIONPOLICY STATEMENTThe Regional Board supports reducing toxic discharges through more efficient use, conservation, recycling, reuse, and waste reduction. The pollution prevention program is designed to eliminate or minimize the discharge of toxic wastes into waters of the region. The program emphasizes pollutant source reduction "upstream" of treatment plants, and techniques such as material recycling, reuse, conservations, material substitution, product substitution, and process modifications. In addition, the program also supports increased water recycling and reuse, wastewater treatment prior to discharge into sewers, and expansion of the Pretreatment Program. This general approach to minimizing waste discharge is a necessary element in the implementation of the State Board's Mass Emission Strategy and will become increasingly important as alternative uses of wastewater are developed. The Regional Board's Waste Minimization Program is a two-tiered program. The first tier is a general program, focused on long-term pollution prevention and overall reduction of toxics entering sewer systems. The general program is structured to allow each POTW to develop and direct pollution prevention efforts in its own service area. It also allows POTW to reduce toxic pollutant loading to their plants and remain in compliance with their discharge permit. The second tier is a more involved, or targeted program aimed at ameliorating existing water quality problems. The goal of targeted programs is to reduce the total amount of a specific pollutant (or pollutants) discharged to specific water bodies. Targeted programs are required when numeric or narrative water quality objectives are exceeded and beneficial uses are impaired or threatened. Both programs will take multimedia concerns into account by coordinating with other relevant regulatory programs related to air and land disposal. All POTWs with an approved pretreatment program and all major industrial dischargers that are not required to implement a targeted program are required to develop and implement a general pollution prevention program within their jurisdiction. When the Pollution Prevention Program was initiated, the largest dischargers (all POTWs with an average dry weather discharge over 10 MGD and all major industrials) were required to prepare and submit for Board approval an initial plan for general pollution prevention by July 1, 1992. Smaller POTWs were placed on a slightly longer schedule and required to submit plans by January 1, 1993. Dischargers submit mid-year progress reports and a comprehensive annual report, discussing progress and accomplishments with respect to the elements outlined below, possible program changes, and future program developments. GENERAL POLLUTION PREVENTION PROGRAMSThe general program is designed to allow individual POTWs to develop and direct long-term waste minimization efforts according to local needs and is more flexible than targeted programs. General programs should contain the following elements:
TARGETED POLLUTION PREVENTION PROGRAMSThe purpose of targeted pollution prevention programs is to reduce the total amount of specific toxic pollutants being discharged to POTWs through source reduction and recycling. Targeted programs are more intensive versions of the general programs and are focused only on one or a select number of pollutants. In those areas of the watershed or estuary system identified as exceeding water quality objectives or having impaired beneficial uses, dischargers that are significant contributors to the water quality problem will be identified and required to participate in a targeted waste minimization program. NPDES permits for each identified POTW will be amended by the Regional Board to require the development and implementation of appropriate pollution prevention measures within a given time schedule. The first phase of a targeted pollution prevention program involves quantifying the amount of the pollutants in question being discharged to the POTW from (a) regulated industrial users, (b) commercial facilities, (c) water supplies, and (d) domestic sewage. It may also be necessary to conduct further monitoring of pollutants of concern in water, sediment, and biota by identified dischargers to POTW systems and/or POTWs at and near their discharge locations in order to more precisely determine associated effects. The second phase of the targeted program is to initiate reductions in pollutant loading, focusing on the most effective and economic control measures first. These reductions may be achievable through focused public outreach, technical information transfer regarding effective management techniques, or installation of appropriate technologies. The targeted program shall include all elements of the general program, expanding where appropriate to maximize the reduction of the targeted pollutants. Targeted programs may also require other options such as performance-based effluent concentration limits and mass limitations for the pollutants of concern, in order to attain water quality objectives in the receiving water body. Phased implementation of the program will be carried out in coordination with the development and implementation of other tasks under the Mass Emissions Strategy required in the State Board's Pollutant Policy Document. DIRECT INDUSTRIAL DISCHARGER POLLUTION PREVENTION PROGRAMIndustrial entities discharging directly to receiving waters instead of public sewer systems are also subject to similar pollution prevention requirements. Overall source reduction and recycling of hazardous wastes, including audits, planning, and reporting to the Department of Toxic Substance Control is required under the Hazardous Waste Source Reduction and Management Review Act of 1989, (CCR Title 22, Ch 31). Rather than require separate pollution prevention programs, these dischargers will be asked to submit copies of the required pollution prevention reports (those sections specifically addressing liquid waste and reduction of pollutants discharged to water) to the Regional Board. Initial plans for pollution prevention, including detailed descriptions of tasks and schedules, were submitted by these dischargers in 1992. In the event that existing pollution prevention reports do not adequately address reduction of toxic pollutants in effluent, the Regional Board will require additional information. In cases where water quality problems exist or where beneficial uses are impaired or threatened by direct industrial dischargers, focused pollution prevention programs similar to POTW targeted programs will also be required. In cases where staff feel that independent audits (as opposed to audits conducted by the involved companies) are justified, the issue will be brought before the Regional Board. The effort should result in the reduction or elimination of specific pollutants of concern. |
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