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BACWA Bulletin - February 2015

Table of Contents

Committee Calendar

The Regional Water Board issues approval of Nutrient Optimization/Upgrade Studies Scoping and Evaluation Plan

On January 15, 2015, the Regional Water Board sent a letter granting their conditional acceptance of BACWA's Scoping and Evaluation Plan for the Nutrient Optimization and Upgrade Studies. In the letter, Regional Water Board staff asked for changes on three issues: 1) Clarification on how the studies will handle site-specific projected growth that will consume facilities' capacity and limit agencies' ability to implement optimization; 2) Inclusion of next steps with respect to implementing innovative technologies in the future; and 3) Consideration of higher levels of nutrient treatment resulting in lower effluent nitrogen concentrations.  BACWA has worked with Regional Water Board to address their expectations without an increase in scope for the HDR consultant team.  The approach is described in a February 3, 2015 letter from BACWA to the Regional Water Board. The Regional Water Board has accepted BACWA's approach and has granted their approval for this phase of the effort. The final Scoping and Evaluation Plan is now posted on BACWA's website.

BACWA submits comment letter on proposed EPA Dental Amalgam rule

The EPA is proposing a new Rule requiring technology-based pretreatment standards for discharges of pollutants into POTWs from certain existing and new dental practices. BACWA member agencies have already implemented dental amalgam programs as part of the Mercury/PCB watershed permit that was initially adopted in 2007. BACWA submitted a comment letter to EPA with recommendations to minimize the burden placed on POTW pretreatment programs to implement the standards.  BACWA also recommended that EPA exempt existing local programs already complying with mercury TMDLs that include dental amalgam control programs.
 

Regional Water Board issues Las Gallinas Tentative Order with numeric chronic toxicity limits

On January 15, 2015, the EPA issued a formal objection letter to the Regional Water Board concerning the need for chronic toxicity limits in Las Gallinas Valley Sanitary District's permit. In response, the Regional Water Board has issued a Tentative Order for Las Gallinas that includes both numeric triggers as well as limits of 2.7 TUc (average month) and 5.3 TUc (maximum day) for chronic toxicity.  They will likely continue to impose numeric chronic toxicity limits in the permits of dischargers whose toxicity testing results show reasonable potential by exceeding their triggers.  This will impact most shallow water dischargers in our Region.  BACWA is concerned that numeric limits are not appropriate for toxicity, which is a measured effect, rather than a constituent that POTWs can control. Additionally, toxicity is often nonpersistent and impossible to replicate, making it impossible to address.  BACWA representatives have met with EPA staff and will meet with Regional Water Board staff to share our concerns and recommend alternatives for implementing chronic toxicity in our Region.
 

BAPPG publishes 2014 Annual Report

The Bay Area Pollution Prevention Group (BAPPG) has released its 2014 Annual Report covering committee activities, as well as a description of BAPPG projects by pollutant. Participating agencies may use this report to demonstrate compliance with pollution prevention requirements in permits.
 

BAAQMD requesting feedback on Draft Water Sector Gap Analysis

The BAAQMD (Bay Area Air Quality Management District) is working on developing a regional climate protection strategy.  As part of that strategy, BAAQMD is conducting sector-based “gap analyses” to see how greenhouse gas (GHG) emissions are growing in each sector, compared to the regional goal of reducing emissions 80% below 1990 levels by 2050.  The current version of the Draft Water Sector Gap Analysis has been shared with a team of outside stakeholders. Because this analysis is likely to shape future GHG policies in the Bay Area, BACWA is working to craft a response letter. Please send questions and feedback on the Draft Water Sector Gap Analysis to Elyse Engel by March 8.
 

New article on the decline of fish in the Delta implicates multiple stressors

In the a recent edition of the IEP newsletter, an article coauthored by Jim Cloern, entitled "The Suisun Bay Problem: Food Quality or Food Quantity" (pg. 15) discusses whether the decline of populations across multiple trophic levels can be attributed to nutrient levels and ratios.  The article concludes that there is no direct causal link between nutrients and organism decline in Suisun Bay, but it is instead attributable to multiple human-caused stressors.
 

NGO sues Sacramento Regional County Sanitation District

The Center for Environmental Science, Agriculture, and Reliability (CESAR) has filed suit against Sacramento Regional County Sanitation District alleging that their ammonia discharges harm the endangered delta smelt.  The treatment plant has already embarked on a major upgrade project to decrease ammonia loading to the San Francisco Bay Delta.  However,  CESAR alleges that the discharges violate the Endangered Species Act and that the treatment plant must acquire an incidental take permit to harm a protected species

What's new in BACWA's Committees


Recycled Water

The governor released a budget (pg. 101 of link) for 2015/16 for Proposition 1.  Integrated Regional Water Management Planning projects are allocated $32.8M, and recycled water is allocated $137.2M ($132M for recycled water and $5.5M for desalination), and the latter is to be mostly managed through the State Water Board.  The cost sharing will be 50% for funded projects.  The recycled water component will be 50 percent grants and 50 percent loans.  There is no firm schedule for when funds will be appropriated, but it will not be earlier than June 2015.
 

Collections Systems

At the February 12 meeting Paul Causey and Doug Humphrey gave a presentation on SSMP auditing based on their experience working with regulators, preparing SSMPs, and conducting audits, which are required every 2 years under the Waste Discharge Requirement. Topics included audit requirements and uses; what is meant by “effectiveness”; what constitutes a good or bad audit;and audit resources and references.
 

Permits

Regional Water Board staff will attend the March Permits committee meeting. A main topic of discussion will be numeric chronic toxicity limits (see above).

BACWA External Representation

Collaboration with outside groups and initiatives is an important facet of BACWA's mission. Below is a list of BACWA's representatives to these  technical, regulatory, and management groups:

Copyright © 2015 BACWA Bay Area Clean Water Agencies, All rights reserved.


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